Measure Protocol Privacy Notice

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. Introduction
2. Things that we will not do
3. Important information and who we are
4. Changes to the privacy notice and your duty to inform us of changes
5. Third-party links
6. The data we collect about you
7. How we use your personal data
8. Disclosures of your personal data
9. International transfers
10. Data security
11. How long will we use your personal data for?
12. Your legal rights
    
13. Accessibility of the privacy notice

1. Introduction

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 16 Great Queen Street, Covent Garden - WC2B 5AH - London, United Kingdom.

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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”).

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1.3        This Privacy Notice together with the Measure MSR App Terms of Use available at https://www.measureprotocol.com/msr-terms (the “Terms”) and any other documents referred to in it sets out the basis on which we process any Personal Data we collect from you, or that you provide to us, will be processed by us. This Privacy Notice also sets out how you can instruct us if you prefer to limit the use of that Personal Data and the procedures that we have in place to safeguard your privacy.  Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

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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.

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2. Things that we will not do

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.

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3. Important information and who we are

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”).

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3.2        Postal address: 16 Great Queen Street, Covent Garden - WC2B 5AH - London, United Kingdom.

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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: privacy@measureprotocol.com

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4. Changes to the privacy notice and your duty to inform us of changes

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.

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5. Third-party links

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.

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6. The data we collect about you

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).

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6.2        This is information that you give us by instructing us to provide you with the services, accepting our online Terms of Use, registering an account on our Website or using our App.

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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.

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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.

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6.5        We may collect, use, store and transfer different kinds of Personal Data about you such as:

• your basic registration data (name, email, country, geo IP country, time zone, joined / became active data, invited by (if invited by another user), balance. Phone number (if used for account validation) (“Registration Data”);
• Record of transactions (IDs and basic transactional information of surveys or other data jobs you have taken and when) (“Transactional Data”);
• Records of gift cards given to you for participating in surveys or other data jobs (“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 data jobs (“Ratings Data”);
• A list of profile demographic questions answered through the Measure MSR app  (“Demo Data”);
• Records of your consents or opt-ins for compliance and contractual purposes (“Opt-in Data”);
• The survey data you fill in or provide when you participate in a survey run and controlled by us (“Measure Survey Data”); and
• If you have:
• contacted our customer service or compliance departments;
• Interacted with us on social media; and
• Provided feedback about our products.

(“Customer Support Data”).

• User Data includes information about how you use our Website and App and your user credentials. In particular, this includes, information we collect about you and your device. Each time you visit our Website or use our App we may automatically collect the following information:
• App Data: A few IDs for our basic app and account analytics such as Measure Unique ID, Device Tokens and AppsFlyer Identifiers;
• Unique Application Numbers: When you install or uninstall our App containing a unique application number or when our App searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us;
• Device Data: including the type of device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface), your mobile operating system and time zone setting;
• Content Data: stored on your mobile device, including contact information, login information (your e-mail address, forename and surname), photos, videos or other digital content, check-ins (collecting location information, including exif image data, of where an image was taken - if you have the GPS switched on), geofencing (collecting the list of stations that you are at with a timestamp);
• Log Data: such as the details of your use of our App or your visits to our Website including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise;
• Location Data: We use GPS technology, or a similar technology, to determine your current or past location. Some of our location-enabled services require your Personal Data for the feature to work.
• 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 jobs, the Users agree to participate in. Each data job 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:,
• Online browsing: This includes the sites Users visit and apps they use, including news sites/apps or social networks, and their interactions with them.
• Online activities: This includes the search terms Users enter and the results of such searches, the videos Users view, the products users shop for online, information Users enter into forms, the materials Users download or upload, the advertisements Users see, cookies on websites Users visit, information and content on sites or apps that Users visit or Use and with which Users interact and may include personal, financial and health information (subject to the process described below in the section entitled “Protecting Personal & Sensitive Information”).
• System information: This includes information about the device and browser that Users are running on, how the MSR app is operating, and which other applications are installed or running.
• Mobile Usage Information: which refers to information about a User’s use of their mobile. This can include the following types of information:
• Information about User’s internet browsing habits: how much time they spend browsing the internet on their mobile device or computer, the sites they visit or apps they use, and the terms of any search they carry out.
• Information about user’s usage of other apps and features: (such as the camera, though we do not collect any photos) on User’s mobile device, including the identity of the apps and features, when they downloaded them, how often they use them and for how long.
• Information about the type of mobile device Users: own, when and for how long they charge it, its battery status, whether it is switched on, off or in a stand-by or ‘Airplane’ mode.
• Information about which mobile network Users use, which wi-fi networks they connect to, and at what times.
• Information about the volume of data: downloaded to Users’ mobile device, the times that they download that data and the method of connection they use (wi-fi or mobile network).
• Information we can deduce from combining the above information: e.g., what apps users were using just before they searched for particular information using their mobile device’s internet browser, or how often they call, email or text a particular contact.
• Operating system capabilities: to view to contents of user’s applications such as Accessibility services.

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7. How we use your personal 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:

• With your consent;
• Where we need to perform the contract we are about to enter into or have entered into with the company you represent or work for;
• Where it is necessary for our legitimate interests or those of a third party) and your interests and fundamental rights do not override those interests; or
• Where we need to comply with a legal obligation.

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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.

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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.

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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.

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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.

7.10        Cookies

We use cookies to distinguish you from other users of the App, or Website. This helps us to provide you with a good experience when you use the App or browse our Website and also allows us to improve the App and our Website. For detailed information on the cookies, the way we use them and the purposes for which we use them, see our cookie policy.

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8. Disclosures of your personal data

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:

• Measure Partners and Measure Customers connected to the data jobs 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 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-organisation 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 the Users’ post code is accurate; (ii) validating Users info against LinkedIn if consent given to do so (and using this to enrich Demo Data); (iii) validating Users info against Facebook if consent given to do so (and using this to enrich Demo 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 only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

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9. International transfers

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”.

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10. Data security

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.

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11. How long will we use your personal data for?

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.

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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.

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11.3        Please contact us using the contact details set out in this Privacy Notice if you have any questions about data retention.

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12. Your legal rights

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.

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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.

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12.3        You have the right to:

• Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
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  You can delete your account directly from the MSR app by going to settings >> Delete Account. This will ensure all your data within the app is deleted, it will register an account deletion with us, and you will be unsubscribed from any emails or communications. This cannot be reversed. You can also submit an account and data deletion request to us at support@measureprotocol.com. Please note it can take up to 72 hours for data to be deleted from our systems.
• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) If you want us to establish the data’s accuracy; (b) Where our use of the data is unlawful but you do not want us to erase it; (c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and (d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Opt out of the sale of your personal data. Where applicable, California residents have the right to opt out of the sale of their personal data under the CCPA (California Consumer Privacy Act) as long as you are a verifiable resident of the State of California. You can submit a verifiable consumer request at https://www.measureprotocol.com/donotsellmypersonalinformation
• Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. You have the right not to receive unlawful discriminatory treatment for the exercise of your privacy rights under the CCPA (California Consumer Privacy Act) as long as you are a verifiable resident of the State of California.

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

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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

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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.

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12.7        Exceptions

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.  

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13. Accessibility of Privacy Notice

13.1        Measure is committed to providing a site and Privacy Policy that is accessible to the widest possible audience regardless of technology or ability. If you experience difficulty in accessing any part of this website or this Privacy Policy, please email us at privacy@measureprotocol.com and we will work with you to provide the information, item, or transaction you seek through an alternate communication method or that is accessible for you consistent with applicable law.