PRIVACY POLICY

Privacy Policy Last updated:
January 9, 2024

1. Purpose 

This is the Privacy Policy of Fletcher Knight, Inc., a Connecticut (United States) corporation. This Policy applies to all services offered under our brands FK, and FK LiveLabs (collectively, “Fletcher Knight”) and to individuals who are engaging with us or our digital platforms as research or prospective clients, as research partners or participants (e.g., consumers, healthcare professionals (HCPs), patients, or other professionals and business individuals). 
The purpose of this privacy policy is to inform you about the processing of your personal data by Fletcher Knight and its entities in accordance with research industry codes and standards relating to the USA and other countries in which Fletcher Knight operates. 

2. Privacy Policy 

Your privacy is important to us.  

It is Fletcher Knight’s policy to respect your privacy and comply with applicable laws and regulations regarding personal information we may collect about you, including across our website and other sites we own and operate.  

In the United States, Fletcher Knight complies with all pertinent Federal and State laws governing privacy, including but not limited to the California Consumer Privacy Act (CCPA) and amended California Privacy Rights Act (CPRA). In Europe, we comply with the European General Data Protection Regulation (GDPR) and the UK GDPR, the amended French Data Protection Act, the Spanish Fundamental Law on Data Protection (the NLOPD), the German Federal Data Protection Act (the BDSG), and the UK Data Protection Act (the DPA). 

In the event that our site contains links to third-party sites and services, please be aware that we have no control over the content and policies of those sites. Fletcher Knight expressly disclaims any responsibility or liability for their respective privacy practices.  

Our privacy policy aims to bring you all the necessary transparency for a positive and confident experience with our services. Additional information may be provided to you as necessary when you sign up for a particular product or service.  

Our privacy policy complies with global research industry codes and standards and all pertinent laws governing privacy. 

3. What Information is Collected 

Information we collect falls into two categories:  

Voluntarily Provided Information refers to any information you knowingly and actively provide us when using or participating in any of our services (e.g., providing your email address when signing up to participate in a research study). This may include: 

  • Personal information” includes information relating to natural persons who can be identified (or who are identifiable) directly from the information in question or indirectly from that information in combination with other information. For example, name, contact details, location, participant options/preferences, or video/audio recordings.  
  • Sensitive information” is a subset of personal information that is given a higher level of protection. The types of sensitive information that we may collect about you include: racial or ethnic origin, political opinions, religion, philosophical beliefs, sexual orientation, sexual practices or sex life, and health information. We will not collect sensitive information about you without first obtaining your consent. We will only use or disclose your sensitive information as permitted, required, or authorized by law. We use strengthened security measures when processing sensitive information. 
  • Transaction data” refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data, and other metrics, as well as other types of information, created or generated, as users interact with our services. 
  • User-generated content” is materials (text, image and/or video content) voluntarily supplied to us by our users for the purpose of publication, processing, or usage on our platform. All user-generated content is associated with the account or email address used to submit the materials. The substance of any user-generated content you submit will be property of Fletcher Knight, who shall have the unfettered right to use and publish such content, with or without attribution, create derivative works from such content, and transfer such content to third parties. Once published, it may be accessible to third parties not covered under this privacy policy. 

By providing us Voluntarily Provided Information, you are granting us consent to process such information in order to provide you services — for example, when you register an account or when you contact us via email, social media, or any similar technologies.  When you contact us, you consent to your name and email address being used so we can respond to your inquiry. If you are a participant in one or more market research studies, your participation is always voluntary and based on the terms of your Research Participant Agreement. You may opt out of any market research project at any time. 

Automatically Collected Information refers to any information automatically sent by your devices while accessing our website or services. This may include: 

  • “Browser Information” includes the data provided by your web browser, including your device’s Internet Protocol (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 other details about your visit. The data we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.  
  • “Error Reporting Data” is data about any errors you encounter while using the site and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even at the moment they occur, that they have occurred, or what the nature of the error is.  
  • “Cookies” are used to collect information about you and your activity across our site to understand how you use our site and to enable you to access and use our website. At all times, you may decline cookies from our site.  

Our Services are not intended for, or aimed at, children. We do not aim any of our products or services directly at individuals under the age of eighteen (18), and we do not knowingly collect personal information about children.  

4. How Information is Used 

We only collect and use your personal information lawfully, fairly, and in a transparent manner. We systematically respect the principle of minimization, which implies collecting and processing only what is strictly necessary to achieve our legitimate objective. If you are a study participant, you will receive a Research Participant Agreement with additional terms and conditions prior to your participation in the study.  

We use your personal information to: 

  • Perform Services For You: For example, if you purchase a product, service, or subscription from us, we may use your personal and payment information in order to process and deliver your order. If you send us an inquiry, we may use your personal information in order to respond to you. 
  • Promote Our Business Interests: These uses may include: 
  • research and development for us or for our clients, understanding our (or our clients’) audience, marketing and promoting our (or our clients’) services, measures taken to operate our services efficiently, marketing analysis (for us or our clients), and measures taken to protect our legal rights and interests,  
  • business development, including operating and improving our website, associated applications, and associated social media platforms,  
  • security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use. 
  • Comply with the Law: In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further inquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy. 

5.  Information Security 

We comply with high international standards for computer security and the protection of personal information and are in the process of applying for ISO 27001 certification. 

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.  

When using our sites, you are responsible for selecting any password and its overall security strength, ensuring the security of your own information while using our services. You are solely responsible for ensuring any passwords associated with accessing your personal information and accounts are secure and confidential. 

We comply with laws applicable to us in respect of any data breach. 

The company is committed to processing data in accordance with its responsibilities under the General Data Protection Regulation (GDPR) and UK Data Protection Act 2018, which require that personal data is: 

  • processed lawfully, fairly and in a transparent manner in relation to individuals; 
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes; 
  • adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed; 
  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased, or rectified without delay; 
  • kept in a form which permits identification of participants for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; 
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures. 
     

6. Information Recipients 

We may disclose personal information to:  

  • a parent, subsidiary, or affiliate of our company;  
  • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators;  
  • our employees, contractors, and/or related entities; 
  • our existing or potential agents or business partners;  
  • credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;  
  • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights;  
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you; or  
  • an entity that buys, or to which we transfer all or substantially all of our assets and business. 

In addition, study participants’ information may be used or disclosed in accordance with the applicable Research Participant Agreement. 

Third parties we currently use include:  

  • Google Analytics for product usage metrics (unless prohibited by national data protection authorities); Google Ads and LinkedIn Insights Tag to measure our marketing campaigns;  
  • Google Cloud Natural Language for text sentiment and for image analytics (brand/logo recognition)  
  • Amazon Web Services, Microsoft Azure, Microsoft OneDrive and Google Cloud for data collection, storage and processing. 
  • Displayr for data processing and temporary storage.  
  • Zoom and Twilio for video interview capabilities.  
  • Rev for video transcription services. 
  • Sentry, RegGaurd, Real Mail, Verity, Imperium, IPQualityScore, MaxMind, Research Defender, ThreatMetrix, Google ADH and RelevantID to identify suspicious participants, eliminate fraudsters and bad actors, and ensure accurate and high-value datasets.  
  • TruValidate and Telesign for detecting bad actors in the panel recruitment process.  
  • OpenAI for processing data on Ethos.  
  • Azure Application Insights for logging and troubleshooting user issues.  
  • Azure Cognitive Services for image and analytics and machine text translation.  

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.  

The personal information we collect is stored and/or processed in the United States, or where we or our partners, affiliates, and third-party providers maintain facilities.  

The countries in which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy. 

7. How Long Your Information Is Stored 

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy.  

For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you. 

If necessary, we may retain your personal information for our compliance with legal, accounting, or reporting obligation such as (i) reporting of incentive payments on a yearly basis to federal and/or state regulatory authorities pursuant to legal requirements or (ii) for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.  

They will then be deleted or archived in accordance with legal requirements.  

8. Your Rights 

By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You are not required to provide personal information to us. 

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

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.  

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.  

We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example processing transaction data), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, imposing penalties, or providing you with a different level or quality of goods or services. Participants are not discriminated against for their answers. Selection for participating in a study relies on research project objectives. Participation in studies is not related to any fees, and membership in our panel will also have no costs.  

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.  

Under European, Australian, and Canadian data protection laws, you also have the following rights:  

  • Access: You may request details of the personal information that we hold about you.  
  • Downloading of Personal Information: We provide a means for you to obtain a copy of  the personal information you have shared through our site. Please contact us for more information.  
  • Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.  
  • Objection to Processing: You have the right to object to the processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.  
  • Data Portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or another easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.  
  • Deletion: The data controller of a project may have a right to request that we delete the personal information we hold at any time, and we will take reasonable steps to delete personal information from our current records. If you ask us to delete your personal information, we will let you know how the deletion affects your use of our website or products and services. There may be exceptions to this right for specific legal reasons which, if applicable, we will set out for you in response to your request. If you terminate or delete your account, we will delete your personal information without undue delay. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.  

We will respond to your requests without undue delay and at the latest within one month of receipt of your request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. 
 

9. Changes to This Policy 

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy. 

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy. 

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information. 

10. Contact Us 

For any questions or concerns regarding your privacy, you may contact us using at info@fletcherknight.com. 

All requests to exercise your rights must be accompanied by the details necessary to process your request. A copy of proof of identity may be requested if necessary. 

You have the right to lodge a complaint with your national data protection authority. You can find more information about your data protection rights on your authority’s website.  

FLETCHER KNIGHT CAREERS

If you apply for a position with us or otherwise contact us through the Site in connection with employment opportunities at Fletcher Knight, any personal information of any kind that you provide, including but not limited to your name, email address or other contact information, education and employment history, and your work skills may be used by us in evaluating your qualification for employment.

If you supply us with references to third parties in support of your request for employment, we will use your personal information as needed to interact with such third parties in evaluating your candidacy for employment.  We will disclose your personal information if we are required by law to do so. Any information provided in the course of your inquiry about employment with Fletcher Knight will be used only for that purpose and will not be used in any of our research activities.

The information that you provide to the Site will be retained as long as necessary with respect to your application or inquiry about employment and to the extent we are required to comply with any laws.  We may also retain your information for a reasonable period of time to allow us to consider you for future employment opportunities with Fletcher Knight that may become available.  If you prefer not to be considered for future opportunities, we will remove your information from our records at your request except to the extent we are required by law to retain it.

Also See: Terms and Conditions of Use