ASDE Survey Sampler Privacy Policy

ASDE Privacy Policy

Last Updated November 4, 2024

This privacy policy (“Privacy Policy”) is designed to help you understand how ASDE Survey Sampler and its affiliates (“ASDE,” “we,” “us,” or “our“) collect, use, and share your personal information and to help you understand and exercise your privacy rights.

• SCOPE & DEFINITIONS

This Privacy Policy governs the handling of personal information by ASDE, whether collected through our website located at https://surveysampler.com/ or other ASDE-branded websites (“Website“), or through other means such as purchased lists, data sharing with our partners, or any other third-party sources (“Services”). It applies to all personal information that we handle, regardless of how it was obtained or whether the individuals have directly interacted with our Website or Services.

While our Website may provide links to third-party sites, this Privacy Policy does not extend to external websites or services. We disclaim responsibility for their privacy practices and content. We encourage you to review the privacy policies of any third-party sites you access through links on our Website.

This Privacy Policy applies to all personal information processed or handled by ASDE, regardless of how we obtain that information. This includes information about individuals who have not directly interacted with our Services or provided information to us. By engaging with our Clients who utilize our Services, or by having your information included in the datasets we use, you are subject to the practices described in this Privacy Policy. By accessing our Website, interacting with our Services, or providing your information to us, you acknowledge and consent to the practices described in this Privacy Policy.

• DEFINITIONS

To ensure clarity and a mutual understanding throughout this Privacy Policy, we provide the following definitions:

Personal Information: Any information about an identifiable individual, including but not limited to name, telephone number, and geographic location data that can be used on its own or with other information to identify, contact, or locate a single person.

Client: Any business or entity that engages ASDE for the purpose of obtaining telephone sampling services, list matching, or any other services we provide.

You: Refers to Clients, members of the public, visitors who access our Website but may not necessarily engage with our Services, and any individuals whose personal information we may process or handle.

Member of the Public: Any individual whose personal information may be included in the datasets we use for sampling and research purposes.

Person Concerned: An individual to whom the personal information pertains and who can be identified by said information, as it is confidential and, barring exceptions, cannot be communicated without the consent of the individual.

• COMPLIANCE WITH LEGAL AND INDUSTRY STANDARDS

ASDE Survey Sampler specializes in providing sample lists and enhancement services exclusively to survey research professionals. We adhere to the privacy policies and codes of ethics of these associations, reflecting our dedication to ethical practices in market research. We ensure the protection and integrity of personal information.

We are committed to upholding the highest standards of data privacy and are a proud member of several industry organizations, including:

• CRIC (Canadian Research Insights Council)
• MRIA (Marketing Research and Intelligence Association – Canada)
• Insights Association (USA)
• ESOMAR (Global Association of Research Professionals – Europe)
• AAPOR (American Association for Public Opinion Research – USA)

• DATA COLLECTION & USAGE

Summary. We collect information primarily from third-party sources in the course of providing our Services. The categories of information we process may include, but are not limited to, telephone numbers and geographic locations, which are necessary for conducting market research and surveys. Our collection practices are consistent with industry standards and comply with applicable laws, ensuring that the information is obtained and used responsibly and ethically.

Incidental Information Handling. In the course of our business operations, ASDE may handle Personal Information incidentally. This incidental handling involves the collection or storage of information without active use or analysis. We restrict the handling of such incidental information to the extent strictly necessary to deliver our Services and minimize privacy risks. Regardless of whether the information is actively or incidentally processed, we apply the same rigorous security and data protection standards to ensure full compliance with applicable privacy regulations.

• INFORMATION YOU PROVIDE

Account Information. If you apply for and/or use our Services, you may be required to create an account, and to submit information about yourself and your business (“Account Information”). Examples of Account Information include:

• Contact details such as your name, email address, postal address, and telephone number.
• Business information, including company name, industry sector, and your role within the company.
• Payment and billing information, which may include credit card details, billing addresses, and transaction history necessary for processing payments and fulfilling orders.
• Preferences and feedback, including communication preferences, survey responses, and service reviews to enhance service delivery and customer satisfaction.

Personal Contact Information. If you as a Client or visitor to our Website request certain information from us, including but not limited to white papers, subscribing to our e-newsletter service or applying for a job, you may be asked to share contact information, such as your email address. This information is kept for our internal purposes only, such as to provide you with Services or products we believe are right for you.

• INFORMATION WE COLLECT FROM OTHER SOURCES

Telephone, Postal Code, and Other Data. ASDE’s Survey Sampler provides statistical sampling and related services exclusively to survey professionals and research organizations (our Clients) that conduct survey research and polls, generally for marketing or social science purposes. Samples are comprised of statistically and/or randomly selected lists of names, phone numbers, addresses, and/or other contact information. We obtain this information from trusted and qualified vendors. Most commonly, our vendors will sell us phone books with the above described information, which we then repackage and sell to Clients, pursuant to data privacy rights. We have procedures in place to confirm to the best of our ability that our vendors and Clients who receive the information described above follow proper legal consent protocols to ensure compliance with consumer data protection rights. For more information, please email: info@surveysampler.com. For more information regarding your rights as a Person Concerned and consumer, please see “YOUR PRIVACY CHOICES AND RIGHTS” in the Privacy Policy.

Non-personal information. We also collect “Non-Personal Information,” meaning technical and other information that does not identify you personally. Non-Personal Information also includes information that may originally have been Personal Information but has been aggregated or anonymized such that it cannot be used to identify any individual or has been segregated from other Personal Information.

• HOW WE OBTAIN PERSONAL INFORMATION

The table below summarizes the methods we use to obtain Personal Information as described above:

Type of Information	How We Obtain the Information
Service Information	Sample data collected from our vendors is shared with our clients via downloadable files hosted on a secured ASDE website. A separate password to access the files is sent via email to the clients, ensuring additional security during transmission.
External Data	From third parties including paid service providers and freely available public databases
Feedback	When you call ASDE to complete a survey with feedback, or provide feedback through another ASDE-provided feedback channel
Usage Data and Website Data	When you use and interact with the Services or visit our Website, such as via server logs and behavioural analytics, pixels or cookies on our websites, which may be provided by us or our third-party partners (e.g., Google Analytics)

Cookies. Cookies are identifiers that we transfer to your device to enable our system to recognize you and your personalized settings, to better understand how Clients interact with the Services, to monitor aggregate usage, and to optimize web traffic routing on our Website and sharing information on social networks. You may be able to disable or limit the use of cookies in your browser or device settings, but please note that certain parts or features of the Services may not be fully functional if you do so. The length of time that a cookie will reside on your device will depend upon the specific set-up of the particular websites you visit. If you are concerned about the use of cookies, you can refer to the help information in your browser software for information on how to disable cookies. If you wish to delete cookies from your machine, consult your browser’s help files for instructions on how to do so.

Please see the “YOUR PRIVACY CHOICES AND RIGHTS” section below for more information on the opt-out options provided by these companies in relation thereto and within the advertising industry generally.

• HOW WE USE YOUR INFORMATION

In addition to the purposes described above, we use your information for a variety of business purposes, as described below.

In Aggregate and De-Identified Form. We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information“). We may use Aggregate/De-Identified Information for any purpose we deem appropriate, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

To Provide Our Services. For Clients, we use your Personal Information to facilitate our market research services, which includes functions such as:

• Managing your account and information;
• Assessing your needs to tailor our telephone sampling and survey services;
• Administering billing and payment processing for transactions related to our Services;
• Coordinating with third-party data providers to compile and deliver telephone samples and other research data;
• Processing information to fulfill service requests, including list matching and custom sampling based on geographic and demographic criteria;
• Ensuring secure access to our services and protecting the integrity of our data collection and processing activities;
• Facilitating interactions with third-party partners integral to our Services;
• Providing support for technical or service-related inquiries;
• Complying with legal, regulatory, and contractual obligations pertaining to our services;
• Communicating important updates about our Services, including changes to policies or terms;
• Continuously improving our offerings to align with your evolving market research needs.

For Legitimate Business Purposes. We may process or handle your Personal Information, for both Clients and Persons Concerned, for a variety of reasons, depending on how you interact with our Services and Website, including:

• Supplying our Clients with telephone samples and survey data for their market research needs;
• Protecting an individual’s vital interests, such as preventing fraud or harm;
• Enhancing the security and functionality of our Services and website;
• Engaging in research and development to refine our offerings and methodologies;
• Upholding our legal, regulatory, and contractual obligations, including fraud prevention and assisting law enforcement;
• Maintaining internal quality control, safety, and service integrity;
• Verifying identities and authenticating user access to prevent unauthorized use of our Services;
• Conducting audits and compliance activities related to our interactions and transactions;
• Enforcing our agreements, policies, and protecting our intellectual property rights;
• Collaborating with third parties for operational improvements and service support;
• Integrating information from third parties to better understand client needs and enhance service delivery;
• Addressing legal claims or complying with legal obligations; and
• Informing you of other purposes for which we may process your Personal Information, subject to your consent where necessary.

Usage Data. ASDE may collect and use quantitative, transactional and performance data on the use of the Services and may also generate technical logs, data, and learnings about use of the Services or Website visits (collectively the “Usage Data”). This Usage Data may be linked to your device ID. However, we only use your device ID if necessary to help us diagnose and/or respond to any issues with the Services. ASDE may use such information to operate, analyze, improve and support the Services and for other lawful purposes.

• HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties to assist with the business purposes set forth above.

Disclosures to Provide our Services. The categories of third parties with whom we may share your information are described below:

Type of Third Party	Description of Disclosure
Clients & Service Providers	As part of our business, we share Personal Information from our vendors with Clients. Information we share with Clients is usually only telephone and postal address, but may also include name and address. Additionally, we may share Personal Information we collect, store, and process with our third-party contractors and service providers who are subject to reasonable confidentiality terms and who are only permitted to use that information to help us provide our Services, including our sub-processors and service providers that provide us with technical support and tools, customer service tools, marketing and analytics, identity verification, and related services. This also includes service providers that provide us with web hosting and maintenance services, technology assistance and support, phone, email and other communications, analytics providers, and data storage providers.
Business Partners	We may share Personal Information we collect, store and process with business partners to provide you with a product or service you have requested. We may also share your Personal Information to business partners with whom we jointly offer products or services. For example, we may disclose certain of your information to a business partner if you choose to purchase and/or use their product to help you fulfill a task in the Services. We also make disclosures to marketing service professionals, to ensure their continued ability to maintain contact with your corporation and your personnel; however, such disclosure is protected by the terms of our contract.
ASDE Entities and Affiliates	We may share with other companies and brands owned or controlled by ASDE, and other companies owned by or under common ownership as ASDE. These companies will use your personal information in the same way as we can under this Privacy Policy.
Authorities and Law Enforcement	We may share Personal Information we collect, store, and process when requested by the authorities in the normal course of a police or other legal investigation.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your Personal Information may be sold or transferred as part of such a transaction (including in connection with any diligence by any potential transacting party conducted prior to and in connection with such transactions).

Other Purposes. We may also share your Personal Information for other purposes or to other parties as requested by you, as permitted by applicable law, or in any manner you have otherwise consented to.

Aggregate and De-Indentified Information. We may share Aggregated/De-Identified Information with any third party we deem appropriate in our discretion, including advertisers, promotional partners, and sponsors.

• DATA RETENTION

We retain Personal Information only for as long as necessary to fulfill the purposes for which it was collected, including providing our Services, and to comply with legal, regulatory, or business record-keeping requirements.

The retention period for Personal Information may vary based on its nature and the purposes for which it is processed:

• Account Information: Personal information associated with your account is retained for the duration of your active engagement with our Services and for a standard period of 1 year post account closure. This period may be extended if required by legal obligations or to resolve disputes.
• Persons Concerned: Information about individuals in our datasets is typically retained for up to 1 year to ensure the integrity of our services and research outcomes. In certain cases, data may be retained for longer periods as necessary to complete our services or as mandated by our clients’ research needs. While some data may not be actively purged, we do not attempt to retrieve it once it is no longer in active use.

Upon the expiration of the retention period, we will take appropriate measures to securely delete, anonymize, or otherwise render the Personal Information non-identifiable, ensuring its confidentiality and compliance with applicable data protection laws.

• DATA TRANSFER

Transfer of Personal Information. Please be advised that we may store or process your data outside your city, province, state, or country, including through one of our contractors. This means that your personal information may be stored in a jurisdiction that operates under privacy and data protection laws different from (and potentially less protective than) those of your home jurisdiction. If you use our Services, you consent to the transfer and processing of your information from any country to any other country in accordance with this Privacy Policy.

• YOUR PRIVACY CHOICES AND RIGHTS

You, as a Client or Person Concerned, may choose not to provide Personal Information. If you choose not to provide Personal Information (or ask us to delete it), as a Client we may not be able to provide you with our Services or certain functionality of the Services. We will tell you what information you must provide to receive the Services or to conduct business with us, including by designating it as required at the time of collection or through other appropriate means.

Marketing Communications. If you register for our Services, you may receive marketing communications from us or our partners. You can use an “unsubscribe” (or similar) link found at the bottom of a marketing email or reply to the email with the subject line “unsubscribe” to opt out of receiving future marketing emails. People who supply us with telephone numbers online or offline may receive telephone contact from us with information regarding new products and services or upcoming events. If you don’t want to receive any other marketing materials in the future, please email: info@surveysampler.com. Note that you will continue to receive transactional or administrative emails regarding products or Services you use (if applicable).

Accessing, Correcting, or Deleting Your Information; Exercising Your Jurisdiction’s Privacy Rights. If you would like to access, correct, amend or delete any of your personally identifiable information collected or held by ASDE or exercise the data privacy rights applicable to your jurisdiction, please email info@surveysampler.com. We will respond to such requests within a reasonable timeframe.

Please note that in certain circumstances we may be required by law to retain your Personal Information or to continue providing a Service. For example, we retain Personal Information used to conduct our anti-money laundering activities and operate our fraud prevention and monitoring program for a minimum period of five (5) years.

“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies. You may stop or restrict the placement of third-party cookie technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, please note that cookie-based opt-outs are often not effective on mobile applications. You may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

More broadly, the online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Please note you must separately opt out in each browser and on each device.

Privacy By Default. By default, the highest privacy settings are set as the default in our systems. In events when you are interacting with us and have the option, you may choose whether you want to keep that privacy default setting or change your privacy preferences.

• SECURITY OF YOUR INFORMATION

General Approach. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken commercially reasonable safeguards designed to keep your Personal Information protected and require our service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing Personal Information to us (or our vendors), you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. Your personal information may be accessible by our employees, contractors, business partners, and service providers who require access solely for the purposes described in this Privacy Policy.

Data Breach. Should our databases with your personally-identifying information be breached, we take reasonable steps to report the breach to relevant authorities. In case of high-risk breaches, we report the breach to the Commission d’accès à l’information (CAI). We also notify individuals whose information was stolen by calling their telephone numbers and utilizing any other contact information we might have.

• SUPPLEMENTAL PRIVACY RIGHTS FOR QUEBEC RESIDENTS

Access to Information & Data Portability. ASDE is committed to being open and transparent about the personal data we collect from you. We want to ensure that the Personal Information we collect is up-to-date, accurate, and easily accessible to you. Where technically feasible, we will make every effort to transfer your data from one organization to another in a structured, commonly used, and machine-readable format, upon request. If you would like a copy of the Personal Information we have collected about you, please send us your request in writing to info@surveysampler.com. Once we receive your request, we will endeavor to respond to you within 30 business days.

Right of De-Indexation. As a resident of Quebec, you have the right under s. 28.1 of Quebec’s Act Respecting the Protection of Personal Information in the Private Sector to “de-index”, or to delete any of your Personal Information that ASDE has. You can exercise your right of de-indexation by sending us a written request to info@surveysampler.com outlining the Personal Information you wish to be deleted. Please note that we reserve the right under s. 28.1 to retain your Personal Information if it is absolutely necessary to provide our Services to you or if retention is required to comply with our legal obligations. We will review your request and respond to you in writing.

Privacy Impact Assessments. As part of our commitment to safeguarding your personal information, ASDE conducts Privacy Impact Assessments (PIAs) for projects and services that involve the collection or use of personal data. PIAs help us evaluate and mitigate privacy risks to ensure compliance with applicable legal and regulatory requirements.

If you have any questions regarding our approach to privacy assessments, please contact us at info@surveysampler.com.

• CHILDREN’S PERSONAL INFORMATION

Our Services are general audience services not directed at children under the age of 18. We do not knowingly collect, share, or sell any information from children under the age of 18. If we learn that any information we collect has been provided by a child under the age of 18, we will promptly delete that information.

• UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our information practices. When we do, we will also revise the “last updated” date at the beginning of the policy. If we make any material changes we may notify you either by prominently posting a notice of such changes or by directly sending you a notification (sent to the e-mail address specified in your account, if applicable). We will always post the then-current version of this Privacy Policy on our Website. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy is posted. We encourage you to review this Privacy Policy periodically to stay informed on our privacy practices.

• CONTACTING US

Questions regarding this Privacy Policy or ASDE’s privacy practices should be directed to our Privacy Officer by email at info@surveysampler.com or by mail at:

ASDE

Attention: Randa Bell, Privacy Officer

ASDE Survey Sampler

729 St-Joseph, Suite 201

Gatineau, QC J8Y 4B6

info@surveysampler.com