ADDITIONAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Last Revised: February 26, 2021
California Privacy Rights Under CCPA
- Right to Know. The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected your personal information; our purposes for collecting or selling your personal information; the categories of your personal information that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information. Please note that some categories of information are excluded from the definition of personal information under the CCPA.
Details regarding the categories and specific pieces of personal information that we collect as well as the purposes for which we collect, please see the section below titled ‘Personal Information We Collect and How We Use That Information.’
To exercise your Right to Know, please refer to the section below titled ‘Exercising Your CCPA Rights.’
- Right to Delete. The right to request that we delete personal information that we have collected or maintained about you.
To exercise your Right to Delete, please refer to the section below titled ‘Exercising Your CCPA Rights.’ Upon exercising this right, if there are no exceptions to your deletion request under the CCPA, we will delete your personal information from our records in accordance with the CCPA and to the extent required by the CCPA, require the deletion of your personal information by third parties with whom we have shared the personal information that you request to be deleted.
Some exceptions to your Right to Delete include, but are not limited to, circumstances where the personal information is necessary to complete a transaction or to provide the service requested by you for which the personal information was collected or provided (e.g. information required to process payment for your participation in our market research studies); to detect security incidents; to protect against fraud or other illegal activity; or to comply with a legal obligation under California or United States federal laws; enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with HCD Research.
- Right to Opt-out. The right under the CCPA to opt-out of the ‘sale’ of your personal information. The CCPA defines “sell,” “selling,” “sale,” or “sold,” as “…selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.”
HCD Research does not sell personal information in the way that a data broker might sell such information to a company for use in direct sales and marketing activities, however, we do collect personal information when conducting marketing research on behalf of our clients (research sponsors) that is in some cases shared with our clients for marketing research purposes only. When you consent to participate in one of our marketing research surveys or interviews, we may ask to share your personal information with our client (research sponsor) and research service providers solely for the purposes indicated in the consent and as otherwise required by law. Please note that the CCPA exempts from the definition of “sale” or “sell” any transfer that takes place because the consumer uses or directs the business to intentionally disclose personal information to a third party. Therefore, if a consumer consents, or opts-in, to an information transfer as part of a marketing research study, it is not considered a “sale” under the CCPA.
Except as otherwise noted in this privacy notice and indicated in research consent forms for certain types of research studies, most of the data that we share with our clients will be encrypted as well as either de-identified as per the CCPA or in aggregate form as defined by the CCPA.
With regard to any personal information of a minor child under the age of 18, we limit disclosure of their personal information to business purposes or use de-identified or aggregate information about them.
Personal information will only be shared to the extent that you have consented for us to use the information.
To exercise your Right to Opt-out, please refer to the section below titled ‘Exercising Your CCPA Rights.’
- Right to Non-discrimination. The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We will not discriminate against you for exercising any of your CCPA rights.
Note that you may not be able to participate in marketing research surveys, interviews, focus groups or user experience research that we conduct if you exercise your right to delete some or all of your personal information. For example, we may not be able to ascertain whether you meet the parameters of the research sample required to participate in a market research study or we may no longer have the information required to invite you to participate in a study.
Compensation is provided for participation in most of our marketing research studies. The amount of compensation is either set by us or by healthcare manufacturers in certain cases where they are the sponsors of the study. Many factors go into determining the payments for research participation. In many cases, the payments are calculated using variables such as the length of time expected for completion of the study, complexity, professional background, experience/years in a practice or profession, sample size required, or size of universe of qualified research responders as well as fair market value determined by healthcare manufacturers using variables to meet legal and regulatory requirements.
If you have any questions or concerns about your Right to Delete, please refer to the section below titled ‘Exercising Your CCPA Rights.’
Personal Information We Collect and How We Use That Information
- Categories of Personal Information we may have collected in the last 12 months by category. ’YES’ indicates that we have collected that information in the last 12 months.
- Identifiers – YES
- Personal Information categories listed at Cal. Civ. Code § 1798.80(e) (California Consumer Records statute) – YES
- Classifications Protected by California or Federal Law – YES
- Commercial Information -YES
- Biometric Information – YES
- Network or Other Similar Internet Activity – YES
- Geolocation Data – NO
- Sensory Data – YES
- Professional or Employment-Related Information – YES
- Non-Public Education Information (Family Educational Rights and Privacy Act, 20 U.S.C. § 1232(g), 34 CFR 99) – NO
- Inferences Drawn from Other Personal Information – NO
- Sources from which we have collected personal information from the categories indicated above.
- Consumers – Marketing research participants and those registering to participate in marketing research studies.
- Business Partners and Their Agents – Our business partners include our research clients and prospective clients as well as agents for both.
- Business Support Consultants – Our business support consultants include, but are not limited to, marketing research consultants such as sample providers, marketing research moderators, marketing research analysts, other research professionals, research facility providers, clinical lab providers, medical/healthcare consultants, translators, technical and data security providers, data storage providers, fraud prevention and verification service providers.
- Use of Personal Information. HCD Research uses, discloses, or shares personal information for commercial and business purposes.
- Commercial purposes.
- Providing consumers with an invitation to participate in marketing research surveys.
- Providing our marketing research services to Business Partners who use the information to improve products, customer experience, services, and messaging.
- For our own research and analysis to improve services to and products for Business Partners.
- Business purposes.
- Processing requests for payment.
- Security and related requirements.
- Responding to technical support requests.
- Communicating with research participants about your research participation, changes to our policies, administration issues, or response to your inquiries and comments.
- Performing services.
- Internal research to provide better research experiences to research participants.
- Ensuring compliance with our policies and terms of service or as otherwise believed by HCD Research to be necessary to protect, enforce or defend the legal rights, privacy, safety, or property of HCD Research and others.
- Complying with legal and regulatory requirements.
- Commercial purposes.
Exercising Your CCPA Rights
- To exercise any of your rights under the CCPA indicated above, please contact us using the following methods indicated below. To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below. Please note that in order to complete a Right to Know or Right to Delete request, you will be asked to verify your identity before we can fulfill your request. This process may require that you provide personal information that we already have about you or, in certain cases, we may require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
- By Online Form/Web Form. Please click here and you will be directed to a form that you may either submit electronically, or print out and mail to us at our address below:
- By Mail. HCD Research
Attention: Privacy Officer
260 U.S. Highway 202/31 North
Liberty Court Suite 1000
Flemington, New Jersey 08822
- By Telephone. Toll fee: (833) 888-0419
- By Email. firstname.lastname@example.org Please put “CCPA Request” in the subject line.
- Who may make the requests regarding your CCPA Rights? You or a person (or California registered business) whom you have authorized to act on your behalf may make a request regarding your personal information. If you make the request, we may require you to verify your identity with HCD Research. If an authorized agent makes the request, under the CCPA, we may require you to provide your agent with written authorization to act on your behalf or a power of attorney signed by you indicating your authorized agent’s ability to act on your behalf.
- Responding to your requests.
- Requests to ‘Know’ and ‘Delete.’ We will confirm receipt of requests to Know and to Delete within 10 business days of receipt and provide you with further information regarding our response and verification process. We plan to fulfill the requests within 45 calendar days of receipt of the request. If we require more time to respond, we will let you know the reason and within 45 calendar days from receipt of your request, we will provide notice of an estimate of the amount of additional time we will need, but we will complete your request within 90 calendar days from receipt of the request.
- Requests to ‘Opt-out.’ We will comply to ‘Opt-out’ requests within 15 business days.
- Frequency of Right to Know requests. You may make Right to Know requests twice within a 12-month period.
- Frequency of Right to Delete requests. You may make Right to Delete requests at any time. However, under CCPA Section 1798.145(i)(3), we may refuse to act on such requests if your requests become ‘unfounded’ or ‘excessive.’