Walker Privacy Statement

Effective: 26-JAN-2017

TRUSTe European Safe Harbor certification

At Walker Information, we believe that survey respondents and online visitors are key stakeholders in our company. For this reason, Walker prides itself not only on its customer focus, but also on its efforts to protect and be sound advocates for our respondents and online visitors. Walker Information conducts market research surveys using scientific methods. We promise that in obtaining your cooperation we will not mislead you about the nature of the research or the use that will be made of the findings. At a minimum, we will adhere to all legal and ethical standards of conduct for market research firms. We promise that when collecting personal information in response to marketing or product requests, we will use your information solely for this purpose.

The remainder of this statement will provide insight on what information we may collect about you, how either Walker Information or our clients may use your opinions and personal information as it relates to our services and your rights, and our commitment to your rights. It also describes your choices regarding use, access and correction of your personal information.

Our Mission
Walker's mission is to provide our clients with information-based measurement solutions to help improve their performance by enhancing business loyalty and critical relationships with their customers, employees, and other key stakeholders. As a part of our process, we use scientific methods that reveal to clients where they have leverageable strengths and critical weaknesses in their relationships with their stakeholder groups. In assessing these strengths and weaknesses, we encourage our clients to act on the feedback provided by their stakeholders by creating process improvement initiatives. The outcome from these efforts is improved quality of products or services and/or increased value delivered to customers of our clients.

Information We May Collect About You
Walker collects personal data either for surveys or for marketing-related activities.

Surveys
For surveys, Walker Information processes, on behalf of our clients, personal data that has been collected by or on behalf of those clients. "Personal Data" means information relating to an identified or identifiable person. Walker Information acts as a Data Processor and each Walker Information Client acts as a Data Controller. A "Data Processor" is an entity that processes Personal Data on behalf of a Data Controller; a "Data Controller" is an entity that determines the purposes for which Personal Data are processed. To "process" Personal Data means to carry out an operation or set of operations on such Personal Data, such as collecting, recording, storing, disclosing, or organizing it. The "Data Subject" means the person to whom a certain set of Personal Data relate; for example, the person who responds to a survey.

Walker Information acknowledges that you have the right to access your personal information. As a Data Processor, Walker Information will only process Personal Data pursuant to the instructions of the applicable Client. Walker Information has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Walker Information’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe.

If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

At times, the Client may ask that a Data Subject confirm their Personal Data for verification. Walker Information may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Client. Walker information will not use or share, either within Walker Information or with a third party, any information collected for our service providers own direct marketing purposes. Walker Information will not be responsible for determining the authenticity of any purported Data Subject's request to access his or her Personal Data. In the absence of express instructions to do so from the applicable Client, Walker Information will not provide a purported Data Subject with access to his or her Personal Data unless it is demonstrated to Walker Information's satisfaction that the applicable Data Controller has refused such access.

Marketing Requests
Walker collects personal information when you register for subscriptions to online newsletters and seminars, information downloads and requests for product information, or when you ask to be included in an e-mail or other mailing list. During registration, we require your name, title, company and email address. You also have the option of providing other information such as a salutation and business contact information. We maintain personal information to control access to specific registration sites. We do log your IP address (the Internet address of your computer) to tell us which part of our website you visit and how long you spend there.

Some of our outgoing emails contain a unique image. When the email is accessed and the image is requested from our server, we will identify when that request occurred and record information from the http request, such as the IP address, user agent, etc. This allows us to gauge the effectiveness of our survey communications and also lets us know which emails and links have been opened by recipients.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Walker Information uses such information, if it has been collected, in accordance with acceptable privacy practices consistent with this policy and applicable laws. Access to certain Walker web pages requires a login and a password. Walker may share your information with one or more of our Global Network Partners so they may provide you with additional information relevant to your request. We will not transfer your personal information to other third parties without your consent.

Walker uses information for several general purposes: to fulfill your requests for certain products and services, to personalize your experience on our website, to keep you up to date on the latest product announcements or other information we think you'd like to hear about, and to better understand your needs and provide you with better services. We may also use your information to send you, or to have our Global Network Partners send you, direct marketing information.

Walker Information subscribes to an "opt-in" policy. This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted. We will always give you the opportunity to "opt out" of receiving direct marketing information.

If Walker is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Tracking Technologies 
Walker Information and its partners use cookies ("cookies" are small text files stored on your PC's hard disk and used for keeping track of settings or data for a particular web site) or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service.

For both online surveys and marketing requests, we automatically capture information about your browser type in order to deliver richer context, tailored for a better experience, and suited to your software and preferred language setting. We do no other invisible processing of data from your computer. Additionally, we may use cookies tied to personal information and other similar devices sparingly and only for quality control and security validation purposes.

Security
If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of Walker's website if you do so.

Our web site has security measures in place to protect the loss, misuse, and alteration of the information under our control. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Only certain Walker Information employees have access to the information you provide us. They have access only for data analysis, quality control purposes, and opt-in marketing. If you have any questions about the security of your personal information, you can contact us at privacy@walkerinfo.com.

How Your Information May Be Used: Surveys
Respondents are adequately informed about the nature of the survey (who is conducting it, how the information will be used, etc.) and understand that their cooperation is entirely voluntary and agree to participate on this basis. Depending upon the nature of the program, it may be necessary for clients look at information from individual respondents in an effort to better understand specific issues or to develop process improvement initiatives. Over the past years, we have conducted very few surveys that have incorporated the use of a "confidentiality" question. In these instances, when a survey respondent specifically requests to have their answers remain confidential by indicating in their respective survey, reasonable measures will be taken to ensure their answers are viewed in aggregate form only and all captured comments will have no association to their contact information displayed. If a Client wishes to do their own additional study and analysis they are required to independently comply with existing state, federal and international statutes governing data privacy regarding the disclosure, receipt and use of personally identifiable information.

Those no longer wishing to receive invitations to take surveys from Walker Information clients may reply to the invitation message with "drop" in the subject.

Upon request Walker Information will provide you with information about whether we hold any of your personal information. Individuals who need to change or delete personal data submitted to Walker Information may send an e-mail to privacy@walkerinfo.com. We will respond to your request to access within 30 days. If after having submitted personally identifiable information to a survey, a user requests not to have their information associated with their survey responses, their survey record will be marked as 'confidential'.

Your information may be stored and processed in the United States or any other country in which Walker Information or its affiliates, subsidiaries, or agents maintain facilities. By participating in a survey, you consent to any such transfer of information outside of your country.Under certain circumstances required by law or court order, Walker Information will collect, use, and/or disclose personal data pursuant to procedures that do not require giving notice or conducting related activities. We may disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Blog
Our Web site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at support@walkerinfo.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Links to 3rd Party Sites
Our Site includes links to other Web sites whose privacy practices may differ from those of Walker Information. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Social Media Widgets
Our Web site includes Social Media Features, such as the Facebook Like button [and Widgets, such as the Share this button or interactive mini-programs that run on our site]. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Single Sign-On
You may be able to log in to www.walkerinfo.com using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.  Services like Facebook Connect give you the option to post information about your activities on this Web site to your profile page to share with others within your network.

How Your Information May Be Used: Marketing Requests
Walker Information uses personal information to respond to your request for marketing materials. We are committed to using this information responsibly. To opt out of receiving Walker Information's online newsletter Creating Loyalty, or another recurring email communication, reply to the corresponding received e-mail message with the word "remove" or "unsubscribe" in the subject.

Walker's Commitment to Respondents and Your Rights
Walker Information participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Walker Information is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. (www.privacyshield.gov/list).

Walker Information is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Walker Information complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Walker Information is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Walker Information may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website (www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

If you have questions or concerns regarding this statement, you should first contact us with the information in the section, “How You Can Reach Us”, below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at feedback-form.truste.com/watchdog/request.

Walker Information complies with the U.S.–Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from Switzerland. Walker Information has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Walker Information’s certification, please visit safeharbor.export.gov/swisslist.aspx.

As with all forms of marketing and opinion research, your cooperation is voluntary at all times.

While Walker Information counsels clients on the appropriate use of survey research data, Walker Information does not review, comment upon or monitor its Clients' compliance with their respective privacy policies, nor does Walker Information review Client instructions to determine whether they are in compliance or conflict with the terms of a Client's published privacy policy. Walker Information will, and reserves the right to, modify and update this policy or its related business practices at any time. Walker Information will not apply changes to this policy that retroactively affects personally identifiable information without your express consent. For material changes affecting personally identifiable information that is not owned by the data controller, we will post a prominent notice on the site for 30 days prior to changes taking effect.

Our Policy for Children under 13
We do not knowingly collect personally identifiable information from users under the age of 13. If for some reason, we find that a US user is under the age of 13 we will delete that personal information accordingly.

How You Can Reach Us
You can contact us at support@walkerinfo.com to discuss any problems related to our privacy policy. If you are concerned about our use of your personal data, or would like to file a complaint, please contact us at privacy@walkerinfo.com. You can expect a response to your requests within 30 days.

We can also be reached via mail at the following address:
Walker Information
Attn: Data Privacy Officer
301 Pennsylvania Parkway
Indianapolis, IN 46280

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© 2017 Walker Information, Inc.