Unruly / Legal Hub / UnrulyEQ Privacy Policy

UnrulyEQ Privacy Policy

Tremor International, parent of the “Unruly” brand companies  (referred to herein, both individually and collectively, as “Unruly,” “we,” “us,” and “our”), will collect, use, share and disclose or otherwise process your personal data from UnrulyEQ surveys in line with this UnrulyEQ Privacy Policy.

When you participate in an UnrulyEQ survey, you are accepting this UnrulyEQ Privacy Policy, and Unruly will have the right to use your information as described in this UnrulyEQ Privacy Policy. If you do not agree to have your information used in any of the ways described in this Unruly EQ Privacy Policy, you must discontinue use of the UnrulyEQ survey.

If you would like to learn about the broader information practices of Unruly and its corporate affiliates including Tremor International, please see the privacy policies posted respective at www.tremorinternational.com, www.tremorvideo.com, www.unruly.com and www.rhythmone.com. 

If you have any queries about how we collect or use your personal data, please contact us at legal@tremorinternational.com.

This UnrulyEQ Privacy Policy will describe the kinds of information Unruly may collect from or use or disclose about you or your computer or device when you participate in an UnrulyEQ survey.  For purposes of this Privacy Policy, and except as otherwise noted, we refer to the information we collect from identifiable consumers as “personal data.” 

1.       Information collected from UnrulyEQ surveys

Survey Information.  When you participate in an UnrulyEQ survey, we collect information about your activities as follows:

a.       Survey Identifiers and Related Information.  When you respond to a survey, we associate your information with a “Survey Identifier” or “Survey ID.”   We in turn associate Survey IDs with information you provide or that we collect passively, which is listed below.

b.       Responses to survey questions. When you participate in an Unruly EQ survey, we collect and analyse your responses to survey questions. Your responses may include personal data, such as information you provide about your age, gender, income, marital status or interests.

c.       Technical Information. When you participate in an UnrulyEQ survey, we log and analyze technical information that is openly available to our servers such as information about the kind of browser being used (e.g., Safari, Internet Explorer), the type of operating system it’s running on (e.g., Windows, Mac OS, mobile OSes), the speed and type of Internet connection (e.g., narrowband, broadband, mobile), and other technical information. This information is anonymous and generally non-personally identifiable but does include “internet protocol addresses” or “IP addresses” which can be used to identify a user and may be considered to be “personally identifiable information”. Unruly archives all technical information in raw log format.  We also collect information about the survey, such as start and end times.

d.       Biometric Information and Facial reactions to videos. Part of our market research includes measuring facial reactions to videos. We partner with Affectiva to record face videos. Affectiva helps us to use these videos to measure unfiltered and unbiased responses to online videos. This process is recorded through your computer’s webcam.

When we do this, we apply facial geometric algorithms to the videos, also known as “biometrics.” We also ascribe a biometric identifier to each video.  This might track and record, for instance, whether viewers appeared to show a particular response to a particular video (e.g., excited, pleased, annoyed).   We then use those records to help evaluate video content and audience reaction, as well as understand aggregate videos trends over time.

If you do not grant access to your webcam, you may still complete our surveys. The video will be used for market research and analytics. If you wish to do so, you can l click to turn the camera on before each video view and it will be turned off automatically at the end of each video. The video of your responses will be analysed by computers and your results will be mixed with those of other people who take part in this study. (Occasionally, researchers may view the video to check everything is working correctly and to understand more about how people react.)  For more information, please visit Affectiva’s privacy available here.

We may combine any personal data that we collect or receive, and we also may derive inferences from such data or combined data. 

You may, of course, decline to share any or certain items of personal data with Unruly, in which case we may be unable to provide you with the UnrulyEQ survey or pay you any monies or rewards that might otherwise be payable to you. Unruly archives any and all information, including personal data, that may be input in any registration process even if the user refuses or is declined or fails to use or abandons the UnrulyEQ survey provided by Unruly.

2.       How Unruly uses your personal data
Unruly uses the information including personal data collected from UnrulyEQ surveys to understand how viewers engage with content and brands based on the survey responses provided, the facial reactions to videos to inform future content and audience choices for brand campaigns. It will not be used to identify or contact you or target or re-target relevant advertising or other content to you.

Unruly may disclose one or more clients’ and/or individual users’ personal data if required to do so by law (or in a good faith belief that such action is necessary or advisable in order to comply with any laws of any country or region which may assert jurisdiction) or in order to respond to a judicial or other governmental action, order, subpoena, request, demand or warrant. We may make such disclosures without providing notice to you.

Unruly also may disclose one or more clients’ and/or individual users’ personal data if it is appropriate or necessary in Unruly’s discretion in order to: take precautions against liability; protect against fraudulent, abusive, or unlawful uses; investigate or defend against any third-party actions or allegations (including assisting a client or third party to do so); assist government enforcement agencies; or protect the security, integrity, rights, property, or personal safety of Unruly, its systems and services, as well as its employees, clients or others.

Unruly may in the future and shall have the right to implement technology to collect or share any information, including any client’s or individual user’s personal data, that we determine to be necessary or advisable in order to comply with a judicial order or other valid legal process, or to cooperate with government and law enforcement officials.

If Unruly sells all, or parts of the company or its affiliates, your personal data may be one of the transferred business assets. If this happens, your information may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed on to the new owners of the business for the purposes set out in this UnrulyEQ Privacy Policy and to ensure continuity of your selected services.

3.       Where Unruly stores personal data
The personal data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order or the provision of support services. However, we only transfer your personal data where there are appropriate measures and controls in place and all information and personal data you provide to us is stored on secure servers.

4.       For European Residents:  About your GDPR Privacy RightsIf you are located in Europe or the United Kingdom, you may have certain right under European privacy law, principally the General Data Protection Regulation (GDPR). This Section of the Privacy Policy is intended solely for, and is applicable only as to, such consumers, i.e., “data subjects”:  if you are not an EEA resident (or otherwise located in an EEA country), this does not apply to you and you should not rely on it.

Our legal bases for using personal data
All organizations need a legal reason to use your personal data. There are a number of legal grounds that enable data processing. Below are the most relevant grounds you should be aware of.

a.     With your consent
There are some activities where we process personal data with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt out at any time.

b.    For a legitimate interest
We may use your information where there is a legitimate interest to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else. Our legitimate interests in processing personal data may include:

  • to develop, deliver and maintain relevant and engaging products, services and advertising;
  • to understand how and why consumers like or engage with certain ads or content (where content is not otherwise required for us to do so)
  • to maximize advertising revenues for publishers and therefore help to maintain a diverse ecosystem of online independent publishers of content for users to enjoy and educate themselves (where consent is not otherwise required for us to do so);
  • to support individual and societal rights to receive information;
  • to improve user website experience by delivering brand safe, high quality advertising to all of the publishers of online content with which we work;
  • to carry on the business of a commercial organization;
  • to demonstrate that we provide services and products to agreed industry standards;
  • to share information with Company International group companies for analysis, audience insights, business efficiencies, content personalization and to deliver relevant advertising.

c.    To comply with legal obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims.

5.       Exercising Your Data Subject Rights Under the GDPR
If you are a resident of the European Economic Area, you have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us at privacy@unrulygroup.com, through which you may make an “access” or “right to know” request, or request that we “delete” your personal data from our active database. When you write to us, please provide the name of the panel company you used to take our survey, and the name and email address you used in doing so. We may respond by requesting additional information needed to identify you or verify your identity.
  • In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data, withdraw your consent, or request portability of your personal data. Again, you can exercise these rights by contacting us at privacy@unrulygroup.com. When you do so, please provide your email address, and we will contact you with instructions, depending on the nature of your request.
  • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us at privacy@unrulygroup.com.
  • You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

In some instances, we may still have an alternative legal basis to continue to process your personal data after a deletion request, i.e., if you require the data for an important legal, compliance or business/auditing purpose. If so, we will inform you of that. If you do withdraw consent, we may not be able to provide the product or service you have requested.

If you have a comment, concern or suggestion, please contact us at legal@unrulygroup.com or privacy@unrulygroup.com. If you have a complaint and we cannot resolve the matter, you have the right to escalate to the Information Commissioner’s Office or the data protection regulator responsible for your country or region.

6.       Retention of personal data
We will retain your personal data for as long as necessary for the uses set out in this UnrulyEQ Privacy Policy, or while there is a legitimate reason for doing so. If you ask us to delete your personal data before that time, we may not be able to do so due to important legal, regulatory or contractual requirements. For example, we would need to retain your name and contact details for suppression purposes if you do not want to receive direct marketing from us.

7.       Changes to this UnrulyEQ Privacy Policy
Unruly may update this UnrulyEQ Privacy Policy from time to time. This may be in relation to changes in the law, best practice, changes in our services or treatment of personal data. We will always display clearly when this UnrulyEQ Privacy Policy was last amended.

8.       Children’s Privacy
Unruly is sensitive to the issue of children’s privacy. Our UnrulyEQ surveys are neither developed for, nor directed at, children, and we do not knowingly collect personal data about children under the relevant legal age under which parental consent would be required, which generally ranges from 13 to 16 years of age, depending on the jurisdiction. If you believe your child has provided Unruly with personal data by registering or participating in any UnrulyEQ surveys, and you would like to have us look into removing the data from our servers, please contact us at privacy@unrulygroup.com.

9.       For California Residents:  Information About Your CCPA RightsThe California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Policy applies if you are a natural person who is a resident of California (“California Consumer”) in the capacity as a business partner of Unruly and uses the surveys described herein, Unruly services, or are a consumer whose information is collected or used by us in providing the Services.  This Section of the Privacy Policy is intended solely for, and is applicable only as to California Consumers:  if you are not a California Consumer (or a resident of California), this does not apply to you and you should not rely on it.

a.         The right to access. You may have the right to request, twice during a twelve-month period, the following information about the personal data (referred to in the CCPA as “personal information”) we have collected about you during the past 12 months:

  • the categories and specific pieces of personal information we have collected about you;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected or sold the personal information;
  • the categories of third parties with whom we shared the personal information; and
  • the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

b.         The right to deletion. You may have the right to request that we delete the personal information we have collected from you. Certain information may be exempt from such requests under applicable law.  We need certain types of information so that we can provide our Services to you, and may retain certain information for important business purposes, such as fulfilling our legal obligations, or for security, auditing or de-bugging purposes. 

c.         How to exercise your access and deletion rights. California residents may exercise their California access or deletion rights by an email to contacting us at privacy@unrulygroup.com. If you write to us, please provide the name of the panel company you used to take our survey, and the name and email address you used in doing so.  We may respond by requesting additional information needed to identify you or your account.

Likewise, or security purposes, we will seek to verify your identity – in part by requesting certain information from you — when you request to exercise your California access or deletion rights.   Once we have verified your identity, we will respond to your request as appropriate.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

d.         The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

e.         The right to opt-out of the sale of your personal information. Should we ever decide to “sell” your personal information as that term is used under the CCPA, we will provide a way to “opt out” of such sale.  We do not currently sell your personal information for purposes of the CCPA. 

f.          Authorized Agents. You may designate an agent to make requests to exercise your rights under CCPA as described above. We may take steps both to verify the identity of the person seeking to exercise their rights as listed above, to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney, and where appropriate to verify your own identity.

10.       Information Security
We take measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data we collect and store.  These may include internal reviews of our data collection, storage, firewalls and processing practices and security measures.  Of course, no security system is perfect.   Thus, while we do take measures to safeguard against unauthorized access to, or alteration of data we collect and store, we cannot guarantee that it will not be disclosed or accessed inadvertently or through the unauthorized acts of others.

11.       Contact Us
In addition to any general data protection enquiries you may have, you can use the below details to contact us:

By email: privacy@unrulygroup.com.  

Last updated: 5.30.22