Updated as of April 13, 2023

Hotspex, Inc. and its affiliates (collectively, “Hotspex”) is committed to protecting the privacy of our clients and research participants. This privacy policy applies to all client and personal information that we collect or use in the course of conducting our business, as well as all client information and research participant data housed at any Hotspex facility or stored on the Hotspex network. Anyone who has access to such information or data must follow this privacy policy.

Client Information

We treat all information we receive from clients as confidential and do not use the information for any purpose other than to fulfill our obligations to them. We keep client information secure at all times, and prevent the misuse and unauthorized disclosure of it by our employees or any third parties.

Research Participant Information

In order to provide our services to clients, we may employ the use of client contact lists which would contain personal information such as names, email addresses, phone numbers, and mailing addresses. On studies involving European citizens, client contact lists will only be used in cases where active consent to be contacted for research purposes has been granted by the participant.

All responses to our research are completely confidential. We collect data in our studies for research purposes only, and our use of that information will be limited to that purpose. Research participant answers will not be used by any entity as an aid for sales.

Research participation is voluntary, and sample members always have the opportunity to decline involvement or to "opt out" of the research even after agreeing to participate.

In order to provide our services to clients, we may request from research participants their personal information such as names, email address, phone number, or mailing address. In cases of video recorded research, the ability to record facial image could be requested. This collection of personal information from research participants is done solely through the legal basis of consent.

We do not rent, sell or give personal information to any third party for the purpose of directly marketing any products or services. In some cases, we may need to share personal information with third parties that provide research services in support of the research project. Any third party that receives personal information is obligated to follow all of the same privacy protection regulations as followed by Hotspex.

At their request, we give research participants access to the personal information we have collected about them. We correct any information that is inaccurate or incomplete, change their consent status, or have their personal information deleted.

Sharing of Information

We may share your information in the following ways: (a) with our service providers, as necessary to enable them to provide services to us (in which cases such service providers are prevented from using the information except has necessary to provide the services); (b) with our clients and always at an aggregate level without linking personally identifiable information (such as email address) with the opinion and research data collected ; (c) as reasonably necessary to comply with law or a legal process (including a court or government order or subpoena), to detect, prevent, or otherwise address fraud, security or technical issues, to enforce this privacy policy, and to protect the rights, property or safety of Hotspex, our users, and/or the public; (d) if we sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a corporate transaction such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this privacy policy; or (e) with your express consent.

Children

We do not knowingly collect personal information under any circumstances from anyone under the age of thirteen (13), and if we become aware that we have inadvertently collected personal information from anyone under this age threshold, we will promptly delete such information.

Information Security

We maintain all necessary physical, electronic and procedural security measures to help safeguard client data and personal information. Third parties that provide us with support or services may also receive client data or personal information, and we require them to maintain security measures similar to ours with respect to such information. Nevertheless, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. If any information under our control is compromised, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised, and also take other steps as necessary in accordance with any applicable laws and regulations.

Data Integrity

Hotspex will take reasonable steps to ensure the personal data is accurate, complete, current and relevant, and is used only as described in the “Data Retention” section below. While we accept responsibility for the management and confidentiality of the personal information collected, please note that we do not always have control over the accuracy of the information provided directly to us, and accept no responsibility for information’s accuracy in such cases.

Data Retention

In general, to determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. We may also process data on behalf of third parties who have engaged us. We keep personal information processed on behalf of third parties for as long as needed to provide services to the third party in question. Notwithstanding anything above to the contrary, we reserve the right to retain personal information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

Data Location

While Hotspex Inc. is a Canadian company with offices in the United Kingdom and the United States of America, we provide services to individuals and our technology processes data from users around the world. Accordingly, Hotspex may transmit your personal information outside of the country, state, or province in which you are located.

Third Parties

Our website may contain links to external websites, and areas where you can provide information to third parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any personal information you provide in such areas, and on such linked pages, is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third-parties before providing them with personal information.

Information Collected Automatically

Hotspex respects the voluntary nature of research participation, and protects our survey respondents’ identities when collecting market research responses online.

We process IP addresses for the legitimate business purpose of identifying and preventing duplicate respondents in our surveys. Whenever we process data for these purposes we take reasonable and customary steps to keep your personal data safe and secure.

You have the right to object to this processing: if you wish to do so please contact Hotspex at privacy@hotspex.com. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.

All other personal information is only collected when the research participant deliberately and voluntarily provides it. The only use of their web browsing activity is to ensure a stable, error-free survey experience.

The only information we collect from visitors to our corporate website (www.hotspex.com) is that which is voluntarily provided by requests for more information about our services, subscribing to our newsletter, or viewing papers, articles and videos from our content library. Otherwise, the only use of visitors’ web browsing activity is to generate aggregate traffic reporting statistics for the website. Notice of this collection is provided on all pages of the site with the ability to opt out.

Do Not Track Signals

Whether or not we receive Do Not Track request signals from a web browser, we will never use browsing activity information from our survey respondents or other website visitors to provide or offer third party advertising content.

Disclosures for Residents of California, Virginia, Connecticut, Colorado, and Utah

In accordance with certain US state-specific privacy laws, residents are provided the following rights:

The right to know which personal information is being collected

The right to know if personal data is being sold or shared, and to whom

The right to object to the sale of personal data

The right to opt out of the processing of personal data for targeted advertising purposes

The right to access, update or remove your personal information

The right to equal service and price, even for consumers who exercise their privacy rights

Notice Of Data Collection

In the preceding 12 months, Hotspex has collected the following categories of personal information:

Compliance, Data Protection Officer

Hotspex strives to model our policies according to the guidelines set forth by the Insights Association and European Society of Opinion and Marketing Research (ESOMAR). As a company based in Canada, the UK and the United States, Hotspex is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If you are concerned about our use of personal or client information, please contact us by email at privacy@hotspex.com.

If you are a citizen of the European Union and would like to contact our Data Protection Officer, please email privacy@hotspex.com.

Changes in the Privacy Policy

We reserve the right to modify this privacy policy at any time. If we decide to change our policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you either by way of an email or by a notice on our website. We will use information in accordance with the policy as it was in effect at the time information was collected.

Class Action Waiver

Any arbitration or court trial, whether before a judge or jury or pursuant to judicial reference, related to any claim under this privacy policy will take place on an individual basis, without resort to any form of class or representative action (“Class Action Waiver”). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS PRIVACY POLICY. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator.

Legal Obligations

Under certain circumstances permitted or required by law (for example, in connection with law enforcement investigations), we may be required to disclose client data or personal information without giving notice.