Chatter Privacy Statement

Chatter Research Inc. (“Chatter”, “We”, “Us”) has created this privacy statement (“Statement”) in order to set out how we collect, use, and disclose personal information through the Chatter Research Services (as those terms are defined in our Terms of Service).

The privacy of our users is of great importance to us. By using the App or the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Statement and you hereby consent to the collection, use and disclosure of your personal information in accordance with this Statement.

 

1. WHAT DOES THIS STATEMENT COVER?

This Statement covers our collection, use and disclosure of information about identifiable individuals (“Personal Information”), particularly those individuals who volunteer to complete surveys of our clients (our “Clients”).

This Statement does not apply to the practices of companies that we do not own or control, including those practices of our Clients. We do not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for the Services.

2. COLLECTION AND USE OF  PERSONAL INFORMATION AND OTHER DATA

2.1 Client Account Information                                                

In order to use certain aspects of the Services, our Clients and their end users may be required to have a valid Chatter account to log in to the App (“Account”). When our Clients register for the Service, we generally collect only business contact information, including the company name and address. However, Chatter may collect personal information of Client employees, technicians or other personnel from our Client, with permission from the Client, if necessary to provide Services.

2.2 End User Data

When end users of our Clients, such as retail customers (“End Users”), engage in a Chatter survey, Chatter will collect the End User’s cell phone number in order to administer the survey and provide the results to the relevant Client for which the survey was conducted. The cell phone number may also be used by our Client to contact an End User to respond to an End User request or resolve a customer service matter. When End Users respond to survey questions, the responses are also collected for analysis and sharing with our Clients.

Personal Information collected by the App is aggregated and anonymized by Us to create aggregate statistical data (“Statistical Data”) which we use to provide analytics to our advertisers and to improve the Services, including improving proprietary machine learning algorithms. The Statistical Data does not include any Personal Information.

3. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

Chatter stores its data, including Personal Information, on servers located in the United States and Canada. By submitting information, you agree to this transfer, storing or processing of your Personal Information in the United States and Canada. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada under lawful access regimes or court order.

4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

4.1 Disclosure of Survey Results to Client

Chatter conducts surveys on behalf of its Clients. Accordingly, all Personal Information provided to Chatter by an End User, including name, contact information, profile picture, survey feedback about the Client and location where End User visited Client (e.g. retail store location), is provided to the specific Client for which the survey was conducted.

Chatter then compiles End User information and creates analytics reports that are shared with the Client.

4.2 Disclosure of Statistical Data

Chatter discloses aggregate Statistical Data to its partners and clients, such as advertisers and other third parties, who may use the data for business purposes. This information does not include any Personal Information or otherwise identify any individual End Users.

4.3 Service Providers and Business Partners

We may from time to time employ other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services to you. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third-party companies and individuals employed by us to facilitate our Services, including database management, web analytics and general improvement of the Services, and businesses who engage our Services (to the extent provided for above).

4.4 Business Transfers

If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

4.5 With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Statement, we will notify you and/or obtain your express consent as required under applicable privacy laws.

5. SECURITY

The security of your Personal Information is important to us.  We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us.  We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.

You are also responsible for helping to protect the security of your Personal Information.  For instance, never give out your email account information or your password for the Services to third parties.

6. RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We keep End User’s cell phone numbers for as long as the relevant Client is a Client of Chatter. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Statement.

7. ACCESS, CORRECTION AND ACCURACY  

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.  As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information.  Having accurate Personal Information about you enables us to give you the best possible service.

8. CHANGES TO THIS STATEMENT

We may amend this Statement from time to time. Use of Personal Information we collect is subject to the Statement in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our App or Services or sending you an email prior to the change becoming effective. You are bound by any changes to the Statement when you use the App after such changes have been first posted.

9. ADDITIONAL INFORMATION

Questions regarding this Statement or Chatter’s privacy practices should be directed to  privacy@chatterresearch.com.

Last Updated: May 2, 2018