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NSAID SURVEY PRIVACY POLICY

Last updated October 19th, 2020

PLEASE READ THIS NSAID SURVEY PRIVACY POLICY CAREFULLY BEFORE YOU AGREE TO PARTICIPATE IN THIS SURVEY.  BY ELECTING TO PARTICIPATE IN THIS SURVEY, YOU AGREE TO THIS NSAID SURVEY PRIVACY POLICY INCLUDING WITHOUT LIMITATION, THE ARBITRATION AGREEMENT AND CLASS ACTION WAIVER DESCRIBED BELOW.

Harris Insights & Analytics, LLC (“The Harris Poll” or “we” or “us” or “our”) wants survey  participants (“participant” “respondent” or “you”) to understand how the information collected by The Harris Poll in connection with this Survey will be used and for you to understand other rights and terms applicable to information you share and information we collect. This NSAID Privacy Policy (this “Privacy Policy”) explains how we collect, use, disclose, and safeguard the information provided by you.  Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT PARTICIPATE IN THE SURVEY. This Privacy Policy supplements the Survey Informed Consent Form (“ICF”) you were presented in connection with the survey and you should ensure you read and understand those terms as well.

Please note that this Privacy Policy does not cover our privacy practices in relation to our more general The Harris Poll website and other surveys or interactions between you and The Harris Poll – this Privacy Policy only applies to the specific study referenced herein.  Our general privacy policy can be found here: https://nharrisco.wpengine.com/privacy/.

  1. SURVEY BACKGROUND.

The Harris Poll is working with CTC Clinical Trial Consultants AB, a company organized under the laws of Sweden (“CTC”), to conduct two online surveys (and the surveys shall individually and collectively be referred to as the “Survey”) regarding the use of nonsteroidal anti-inflammatory drugs (“NSAIDs”) by individuals who may have had mild to moderate cases of severe acute respiratory syndrome coronavirus 2 (“COVID-19”) that did not result in hospitalization, including individuals who were asymptomatic. One Survey will be for those without inflammatory conditions while the other Survey will be for those with inflammatory conditions.

Survey participants – like you – are referred to us by our panel partners (such as Dynata).  While our panel partners collect and maintain personal information for their panel members like you, identifiable personal information is not disclosed to The Harris Poll under any circumstances and for any reasons, unless a participant exercises any privacy rights with respect to their personal information (and in such cases it is limited only to the exercise of such rights). This Privacy Policy relates solely to the information collected by The Harris Poll and does not address the information collection and privacy practices of the panel partners.  Please see the applicable privacy policy of the panel provider that referred you for more information on their privacy practices and how they treat your personal information but please note that such other privacy policies will not apply to the information we collect via the Survey as described herein.

The panel partners assign to each participant a unique ID (the “Panel ID”) to confirm your participation in the Survey and to allow such panel partner to deliver your participation incentive. The Harris Poll will delete the Panel ID that is associated with you after you complete of the Survey. The Harris Poll will create its own separate unique ID (the “Harris ID”) when you enter the Survey.  For a brief period of time (e.g. while The Harris Poll is still fielding the Survey generally and inviting respondents – and for up to a few weeks thereafter), both the Panel ID (known only to the panel partner after you complete your survey) and the Harris ID may be in existence and it may be technically possible for your personal information to be associated with your Survey responses. However, Harris will not share the Harris ID with the panel provider and the panel provider will never be provided with your Survey responses.  The panel partners will only be provided the list of Panel IDs corresponding to which panel members completed the survey, which will be used by them to verify who will be paid.

When the Survey is finally closed by The Harris Poll (after completion by all respondents) or at other times as determined by The Harris Poll, The Harris Poll will permanently destroy the Harris ID and generate an anonymous random identifier that will be associated with your Survey responses.  Thus, once The Harris Poll deletes your Harris ID, there will be no way to tie your Survey answers back to you (at such point or at any time in the future) and your specific responses to this Survey will not be associated with your identity.

  1. TYPES OF INFORMATION COLLECTED

We will collect the following types of information in connection with the completion of the Survey:

  • Personal Information. Personal information is information that is identifiable with you. Personal information may include, but is not limited to, your name, date of birth, gender, mailing address, phone number, email address, identification numbers and, in certain circumstances, your opinions and individual preferences. In connection with the Survey, we will ask for personal information consisting of your sex, year of birth, country of citizenship and residence, and other demographic variables. Please note that Survey responses will not include name, social security number, or email address.  While The Harris Poll does not collect personal information that is identifiable directly to you when you complete the Survey, as described in the ICF and in this Privacy Policy, it may be possible for a period of time for your Survey responses to be considered personal information due to the information that the panel provider maintains about you and the fact that the Panel ID and the Harris ID will be concurrently in existence for a period of time and can be connected.
  • Sensitive Information.  Sensitive Information is generally defined as personal information that discloses or reveals health or medical conditions, biometric or genetic data, sexual orientation or sexual life, political opinions/views, race/ethnic origin, religious and philosophical beliefs and trade-union membership.  For purposes of the Survey the Sensitive Information we ask you to provide relates to health or medical conditions.  Specifically, we will ask you about the COVID-19 symptoms you experienced in terms of frequency and intensity, your NSAID use, your general quality of life while you had COVID-19 (such as general health, sleep, fatigue, etc.), and about your pre-existing health conditions.  While The Harris Poll does not collect sensitive information that is identifiable directly to you when you complete the Survey, as described in the ICF and in this Privacy Policy, it may be possible for a period of time for your Survey responses to be considered sensitive information identifiable to you due to the information that the panel provider maintains about you and the fact that the Panel ID and the Harris ID will be concurrently in existence for a period of time and can be connected.
  • Non-personal Information. Non-personal information refers to information that does not by itself identify you. All information and responses you provide in the Survey is non-personal information unless your information and responses are associated with information from the panel provider by connecting the Panel ID and the Harris ID.  After we permanently destroy the Harris ID and replace it with an anonymous identifier, all information you provide in the Survey shall be non-personal information and we will never be able to link it or associate it with you after such time.

You are under no obligation to provide us with personal information or sensitive information of any kind, however your refusal to do so may prevent you from completing the Survey and from earning an incentive reward.

3.  COLLECTION/SOURCES OF INFORMATION

We generally collect information through the following methods:

  • Disclosure by You. We collect any information about you when you voluntarily provide it to us – for example, when you complete the Survey.
  • Automatic Collection / Technical Collection. We may use various other methods to collect certain technical information related to you. Collection of technical information may include (i) IP addresses, and (ii) browser types and user agent strings.  We collect this information to reduce respondent fraud and avoid any duplication of respondents.  Such data is only transiently used by The Harris Poll and is not stored into permanent memory and is not used to identify an individual.
  • Panel Provider. In the event you exercise any of your privacy rights under this Privacy Policy or applicable law, we may receive information from the panel provider that referred you to our Survey.
  1. USE OF YOUR INFORMATION

We may use information you provide or that we collect for the following purposes:

  • Provide the Survey, including allowing you to access and complete the Survey;
  • Respond to your requests, inquiries, comments and concerns;
  • Comply with our legal obligations, resolve disputes, and enforce our agreements; and
  • For the purposes set forth in and as outlined in the ICF, including to provide information to CTC for their commercial use and that of their clients and customers (as also described below).
  1. DISCLOSURE OF YOUR INFORMATION

We may share and disclose your information with third parties, including as follows:

  • CTC and other Survey Partners. We will share information we have collected about you (i.e., the Survey results) with CTC for purposes of enabling CTC to review and analyze the results of the Survey and to prepare reports, tables and graphs relating to the Survey.   However, please note that prior to any data, information or results being sent to CTC, The Harris Poll shall permanently destroy the Harris ID and generate a random identifier that will not be associated with the Harris ID and thus your Survey responses will no longer be able to be associated with you. The Harris Poll shall ensure that such process is performed in such a manner that will be permanent and there shall be no method of reverse engineering or otherwise matching your survey responses with you. The Harris Poll shall perform such actions prior to the transmission of any data being sent to CTC staff in Sweden. Once such actions have been taken, your Survey responses shall be anonymous and CTC will never receive any Survey responses or data that may be identifiable to you.  CTC will use the anonymized data, information and results that we provide for purposes of reviewing and analyzing the Survey results and preparing tables, graphs and reports regarding the same (including “aggregated” tables, graphs, and reports that combine all of the Survey responses received).  CTC will share those results, tables, graphs and reports with its client and such client may provide it to its clients.  Such anonymous or aggregated information may be used for commercial, research or other purposes consistent with applicable law. Please note that for the period of time when the Panel ID and the Harris ID are both in existence, certain privacy rights (as described in the Sections below) may be applicable to certain participants depending on where they live (the “Non-Anonymized Period”).
  • By Law or to Protect Rights. If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.
  • Third­ Party Service Providers. We may share your information with third parties that perform services for us or on our behalf, including hosting the site and infrastructures we use to provide the Survey. We use reasonable efforts to ensure that our subprocessors have privacy and security practices in place to reasonably ensure compliance with applicable privacy law.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Sale or Bankruptcy. If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.
  • You. We will use and share your information as and to extent authorized by you. For example, if you request information that we may have on you.
  1. DATA RETENTION

We will retain your information for as long as needed for the purposes described in this Privacy Policy and in accordance with applicable law.  We will delete all Survey responses and information we collect from you related to the Survey within one month of the date we send all of the Survey data to CTC.  Harris will delete all Survey responses and information we collect from you related to the Survey upon notice from CTC to delete such information which in no event shall be longer than one year from the date that we discontinue fielding the Survey.

  1. THIRD­ PARTY WEBSITES

This Privacy Policy only applies to the Survey and does not apply to the privacy practices of any panel provider that referred you or The Harris Poll’s general privacy practices.  With regard to panel providers or once you leave the Survey, any information you provide to third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. We do not endorse or sponsor any panel partners or other websites, are not responsible for the privacy practices any panel partners or third party sites (or the content on any third party sites), expressly disclaim any statements or assertions made on or by such websites or panel partners, and deny all liability associated with your membership with a panel partner or you use of or the content on such other websites.  Before registering as a member of a panel partner, or visiting and providing any information to any third­ party websites, you should inform yourself of the privacy policies and practices (if any) of the panel partner or third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from our website.

  1. SECURITY OF YOUR INFORMATION

We use administrative, technical, and physical security measures to help protect your information. While we have taken reasonable steps to secure the information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information and you do so at your own risk.

We may store and process information collected via the Survey in the United States and/or we may transfer and export information to Sweden (where CTC is located), or other countries where we or parties involved in the Survey (or our or their respective service providers) have facilities. The data protection laws of other countries may differ from those in the United States.  By participating in this research, you consent to the storage of your information in the United States as well as the transfer of your information to countries outside of the United States. By way of clarification, by voluntarily participating in the Survey and disclosing your information, you expressly consent to the transfer of that information by us to any country where we have facilities or in which we engage service providers and processors, including the United States and Sweden.

  1. POLICY FOR CHILDREN

We do not knowingly solicit information from or market to children under the age of 18. If you become aware of any data we have collected from children under age 18, please contact us using the contact information provided below.

  1. CONTROLS FOR DO ­NOT­ TRACK FEATURES
    Most web browsers and some mobile operating systems include a Do­Not­Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
  1. HOW CAN I ACCESS, CORRECT AND UPDATE PERSONAL INFORMATION?

You can access, correct and update certain information that you have provided to us, if any, by emailing us using the “Contact Us” information below.  Please be aware that we will process your request as quickly as we reasonably can, but it may not be possible to update our systems immediately.

Notwithstanding the foregoing, if your request is received after the Non-Anonymized Period, we may not be able to respond to your request.  This is because once The Harris Poll permanently deletes the Harris ID and creates a random identifier for Survey participants, any survey responses will no longer be capable of being associated with an individual and such survey responses shall be anonymous.  Also, it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.

As described in Section 13 below, California residents may have different or additional rights applicable to their personal information.

  1. CHOICE OF LAW

This Privacy Policy, including all revisions and amendments thereto, is governed by the internal laws of the United States, State of Illinois, without regard to its conflict or choice of law principles which would require application of the laws of another jurisdiction.

  1. CALIFORNIA RESIDENTS; CALIFORNIA CONSUMER PRIVACY ACT

The following provisions apply to residents of California only.  The California Consumer Privacy Act (“CCPA”) grants California residents certain rights regarding the collection of their personal information and imposes various data protection duties on certain entities conducting business in California.

13.1           Categories.  You have the right to receive notice of the categories of personal information we collect, and the purposes for which those categories of personal information will be used.

  • Internet or other similar network activity. We collect the following Internet information that may be personal information: IP addresses and browser and User Agent strings.
  • Identifiers. We do not collect other personal information directly from you but the panel provider that referred you has identifiers such as name, email, address and other information you provided to them. That information will not be shared with The Harris Poll unless you exercise any privacy rights described herein or as required under applicable law.  However, the co-existence of the Panel ID and Harris ID for a certain period of time means it could be possible to link your Survey responses to your Panel ID and it may mean that your Survey responses are personal information under CCPA until the Harris ID is deleted.

13.2           Rights.  In addition, California law gives California residents the right to make the following requests with regard to certain information collected about them, at no charge, two times every 12 months:

  • Disclosure Right.The right to request disclosure of data collection and sales practices, including categories of information collected, the source of the information, use of the information and, if the information was disclosed or sold to third parties, the categories of personal information disclosed or sold to third parties and the categories of third parties to whom such information was disclosed or sold.
  • Copy Right.The right to request a copy of the specific personal information collected about you in the past 12 months.
  • Deletion Right.The right to request deletion of personal information collected about you, subject to certain exemptions (for example, where the information is used to detect security incidents, debugging or to comply with a legal obligation, and where the personal information is being used on an anonymized and aggregated basis consistent with the requirements of the CCPA).
  • Opt-out Right.The right to opt-out of the sale of your personal information, if applicable.
  • Non-discrimination Right.The right not to be discriminated against when exercising any of these rights.

To exercise your rights under the CCPA with respect to your Survey information, please contact Michelle Gosney at (+1) 585-228-5268 or [email protected] and provide information regarding the nature of your request.   We will then use commercially reasonable efforts to connect you with the appropriate Survey-related party (your panel partner, CTC, etc.) to fulfill your request and resolve your concerns or, to the extent permitted by applicable law and our contractual obligations, fulfill and resolve your request ourselves.  However, please note that once the Harris Poll permanently deletes the Harris ID and creates a random identifier for Survey participants, we will not have a way to connect the information you have provided to us back to you and we will no longer have any information that identifies you as an individual  Accordingly, we may unable to resolve your request after the Non-Anonymized Period due to a lack of identifiable information with you.

13.3     Sale of Personal Information.  We do not sell your personal information to any unaffiliated third party but we do share and provide your Survey responses to CTC and otherwise as set forth in this Agreement in connection with the provision of our services to CTC.

13.4     Other Terms.  The other terms of this Privacy Policy, including who we share information with and how we use information apply to California residents as well.

  1. SURVIVAL; APPLICATION

Once the Harris Poll permanently deletes the Harris ID and creates a random identifier for Survey participants, any survey responses will no longer be capable of being associated with an individual and such survey responses shall be anonymous.  As a result, certain rights described in this Privacy Policy (in particular, many of the rights afforded by the CCPA) will only apply during the Non-Anonymized Period, and will cease to apply following the Non-Anonymized Period.  Additionally, please note that this policy only applies to information collected in connection with the Survey.  The Harris Poll also collects information from visitors to its general website.  For more information regarding our privacy practices associated with that information, please see our website privacy policy located at https://nharrisco.wpengine.com/privacy/.

15. ARBITRATION

By participating in the Survey in any way, you unconditionally consent and agree that: (1) any claim, dispute, or controversy (whether in contract, tort, or otherwise) you may have against us and/or our parent, subsidiaries, affiliates and each of their respective members, officers, directors and employees (all such individuals and entities collectively referred to herein as the “Harris Entities”) arising out of, relating to, or connected in any way with the Survey or the determination of the scope or applicability of this agreement to arbitrate, will be resolved exclusively by final and binding arbitration administered by JAMS and conducted before a sole arbitrator in accordance with the rules of JAMS; (2) this arbitration agreement is made pursuant to a transaction involving interstate commerce, and shall be governed by the Federal Arbitration Act (“FAA”), 9 U.S.C. §§ 1-16; (3) the arbitration shall be held in Chicago, Illinois; (4) the arbitrator’s decision shall be controlled by the terms and conditions of this Privacy Policy and any of the other agreements referenced herein that the applicable participant may have entered into in connection with the Site; (5) the arbitrator shall apply Illinois law consistent with the FAA and applicable statutes of limitations, and shall honor claims of privilege recognized at law; (6) there shall be no authority for any claims to be arbitrated on a class or representative basis, arbitration can decide only your and/or the applicable Harris Entity’s individual claims; the arbitrator may not consolidate or join the claims of other persons or parties who may be similarly situated; (7) the arbitrator shall not have the power to award punitive damages against you or any Harris Entity; (8) in the event that the administrative fees and deposits that must be paid to initiate arbitration against any Harris Entity exceed $125 USD, and you are unable (or not required under the rules of JAMS) to pay any fees and deposits that exceed this amount, we agrees to pay them and/or forward them on your behalf, subject to ultimate allocation by the arbitrator.  In addition, if you are able to demonstrate that the costs of arbitration will be prohibitive as compared to the costs of litigation, we will pay as much of your filing and hearing fees in connection with the arbitration as the arbitrator deems necessary to prevent the arbitration from being cost-prohibitive; and (9) with the exception of subpart (6) above, if any part of this arbitration provision is deemed to be invalid, unenforceable or illegal, or otherwise conflicts with the rules of JAMS, then the balance of this arbitration provision shall remain in effect and shall be construed in accordance with its terms as if the invalid, unenforceable, illegal or conflicting provision were not contained herein.  If, however, subpart (6) is found to be invalid, unenforceable or illegal, then the entirety of this Arbitration Provision shall be null and void, and neither you nor us shall be entitled to arbitrate their dispute.  For more information on JAMS and/or the rules of JAMS, visit their website at www.jamsadr.com.

  1. CONTACT US

If you have questions or comments about this Privacy Policy, please contact us at:

Harris Insights & Analytics
1808 ST NW, Fl 6
Washington, DC 20006
Attention:
Michelle Gosney
(+1) 585-228-5268

[email protected]

  1. UPDATES

We reserve the right to make changes to this Privacy Policy, in whole or in part, at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy  at the same URL as which this is posted, and you waive the right to receive specific notice of each such change or modification.  You are encouraged to save the URL to this privacy policy periodically review this Privacy Policy to stay informed of updates.

[email protected]