Effective Date: April 27th, 2023
1. Our Commitment to Protecting Your Privacy
PointClub is operated by Innovate MR, LLC (“Innovate”). As used herein all references to “PointClub” are also references to Innovate.
PointClub is committed to respecting individual and client privacy, to safeguarding confidential information and to ensuring the security of all personal information. When you decide to share your information with us, we feel it is important to assure you your information will be safely protected. This statement discloses our information collecting, handling, and disclosure practices.
2. What Do We Do?
PointClub is an online panel company focused on providing quality survey responses to our clients which represent the market research industry. PointClub is headquartered in Calabasas, California, with offices in US and India. You acknowledge and agree that your participation in PointClub surveys or other market research programs is completely voluntary, and that PointClub’s use of your personal information is carried out with your consent.
3. Your Privacy Rights
PointClub makes efforts to conform its privacy and security practices to applicable laws, codes, and regulations, including without limitation the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and other applicable state privacy laws.
Depending on your location, you may have certain rights under the law of your home jurisdiction with respect to your personal information.
To access, correct, request deletion of your personal information, or to request a copy of your personal information or opt out of the processing of your personal information, please contact us as provided in the “Contact Us” section below. Depending on your location, you may also have the right to appeal any decision we make regarding your personal information by contacting us as provided below.
4. Collection and Use of Personal Information
We use your information to operate, evaluate, and improve our business, including for such purposes as verifying your identity, developing new products and services, managing our communications, and analyzing our products, and fulfilling incentives. If you provide us with your name and contact information, we will use this information to answer requests from you, communicate with you regarding any services we are providing to you, and inform you about new products and services (unless and until you opt-out of marketing information). If you come to our website to qualify for or take surveys, we also collect self-reported demographic, firmographic, and other profile information, such as age, gender, education, profession, job title, political affiliation, and consumer preferences and ownership. We use this information to make your survey answers more meaningful to us and our clients. We also use this information, along with information derived from cookies, pixels, and other technologies, to determine your interests in particular surveys, advertisements, and other communications.
We also collect certain information automatically when you use our website, including without limitation log files, including Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, and plug-in information. We use this information to analyze web traffic and survey usage, to optimize survey platforms for different operating systems and to analyze authenticity of respondent; and to communicate insights to our clients.
We also collect other browsing information, such as date and time you visited our website, number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or other research program. We use this information for website optimization for different operating systems; and to optimize user participation.
Any e-mail communications to you regarding new products and services, or any email updates, newsletters, or other communications to which you’ve subscribed, will contain a link with instructions for how to opt out of future communications of that type.
5. Sensitive Personal Information
Please note that some of the personal information described above, such as demographic information about your race or ethnicity, may constitute “sensitive” personal information under applicable laws. We will never use your “sensitive” personal information except for research purposes, or otherwise to verify your identity or prevent fraud. For more information on how to opt out of the processing of your sensitive personal information, please click here.
6. Selling and Sharing of Personal Information
We will never share your name, email address, mailing address, phone number, or similar personally identifiable information without your consent. However, we may share other information described above, such as your IP address, self-reported demographic and firmographic information, and other information provided in your survey or research answers to our clients in order to better communicate research insights to them. Please note that under certain state privacy laws, including CCPA, this may constitute a “sale” of personal information.
In the past 12 months, we’ve “sold” the following categories of information to our clients in connection with our delivery of research results: name, email address, mailing address, and phone number (with your consent); log files, including Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, plug-in etc.; Self-reported demographics (i.e. age, gender, education, etc.); Self-reported firmographics (i.e. employment-related information such as title and profession etc.); Self-reported profile information (i.e. political affiliation, technology usage, consumer preferences and ownership etc.); System Metrics inclusive of survey status (completed survey, terminated etc.) Length of time spent in a survey.
To assist us in the delivery of our service offerings we may also share your personal information with third party suppliers such as those who provide and manage incentives in connection with the completion of surveys, data hosting and storage services, third party technology providers, data matching providers to facilitate analytic and related objectives, and other consultants who we retain from time to time. These third parties are bound by confidentiality obligations and will not use your information for purposes outside of those specified herein. We also reserve the right to disclose your personal information as required by law or when we believe the disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, national security requirement, or legal process served on our website.
Also, PointClub discloses aggregated user statistics in order to describe our services to prospective partners, advertisers, and other third parties, and for other lawful purposes. PointClub may also disclose account information in special cases when we have reason to believe disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating PointClub Terms & Conditions or may be causing injury to or interference with (either intentionally or unintentionally) PointClub rights or property, other PointClub users, or anyone else who could be harmed by such activities.
Finally, if there is a sale of a majority of the shares or assets of the legal entities owning and operating PointClub, you agree your personal information and data may be transferred or assigned to such new owners.
7. Special Notice to California Residents
Your Right to “Know,” to Request Deletion, and to Correct
You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting, selling, or sharing personal information, and the categories of third parties with whom we share personal information.
You have the right to request deletion of personal information we’ve collected or maintain, subject to certain exceptions. Please note, however, that our deletion of your personal information may negatively affect our ability to provide you with services.
You also have the right to correct any inaccurate personal information that we maintain about you.
To exercise these rights contact us as provided in the “Contact Us” section below. We may ask you to provide additional information, such as first and last name and email in order to verify who is making the request.
Please note that any requested disclosures may only apply to the 12-month period preceding the request, depending on how difficult it is for us to retrieve the necessary information, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.
Your Right to Opt Out of the “Sale” of Your Information
CCPA defines the term “sell” broadly. Its meaning includes “renting, releasing, disclosing, disseminating, making available, [and] transferring…for monetary or other valuable consideration.”
Under this definition, and the CCPA’s broad definition of “personal information,” we may “sell personal information” about you to our clients or other collaboration partners, such as your contact information or certain combinations of anonymized or pseudonymized demographic and other information.
You have the right to opt out of such sale of your personal information. For more information on how to opt out, please click here.
Please note that we will not “share” your personal information for purposes of cross-context behavioral advertising, as that term is defined under CCPA.
Your Right to Non-Discrimination
You have the right not to receive discriminatory treatment by PointClub for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please understand, however, that certain exercises of your rights may render it impossible for us to render services to you.
Your Right to Use an Authorized Agent
You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided below. In order to verify you have authorized an agent we will require a signed, written authorization from you.
If you make a request to access or delete your information, or to opt out of the sale of your personal information, we may ask you for additional information to verify your identity. This information may include: your full name, birth date, phone number, email address, or other basic personal information about you that we already have on file.
8. Data Matching
Under confidentiality agreements, PointClub may match user information with third party data.
9. Opt Out
We may use your personal information ourselves to conduct direct marketing when you have opted into this, but you are entitled to opt out from receiving direct marketing communications from us at any time. You may do so by responding to the opt out option which is included with each direct marketing communication we send.
10. European Economic Area (“EEA”)
Information displayed on our website or sent to us over the Internet may be transferred outside of the EEA to one of our local offices. If you have any concerns in relation to such transfers, you should not use the Internet as a means of communication with PointClub.
The website and our services may be accessed abroad. All personal data collected by us will be stored and processed in the United States or any other country in which PointClub or its affiliates, contractors or agents maintain facilities. By using the website or our services, you consent to any such transfer of data outside of your country.
Users in Europe have the right to request access to and rectification or erasure of personal data, to restrict of processing of their personal data, and to object to processing. Users in Europe also have the right to lodge a complaint with a supervisory authority. If you would like to exercise any of your data protection rights, please contact us using the “Contact Us” section below.
We will not process your personal data unless you have given your consent to our processing for a specific purpose, processing is necessary for the performance of a contract with you or to comply with a legal obligation, or processing is necessary for the purposes of the legitimate interests pursued by PointClub or a third-party controller.
In cases where the purpose of our processing is the “legitimate interest” purpose, we will also carefully balance those interests against your fundamental rights and freedoms related to your data. Where processing is based on your consent, we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.
11. How We protect Your Personal Information
PointClub takes reasonable steps to protect your personal information from unauthorized access, use, disclosure, or loss. This website has security measures (including online and offline physical, electronic, and managerial safeguards) in place to protect against the loss, misuse, and alteration of the information, including your e-mail address, under our control.
We recommend you do not divulge your password to anyone. PointClub will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also remember to sign out of your PointClub account and close your browser window when you have finished your work. This is to ensure others cannot access your personal information 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.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, PointClub cannot ensure or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk. Once we receive your transmission, we make our best effort to ensure its security on our systems.
12. Do Not Track
Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will treat any “do not sell” or similar signals as opt-out requests under CCPA.
A cookie is a small amount of data sent to your browser from a web server and stored on your computer’s hard drive. We may use technology to track the patterns of behavior of visitors to the website. Currently, cookies are utilized by PointClub within the following four primary categories or uses: (1) business cookies which operate as a quality control and verification mechanism in connection with the survey process; (2) performance cookies so traffic patterns and uses on the PointClub website may be measured and optimized; (3) user cookies so user information may be recorded so as to enhance performance and user experience on the website; and (4) targeting cookies which are utilized to measure web viewing for market research purposes. Tracking cooking will help us to speed up your future activities at the site and allow PointClub to provide you with information specifically tailored to your interests. You can usually modify your browser to prevent this happening. The information collected in this way can be used to identify you unless you modify your browser settings. To modify your browser settings, click on the help section of your Internet browser and follow the instructions. Please note: not accepting cookies may affect the performance of our website.
From time to time, PointClub collaborates with third parties (including clients) to enable the use of targeting cookies, web beacons, pixels, SDK’s, and mobile device identifiers to measure web-viewing and mobile use activities, for behavioral measurement purposes, in connection with ad exposure and display advertising for market research purposes and other related activities. Our partners use this information to recognize you across different channels and platforms, including but not limited to, computers, mobile devices, and Smart TVs, over time for advertising, analytics, attribution, and reporting purposes. You also agree web beacons and pixels may appear and/or be activated to collect information from emails you open. To facilitate these services, PointClub’s clients (or their agents) or other collaboration partners may write, set, or read: (i) cookies, (ii) locally shared/stored objects, (iii) flash cookies and (iv) other related technologies (“Third Party Technologies”). If you participate, your Member ID will be stored in, or associated with, Third Party Technologies to allow you to be contacted about online ads, promotions, or in connection with market research surveys. PointClub’s clients (or their agents) will use the Third Party Technologies to determine whether you have seen, clicked on, or otherwise interacted with the online ad or promotion. PointClub will share your Member ID name, postal address, email address, or Device ID with PointClub clients (or their agents) so you will have an opportunity to receive a promotion, be contacted about an online ad, complete a survey, or so data previously collected by PointClub, such as age, gender, income, etc. (“Audience Measurement Data”) may be shared with third parties, including without limitation PointClub’s subcontractors, partners, and/or clients for the purpose of audience measurement reporting on the advertising, advertising or other promotional campaigns, and websites you visit, view, and/or click on. The Audience Measurement Data will be used to assist in the creation, development, and implementation of websites, online advertisements, and other Internet and digital media features, functionality, and campaigns. Your data may be transferred outside of the country from which it was originally collected. To learn more about interest-based advertising in general and to opt out, please visit http://www.aboutads.info/choices.
14. Our Commitment to Children’s Privacy
PointClub encourages all parents and guardians to instruct their children in the safe and responsible use of their personal information whilst using the Internet. PointClub will not (through our website or otherwise) intentionally collect information relating to or originating from a child unless we have the consent of the child’s parent or guardian. If we become aware a user of our website is a child who is using this website without the consent of his parent or guardian, we will use reasonable endeavors to delete any information submitted by that child as soon as possible and to ensure such information is neither transferred to anyone else nor used by us. Please let us know as soon as you become aware a child has submitted information about him/herself through our website without the consent of his parent or guardian. You can contact us in the ways outlined at the end of this policy.
16. Governing Law
17. How to Unsubscribe Your Email:
To unsubscribe your email account and not receive any further emails from PointClub, please send an email (from the address used as your PointClub member contact) to support@PointClub.com with “unsubscribe” as the subject line.
18. Contact Us
Attn: Data Protection Officer (DPO)
23679 Calabasas Road # 1038,
Calabasas, CA 91302