Lightspeed Privacy Policy

Effective Date: 21 May 2021
Last Revised: 21 May 2021
Version: Version 1.1

1. Introduction
This Privacy Policy sets out the commitment of Lightspeed LLC, 685 US-206, Suite 204, Bridgewater, New Jersey NJ 08807, USA and its affiliates including Lightspeed Research Limited, 4 Millbank, Westminster, London, SW1P 3JA, UK (altogether "Lightspeed"), a Kantar group company ("Kantar"), to the privacy of its panel members ("Panellists", "Panellist"), and governs Panellists' rights regarding privacy and data protection.
This Privacy Policy applies to the Lightspeed panels known as LifePoints, All Global Circle and MobiWorkX, altogether identified in this Privacy Policy as the Lightspeed panels (the "Panels"). For clarity, this policy is publicly available on the LifePoints panel site as "LifePoints Panel Privacy Policy", on the All Global Circle site as "All Global Circle Privacy Policy" and on the MobiWorkX site as "MobiWorkX Privacy Policy". Panellists are members of the Panels, operated by Lightspeed and for which Lightspeed is the data controller. Taking part in our panels, surveys and research activities is entirely voluntary. By registering to the Panels and accepting these terms, you confirm that you have read and understood the terms of this Privacy Policy. We ask you to read this Privacy Policy carefully.
For the purpose of this Privacy Policy, personal data means any information which relates to an identifiable living individual (or the equivalent applicable term in your jurisdiction - for example in California, personal information would also relate to a specific household).

2. Lawful Collection and Use of Data
We collect your personal data in several ways such as through our website(s) (for example your panel portal), our mobile applications and other activities such as social media, apps and online, face to face or telephone studies or other research activities. We may add other ways and activities moving forward but we will always operate in compliance with this policy.
We have set out below, more detailed information about how we use your personal data. We are also required by law to explain the legal basis for processing your personal data. These legal bases are listed below and could be different for each use case:

We will never misrepresent ourselves or what we are doing. If you receive an email that concerns you, purporting to be from us, please let us know as shown below in ”How to Contact Us”.

Case Purpose Data collected / processed Source
Operating our website(s) Ensure that content from our site is presented effectively, according to the device you are accessing it on. Analyse statistical data about user(s) browsing actions and their patterns IP address, operating system information, browser type We obtain this data from you directly
Panel registration and management To administer your panel profile and to communicate with you, including informing you about the panel, selecting you for future surveys, contacting you to participate in our survey and other research activities, issuing your incentive, helping when you contact our panel support, etc. Name, email address, mobile phone number, postal address, mobile device ID, medical education number (US), GMC Number (UK), le numéro RPPS (France), el número de colegiado (Spain), demographics and any detail you share with us about yourself and your household We obtain this data from you directly
Market Research To understand your views about certain products and services or to understand your behaviour in different situations Identifier, contact details, email address, voice, image, opinion We obtain this data from you directly
Scientific Research for academics, public health organisations or Research Council institutes Including but not limiting to clinical studies, health economics and outcomes research (HEOR), non-interventional studies (NIS), real world research (RWR), observational studies, epidemiology research Identifier, contact details, email address, health data, e.g. disease, health status, diagnose, treatment pattern, unmet needs We obtain this data from you directly, or combined with other secondary database
Scientific Research for commercial companies and charitable research organisations Including but not limiting to clinical studies, health economics and outcomes research (HEOR), non-interventional studies (NIS), real world research (RWR), observational studies, epidemiology research Identifier, contact details, email address, health data, e.g. disease, health status, diagnose, treatment pattern, unmet needs We obtain this data from you directly, or combined with other secondary database
Safety monitoring (Pharmacovigilance Adverse Events Reporting) Report Adverse Events during our studies to competent authorities Identifier, contact details, email address, disease, treatment, product taken and adverse events We obtain this data from you directly, or combined with other secondary database
Public Disclosure To share or disclose pursuant to judicial or other government subpoenas, warrants, orders or pursuant to similar and other legal or regulatory requirements, we will provide such information to the appropriate authorities Identifier, name, contact details, email address, incentive received We obtain this data from you directly, or combined with other secondary database
Fraud Protection Protection of our business interests against fraudulent behaviour IP address, browser specifications, device specifications, postal addresses, email addresses, official identification number (i.e. ME number) We obtain this data from you directly
Survey Participation Uniqueness Prevention of multiple entries in surveys by the same individuals in line with our Terms and Conditions IP address, browser specifications, device specifications We obtain this data from you directly
Tracking of the Answers of Recurring Respondents (special research design projects) When you participate in our surveys, we typically use a temporary ID which makes your answers in the survey anonymous to our clients. However, some of our clients have the specific research design need to understand how your opinion has evolved over a period of time. For this specific project type that we call "tracking" projects we will use persistent IDs and we will make this clear at the beginning of each of these surveys. Your survey responses will be considered as personal data and you will have the right to access them. Such projects will contain a notice on the very first page of the survey, so that you can identify them and decide whether or not to take part Persistent unique project-specific identifier We obtain this data from you directly
Data Matching and Enrichment We enrich the data we hold on file about you by matching your personal data with third parties. This will help us to improve your panel profile and ensure that we select relevant surveys for you. We utilize matching services (i.e. third parties who are specialized in data management) to acquire additional information about you from public and private data sources (such as social networks, retailers and content subscription services with whom you have an account) or to use your personal data as an aid to develop additional or new types of anonymous data sets (i.e. we compile your aggregate data with data from other consumers to create a new lifestyle segment). The matching service (our data partner) holds the personal data we share for a short time, uses it to assemble the additional information, and then returns the combined information to us. Data partners are contractually bound to delete the data we share with them and/or are not authorised to use it in any way other than for this specific purpose. Persistent unique identifier, contact details, email address, social login, cookie, mobile device ID, official identification number (i.e. ME number) We obtain this data from you directly
Advertising Targeting and Media Buying Research We use your personal data to help our clients and data partners enrich their data by using lookalike modelling techniques. Thanks to your participation in our surveys and your profile data, we can help our clients to improve their advertising targeting, and to create better online advertising models, through lookalike modelling or similar research methodologies. We will use your personal data we collect about you through profile building, participation in research surveys or data matching to match with third-parties and platforms (our data partners). We include contractual safeguards to ensure that you will not automatically be targeted for commercial purposes, as a result of your data being used to help create a lookalike audience, and that our data partners cannot use your data for any other purpose. Persistent unique identifier, contact details, email address, social login, cookie, IP address, mobile device ID, official identification number (i.e. ME number) We obtain this data from you directly or combined with other secondary database
Ad Exposure and Measurement In addition to cookie-based matching (which you can control and consent to via your panel account), we will use personal data you provide to us, such as an email address, in a direct matching process with third parties (i.e. our clients and publishers) to determine if you are a user of that service (such as social networks, websites, mobile apps) for advertising measurement research purposes. We will identify what advertisements you may have been exposed to on those sites and platforms and measure how brand attitudes or brand recall have impacted sales. The third parties that we work with are not permitted to use the data for any other purpose. Persistent unique identifier, contact details, email address, social login, cookie, IP address, mobile device ID, official identification number (i.e. ME number) We obtain this data from you directly or combined with other secondary database

3. Third Parties (Clients and Suppliers)
We may share your personal data with our third-party vendors and processors to perform panel management related activities in order to deliver panel services and activities to you. This could include vendors managing or assisting us in managing our panel databases, marketing automation and CRM, quality checks and fraud prevention, incentive management, and customer care. Some vendors will specifically work with us on enriching your panel profile, allowing us to select you for surveys, such as vendors specialized in, but not limited to, data matching, online ad effectiveness measurement, and social media data interactions. Categories of personal data shared with these vendors would typically be, but may not be limited to, name, email address, postal address, phone number, cookie ID, panelist ID, and IP address. Your personal data is not sold to third parties.
Our third-party data partners and publishers are all contractually bound to keep any information they collect and disclose to us, or that we collect and disclose to them, confidential and must protect it with security standards and practices that are equivalent to our own.

4. Confidentiality, Security and Industry Requirements and Where We Store Your Personal Data
We take appropriate technological and organisational measures to protect your personal data, both during transmission and once we receive it. Our security procedures are consistent with generally accepted standards used to protect personal data.
The data that we collect from you may be transferred to and/or stored outside your territory. It may also be processed by staff operating outside your territory who work for us or for one of our suppliers. If your personal data is transferred to, stored at or otherwise processed outside your country or territory, 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, as required by applicable law. For example, if you are in the EEA, standard contractual clauses would be used if we process your data outside the EEA.
Your account information and personal data are password protected so that you and only you have access to your information. In order to keep your personal data safe, we recommend that you do not divulge your password to anyone. Lightspeed will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also, please remember to sign out of your Panels account and close your browser window when you have finished visiting our site. This is to ensure that others cannot access your personal data and correspondence if you share a computer with someone else or are using a computer in a public place like a library or Internet cafe. Please change your password regularly.

5. Industry Standards
We adhere to various standards and industry codes depending on your location, including:

6. Cookie Disclosure
Cookies are small text files stored on your computer or mobile device by a website that assigns a numerical user ID and stores certain information about your online browsing. They are used to help users navigate websites efficiently and perform certain functions. The website sends information to the browser, which then creates a text file on the user’s computer or mobile device. Every time the user goes back to the same website, the browser retrieves and sends this file to the website's server.
For behavioural tracking research, we use optional cookies / software applications, but only if you have given your consent to these cookies / applications.
As is true of most online surveys, we gather certain information automatically and store it in survey data files. This information may include the following: Internet Protocol addresses (IP address), browser type, Internet service provider (“ISP”); referring/exit pages, operating system and date/time stamp.
We use this automatically collected information to analyse trends such as browser usage and to administer the site, e.g. to optimise the survey experience depending on your browser type. We may also use your IP address to check whether there have been multiple participations in the survey from this IP address and to protect our business against fraudulent behaviour.
Lightspeed defines cookies within 3 categories:

Specifically for the MobiWorkX panels, we use the following cookies which are categorized as “required” or “security-specific” cookies.

Cookie Name Source Type Validity
_ga Google Analytics (non personal) 2 years
_pk_ses.16.1182 Piwik PRO Analytics (non personal) 2 years
_gat_gtag_UA_110023928_17 Google Analytics (non personal) 2 years
ARRAffinity Unsigned Security No expiry date
ARRAffinitySameSite Unsigned Security No expiry date
_gid Google Analytics (non personal) 2 years
_pk_id.16.1182 Piwik PRO Analytics (non personal) 1 year
.AspNetCore.Antiforgery.w5W7x28NAIs ASP.NET Core Security Session based (30 mins)
.AspNetCore.Session ASP.NET Core Security Session based (30 mins)
_pk_ses.16.1182 Piwik PRO Analytics (non personal) Session based (30 mins)
uic ASP.NET Core Security Session based (30 mins)

7. Accuracy
We take reasonable steps to keep personal data in our possession or control accurate, complete and current, based on the most recent information made available to us by you and/or by our client.
We rely on you to help us keep your personal data accurate, complete and current by answering our questions honestly. You are responsible for ensuring that you notify us of any changes to your personal data.

8. Children’s Data
Lightspeed recognizes the need to provide further privacy protections with respect to personal data collected from children. We never knowingly invite children under the legal age set by the authorities in the country in which you reside to participate in research studies without parental permission. If it is necessary and appropriate to a particular project to directly involve children under the legal age, we take measures to ensure we have been obtained permission by a parent and/or legal guardian. Lightspeed will provide parents and/or a legal guardian information about the survey topic, any personal or sensitive information which may be collected from the children, the way the data will be used and whether and with whom Lightspeed may share such information. We do not sell children’s personal data.
While the child is completing the survey, it is the responsibility of the parent and/or guardian to supervise them.

9. Sensitive Data
From time to time, Lightspeed may collect personal data that is classified as “special categories” of personal data. This includes racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. You can always choose whether to provide this data to us.

10. Rights of Individuals
To request access to personal data that we hold about you, you should submit your request in writing to the e-mail address or postal address shown below in the ”How to Contact Us” section. When you make a request you should provide your panellist ID or any other relevant identifiers. We may also request you provide a copy of a valid government issued or official identification (such as drivers licence or passport) if we need to verify your request.
You have the following rights in relation to your personal data:

If necessary, we shall also notify third parties to whom we have transferred your personal data of any changes that we make on your request. Note that while Lightspeed communicates to these third parties, Lightspeed is not responsible for the actions taken by these third parties to answer your request. You may be able to access your personal data held by these third parties and correct, amend or delete it where it is inaccurate.

11. Data Storage and Retention
Personal data shall be retained only for such period as is appropriate for its intended and lawful use. Lightspeed shall retain your personal data for as long as you are a member of the Panels. In the event that you unsubscribe from the Panels, we shall retain data for no longer than 3 months after you unsubscribe, unless otherwise required by law. Personal data that is no longer required shall be disposed of in a manner that ensures that the confidential nature is not compromised.
As part of the Company Business Continuity Plan and as required by ISO 27001, ISO 9001, ISO 20252 and in certain instances the law, our electronic systems are backed up and archived. These archives are retained for a defined period of time in a strictly controlled environment. Once expired, the data is deleted and destroyed to ensure the data is erased completely.

12. Updates to our privacy policy
We keep our privacy policy under regular review and it may be amended from time to time and at least every 12 months. We will always have the most up-to-date policy on our website, or within your panel portal. We will record when the policy was last revised. Non-material changes to this Privacy Policy will be announced through the Panels’ sites only. Your continued access to the Panels’ sites and services after such changes conclusively demonstrates your consent to any changes.

13. How to Contact Us
If you have any questions or concerns relating to your privacy or to Lightspeed privacy practices, (or for example you wish to unsubscribe) you can contact our General Counsel and Data Protection Officer and you can contact Lightspeed:

14. Complaints & Country Specific Disclosure
If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state or jurisdiction of your habitual residence, your place of work or the place of the alleged infringement. If you are in the EU and to find the contact details of your country supervisory authority, please consult this page: