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: (i) Measure Protocol App (the “App”); and (ii) the data collection services available through our Website (the “Web Services”). "we" or "us", "our" means Measure Protocol Ltd (“Measure”), with registered office at 16 Great Queen Street, Covent Garden, London, United Kingdom, WC2B 5AH.
1.2 Measure provides a marketplace with groundbreaking solutions for person-based data where individuals are paid, or rewarded, for participating in data tasks. For instance, using the Measure App (the “App”), end users (the “Users”) are pre-selected, based on demographic data previously provided by them, to participate in surveys or other data tasks organised by us or by researchers (“Measure Partners”) for brands, and advertisers (“Measure Customers”). Users are also able to participate in data tasks available through our Web Services.
1.4 Depending on the data task you participate in:
1.4.1 you may be asked to fill in questionnaires and participate in surveys; or
1.4.2 you may agree to participate in device metering tasks 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.
1.4.3 you may agree to submit to us screenshots, videos or exported files, etc., showing for instance, your recent purchasing history on a website or app, or your recently watched videos on a specific platform or similar usage data.
2.1 At no time will we collect from you: (i) data such as bank cards or bank account numbers; (ii) the contents of any communications between you and third parties (emails, texts, WhatsApp or social media posts); or (iii) the contents of any files on your device.
2.2 We will not use any data we collect from you for direct marketing purposes (i.e., to advertise, or to 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 EEA and the UK, “Applicable Data Protection Legislation”, which means: In the EEA: (1) the General Data Protection Regulation (EU) 2016/679) (the “EU GDPR”) and any other data protection legislation applicable in the EEA; (2) in the UK: (i) the UK Data Protection Act 2018; (ii) the GDPR as amended and adopted by UK law by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”); (3) applicable data protection legislation in the U.S.A such as the California Consumer Privacy Act for California residents. 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: 16 Great Queen Street, Covent Garden - WC2B 5AH - London, United Kingdom.
3.3 You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues, such us 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 regularly review our Privacy Notice. Please check back frequently for any updates or changes. 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 those 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 or data use policies.
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 7 of this Privacy Notice and that you only provide such data to us in accordance with Applicable Data Protection Legislation.
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 some services offered by Measure.
6.5 We may collect different kinds of Personal Data about you such as:
● your basic registration data (name, email, location, country, IP address, time zone, date joined / became active (“Registration Data”);
● Records of transactions (IDs and basic transactional information of surveys or other research projects you have taken and when) (“Transactional Data”);
● Records of gift cards given to you for participating in surveys or other research projects (“Rewards Data”);
● the survey ratings the survey partners give you based on the quality and completeness of your survey answers or the ratings our partners give you for your participation in other research projects (“Ratings Data”);
● A list of profile demographic questions answered through the App (“Profile Data”);
● Records of your consents or opt-ins for compliance and legal purposes (“Opt-in Data”);
● The survey data you fill in or provide when you participate in a survey run and controlled by us (“Survey Data”), including social media IDs that you may choose to provide; and
● If you have:
(“Customer Support Data”).
● Passive Data: (Applicable to Android users only) Passive tracking is a Measure product that upon User’s consent, allows the collection and metering of the User’s device level usage, internet browsing habits, online activities, app and feature usage, location, and system information (“Passive Data”). The Passive Data collected will depend on the data tasks, the Users agree to participate in. Each data task will inform the User about the scope of the data that will be collected from the User’s device through the App and the term, which would typically comprise:
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, Survey Data and Retro 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 used 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 task 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 For Retro, we automatically extract pertinent data from the screenshots, videos, exported files you submit and use it to generate market research reports in aggregate form, and/or anonymised User level.
7.6 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.
7.7 Aggregated and/or Anonymized 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.
7.8 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
7.9 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.
7.10 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 listed below, as described in the “Purposes for which we will use your Personal Data” table above:
● Measure Partners and Measure Customers connected to the research projects you agree to participate in;
● Service providers and cloud storage providers who provide us with IT and system administration services or any other services we require to operate our business such as data mining / metering services, data analysis, processing of rewards or incentives, or for market research product development purposes;
● Professional advisers including researchers, lawyers, bankers, auditors, and insurers;
● HM Revenue & Customs (United Kingdom), regulators, and other authorities
● Our successors in title, our prospective sellers or buyers of our business, or to our affiliates when we have a merger or re-organization business or assets.
● We may check some of the information that you provide against third party databases to confirm that it is accurate, for example: (i) validating that your post code is accurate; (ii) with your consent, validating your Profile Data against LinkedIn (and using this to enrich Profile Data); (iii) with your consent, validating the data captured through any or all approaches mentioned against the social media IDs you may provide (and using this to enrich Profile Data).
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 permit them to process your Personal Data only 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 to non-adequate countries 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 tasks, 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 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.
12.5 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.
The following paragraphs apply to California residents.
Under the California Consumer Privacy Act (CCPA), verifiable residents of California have additional rights as outlined below.
Last Update: January 2023