Your privacy is important to us. It is 5 Surveys' policy to respect yourprivacy regarding any information we may collect from you across ourwebsite, https://www.fivesurveys.com, and other sites we own and operate.

Last Update: May 6, 2022

1. Information we collect

Log data

When you visit our website, our servers may automatically log the standarddata provided by your web browser. It may include your computer’s InternetProtocol (IP) address, your browser type and version, the pages you visit,the time and date of your visit, the time spent on each page, and otherdetails.

Device data

We may also collect data about the device you’re using to access ourwebsite. This data may include the device type, operating system, uniquedevice identifiers, device settings, and geo-location data. What we collectcan depend on the individual settings of your device and software. Werecommend checking the policies of your device manufacturer or softwareprovider to learn what information they make available to us.

Personal information

We may ask for personal information, such as your:

• Email

In order to match you with the right surveys, we may collect additionalinformation from you, including demographic information such as postal code,gender, marital status, education, employment related information, andnon-personally identifiable information on household members, householdincome, age, etc.

2. Legal bases for processing

We will process your personal information lawfully, fairly and in atransparent manner. We collect and process information about you only wherewe have legal bases for doing so.

These legal bases depend on the services you use and how you use them,meaning we collect and use your information only where:

• it’s necessary for the performance of a contract to which you are a partyor to take steps at your request before entering into such a contract (forexample, when we provide a service you request from us);
• it satisfies a legitimate interest (which is not overridden by your dataprotection interests), such as for research and development, to market andpromote our services, and to protect our legal rights and interests;
• you give us consent to do so for a specific purpose (for example, youmight consent to us sending you our newsletter); or
• we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specificpurpose, you have the right to change your mind at any time (but this willnot affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While weretain this information, we will protect it within commercially acceptablemeans to prevent loss and theft, as well as unauthorized access, disclosure,copying, use or modification. That said, we advise that no method ofelectronic transmission or storage is 100% secure and cannot guaranteeabsolute data security. If necessary, we may retain your personalinformation for our compliance with a legal obligation or in order toprotect your vital interests or the vital interests of another naturalperson. Upon termination of your account, either by you or us, we reserve the right to delete or anonymize your personal data, in compliance with applicable legal requirements to ensure the protection and privacy of your information.

3. Collection and use of information

We may collect, hold, use and disclose information for the followingpurposes and personal information will not be further processed in a mannerthat is incompatible with these purposes:

• to match you with surveys based on your demographic information and thesurveys targeting criteria
• to enable you to customize or personalize your experience of our website;
• to enable you to access and use our website, associated applications andassociated social media platforms;
• to contact and communicate with you;
• for internal record keeping and administrative purposes;
• for analytics, market research and business development, including tooperate and improve our website, associated applications and associatedsocial media platforms;
• for advertising and marketing, including to send you promotionalinformation about our products and services and information about thirdparties that we consider may be of interest to you;
• to comply with our legal obligations and resolve any disputes that we mayhave; and

4. Disclosure of personal information to third parties

We may disclose personal information to:

• third party service providers for the purpose of enabling them to providetheir services, including (without limitation) IT service providers, datastorage, hosting and server providers, ad networks, analytics, errorloggers, debt collectors, maintenance or problem-solving providers,marketing or advertising providers, professional advisors and paymentsystems operators;
• our employees, contractors and/or related entities;
• sponsors or promoters of any competition we run; and
• third parties, including agents or sub-contractors, who assist us inproviding information, products, services or direct marketing to you;
• clients, agencies, exchanges and marketplaces providing us surveys.

5. International transfers of personal information

The personal information we collect is stored and processed in UnitedStates, or where we or our partners, affiliates and third-party providersmaintain facilities. By providing us with your personal information, youconsent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries inthe European Economic Area (EEA) to countries outside the EEA will beprotected by appropriate safeguards, for example by using standard dataprotection clauses approved by the European Commission, or the use ofbinding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to anothercountry, you acknowledge that third parties in other jurisdictions may notbe subject to similar data protection laws to the ones in our jurisdiction.There are risks if any such third party engages in any act or practice thatwould contravene the data privacy laws in our jurisdiction and this mightmean that you will not be able to seek redress under our jurisdiction’sprivacy laws.

6. Your rights and controlling your personal information

Choice and consent:

By providing personal information to us, you consent to us collecting,holding, using and disclosing your personal information in accordance withthis privacy policy. If you are under 16 years of age, you must have, andwarrant to the extent permitted by law to us, that you have your parent orlegal guardian’s permission to access and use the website and they (yourparents or guardian) have consented to you providing us with your personalinformation. You do not have to provide personal information to us, however,if you do not, it may affect your use of this website or the products and/orservices offered on or through it.

Information from third parties:

If we receive personal information about you from a third party, we willprotect it as set out in this privacy policy. If you are a third partyproviding personal information about somebody else, you represent andwarrant that you have such person’s consent to provide the personalinformation to us.

Restrict:

You may choose to restrict the collection or use of your personalinformation. If you have previously agreed to us using your personalinformation for direct marketing purposes, you may change your mind at anytime by contacting us using the details below. If you ask us to restrict orlimit how we process your personal information, we will let you know how therestriction affects your use of our website or products and services.

Access and data portability:

You may request details of the personal information that we hold about you.You may request a copy of the personal information we hold about you. Wherepossible, we will provide this information in CSV format or other easilyreadable machine format. You may request that we erase the personalinformation we hold about you at any time. You may also request that wetransfer this personal information to another third party.

7. Cookies

We use “cookies” to collect information about you and your activity acrossour site. A cookie is a small piece of data that our website stores on yourcomputer, and accesses each time you visit, so we can understand how you useour site. This helps us serve you content based on preferences you havespecified. Please refer to our Cookie Policy for more information.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out ofbusiness or enter bankruptcy, we would include data among the assetstransferred to any parties who acquire us. You acknowledge that suchtransfers may occur, and that any parties who acquire us may continue to useyour personal information according to this policy.

9. GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Datafor one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessaryfor the performance of an agreement with You and/or for anypre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary forcompliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order toprotect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a taskthat is carried out in the public interest or in the exercise of officialauthority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for thepurposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legalbasis that applies to the processing, and in particular whether theprovision of Personal Data is a statutory or contractual requirement, or arequirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality ofYour Personal Dataand to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are withinthe EU, to:

• Request access to Your Personal Data. The right to access, updateor delete the information We have on You. Whenever made possible, you canaccess, update or request deletion of Your Personal Data directly withinYour account settings section. If you are unable to perform these actionsyourself, please contact Us to assist You. This also enables You toreceive a copy of the Personal Data We hold about You.
• Request correction of the Personal Data that We hold about You. Youhave the right to to have any incomplete or inaccurate information We holdabout You corrected.
• Object to processing of Your Personal Data. This right exists whereWe are relying on a legitimate interest as the legal basis for Ourprocessing and there is something about Your particular situation, whichmakes You want to object to our processing of Your Personal Data on thisground. You also have the right to object where We are processing YourPersonal Data for direct marketing purposes.
• Request erasure of Your Personal Data. You have the right to ask Usto delete or remove Personal Data when there is no good reason for Us tocontinue processing it.
• Request the transfer of Your Personal Data. We will provide to You,or to a third- party You have chosen, Your Personal Data in a structured,commonly used, machine-readable format. Please note that this right onlyapplies to automated information which You initially provided consent forUs to use or where We used the information to perform a contract with You.
• Withdraw Your consent. You have the right to withdraw Your consenton using your Personal Data. If You withdraw Your consent, We may not beable to provide You with access to certain specific functionalities of theService.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

We will respond to your request without undue delay and in any event within one month of receipt of your request. In case the complexity or number of requests requires an extension of this period, we will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. In this case, the period period may be extended by two further months where necessary.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

10. CCPA Privacy

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California,You have the following rights:

• The right to notice. You must be properly notified which categoriesof Personal Data are being collected and the purposes for which thePersonal Data is being used.
• The right to access / the right to request. The CCPA permits You torequest and obtain from the Company information regarding the disclosureof Your Personal Data that has been collected in the past 12 months by theCompany or its subsidiaries to a third-party for the third party's directmarketing purposes.
• The right to say no to the sale of Personal Data. You also have theright to ask the Company not to sell Your Personal Data to third parties.You can submit such a request by visiting our "Do Not Sell My PersonalInformation" section or web page.
• The right to know about Your Personal Data. You have the right torequest and obtain from the Company information regarding the disclosureof the following:
        - The categories of Personal Datacollected.
        - The sources from which the PersonalData was collected
        - The business or commercial purposefor collecting or selling the Personal Data
        - Categories of third parties withwhom We share Personal Data
        - The specific pieces of Personal Datawe collected about You
• The right to delete Personal Data. You also have the right torequest the deletion of Your Personal Data that have been collected in thepast 12 months.
• The right not to be discriminated against. You have the right notto be discriminated against for exercising any of Your Consumer's rights,including by:
        - Denying goods or services to You
        - Charging different prices or ratesfor goods or services, including the use of discounts or other benefits orimposing penalties
        - Providing a different level orquality of goods or services to You
        - Suggesting that You will receive adifferent price or rate for goods or services or a different level orquality of goods or services.
  

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are aCalifornia resident, You can email or call us or visit our "Do Not Sell MyPersonal Information" section or web page.

The Company will disclose and deliver the required information free ofcharge within 45 days of receiving Your verifiable request.The time periodto provide the required information may be extended once by an additional 45days when reasonable necessary and with prior notice.

11. VCDPA privacy

Information for Virginia consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the “VCDPA”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

Categories of personal data we collect and process

We have collected the following categories of personal data: E-Mail

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Information we collect” and “Legal bases for processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

We do not share nor disclose your personal data with third parties.

For our purposes, the word “third party” means “a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller” as defined by the VCDPA.

Sale of your personal data

We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such a sale.

Processing of your personal data for targeted advertising

We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

• access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
• correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
• request the deletion of your personal data. You have the right to request that we delete any of your personal data.
• obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
• opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a minor under your parental authority.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

12. LGPD Privacy

On September 18, 2020, the Lei Geral de Proteção de Dados Pessoais (LGPD) came into effect for Brazilian residents. In addition to the rights outlined in our Privacy Policy, as a user located in Brazil, you may be able to exercise the following rights with respect to the personal information that we have collected, subject to certain limitations:

• The right to confirmation of the existence of the processing. You have the right to ask that we confirm whether we process your personal data.
• The right to access the data. You have the right to access the personal data we hold about you and certain information about how we use it and who we share it with, including information about any public and private entities we have shared your personal data with.
• The right to correct incomplete, inaccurate, or out-of-date data. If you want to correct or revise any of the data we retain on you, you may do so by accessing your account and the information contained within it or contacting our team.
• The right to anonymize, block or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD. Please note that, depending on the request, this may result in a suspension or discontinuation of certain services and may be governed by legal and/or contractual retention guidelines.
• The right to the portability of data to another service or product provider, by means of an express request. We provide you with the ability to move any of your account data to a third party, at any time.
• The right to delete personal data processed with the consent of the data subject. You have a right to request the permanent deletion of your data, subject to certain exceptions. However, please note that exercising this right may result in a suspension or discontinuation of services and may also be governed by legal and/or contractual retention guidelines.
• The right to information about the possibility of not giving consent and about the consequences of the refusal. You have the right to ask us to provide information about the possibility of not giving consent for the processing of your personal data and the consequences of such refusal.
• The right to revoke consent.

Please note that not all of these rights listed above are absolute, and limitations/exceptions apply in some cases. For example, we may not be able to fully comply with your request if we are bound by certain legal restrictions or contractual requirements, but in those circumstances, we will still respond to notify you of such a decision.

Exercising Data Portability and Deletion Rights

To exercise the data portability and deletion rights described above, please submit a verifiable consumer request to us: privacy@fivesurveys.com

We will need to verify your identity before processing your request. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legal representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 15 days of its receipt but no more than 30 days. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

13. Limits of our policy

Our website may link to external sites that are not operated by us. Pleasebe aware that we have no control over the content and policies of thosesites, and cannot accept responsibility or liability for their respectiveprivacy practices.

14. Changes to this policy

At our discretion, we may change our privacy policy to reflect currentacceptable practices. We will take reasonable steps to let users know aboutchanges via our website. Your continued use of this site after any changesto this policy will be regarded as acceptance of our practices aroundprivacy and personal information.

If we make a significant change to this privacy policy, for example changinga lawful basis on which we process your personal information, we will askyou to re-consent to the amended privacy policy.

Data Protection Officer

Bogdan Pashynskyi

dpo@fivesurveys.com

Legal Nodes Ltd

Company number: 11668206

Address: 90a High Street Berkhamsted,

Hertfordshire, England, HP4 2BL