Vital Findings, LLC (“us”, “we”, or the “Company”) is committed to protecting the privacy of its clients, research participants, and other users of the company Website (the “Site”). This Privacy Policy (the “Policy”) applies to all client and personal data that we collect or use in the course of conducting our business and data you provide to us on our Site.  This policy does not apply to information which we might collect from our employees, job applicants, or independent contractors.    

By accessing or browsing our Site, participating in surveys, or otherwise providing your data to us, you confirm that you have read and understood the entirety of this privacy policy.

Information we collect from you or about you

Information we collect from you
We collect and process the following data on our site:

  • Information that you provide by filling in forms on our site. We may also ask you for information when you report a problem with our site.
  • If you contact us, we may keep a record of that correspondence.
  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Participation In Research

We conduct market research for our clients. Most of the information we collect about you (only a small subset of which may be “personal data” or “personally identifiable information” as defined under applicable law) is information you voluntarily disclose to us in connection with our research studies. Consistent with industry practice, online survey activity is typically conducted on an anonymized basis through the use of randomly assigned identifier codes, so the identity of research participants is not known to us or to the client commissioning the study. Some of our studies take the form of “communities,” which involve repeated interaction over a defined period of time; in those cases, we would typically have personal data about you (including a means to contact you), but other participants in the study would not have access to this information. Data collected as part of our studies may include respondent demographic data and respondent-supplied opinions on products or brands. As to some studies, we may also collect video or audio responses. Research participation is voluntary and participants always have the opportunity to decline involvement or to “opt out” of the research after agreeing to participate, as clearly identified in each survey. If the survey involves an incentive or a contest, we may ask for your name and telephone number or email address to notify you if you are a winner. There is never an obligation to provide this information to participate in the survey but if you don’t provide it, you may not be able to participate in the incentive program. Our legal basis for collection and processing of respondent-supplied personal data is consent; we do not collect personal data without the affirmative consent of the research participant. Consent can be withdrawn at any time.

As to certain studies, we may obtain information about you (which in some cases may be “personal data” or “personally identifiable information” as defined under applicable law) from our clients, third party vendors, or partners for use in connection with the studies. As to some studies, this might be your contact information, so we can send you an invitation to participate in the study. As to other studies, we may purchase existing data, such as demographic, interest, or behavioral information, about you from third party vendors and correlate and append that data to your survey responses so we can perform more robust analysis in connection with the study. This is typically done through the use of third party intermediaries who are able to associate your responses to other existing data through technology, such as pixel tags or cookies, or other identifying information which they (but not we) possess. In those cases, our legal basis for the processing of the information is our legitimate interest to perform our obligations under our contract with the client commissioning the research study in question.

As to certain other studies, we may collect public postings and comments you may have made in connection with product reviews or on social media pages of different companies or brands which may, from time to time, include the “handle” or “username” you used for that posting, and which we obfuscate at time of collection.  In those cases, our legal basis for the collecting and processing of the information is our legitimate interest to perform our obligations under our contract with the client commissioning the research study in question.

Additionally, in connection with our online survey activities, we employ software to identify certain systems-related information about respondents, including IP address, device and browser type, and geographic location, in order to detect fraudulent activity (e.g., bots), to protect the integrity of the research, and to optimize the survey experience.  This information is only used for these purposes, and may also be shared with third party vendors in connection with the mechanics of the fraud detection process.  Our legal basis for the collection and processing of this information is our legitimate interest to protect the integrity of our business and enhance the services we perform for our clients.

If you are a client or work for a client, we likely have collected various contact, business, and in some cases financial information about you in the course of administering our relationship with you or your employer.  In those cases, our legal basis for the collection and processing of the information is our legitimate interest to perform our obligations under our contract with you or the company for which you work.

If you choose to use social media (for example, Facebook, Instagram, Twitter, or LinkedIn) in order to contact us or find out about our services, we may collect your public-facing profile data, data relating to your interactions with us, and any data you post on message boards which are relevant to our business.

We may collect certain information regarding visitors to our Site, including IP address, device and browser type, and behavior while on the Websites (e.g., which links were clicked on). We may do so using cookies to distinguish you from other users to our site and to remember you between visits.  A cookie is a small file of letters and numbers that we store on your browser.  Occasionally, cookies, pixels, or web beacons may be placed on our Websites by service providers or partners; we do not permit personal data to be collected or accessed by these cookies, pixels, or web beacons. If you prefer not to receive cookies from our Site you can disable their use in your browser settings. By doing so you may reduce the functionality of the web pages you view. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.  Currently, our systems do not respond to browser do-not-track signals, and do not treat such do-not-track signals as “do not sell” signals under CCPA (as defined below).  If you wish to be removed from our email lists, please email us at info@vitalfindings.com or call us at 310-279-5510. 

How we use and store your data

Depending on how we obtain your personal data (as described above), we may either be considered a “controller” or a “processor” under applicable law as to that data. If we are the processor, we will process the data in accordance with the instructions provided to us by the controller of that data.

Regarding data collected as part of our research activities, we collect data in, and in connection with, our studies for research purposes only, and our use of that information is limited to that purpose. Research participant information is not used for sales purposes.  In many cases, this information (which is typically anonymized) is shared with the client commissioning the study pursuant to our contract with that client. In some cases we may need to share personal data with third parties for ancillary services in support of a research project. In these cases, we require the third party to follow all of the same privacy protection regulations as followed by us.  

As to client data we collect, we do not use the information for any purpose other than to fulfill our obligations to clients. We keep client information secure at all times, and prevent the use and disclosure of it by our employees or any third parties.

In order to deliver to our clients, we use several third-party vendors.  All are vetted and hand selected to carry out the task at hand. In all cases, we take appropriate measures to ensure that the vendor protects any personal data so transferred adequately in accordance with this privacy policy. The data that we collect from you may be transferred to, and stored at, a destination outside the United States (“US”) or the European Economic Area (“EEA”). It may also be processed by staff operating outside the US or the EEA who work for us or for one of our suppliers. If your personal data is transferred to, stored at or otherwise processed in a country or territory outside the US or the EEA, and that country or territory has not been recognized as providing an adequate level of data protection, we will put in place additional safeguards to protect your personal data, based on standard contractual clauses.

We do not sell personal data in the traditional sense, do not rent, sell or give personal data to any third party for the purpose of directly marketing any products or services. However, you should be aware that certain laws to which we are subject, for example the California Consumer Privacy Act (the “CCPA”), define the terms “sell” and “sale” very broadly, such that some of our research-related activities—for example, the inclusion of a study participant’s photo or video in a market research deliverable for our client—might fall within the definition of “sale” under certain circumstances. 

Under certain circumstances, we may be required to release personal data in response to a legal request from public authorities including to meet national security or law enforcement requirements.

We do not discriminate financially between those who elect to supply their personal data to us and those who elect to not do so, provided, however, that to the extent a survey or other research study—the completion of which would result in the payment of a financial incentive or entry in a sweepstakes—involves the collection of data and you decline to consent to such collection, you would not be able to proceed to participate in the study, and (depending on the specific study) to the extent you are required to supply your contact information at the conclusion of a survey in order for us to fulfill the participation incentive and you decline to provide your contact information, you would not receive the participation incentive.

In all cases, Vital Findings will take reasonable steps to ensure the personal data is accurate, complete, current and relevant and being used only for the intended purposes. We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.

Retention of Personal Data

We keep personal data for no longer than necessary for the purposes for which the personal data is collected or processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Information Security

We maintain physical, electronic and procedural security measures to help safeguard client and personal data which are consistent with industry standards and practice and in compliance with applicable law. Third parties that provide us with support or services and that may also receive client or personal data are required by us to maintain security measures similar to ours with respect to such information. We will take reasonable precaution, consistent with industry standards and practice, to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Your Rights As to Your Personal Data

You have certain rights by law to know certain details regarding our data handling practices generally; this information is described above and elsewhere in this Privacy Policy.  In addition, you have the right to request the following as to any personal data we have about you:  that we provide access to any personal data we hold about you; that we update any of your personal data which is out of date or incorrect; where our basis for processing your personal data is consent, that your consent to further processing be withdrawn; where we received your personal data from a third party, inquire where the data originated; that we delete any personal data which we are holding about you; restrict the way that we process your personal data (including that we no longer “sell” your personal data as such term is defined in the CCPA); prevent the processing of your personal data for direct-marketing purposes; that we provide, or not provide, your personal data to a third party provider of services; that we provide you with a copy of any personal data which we hold about you; that we consider any valid objections which you have to our use of your personal data; and that you not be discriminated against for exercising any of your privacy rights.  Under applicable law, certain personal data may be exempt from some of these requests in certain circumstances. 

If you would like further information about these rights or would like to exercise any of them, including to opt out of the “sale” of your information as defined in the CCPA, please email us at legal@vitalfindings.com or info@vitalfindings.com.  

By law, as well as for your protection, if you request that we take certain actions as to personal data we have about you, we are required to take certain steps to verify your identity.  If we are not able to verify your identity, we may not be able to respond to your request.  To verify your identity, we request, at point of submission of your request, that you supply your basic contact information, as well as certain other non-personally identifiable information (e.g., information relating to your last interaction with us, such as subject matter and type of study), and we endeavor to match at least two pieces of this information with information in our possession.  In addition, as to those rights permitted by law to be exercisable by an authorized agent on your behalf, in addition to verifying your identity as described above, we require the agent to also supply written authorization from you to act on your behalf, except where restricted by law.

Note, some of these rights may not be applicable to information which we might collect or process from or about you in your capacity as our employee, job applicant, or independent contractor; there are other laws applicable to those relationships which are not addressed in this Privacy Policy.  If you have any questions, please contact us.  

Careers

Any personal data which may be collected in the Careers sections of our Site will be used solely for purposes of the consideration of possible employment. This information will not be used towards research and is not human resources data within the context of the working relationship.

Children

We operate in compliance with the Children’s Online Privacy Protection Act (“COPPA”), governed by the US Federal Trade Commission (“FTC”). We do not collect, use or disclose information from children under the age of 13 online without a statement of permission from a parent or guardian.  We also do not “sell” (as defined in CCPA) personal information of persons under 16 without affirmative authorization. For more information on COPPA, please visit http://www.ftc.gov/ogc/coppa1.htm.

Last update: February 2, 2021