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UnrulyEQ Privacy Policy

Unruly Group Limited, and its affiliates including Unruly Media Inc, Unruly Holdings Limited, Unruly Media Limited, Unruly Media AB, Unruly Media AS, Unruly Media GmbH, Unruly Media Inc, Unruly Media KK, Unruly Media Pte Ltd, Unruly Media Pty Ltd and Unmedia Video Distribution Sdn Bhd (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 have any queries about how we collect or use your personal data, please contact us at legal@unrulygroup.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.

Technologies used by Unruly to collect information

Unruly may use one or more varieties of technologies to collect information from UnrulyEQ surveys. These are listed and described below.

Cookies. A “cookie” is used by a website to send some data to a user’s device. Depending on the settings of the device or web browser this data may be stored on the user’s device so that the device can later return that data to the same website. Cookies can be used by online services, such as websites or ad technologies, to recognize an Internet- or mobile-connected device that they have encountered before. A user may configure his or her web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being sent.

Unruly partners with Oracle (a data management platform). During UnrulyEQ surveys, Oracle drops a cookie on behalf of Unruly on a survey participant’s browser to help Unruly categorise the participant based on their responses to the survey questions. These cookies identify personality traits or behaviours. Oracle drops cookies based on:

  • Emotions. For example, if you respond that a video makes you happy in an UnrulyEQ survey, a “happy” cookie will be dropped.
  • Personality profile. See “Information collection from UnrulyEQ surveys” below for more detail.
  • Cultural leanings. For example, a participant might identify themselves as “individualistic” or “collective”.

With this information in combination with the third party data held by Oracle, Unruly creates data segments associated with certain interests, behaviours and attributes (e.g. an interest in travel or sports) for the purpose of delivering interest-based advertising. These data segments are stored in Tremor DMP, a data management platform owned and operated by Unruly’s affiliated company. For more information, please visit Oracle’s privacy policy available here.

Information collection from UnrulyEQ surveys

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

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. Please see “How Unruly uses your information” for further detail.

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.

Facial reactions to videos. Part of our market research includes measuring facial reactions to videos. We partner with Affectiva to record face videos. Affectiva use these videos to measure unfiltered and unbiased responses to online videos. This process is recorded through your computer’s webcam. If you do not grant access to your webcam, you may still complete the survey and we will NOT be able to access your webcam in any way. This process is entirely secure and will be strictly safeguarded for your privacy. The video will be used solely for research and will NEVER be publicly accessible. You will 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, ensuring your anonymity. 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.

Personality profile. During an UnrulyEQ survey, we offer you the chance to see your personality profile. This personality profile is created by an automated third party service (see here for more information) that accesses and analyses your social media posts using artificial intelligence. Unruly does not have access to your social media profiles or posts and this process will NEVER post anything to your social media accounts. Your results will be mixed with others who take part in this study to understand relationships between personality types. Your posts cannot and will not be stored on any system outside of your social media account.

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.

Note about Children’s Privacy: Unruly is very 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 13. 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 legal@unrulygroup.com

Our legal bases for using personal data

All organisations 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.

With your consent

There are some activities where we process personal data with your consent. For example, where we want to record your facial reaction to a video, we would ask your permission first and you could opt-out at any time.

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.

We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights.

Our legitimate interests in processing personal data include

  • to develop, deliver and maintain relevant and engaging products, services and advertising;
  • understanding when audiences engage with our clients’ ads;
  • to build a clearer understanding of who our clients’ audiences are in order to better serve more relevant advertising to those audiences, for the benefit of both individuals and our clients;
  • to maximise 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;
  • 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 organisation;
  • to demonstrate that we provide services and products to agreed industry standards;
  • sharing information with Tremor International companies for analysis, audience insights, business efficiencies, content personalisation and to deliver relevant advertising.

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.

How Unruly uses your information

Unruly uses the information collected from UnrulyEQ surveys to understand how viewers engage with content and brands based on the survey responses provided, the facial reactions to videos and a respondent’s personality profile 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’ information 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’ information 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 information, that we determine to be necessary or advisable in order to comply with a judicial order or to cooperate with government and law enforcement officials.

If Unruly sells all, or parts of the company or its affiliates, your information 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.

Where Unruly stores personal data

The 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 information where there are appropriate measures and controls in place and all information you provide to us is stored on secure servers.

Access and control of your information

Where we rely on your consent to process personal data, you have the right to withdraw that consent at any time. Please contact us at legal@unrulygroup.com with details of your request. In some instances, we may still have an alternative legal basis to continue to process that personal data and 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. 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.

Retention of personal data

We will retain your information 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 information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints. 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.

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. Where necessary, we will seek your consent to these changes. We will always display clearly when this UnrulyEQ Privacy Policy was last amended.

Contact us

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

By email: legal@unrulygroup.com

By mail: Unruly Group Limited, The White Chapel Building, 15 Whitechapel High Street, London, E1 8QS

Last updated: April 2020