Welcome to Measure Protocol’s Privacy Notice. Measure Protocol respects your privacy and is committed to protecting your Personal Data. This Privacy Notice will inform you as to how we look after your Personal Data and tell you about your privacy rights and how the law protects you.
This privacy notice sets out:
1.1 For the purpose of this Privacy Notice "you" or "your" means an individual who is the subject of Personal Data we process as a controller, including the end users of Measure Protocol App (the “App”). "we" or "us", "our" means Measure Protocol Ltd (“Measure”), with registered office at C/O Blick Rothenberg Limited, 7-10 Chandos Street, London, W1G 9DQ.
1.2 Measure provides a marketplace powered by blockchain for person-based data where individuals are paid for participating in data jobs. Using the Measure App (the “App”), our end users (the “Users”) are pre-selected, based on demographic data previously provided by them, to participate in surveys or other data jobs organised by us or by researchers (“Measure Partners”) for brands, and advertisers (“Measure Customers”).
1.4 Depending on the data job you participate in:
you may be asked to fill in questionnaires and participate in surveys; or
you may agree to participate in device metering jobs where we may collect data automatically from your devices, and it may not be obvious to you when this is happening (“Passive Tracking”). We will only install measurement software or collect data from your devices for data measuring purposes when you consent to it.
2.1 We do not collect from you: (i) financial data such as bank cards or bank account numbers; (ii) the contents of any communications between you and third parties (emails, texts, WhatApp or social media posts); or (iii) the contents or any files open on your device.
2.2 We will not use the data we collect from you for direct marketing purposes (i.e. to advertise, or sell third party products to you) and we do not allow Measure Partners or Measure Customers to do so.
3.1 This Privacy Notice provides information as to how we process your personal data as a controller in accordance with applicable data protection legislation in the EU and the UK, “Applicable Data Protection Legislation”, which means: (i) in the EU, the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any other applicable legislation; and (ii) in the UK, the GDPR, until such time it is repealed or ceases to apply in the UK, the Data Protection Act 2018, and any other applicable legislation. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights (see section 11 below), please contact us using the details set out below:
Full name of legal entity: Measure Protocol Limited.
Website address: https://www.measureprotocol.com (our “Website”).
3.2 Postal address: C/O Blick Rothenberg Limited, 7-10 Chandos Street, London, W1G 9DQ.
3.3 You have the right to make a complaint at any time to the supervisory authority for data protection issues, the Information Commissioner’s Office of the United Kingdom (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our contact details are: Email address: firstname.lastname@example.org
4.1 We keep our Privacy Notice under regular review. Please check back frequently to see any updates or changes to our Privacy Notice. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
5.1 The Website may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices.
6.1 Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (anonymous data).
6.3 You are responsible for ensuring that you are authorised to share all such information with us for the purposes described in Section 5 of this Privacy Notice and that you only provide such data to us in accordance with Data Protection Laws.
6.4 Measure will indicate on our forms those data fields which are required for our services to function using the symbol: “*”. If you do not fill in the required fields specified above, you will not be able to sign up and receive the some services offered by Measure.
6.5 We may collect, use, store and transfer different kinds of Personal Data about you such as:
(“Customer Support Data”).
7.1 We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
7.2 We use the Demo Data you provide to: (i) generate market research reports in aggregate form, and/or anonymised User level insights (where the data per User would be analysed and use more granularly but the Users cannot be identified); and (ii) pre-select you for surveys and then ask you to participate in them. When you consent to it, we will share your Demo data with Measure Partners and Measure Clients so that they can match you for data job opportunities and they can generate market research reports / insights using your Survey Data and such Demo Data.
7.3 We use the Survey Data provided by our Users (by filling in questionnaires) for the purposes of allowing the applicable Measure Partners and/or Measure Customers analysing the survey responses for market research purposes. We may also use the Survey Data ourselves to generate market research reports in aggregate form and/or anonymised User level insights.
7.4 We use the Passive Data we collect from you to: (i) generate market research reports in aggregate form, and/or anonymised User level; (ii) pre-select you for surveys and then ask you to participate in these surveys; and (iii) when you consent to it, allow specific Measure Partners and Measure Clients to access your Passive Data to generate market research reports in aggregate form, and/or anonymised user level insights.
7.5 We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose.
7.6 Aggregated and/or Anonymised Data
We may share anonymised User data and/or aggregated information about our Users and information collected from providing those services, such as, but not limited to, by publishing market reports or providing anonymised User information to our business partners on trends.
7.7 Marketing and Promotional Offers
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased our services and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.
7.8 Opting Out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us because of a product or service purchase, product/service experience or other transactions.
Under the California Consumer Privacy Act (CCPA), verifiable residents of California may request to opt out of the sale of their data as outlined in section 12.3 of this policy.
7.9 Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
8.1 We may share your Personal Data with the parties set out below, for the purposes set out in the “Purposes for which we will use your Personal Data” table above:
8.2 We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes, and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
9.1 Measure serves customers globally. Accordingly, your Personal Data may be shared with other entities outside of the European Economic Area (“EEA”) or the UK, when this is necessary for the purposes mentioned in this Notice. These countries include the countries in which we have operations. It also includes the countries in which some of our service providers are located.
9.2 To protect your data when these are transferred to countries outside of the EEA or the UK, we have implemented appropriate safeguards. Every transfer of Personal Data is protected by a data processing agreement containing standard contractual clauses approved by the EU or the UK as applicable. If you want to receive more information about these safeguards, you can contact us using the details below under “Contacting us”.
10.1 We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator if we are required to do so.
11.1 We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
11.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
11.3 Please contact us using the contact details set out in this Privacy Notice if you have any questions about data retention.
12.1 You may cancel your participation in surveys or other data jobs, such as Passive Tracking by deinstalling the software or our App or by contacting us. If you do so, please note that we will continue to process the data we collected before your cancellation.
12.2 Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of your legal rights, please contact us using the contact details set out in this Privacy Notice.
12.3 You have the right to:
12.4 Categories of Personal Information to be Collected and May Have Been Sold or Disclosed
Measure collects personal information from research participants utilizing the Measure MSR app during and after registration with the service, including, without limitation, during participation in surveys or other data collection tasks in connection with the receipt and redemption of rewards and incentives during the process. These tasks may be for Measure’s own purposes or in conjunction with partners.
Measures are taken to minimize, de-identify, anonymise and aggregate data where possible to protect users data and privacy as pursuant to this policy. Categories of personal information we may collect are outlined in section 6. The Data we Collect about you in this policy and for the purposes outlined in section 7. How we use your personal data.
12.4.1 Categories of Personal Information that May Have been Sold
Within the last 12 months, Measure has sold data of the following categories: Demo data, Survey data, Passive Data
12.4.2 Categories of Personal Information that Were Disclosed
Within the last 12 months, Measure has sold data of the following categories: Demo data, Survey data, Passive Data
12.5 No Fee Usually Required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. We will notify you if this is the case at the time
12.6 Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
It may not be possible for us to delete your Personal Data if we are required to keep it by law or if we hold it in connection with a contract with you. Similarly, access to your Personal Data may be refused if making the information available would reveal Personal Data about another person or if we are legally prevented from such disclosure.