Updated for 2016/679/EU General Data Protection Regulation (GDPR) 

Last Updated: January 7, 2020 

1. Introduction 

Op4G (“Op4G,” “we,” “us,” and “our“) is a market research firm and sample provider in the United States of America.   As a user of our websites, a participant of our web surveys, or a member of our research panels (“Services”), your personal information is held in the strictest of confidence. 

Please read this Privacy Policy carefully.  It explains our legal basis for processing your data, and our responsibilities as defined by the General Data Protection Regulation (“GDPR”). 

1A. As Data Controller 

• Interactions with opinions4good.com, op4g.com, and their sub-domains (“Websites“). 

• Data submitted or generated while registering for or accessing our Panel application (“Platform”). 

• From the installation of mobile applications for the purpose of participating in research activities. 

1B.  As Data Processor 

• Web surveys or data collection hosted by Op4G on behalf of a research partner or client. 

• Contact lists and targeted sample provided by client. 

• Publisher or advertiser data collected from offer conversions. 

2. Age Limitation 

To the extent prohibited by applicable law, Op4G does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us at compliance@op4g.com and we will take steps to delete such information. 

3. Information We Collect About You 

As a member of one or more of our panels, all of the data listed below is obtained directly from you through questions asked during registration or in a research study, unless otherwise noted. 

3A. Personally Identifiable Information (“PII”) 

PII is data that directly identifies you.   We ask for your real name, e-mail address, and in certain cases, a phone number for verification. 

3B. Non-PII (Linkable) Data 

This is data that cannot identify you independently, but could be linked to other data that would. Panel members may be asked for their race, gender, income, profession, and other demographic questions that fall into this category. 

3C. Special Categories 

Special categories of data cover topics such as ethnic origin, political opinions, religious beliefs, and your sexual orientation. Extra steps are taken to document the collection and storage of special categories. 

3D. Generated or Technical Data 

This is data passively collected by our Platform or other technologies, and includes data that must be secured like your IP Address, usage details, and information collected through cookies and other tracking technologies. Methods used to gather this data include: 

• Logs or records generated automatically as you interact with our Services. 

• Dev Ops services or reports generated by clients and research partners. 

• Service providers who provide services essential to our operations. 

4.  Information You Provide to Us 

To become a member and gain access to our Services, the following is required: 

• A valid email address to receive double opt-in. 

• Candid, honest answers to our eligibility survey. 

• A determination of your eligibility based on your complete member profile. 

Data you submit via the following channels may be retained: 

• Data collected through your participation in Surveys. 

• Your correspondence with our help desk or emails to our support team. 

• Interactions with Op4G and affiliated social media sites or feeds. 

Information Collected with Data Collection Technologies 

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, such as: 

• Details regarding your participation in our Services, including traffic data, logs, and session data. 

• Information about your computer and internet connection, including your IP address, operating system, and browser type. 

The information we collect automatically is used for web analytics, quality control and fraud prevention, and may be combined with other data sources to detect outliers or other unusual patterns.   Such technology includes: 

The use of digital fingerprinting, watermarking, and identity verification services. 

5. How We Use Your Information 

We process the information collected, including your personal information, for the following business operations: 

• Create and secure your account on our Platform. 

• Match you to relevant Services and Surveys that you are most likely to qualify for. 

• Provide you with nonprofit updates, newsletters, and technical support. 

• Process payments to you when your account balance becomes eligible for payout. 

• Verify your identity and account status with service providers. 

• Accommodate any other purpose for which your personal data is provided. 

• Notify you of changes to our Services that may require you to grant consent. 

Legal Bases for the Processing of Personally Identifiable Information (“PII”) 

As a controller of your personal data, a legal basis is required for the lawful processing of your personal data. Our multiple legal bases include: 

• Data subjects’ consent – The legal basis for most of our offered Services.   We require explicit, informed consent be recorded for all panelists in order to participate in our Services, including our Platform, Surveys, and Reward offerings. Your consent can be withdrawn at any time as per our Terms & Conditions 

• Contractual performance – As a member of one or more research panels, you are eligible to receive payments each month where your account balance exceeds $10 USD.  The processing of your identifiable personal information to initiate this transaction is lawful as it fulfills our contract to you as a panelist. 

• Compliance with a legal obligation – Requests originating from law enforcement officials, fraud examiners or a public authority constitute the use of Legal Compliance as a lawful basis; 

6. Disclosure of Your Information 

We are extremely protective of our members’ personal information and do not sell personally identifiable data such as email address, real name, or date of birth.   Personal data may be disclosed to a variety of parties, depending upon the purpose for which the information was provided and the context in which it was provided. 

6A.   Clients and Research Partners 

• Data shared as pseudonymous data in a deliverable file. 

• Data shared in aggregate for operations and project reports. 

Our clients and research partners do not purchase your data and we do not share or sell your PII with them. In general, the clients cannot contact you, or any member of the Op4G Platform, without documented approval from Op4G.   Methodologies that require personal contact (follow-up interviews, in-home and on-site product testing, focus groups) must be approved and brokered by Op4G and would require explicit written or digital consent from you. 

Op4G will oversee and approve all member and client communication in the event that a client wishes to include you in an interview, product test, or other service beyond the scope of Op4G’s Platform. 

6B.  Service Providers 

Service Providers critical to Op4G’s operations are authorized to process personal data when it is required to perform a business service, such as payment processing, identity verification or mass emailing services. 

6C.  Legal Processing 

We may also disclose your personal information as required by law, such as to comply with a subpoena or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government or regulatory request. 

7.  Protection of Personal Data 

Our Data Protection Statement establishes company-wide principles relating to the processing of personal data, and documents the steps we’ve taken to ensure the security of our members’ information.   Our managing hosts operates with the following security certifications: 

• SSAE 18 

• SOC 2 Type II 

• ISO/IEC 27001: 2013 

• HIPAA/HITECH 

• PCI DSS 3.2 

To prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction, we follow industry-standard technical, organizational and administrative security measures. 

8. Data Access Rights 

As a data controller, it is our responsibility to provide you with a clear list of rights and actions available to you as a Data Subject: 

8A.  Right to be Informed 

You have the right to know what personal data we are processing, why we process it, and who that data may be shared with.   This policy provides this information. 

8B.  Right of Access 

You have the right to request copies of your personal data.   This is provided through the Platform, which allows members viewing access to all profile data, survey activity, and full payment history.   A login with valid credentials is required to access this data. 

You may also make a Data Subject Access Request (“DSAR”) via email.  All requests should be submitted to compliance@op4g.com by the Data Subject and will require verification of identity.  Requests can take up to thirty (30) days to process. 

8C.  Right to Rectification and Erasure 

You have the right to request changes to your data record to correct inaccuracies.    Requests should be submitted to compliance@op4g.com and will require verification of identity. 
You also have the right to request the erasure of this data.   This requires you to log into our Platform with your credentials and selecting the “Delete your Account” menu option.   Deletion of your account is permanent and forfeits any account balance you have accrued. 

8D.  Right to Restrict, Object, and Withdraw Consent 

You have the right to request restrictions on the processing of your data, to object to the processing of that data, and the freedom to withdraw your consent to data processing at any time.   Op4G’s collection and processing of your personal data is entirely voluntary and requires your explicit consent, which can be revoked at any time by logging into our Platform with your credentials and selecting the “Delete your Account” menu option. 

This will delete all data associated with your membership, remove you from all email campaigns, forfeit remaining account balance, and remove access to the Platform.  This option cannot be undone. 

8E.  Right to Data Portability 

You have the right to request a copy of your personal data and activity history over the past 12 months to retain and reuse for your own purpose.  All requests should be submitted to compliance@op4g.come by the Data Subject and will require verification of identity. 

9. Data Retention 

Your personal information will be retained indefinitely while your panel membership is active and our lawful basis for processing your data is intact. Your account is classified as Suspended in the following scenarios: 

• There is no login or survey activity for six months. 

• Your email is returned as undeliverable. 

• Your account is flagged and requires verification of your identity. 

• You request the account be closed but not deleted. 

Suspended accounts are disabled, but can be re-enabled at the request of the panelist.   If the account is not reopened within one year, all personal information and accrued reward balance will be deleted.  Data required for legal, tax or accounting requirements, or to enforce our agreements or comply with our legal obligations, is retained as business record. 

If you received an account payout while an active member, PII data used in those transactions will be secured and archived as business records for a minimum of seven (7) years. 

10. Browser Cookies and Tracking Technologies 

We provide full disclosure and consent options for cookies in our Cookie Policy. 

We collect and parse web server logs, which include data such as IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. 

Pixel tags and web beacons are transparent image files designed to collect information regarding your interaction with an email message, webpage, or Survey.   While Op4G does not make use of these tracking technologies in our Platform and retains no data associated with them, some Clients or Research Partners may require this method as a means to track survey statuses or as a tool to detect fraud. 

11. International Transfer of Data 

Op4G operates in and uses service providers located in the United States.   If you are outside the U.S. and submit personal data to us through our Websites or Services, that personal data will be transferred to and processed outside of your country of residence. 

12. Links to Third Party Web Properties 

When participating in our Services, you may be routed or linked to a website or Survey hosted by a third party on behalf of a client or research partner.   We have no oversight or control of these websites and they are not governed by our policies. 

We encourage you to carefully review the privacy policy of any unfamiliar website or survey provider prior to submitting any personal information. 

13. Public Blogs and Contact Forms 

Forums and comments within the Blogs section of our website are considered public discourse, and are available to be collected and processed by Op4G.    Comments shared within these public features may be read, collected, and used by others who access them.  Requests to remove your personal information from our blog or community forum can be sent to compliance@op4g.com. 

14. Testimonials 

We display personal testimonials of satisfied customers on our Websites in addition to other endorsements. With your consent, we may post your testimonial along with your name.  To update or remove testimonial content, email your request to marketing@op4g.com. 

15. Social Media Integrations 

Our Services include several social media features that may store personal data such as IP address and site activity, and may require you to authenticate with your account credentials.    We do not access or capture such data anywhere in our Services, and content posted or displayed within these integrations is governed by the Privacy Policy of the social media provider. 

16. Changes to Our Privacy Policy 

We reserve the right to change our policy at any time by providing updated information on this page. This policy was last modified on January 7th, 2020. 

California Consumer Privacy Act 2018 Addendum 

This Policy addendum supplements the information in our Privacy Policy and applies to respondents, panelists, and others who reside in the State of California.  We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. 

A. Information We Collect 

Through your participation in our Panel and related Services, we collect information that identifies, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Panels have collected the following categories of personal information from our members within the last twelve (12) months: 

Other uncategorized data includes: 

• Publicly available information from government records 

• Pseudonymous or de-identified aggregate data 

• Information excluded from CCPA scope, such as: 

• Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data 

• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver’s Privacy Protection Act of 1994. 

We obtain the categories of personal information listed above from the following categories of sources: 

• Data provided during our panel registration and process. 

• Surveys you have completed while conducting Services. 

• Automated collection sources such as server access logs or captured user agents. 

B. Use of Personal Information 

We may use, or disclose the personal information we collect for one or more of the following business purposes: 

To fulfill or meet the reason you provided the personal information, e.g. PayPal account shared to process information. For example, if you share your name and contact information and inquire about an upcoming panel payment, we will use that personal information to respond to your inquiry. If you provide your personal information to request some form of opt-out or data accessibility, we may require verification of your identity and release this data in your possession, 

• We may also save your information to facilitate new product orders or process returns. 

• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. 

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. 

• As described to you when collecting your personal information or as otherwise set forth in the CCPA. 

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice. 

C.  Sharing Of Personal Information 

We disclose your personal information to service providers for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract, e.g. PayPal receives the email address you provided to us for the purpose of sending payments. 

The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.  We do not share your personal data with third parties in this capacity. 

D.  Disclosure of Personal Information for Business Purpose 

In the preceding 12 months, Op4G has disclosed personal information for the following business purposes, as categorized in Section 1798.140: 

• While auditing Interactions with Consumers: Help desk ticketing, verification of identity. 

• For purposes of security, including fraud prevention aand digital fingerprinting. 

• To fulfill invitation emails and newsletter requests. 

• In the performance of services such as payment processing, technical support, identity verification, accounting, and gift card services. 

E.  Sales of Personal Information 

The “sale of personal information” has a broad definition within the CCPA: 

“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.” 

Processing your personal information allows us to place you in relevant online surveys across a network of research partners, targeting studies you appear qualified for based on the data available. As we are paid for completions, e, ‘monetary consideration’. 

F.  Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. 

G.  Access to Specific Information and Data Portability Rights 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: 

• The categories of personal information we collected about you. 

• The categories of sources for the personal information we collected about you. 

• Our business or commercial purpose for collecting or selling that personal information. 

• The categories of third parties with whom we share that personal information. 

• The specific pieces of personal information we collected about you (also called a data portability request). 

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: 

• sales, identifying the personal information categories that each category of recipient purchased, and 

• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

H. Deletion Request Rights 

You have the right to request deletion of all personal information that we collected and retained, subject to certain exceptions listed below.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s): 

• To complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 

• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 

• To debug products to identify and repair errors that impair existing intended functionality. 

• To exercise free speech, ensure the right of another consumer to exercise their free speech rights or exercise another right provided for by law. 

• To comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 

• To engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent. 

• To enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 

• To comply with a legal obligation. 

• To determine a lawful basis for processing the data that is compatible with the context in which you provided it. 

I. Exercising Access, Data Portability, and Deletion Rights 

To exercise your access, data portability, and deletion rights as listed, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or confirm the credentials of the authority making the request. We will only use personal information provided in a verifiable consumer request for the purpose of verification. 

J. Response Timing and Format 

We make every effort to respond to all verifiable consumer requests within forty-five (45) days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication. 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

K.  Personal Information Sales Opt-Out and Opt-In Rights 

All members and Data Subjects have the right to withdraw their consent to process their personal information. See our Terms and Conditions for more information on requirements for membership. All members must provide consent to partake in our Services, but may withdraw that consent at any time. Consent must be withdrawn by the individual or an authorized representative, and data collected to verify such authorization will only be used for that purpose. 

Once you have withdrawn consent, we will retain your data for up to twelve (12) months before deletion. 

L.  Non-Discrimination 

We will not discriminate against you for exercising your rights. Requests for information or clarification will be honored, without fear of: 

• Imposed penalties or limitations on your participation in research activities. 

• Degradation in level or quality of support or service. 

• Reduction in payment amounts. 

However, we require your continued consent to our Privacy Policy and Terms and Conditions to participate in our research studies.   Should you revoke consent of exercising your rights, we cannot by law process data on your behalf and your panel account will be closed until consent can be reestablished. 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our website or write us at compliance@op4g.com. 

M. Contact Us 

If you have any questions or comments about the contents of this CCPA Addendum, do not hesitate to contact us: compliance@op4g.com