The Pert Group
PRIVACY POLICY
The Pert Group respects the personal privacy of visitors to our Web site. Our privacy policy is subject to change at any time, and we encourage you to periodically review this page for any updates.
The Pert Group may collect personal information provided by you — name, address, phone number, email address etc. — and store those details in a database. The collected information may be used to generate follow-up messages and responses that are tailored to your request. If you have not chosen to "opt out" from our mailings, we may also use the collected information to send you periodic newsletters and other mailings. The Pert Group does not sell or rent your information to anyone. If you have any additional questions or would like to be removed from our database, please contact info@thepertgroup.com.
When you visit the The Pert Group web site, your Web browser software may automatically provide us with information such as the Web browser name and version, your computer type and operating system, and the previous Web site you visited if you clicked to our site from another. We also automatically determine your Internet IP address or your Internet service provider's IP address. Any of this information may be recorded in our Web server logs or securely collected on our behalf via third-party services. This information will only be used internally in anonymous, aggregate reporting.
Certain parts of our Web site may use cookies. A cookie is a small amount of data sent to your Web browser and saved on your computer. On subsequent visits to our site, your browser will automatically retransmit the cookie data to our site. We may use cookies to customize the content shown to you, to provide conveniences to your browsing experience, or to track aggregate traffic trends on our site. You are not required to accept and store cookies to browse the The Pert Group site.
The Pert Group
SAFE HARBOR PRIVACY POLICY STATEMENT
The Pert Group is a quality oriented, full service, custom market research firm providing actionable results in a cost efficient and timely manner. As such, we believe that our survey respondents are key to our overall success. For this reason, The Pert Group prides itself not only on its customer focus, but also on its efforts to protect the privacy of our respondents. We pledge that in obtaining your assistance with any of our business related activities that we will not mislead you about the nature of our research methods or the use of any information provided by you. We adhere to all legal and ethical standards of conduct for market research firms and are active members of ESOMAR, CASRO & MRA, renowned professional and governing organizations for professionals in the market research industry. We further promise that when collecting personal information in conjunction with our client research requests, that we will use the information solely for that purpose.
Information We May Collect About You
The Pert Group collects personal data for either surveys or other marketing related activities. This Privacy Statement applies only to personal data (as defined below) that The Pert Group receives from the European Union (EU). The Pert Group adheres to the Safe Harbor Agreement concerning the transfer of personal data from the EU to the United States. Accordingly, The Pert Group follows the Safe Harbor Principles published by the U.S. Department of Commerce with respect to all such data, and this Statement complies with such Principles. Compliance with the Principles may be limited, however, in certain cases to the extent necessary to meet national security, public interest or law enforcement requirements. All Pert Group employees with access to personal data are obligated to familiarize themselves and comply with the provisions of this Statement.
Surveys
In terms of our market surveys, The Pert Group processes, on behalf of our clients, personal data that has been collected by or on behalf of our clients. “Personal Data” is defined as information / data that is (a) transferred to the U.S. from the EU, (b) is about, or relates to, an identified or identifiable individual, (c) can be linked to that individual, and (d) is recorded. Personal data may include, among other things, an individual’s name, address, phone number, e-mail address, or social security, national health insurance or an equivalent number. For further clarity, the term “personal data” does not include data that pertains to a specific individual, but from which that individual cannot reasonably be identified. Unless otherwise indicated, references herein to personal data include sensitive personal data (as defined below). Sensitive personal data is a subset of personal data that indicates an individual’s medical or health condition, racial or ethnic origin, political opinions, religion, union membership, sexual orientation, or actual or alleged criminal activity.
Under the United States / European Union Data Protection Safe Harbor Arrangement, The Pert Group acts as a Data Processor and each PERT Client acts as a Data Controller. For the purposes of the Safe Harbor and Privacy Statement: a “Data Processor” is an entity that processes Personal Data on behalf of a Data Controller; a “Data Controller” is an entity that determines the purposes for which Personal Data are processed. To “process” Personal Data means to carry out an operation or set of operations on such Personal Data, such as collecting, recording, storing, disclosing, or organizing it. The “Data Subject” means the person to whom a certain set of Personal Data relate; for example, the person who responds to a survey.
As a Data Processor, The Pert Group will only process Personal Data pursuant to the instructions of the applicable Client. The Pert Group may use the services of third party Data Processors to process Personal Data in accordance with purposes identified for such Personal Data by the applicable Client. The Pert Group will not use or share, either within The Pert Group or with a third party, any information collected, for our own direct marketing purposes or our service providers.
How Your Information May Be Used: Surveys
Respondents are adequately informed about the nature of the survey (who is conducting it, how the information will be used, etc.) and understand that their cooperation is entirely voluntary and agree to participate on this basis.
Your information may be stored and processed in the United States or any other country in which The Pert Group maintains facilities. By participating in a survey, you consent to any such transfer of information outside of your county. The Pert Group abides by the Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of data from the European Union.
Notice
The Pert Group collects personal data from and about individuals for use generally in connection with the operation of its business. Such personal data may be used by The Pert Group to provide market research services to its clients.
The Pert Group may disclose personal data to third parties when such disclosure is necessary or appropriate for The Pert Group’s provision of such services to its clients or otherwise for The Pert Group’s operation of its business.
When The Pert Group receives personal data from the EU merely for processing purposes and does not control the collection of the personal data, The Pert Group may not provide notification of this Statement to the individuals to which such personal data relates. In such event, The Pert Group reserves the right to process personal data in the course of providing services to its clients without the knowledge of the individuals involved.
Choice
As part of our market research process, all The Pert Group questionnaires provide respondents with the following informational statements related to personal data:
- “These last few questions are just to divide our interviews into groups, no one interview is looked at individually” and
- “Finally, here are a few questions for classification purposes. Please be assured that your responses will be kept in the strictest confidence.”
If a respondent chooses not to provide personal information, they are automatically “termed” out of the study; the choice to provide such information is purely voluntary.
In addition, we review and communicate results to clients in a consolidated format and as such, no one individual’s personal info is ever reported separately.
Any personal address information collected by respondents is used by The Pert Group only to validate the identity of the respondent who has agreed to participate in the study.
When The Pert Group receives personal data from the EU merely for processing purposes and does not control the collection of the personal data, The Pert Group may not provide such choices to the individuals to whom such personal data relates. In such event, The Pert Group reserves the right to process personal data in the course of providing services to its clients without the knowledge of the individuals involved.
Onward Transfer to Third Parties
The Pert Group would only disclose personal data to a 3rd party if (a) The Pert Group has received the applicable individual’s permission to make the disclosure, (b) the disclosure is required by law, (c) the disclosure is reasonably related to the sale or disposition of all or part of The Pert Group’s business, (d) the information in question is publicly available, and/or (e) the disclosure is reasonably necessary for the establishment of a legal claim.
Additionally, The Pert Group may disclose personal data to a third party if the disclosure is to a Pert Group affiliate or to persons or entities providing services on behalf of The Pert Group, a Pert Group client, or the individual (each a transferee), consistent with the purpose for which the information was obtained, if the transferee, with respect to the data in question (a) is subject to law providing an adequate level of privacy protection including, without limitation, transferees that are located within the EU or transferees that are otherwise subject to an “adequacy” finding, (b) has agreed in writing to provide an adequate level of privacy protection, and/or (c) subscribes to the Principles.
Security
The Pert Group takes reasonable precautions to protect personal data from loss, misuse, tampering, destruction and unauthorized access. These precautions include password protections for on-line information systems, restricted access to employee personal data within the Human Resources Department, and other measures implemented by The Pert Group.
Data Integrity
The Pert Group takes reasonable steps to ensure that personal data is accurate, complete, current and relevant for the purposes for which it was collected.
Access
Upon request, The Pert Group will permit respondents to access any personal data submitted as part of our research study process. The individual may need to provide specific identifiable information to include, but not limited to, name, address, birth date or social security number. Such access may be denied or limited by The Pert Group, however, if providing such access is unreasonably burdensome, time consuming or would result in significant and/or unreasonable monetary cost.
Enforcement
The Pert Group has a Privacy Administrator who is responsible for the internal supervision of The Pert Group’s privacy policies. The Pert Group educates its employees about compliance with the Safe Harbor Principles and has self-assessment procedures in place to ensure its compliance. The following is actual language taken from The Pert Group Online Policy Manual that is accessible by all employees through The Pert Group Intranet site:
The Pert Group Safe Harbor Certification Policy Statement
Given our client relationships, which extend into the European Union, we have developed and implemented a formal Safe Harbor Certification Policy Statement, the purpose of which is to confirm our compliance with the regulations established by the EU to protect individuals with respect to the “processing” of personal information as well as to ensure the free movement of personal information within the EU through the coordination of national laws.
The Safe Harbor Policy is posted on both our Pert Group website (www.thepertgroup.com) and The Pert Group Intranet site. As an employee of The Pert Group, you are responsible for reading the contents of the Safe Harbor Policy Statement in order to familiarize yourself with the regulations, including the method of handling formal complaints. In addition, as an employee of The Pert Group, you are required to abide by the terms of the policy at all times during your employment. An employee who is found to be in violation of the policy will be subject to appropriate disciplinary action, up to and including termination of employment.
As stated in the Safe Harbor Policy Statement, The Pert Group conforms to all Safe Harbor Principles required by the EU. The Pert Group Privacy Administrator is the internal individual who is responsible for ensuring the ongoing administration and maintenance of The Pert Group Safe Harbor Certification Policy Statement. The Privacy Administrator also conducts regular self-assessment reviews to ensure full compliance with the Principles. Each assessment is a formal document which outlines any reported violations and the subsequent follow-up to address and resolve such complaints. Self-Assessment documents are signed by a corporate officer of The Pert Group and are available upon request by individuals or in the context of an investigation or a complaint about non-compliance.
In compliance with the Safe Harbor Principles, The Pert Group commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact The Pert Group at:
The Pert Group
522 Cottage Grove Rd.
Bloomfield, CT 06002
(860) 242-2005
(800) 873-7811
(860) 242-2708 (fax)
euprivacy@thepertgroup.com
The Pert Group has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU Safe Harbor, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by The Pert Group, you may contact:
Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor
4200 Wilson Blvd., Suite 800
Arlington, VA 22203
(703) 276-0100
web: www.us.bbb.org
eusafeharbor@council.bbb.org
Modification & Amendment
The Pert Group may modify or amend this Statement from time to time by posting a revised Statement on the web at www.thepertgroup.com. If The Pert Group amends this Statement, the new statement will apply to personal data previously collected only in so far as the rights of the individuals affected are not reduced. So long as The Pert Group adheres to the Safe Harbor Agreement, The Pert Group will not amend this Statement in a manner inconsistent with the Principles.
Other The Pert Group Policies
This Statement is subject to other policies and procedures implemented by The Pert Group. For instance, if another Pert Group policy or procedure grants broader rights to the Company relating to the collection, handling or disclosure of personal data, the Company may exercise those broader rights.