Privacy Policy

Last Updated March 16, 2021

Who We Are and What We Do

Brookmark Research Services, LLC (“Brookmark”) is a full-service market research agency that
conducts both qualitative and quantitative studies among consumers and businesses.

Our Commitment to Privacy

Brookmark recognizes the importance of the privacy of our clients and the people who complete
the surveys we prepare on their behalf (such people, the “data subjects”), and take steps to
protect their privacy. Brookmark has also taken steps to comply with applicable requirements of
the EUs General Data Protection Regulations (“GDPR”).

This Privacy Policy describes the information that Brookmark gathers, uses and discloses from
the contacts we have with you and your data subjects, such as by survey, mail, email, telephone,
Internet, mobile applications, and otherwise and your choices about how we may disclose the
information.

This Privacy Policy applies only to data we collect from our clients and their data subjects in
connection with our services. If you have any questions about this Privacy Policy, please send us
an email at privacy@brookmark.com, or contact us by mail at 3 Bessom Street, Suite 328,
Marblehead, Massachusetts 01945.

About Market Research Surveys

Brookmark conducts market research to gather and analyze information from various audiences
including consumers, customers/potential customers, business owners and other stakeholders.
The topics or purpose of the research is varied but examples include evaluating reactions to
products and services, evaluating new concepts, measuring satisfaction with products and
services and measuring general awareness of brands.

The Personal Information We Typically Collect About You in Our
Surveys

It is important to understand that one of the many goals of market research is to capture the
opinions of a representative portion of a specific population. As a result, Brookmark collects
what is defined as personal data or personally identifiable information under an applicable law
(“personal information”). This typically relates to demographic information and includes
questions regarding age, gender, ethnicity, income, marital status, education level, email address,
etc.

Personal information may also be provided by sources who have assured Brookmark that each
applicable individual has explicitly consented to being disclosed to Brookmark. These sources
include:

  • Clients who engage Brookmark to conduct research on their behalf
  • Suppliers / list providers / panel owners who manage lists as part of their core business


Unless you have provided specific consent to do otherwise, Brookmark will protect the
anonymity of your responses to surveys, participation in focus groups or in-depth interviews or
any other means of collecting feedback from you. In fact, in most cases, Brookmark collects only
anonymized information and cannot identify you or connect your survey responses and other
feedback to you personally.

Data Collection Methods

The following are ways Brookmark either collects or receives personal information about you:

  • Data provided by clients or companies you may have a relationship with
  • Data provided by industry suppliers, list providers or panel owners
  • Data provided by focus group facilities
  • Data provided by other third parties
  • Data provided by you, the data subject, while participating in a survey including online surveys, telephone interviews, mall intercepts, etc.


Information We Typically Collect When You Start Our Surveys

As you navigate our surveys, we may use automatic data collection technologies to collect
certain information about your computer, mobile device or other device that you use to access
the survey. This information may include IP address, geolocation information, unique device
identifiers, browser type, browser language and other transactional information.

Brookmark may collect non-personally identifiable information through the use of cookies. A
cookie is a file that a website installs on your hard drive or mobile device so the site can identify
you while you are using it or when you return to the website. Similarly, a mobile application may
use a unique device identifier to identify your mobile devices. Cookies and unique device
identifiers may remain on your computers or mobile devices after you cease using the website or
mobile application. You may decline to accept cookies by modifying your web browser settings,
and you may be able to disable unique device identifiers. If you choose so, however, you may be
unable to use all functions of websites and mobile applications, or the websites and mobile
applications may operate less efficiently.

Information We Never Ask for in Our Surveys


Brookmark will never ask you for any of the following information:

  • Driver’s license number or any state issued ID numbers
  • Social security number or any government issued ID numbers
  • Bank account information
  • Credit card numbers


Information We May Collect When You Visit Brookmark.com

As a general matter, you can browse the Brookmark website without submitting your personal
information to us. Brookmark also collects personal information when you submit information
to us via the “Contact Us” page on our Website. Similarly, Brookmark retains information sent
to us via other means, such as email, mail, and telephone. This information frequently incudes
names, addresses, emails, telephone numbers, and cellphone numbers. Contact information is
generally used for purposes of conducting business. We will treat this information as
confidential personal information.

We also collect and store certain other information regarding our users’ use of the Website so
that third parties may provide us with reports and analysis regarding usage and browsing patterns
of the Website.

If you give us your email or address, we may send you emails, notices, or other information. If at
any time you do not wish to receive emails, notices, or other information from us, please see the
“How to remove your name from our mailing, sharing or email list” section below.

When you interact with any Brookmark page or account on a social media platform, such as
Facebook, Twitter, Google+, LinkedIn, Tumblr, YouTube, or Pinterest, we may also collect the
personal information you make available to us on that page or through that account, including
your account ID or “handle”.

Other than as set forth in this Privacy Policy, Brookmark will give you notice when personal
information about you might be shared by us with third parties, and you will have the
opportunity to instruct us not to share the information.

How We Use Your Information

Brookmark is a marketing research company. Brookmark uses personal information (collected as
described in this Privacy Policy) to provide marketing research and analysis services to its
clients. The research and analysis Brookmark delivers does not identify survey participants
individually.

If your personal information is provided to Brookmark via a client or customer of that
client
, we will only use it for purposes of conducting market research for that client. The survey
results will be provided to the client in a way that will protect your anonymity unless you have
explicitly given permission or have explicitly requested that Brookmark shares your individual
survey results, your identify and/or your contact information. We will not use any information to
sell you any goods or services and we will not provide your information to other parties to
directly sell you goods or services.

If your personal information is provided to Brookmark via a list, panel or sample
company
, we will only use it for purposes of conducting market research. We will not use any
information to sell you any goods or services and we will not provide your information to other
parties to directly sell you goods or services. As previously stated, Brookmark will only work
with list, panel or sample companies that have received consent from individuals (i.e., data
subjects) who have agreed to participate in market research.

If your information is provided to Brookmark directly from you, the data subject, we will
only use it for purposes of conducting market research or the specific purpose for which you
provided the information (such as to comply with your request to contact you). We will not use
any information to sell you any goods or services and we will not provide your information to
other parties to directly sell you goods or services. Your survey responses will be provided to
the client in a way that will protect your anonymity unless you have explicitly given permission
or have explicitly requested that Brookmark shares your individual survey results, your identify
and/or your contact information.

Brookmark may employ others to perform certain functions. Examples include operating and
maintaining our website, sending mail and email, maintaining client lists and other records,
analyzing data, providing marketing consultation and other assistance, distributing surveys,
fulfilling incentives for participating in surveys and providing customer service. Brookmark will
provide personal information to such other companies and individuals to the extent it is
necessary or appropriate for them to perform the functions that we retain them to perform, in
each case pursuant to a written agreement that includes data privacy and protection measures
appropriate for the circumstances.

Brookmark may disclose personal information when we believe that it is necessary or
appropriate to comply with applicable laws, regulations, legal processes, governmental requests,
or contractual obligations, to address insurance, audit, or security matters, or for any other
purpose that we have a good faith belief the disclosure is required, authorized or appropriate. We
also may release such information to enforce or apply this Privacy Policy or other agreements, or
to protect the rights, property, or safety of Brookmark, you, other clients, data subjects,
employees, or others. We also may disclose such information if you or a data subject expressly
or, where permitted, impliedly authorize or consent to such disclosure of the information, and in
each such case our disclosure will be limited to the purpose for which such authorization or
consent was given.

GDPR

If you live in the European Union or an adjacent country to which GDPR applies, you may have
additional rights under GDPR, depending on the nature of the personal information and our use
of that information under this Privacy Policy and, if applicable, our agreement with the
applicable client. These rights may include the right to access and correct your personal
information, to request the erasure or transfer of your personal information, and to object to or
restrict the processing of your personal information. If the processing of your personal
information is based on your consent, you have the right to withdraw your consent at any time.

How To Inquire About Your Personal Information

If you have any questions or concerns about our GDPR policies and/or the privacy or security of
your information, or if you wish to exercise your rights relating to your personal information,
you may send us an email at privacy@brookmark.com, or contact us by mail at 3 Bessom Street,
Suite 328, Marblehead, Massachusetts 01945. If your personal information has been provided to
us by a third party, such as your employer or other party with which you have an agreement that
relates to that party’s collection and use of your personal information, please note that our use of
your information may be determined by our agreement with that third party. Accordingly, where
that is the case, please direct your inquiry to that third party. If we receive a request from a client
or other source of personal information relating to an inquiry by an individual data subject or a
supervisory authority, we will respond promptly and in accordance with applicable law.

Justifying the Use of Your Personal Information

The use of your personal information under GDPR requires that there be a “legal basis” for each
use.

Where Brookmark receives your personal information from a client or a customer of that client,
or from a list, panel or sample company, Brookmark’s use of your contact information and
demographic information is based on the need for such information in order to perform
Brookmark’s obligations under the contract between Brookmark and that client, customer or
other company. Brookmark, in turn, relies on that client, customer or other company to have
properly addressed GDPR requirements with individual data subjects, whether through contracts
or appropriate consent. Again, in most such cases, Brookmark does not actually receive personal
information that can be associated with you by us.

Where Brookmark itself collects additional personal information about data subjects whose
contact or demographic information has been provided initially by a client or a customer of that
client, or from a list, panel or sample company, Brookmark’s use of such information is based o
Brookmark’s legitimate interest in preventing fraud, and in analyzing and improving
Brookmark’s services. As described above, this type of information is generally limited to IP
address, device identifiers, and other technical information and is used by Brookmark only as
described in this Privacy Policy.

Where you choose to provide other personal information directly to Brookmark, such as your
email address, Brookmark’s use of such information is necessary to fulfill the purpose for which
you provided the information. For example, if you ask Brookmark to send you information and
you provide your email address, Brookmark will use your email address to respond to your
request. Brookmark also has a legitimate interest in using such information for the purposes
described above.

California Residents

California residents may have additional rights under the California law, including the California
Consumer Privacy Act (the “CCPA”). If you are a California resident, you have the right to
request and obtain from us once per year, free of charge, a list of third parties to whom we have
disclosed your personal information (if any) for their direct marketing purposes in the prior
calendar year, as well as the type of personal information disclosed to those parties. We do not
share personal information for direct marketing purposes. Note that CCPA does not currently
apply to us, although it may apply to our clients or their customers, or to a list, panel or sample
company from which we may have received your personal information. In any case, we do not
sell personal information, and our role for CCPA purposes is that of a service provider. For
more information about CCPA, please refer to the following: https://oag.ca.gov/privacy/ccpa.

How to Remove your Name from Our Mailing, Sharing or Email List

To not receive future communications from us, and, where applicable, to have us not share your
information with third parties, you can do either of the following:

  1. Send us an email at privacy@brookmark.com, or contact us by mail at 3 Bessom Street, Suite
    328, Marblehead, Massachusetts 01945, and instruct us to remove you from our mailing, sharing
    or email lists. You may also use this email and address to request that we correct any information
    we have about you.
  2. If available, use the “opt out” or “unsubscribe” option included in an email that you receive
    from Brookmark.

    Children’s Privacy

    Brookmark does not sell products or services to children or minors, and we do not want to collect
    or store personal information about children or minors. If you are under 18 years old, you may
    complete Brookmark’s surveys, use Brookmark’s website and purchase products or services
    from us only with the direct involvement of a parent or guardian. If you are under 13 years old,
    do not send Brookmark any personal information about yourself, including your name, address,
    email, telephone number, or cellphone number. In the event Brookmark learns that we have
    collected personal information about a person who is younger than 13 years old, we will
    endeavor to delete the information as soon as possible. If you know Brookmark has collected
    personal information about any person who is younger than 13 years old, please inform us by
    contacting Brookmark as provided below.

    External Links

    If any part of the Brookmark’s website links you to other websites or mobile applications, those
    websites and mobile applications are not under Brookmark’s control and do not operate under
    this Privacy Policy. Brookmark recommends that you examine the privacy statements posted on
    those other websites and mobile applications to understand their procedures for collecting, using,
    and disclosing personal information.

    Information Security

    Brookmark has implemented physical, managerial, administrative and technical security
    measures to protect the personal information it collects, including against loss, theft, fraud, and
    unauthorized access, use, copying and disclosure. If Brookmark becomes aware that a breach or
    potential breach of security has occurred involving your personal information, we will take
    prompt action to investigate the situation, remediate to the extent remediation is necessary,
    appropriate, effective or otherwise required by law, and notify you or the appropriate third party
    about any breach affecting your personal information that has occurred if required to do so by
    applicable law.

    Data Retention Policy

    Our data retention policy varies by client. Brookmark will only store data as long as it is
    necessary to successfully complete the requirements of a research project. We retain personal
    information we collect when we have an ongoing legitimate business need to do so. When there
    is no longer a legitimate business reason to process/retain your personal information we will
    either delete it or in some cases anonymize it.

    International Data Transfer

    If you are participating in one of our research studies or visiting our website, please be aware that
    your personal information may be transferred to, stored in and/or processed in, countries other
    than the country in which you are resident. These countries may have data protection laws that
    are different to the laws of your country. Specifically, our data servers are located in the United
    States and the EU , and our third-party service providers (including Amazon Web Services
    (“AWS”)) and partners operate around the world. This means that when we collect your personal
    information, we may process it in any of these countries. If you send us personal information
    directly, you acknowledge and consent to such transfer and processing. We enter into appropriate
    written contracts with our clients and service providers in connection with cross-border transfers
    and processing of personal information.

    How To Contact Us

    If you have any questions or concerns about the privacy or security of your information, you may
    send us an email at privacy@brookmark.com, or contact us by mail at 3 Bessom Street, Suite
    328, Marblehead, Massachusetts 01945.

    Changes To Privacy Notice

    Brookmark may change or update this Privacy Policy in the future, with or without notice.