Privacy Policy

PRIVACY POLICY

Last Updated: July 28, 2020

Introduction

Welcome! You have arrived at the Halverson Consulting LLC website (referred to herein as “Halverson” or “we,” “our,” or “us”), or you are otherwise interacting with our services or engaging with our studies, surveys or other programs (our “Services”). We are committed to respecting and protecting your privacy. It is important that you read and understand this Privacy Policy before using this website or interacting with our Services. To ease review, you may click on each section heading below to link to the full disclosure.

Table of Contents

Who We Are

Halverson is a global strategy and research agency. We partner with companies in a variety of industries (our “Clients”) to help them better understand who their consumers are and what drives people to make the purchase decisions that they make. With a better understanding of their consumers, our Clients are better able to expand their brand influence, innovate their products and services, and create meaningful connections with people. Our mission is to help organizations grow today and flourish for future generations.

 

While providing Services to our Clients, we may collect personal information (“Personal Information”) from consumers on behalf of our Clients. The collection and use of this Personal Information are governed by our contract with the relevant Client and that Client’s own privacy policies. However, we have provided in this Privacy Policy a general overview below of the categories of Personal Information we collect on behalf of our Clients, and how we collect and use such information.

Scope

This Privacy Policy applies to and describes the treatment of Personal Information collected through websites and applications that post a link to this Privacy Policy (each referred to herein as a “Site”), including https://halversonprod.wpengine.com/; certain offline collection of Personal Information through the Services; and from third party sources, as described in more detail below.

Participation in our Site and Services is completely voluntary. You are not required to provide all Personal Information identified in this Privacy Policy; however, please be advised that if you choose not to provide certain Personal Information, we may be unable to provide some or all of the Services to you, and your ability to use the Site or Services may be limited. Please be sure to review the Site’s Terms of Use which, in addition to this Privacy Policy, governs your use of the Site. If you voluntarily provide Personal Information in the course of using our Site or Services, you consent to our Privacy Policy and Terms of Use.

Please note, unless otherwise stated, this Privacy Policy does not apply to the following:

  • Sites or Services that post separate privacy policies or privacy notices;
  • Information that is de-identified or anonymous;
  • Our Client’s use of your Personal Information; and
  • Third-party websites, applications or services, even if they are accessible from our Site or Service. Any information collected by such third parties is governed by that third party’s privacy policy, and we are not responsible for the privacy practices of such third party. We encourage you to be aware when you leave our Site and to read the third-party privacy policies to understand their privacy practices.

Information We Collect About You

We refer to “you” a number of times in this Privacy Policy. To better understand what information is most relevant to you, see the following useful definitions.

 

Clients

You are a representative of a company that has hired us to perform Services on such company’s behalf.

 

Participants

You have responded to a survey, or participated in a research study, interview, or other program, run by Halverson on behalf of one of our Clients.

 

Website Visitors

You are just visiting the Site to learn more about our Services.

 

Types of Information We Collect

We collect the following types of Personal Information through the Site and Services:

  • Your contact information, such as your first and last name, phone number, email address, and mailing address, and that of others you provide to us (e.g., other contacts in your business or household).
  • Registration information where you are required to create an online account, such as username and password.
  • Biographic or demographic information, such as your employer and job title/position.
  • Commercial information, such as Services you have considered or purchased from Halverson.
  • Usage, technical, and device information when you visit our Sites or participate in our Services, such as: operating system and browser; IP address (which may be associated with your location); identifier information assigned to your mobile device (e.g., Apple’s IDFA or Google’s GAID); geolocation data (if you have consented to provide this through your mobile or other device); wireless service provider; your interaction with our Site or Services; and other transactional information for that device.
  • Any other information you submit to us, such as through any “contact us” feature.

Information We Collect on Behalf of Clients

In connection with our Services, we may collect the below types of Personal Information from Participants on behalf of our Clients. As a reminder, the use of this information is governed by our contract with the relevant Client and such Client’s privacy policies.

  • Your contact information, such as your first and last name, phone number, email address, and mailing address, and that of others you provide to us (e.g., others in your household).
  • Biographic or demographic information, such as your employment and education history, gender, ethnicity, age, marital status, and household income.
  • Images, videos, and audio recordings that may include you as a consumer in one of our Client’s retail locations, or that you submit or consent to be in.
  • Your account or transaction history with a Client (note, this information is typically anonymized and never contains any credit card or banking information).

Health and Other Sensitive Information

We ask that you not send us any sensitive Personal Information (such as health or medical information, social security numbers, or information related to racial or ethnic origin, political opinions, religion or other beliefs, criminal background or trade union membership) unless we specifically request it from you and you opt in to providing such information for the specific purposes we explain in advance.

How We Collect Your Information

We may obtain Personal Information about Clients, Participants, and Website Visitors from the following categories of sources:

 

Directly from You

We collect Personal Information you provide to us when you request or purchase Services from us, request information from us regarding our Services, create or register for an online account and save information on our Sites, sign up for marketing email lists, or otherwise interact with our Site and/or Services.

 

If you are a Participant, we collect Personal Information directly from you when you sign up for and participate in our Services, such as surveys, research studies, interviews, or other programs that we run on behalf of our Clients. In some cases, our Clients request additional confidentiality protections in place before collecting feedback from Participants. In these cases, you will be asked to sign confidentiality, release, and/or consent agreements prior to your participation in the Services.

 

Cookies and other Tracking Technologies

We may use various methods and technologies to store or collect information (referred to herein as “Tracking Technologies”), including about your visit to and use of our Sites. These Tracking Technologies may include the following:

  • Cookies. A cookie is a file placed on a device to uniquely identify your browser or to store information on your device. Our Sites may use HTTP cookies, HTML5 cookies, Flash cookies, and other types of cookie technology.
  • Web Beacons/Pixels. A web beacon is a small tag (which may be invisible to you) that may be placed on our Site’s pages or emails we send.

There may be other Tracking Technologies used by us now or later developed and used by us in connection with our Sites and Services. For more information and your choices and options with respect to our use of Tracking Technologies, please visit our Cookie Policy. Please note that changes you make to settings for Tracking Technologies may render certain functions of our Sites or Services inoperable or more difficult to use.

From Our Clients

We may receive Personal Information of Participants from our Clients in connection with our Services, such as information related to account history, purchase frequency and history, and information regarding store visits. This information is typically anonymous, aggregated data used for research purposes.

 

From Other Third Parties

We may also obtain Personal Information from third-party sources, such as recruitment or research agencies that assist connecting us with Participants; technology providers who assist collecting Personal Information from Participants (such as third party applications and websites that collect survey responses on our behalf); lead generation partners that connect us with potential Clients; our affiliate and subsidiary companies; vendors we use to validate postal or email address; and other trusted third parties.

 

Why We Collect Your Information

Our Use of Your Information

We may use Personal Information of Clients and Website Visitors, and in limited cases Participants, to:

  • Provide you with requested Services;
  • Operate, understand, optimize, develop, or improve our Sites, Services and operations, including tailoring the Sites and Services to your preferences;
  • Ensure device and/or survey compatibility;
  • Ensure we do not analyze multiple responses from the same Participant;
  • Establish and verify the identity of visitors to our Sites or users of our Services;
  • Open, maintain and administer accounts you open through our Sites or Services;
  • Send you email or SMS/text marketing messages, where you have signed up to receive them;
  • Respond to your questions, inquiries, comments, complaints, or other communications you send to us;
  • Communicate with you about our Sites and Services, including important updates to Sites and Services;
  • Provide you with information about new opportunities, and related communications;
  • Ensure our compliance with relevant legal and regulatory obligations;
  • Maintain the security and integrity of our systems, Sites and Services; and
  • Detect, investigate and prevent activities that may violate our policies or be illegal.

Our Use on Behalf of Clients

Where we have collected or received Personal Information from Participants on behalf of Clients, we use that information to perform the Services for our Clients, including to:

  • Contact you regarding the Services, such surveys, research studies, interviews, or other programs that we run on behalf of our Clients;
  • Send you financial incentives provided by our Clients for participating in the Services;
  • Provide analysis, insights and research reports to our Clients;
  • Compile and provide to Clients Participant feedback, including through the use of photo or video submissions;
  • Validate (in some cases) responses came from a “real” individual (i.e., not a robot or a duplicate submission) through the use of photo or video submissions; and
  • Provide our Clients with a better understanding of consumer behavior, elements of the workplace environment (i.e., the area consumers pass through), and the conditions and environments in which consumers interact with a Client brand, through the recording of images, video and audio in our Client’s retail locations.

 

We will inform Participants of the Personal Information to be collected and uses thereof prior to you agreeing to participate in the Services and provide you with the opportunity to opt out before or at any time during your participation in the Services. We will only collect the Personal Information of Participants, including video or photo submissions, with your prior consent, and your likeness will only be used for research purposes in connection with our Services performed on our Clients’ behalf. Where we are recording images, video, and/or audio from Client retail locations, notices will be clearly posted at each entrance notifying you that you may be recorded with a link to this Privacy Policy for additional information. Such recordings only occur in public areas. We do not link any such recordings, including your likeness and/or activity contained therein, to any other Personal Information, and such recording are used solely in connection with our Services to Clients.

 

How We Share Your Information

We do not share any Personal Information with third parties for their direct marketing purposes unless we have first given you the choice to consent or withhold consent to such sharing. We may share your Personal Information in the following circumstances, or as otherwise described in any privacy notices provided to you at the time your Personal Information is collected:

  • When you request that we share your Personal Information with other companies so they can send you information, offers and/or promotions about their products and services, or when you interact with third parties through our Sites or Services, such as social media sites. Please note we are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies and practices before requesting information from or otherwise interacting with them;
  • When we use third-party service providers to perform services on our behalf, such as hosting and analytics providers, marketing and advertising, consulting services, auditors, and other providers; however, these companies are prohibited from using your Personal Information for purposes other than those requested by us or required by law;
  • With our affiliate companies, meaning companies that are subsidiaries, joint ventures, or are otherwise controlled by or under common control with us;
  • In connection with the sale of one of our businesses, to enforce our Terms of Use or policies, to ensure the safety and security of visitors to our Sites and users of our Services, to protect our rights and property and the rights and property of others, to comply with legal processes, and in other cases if we believe in good faith that disclosure is required by law; and
  • In the case of Participants, with the Client for which the information was collected or as otherwise directed by such Client.

Your Rights and Choices

 

Individuals in certain jurisdictions may have certain rights under applicable privacy laws. Rights specific to California residents are described below. Subject to applicable law, you may have the right to request access to, modification or correction of, or deletion of your Personal Information, and information on how it has been used or disclosed. To exercise your rights, you may contact us at [email protected] We will respond as soon as practicable, and in accordance with applicable law. We may take steps to verify your identity prior to responding to your request, and, where permissible by law, we may charge for such submissions.

Nevada Residents

We do not exchange Nevada residents’ Personal Information for money with anyone so they may further license or sell the Personal Information to additional parties.

Participants’ Right to Opt Out

As a reminder, engaging in our Services is completely voluntary, and  as a Participant you have the right to opt out and/or withdraw your consent to your participation in the Services and our and our Clients’ use of your Personal Information prior to or anytime during the Services (even if you have already consented).  We will provide you with notice of the Personal Information that will be collected and how it will be used prior to you agreeing to participate in our Services. Where we are recording images, video or audio at Client retail locations, notices will be clearly posted at each entrance notifying you that you may be recorded with a link to this Privacy Policy, to allow you the opportunity to opt out of such recording by not entering the premises.

 

You may visit our PRIVACY PORTAL to exercise your right to opt out.

California Residents’ Rights

This section applies only to California residents, as defined in the California Consumer Privacy Act (“CCPA”). As a reminder, if we collected information on a Client’s behalf, our contract with the relevant Client and such Client’s privacy policy governs the collection, use, and exercise of your rights related to that information. If you have questions on how to exercise your rights, you may contact us using the contact information below.

Your Rights Under California Law

If you are a California resident, subject to applicable law, you have the following rights with respect to your Personal Information:

  • Right to Know. You have the right to request, up to two times each year, the categories and/or specific pieces of Personal Information about you that we collect, use, disclose and sell, as applicable, and subject to applicable legal exceptions.
  • Right to Delete. You have the right to request that we delete Personal Information that we collect from you, subject to applicable legal exceptions.
  • Right to Non-discrimination. You have the right not to receive discriminatory treatment by us for the exercise of your rights under the CCPA.
  • Right to Opt Out of “Sale”. You have the right to opt out of the “sale” of your Personal Information to “third parties,” as those terms are defined in the CCPA. Halverson does not “sell” any Personal Information. However, because some uses of third-party services identified in the Cookies and Other Tracking Technologies section may constitute a “sale” under the CCPA (e.g., of Internet or other electronic network activity information), we encourage you to exercise the choices available there from every browser you use to access the Site or Services.

California residents also have the right under the Shine the Light Act to request and receive certain information about the disclosure of Personal Information to third parties for their own direct marketing use, and options with respect to such disclosures. Because we do not share your Personal Information with third parties for their direct marketing use without your consent, these requirements are not applicable.

How to Exercise Your California Rights

You can submit a Right to Know or Right to Delete request through our PRIVACY PORTAL (click the link to access); or calling us at (888) 651-2032.

These rights are subject to our being able to reasonably verify your identity. We will verify your identity by matching information you provide with your request with information in our systems; and, for requests submitted through our Privacy Portal, by requiring you to respond to an automated email to verify your email address. In general, we will ask you to provide the following information in connection with your request: first and last name, email address, participant identification number (if applicable), the relevant Client(s) you were involved with, and the state and country of residence. We may also request additional documentation or information solely for the purpose of verifying your identity.

You may also authorize someone else to exercise these rights on your behalf. When a third party submits a request on your behalf, they must indicate in our Privacy Portal, in their email, or on the phone that they are an authorized agent, and supply us with evidence of such authorization; we will not fulfill any request submitted by a third party related to your Personal Information until we have received confirmation that you authorized such third party to submit a request on your behalf.

Please note that your exercise of these rights is subject to certain exemptions and exclusions, and your requests may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject any part of your request and the reason(s) we are unable to honor it.

CCPA Disclosures

In addition to the information provided elsewhere in this Privacy Policy, we make the following disclosures to comply with the CCPA:

  • We collected the following categories of Personal Information in the last 12 months: identifiers (such as name, address, and email address); commercial information (such as transaction data); internet or other network or device activity; location information (e.g., inferred you’re your IP address or through geolocation data); professional or employment data (such as the name of your employer); legally protected classifications (such as age and gender); audio, electronic, visual, or similar information; and inferences drawn from the above.
  • The sources of Personal Information we collected are outlined in the How We Collect Your Information section above.
  • The business or commercial purposes of collecting Personal Information are outlined in the Why We Collect Your Information section above.
  • We disclosed the following categories of Personal Information for a business purpose in the last 12 months: identifiers (such as name, address, and email address); commercial information (such as transaction data); internet or other network or device activity; location information (e.g., inferred you’re your IP address or through geolocation data); professional or employment data (such as the name of your employer); legally protected classifications (such as age and gender); audio, electronic, visual, or similar information; and inferences drawn from the above. We disclose these categories only as described in the How We Share Your Information section above.
  • We do not “sell” any Personal Information, including that of known minors under 16 years of age.

Visitors from Outside the United States

Our Site and Services are operated in the United States. If you are located outside of the United States, please be advised that information we collect, including Personal Information, may be transferred to, and processed, stored and used, in the United States, and that this is necessary to provide you with the information or Services you have requested, and/or perform any requested transactions. Privacy laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States subject to applicable law. By using this Site or the Services, or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.  For more information about our policies regarding cross-border transfers of Personal Information, you may contact us at [email protected]

Children’s Privacy

We recognize the importance of children’s safety and privacy. Our Sites are general audience websites and applications and are not designed or intended to attract or be used by children under the age of 16. We do not knowingly collect or request Personal Information from children under the age of 16. If you are under the age of 16, you are not permitted to use this Site and should not send us any information about yourself. In the event we become aware we have collected Personal Information from a child under the age of 16, we will take steps to dispose of that information in accordance with the Children’s Online Privacy Protection Act and other applicable laws and regulations. If you are a parent or guardian and you believe your child under the age of 16 provided us with Personal Information without your consent, you may contact us at [email protected]

Data Security and Retention

The security, integrity and confidentiality of your Personal Information are extremely important to us. We have implemented technical and organizational safeguards designed to help protect and secure your Personal Information. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable; and no data transmission over the Internet is guaranteed to be secure. As a result, we cannot guarantee or warranty the security of any Personal Information you provide to or from our Site or through our Services. We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Privacy Policy Updates

We may modify this Privacy Policy from time to time due to evolving legal, operational, or business requirements. When we do, we will post an updated copy on our website. Please look at the posted date at the top of this Privacy Policy to see when we last revised it. Any changes to this Privacy Policy will become effective upon posting.

Contact Us

For more information about our privacy practices, or if you have questions about this Privacy Policy, you can contact us via email at [email protected]