This policy is provided in a layered format so you can click through to the specific areas set out below.
- About Clementine
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Disclosures of your personal data
- International Transfers
- Data security
- Data retention
- Your legal rights
Clementine is a trading name used by Apater UK Limited, which is a controller in respect of your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).
Part of our offering is to provide recruitment services to the market research sector, which means that we recruit members of the public to take part in market research projects.
In respect of the data that we collect, we may also be a data processor for one-off projects where participants are recruited on behalf of a client and the client alone instructs us in relation to what data to collect, about whom, how long to hold it for, what to tell individuals about the processing and such like. You will be made aware of who the data controller is for each specific project via information provided at the time of participating in the research project.
Our full details are:
- Full name of legal entity: Apater UK Limited, trading as Clementine
- Name or title of data privacy manager: Research Director
- Email address: firstname.lastname@example.org
- Postal address: The Stanley Building, 7 Pancras Square, N1C 4AG
The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender, race or ethnicity.
- Contact Data: billing address, delivery address, email address and telephone numbers.
- Financial Data: bank account details, payment platform details.
- Device Data: includes the type of mobile device you use mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
- Content Data: includes information sent by you to us from your device, including photos, videos or other digital content.
- Profile Data: includes your username your interests, preferences, feedback and survey responses.
- Usage Data: includes your use of any of our apps including, but not limited to, the resources that you access.
- Location Data: includes your current location disclosed by GPS technology or other technology.
Except for your race and ethnicity and except with your specific and informed prior consent which we will seek at the start of the screening questionnaire, we do not collect any Special Categories of Personal Data about you (such as your religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
We will collect and process the following data about you:
- Information you give us. If you click on one of our ads to express interest in taking part in a research project we will need to ask you a number of questions to see if you meet the eligibility criteria. The questions you are asked will vary with each project but in summary the type of information we ask for as part of each screening questionnaire includes Identity and Contact Data (contact details such as your name, phone number and email address), Profile Data and Usage Data. We will collect Financial Data from you at a later point so that we can pay you where appropriate that you consent to giving us by filling in forms on the screening questionnaire. Occasionally we may need to ask you about Special Category Data (such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) but you will have the opportunity at that point to opt out if you do not wish to provide this.
- Location Data. We also use GPS technology and/or other technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings or you may contact us at email@example.com.
- Information we receive from other sources including third parties. We will receive personal data about you from third parties, for example, Device Data from analytics providers such as Typeform, which is based in the EU.
How we make payment
When you successfully complete the project we need to arrange payment of your reward. We may ask you for the email address you have registered with a third-party provider such as PayPal. If this isn’t an option, we may need to ask for your bank details and a form of ID to be able to make the payment.
How we use your personal data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We will not send you any direct marketing communications in any form whatsoever nor will we share your data with any third party for marketing purposes.
Purposes for which we will use your personal data
Purpose/activity Type of data Lawful basis for processing When you register as a potential recruit for market research and when we communicate with you regarding your registration and when we let you know whether you have been selected to take part.
Special Category (ethnic background only)
Your explicit consent for ethnic background data
Your consent for all other data
When we process your responses to our screener questionnaire and share this information with Typeform which will host the questionnaire and export it to Google Sheets (G Suite) and we export the same to our client.
Performance of a contract with you
Throughout the project, to process correspondence with you through email, phone or via our third party research platform (such as Indeemo or Recollective).
Performance of a contract with you
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated)
To manage payments of your incentive to you for taking part in the research
Performance of a contract with you
Necessary for our legitimate interests (to make payment to you)
To administer and protect our business and this Facebook page including support by Typeform which hosts the survey and provides troubleshooting, error logging, performance metrics, data analysis, web analytics, generating aggregate usage metrics and system testing / fixing
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent in case we may need on occasion to share your personal data with the third parties set out below for the purposes set out in the table above (Purposes for which we will use your personal data).
- Internal Third Parties: Other companies in the Apater Group who are based in the UK either with whom we may on occasion share some of your Content Data (for internal presentation / leadership reporting purposes) or who provide IT and system administration services.
- External third parties:
- Freelancers engaged by us in connection with the project.
- Typeform SL who host your data on Amazon’s AWS service. Typeform’s main servers are located in Virginia, USA and backup servers are located in Frankfurt, Germany. They will keep your data for no longer than 5 years from the date you provide it.
- Indeemo is a mobile app research platform that allows participants to upload text, audio, photos and videos in response to questions as part of a research project. They will receive the data such as Identity, Contact, Device, Location, Usage and Profile Data about each participant. Indeemo is based in the Republic of Ireland.
- Recollective is a mobile and desktop research platform which has the same capabilities as Indeemo and would receive the same data types. Recollective is based in Canada.
- Paypal in the USA for managing payments to you.
- Service providers based in the UK who provide IT and system administration services.
- Professional advisers including accountants, lawyers, bankers, auditors and insurers based in the UK who provide accounting, legal, banking, auditing and insurance services.
- HM Revenue and Customs, Market Research Society, regulators and other authorities based in the UK who may require reporting of processing activities in certain circumstances.
- Any other third party requiring data for our compliance with legal or regulatory requests or in order to protect the rights, property, or safety of Apater UK Limited, our customers, or others (which includes exchanging information for the purposes of fraud protection).
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you would you like further information on these transfers.
All information you provide to us is stored on our secure servers. We regularly update our systems to ensure your data is stored and transferred as securely as possible. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using their encryption and security technology.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of the research platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
All information that we hold and that we are not required by law to keep for longer will be permanently deleted and expunged from all our records after 12 months of your completion of the project. We may contact you within 12 months after your completion of the project to reconnect if we believe that you may be an appropriate participant for another research project.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For any of the above requests, please email us at firstname.lastname@example.org.
If you have a complaint regarding the way we handled your data please contact our data protection manager using the contact details at the top of this policy. If you are not happy with our response you can lodge a complaint with the Information Commissioner’s Office. Apater UK Limited is an ICO-registered data controller, registration number: ZA786618.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.