BERA.ai Privacy Policy for Survey Respondents

Additional Privacy Notice for California Residents

This Additional Privacy Notice for California Residents applies solely to all clients, visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. 

The CCPA grants rights to California consumers as follows:

• The right to know what Personal Information is collected, used, shared, or sold, both as to the categories and specific pieces of Personal Information; 

• The right to delete Personal Information held by businesses and by extension, a business’ service provider; 

• The right to opt-out of sale of personal information; and

• The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA.

The data we collect through Surveys is not subject to CCPA because it is de-identified aggregate data. In other words, we do not hold the requisite information to link this data to a specific person.

Information We Collect

We collect Personal Information via our Website, but not through our Surveys. In particular, we, through our Website, have collected the following categories of Personal Information from our consumers within the last twelve (12) months: 

• Identifiers – names, aliases, postal addresses, telephone and mobile phone numbers, and email addresses.

• Internet or other similar network activity – Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

We collect this information both from our clients and visitors to our Website.

Personal Information does not include:

• Publicly available information from government records.

• De-identified or aggregated consumer information.

• Information excluded from the CCPA’s scope, like:

• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete.

• Indirectly from you. For example, from reports of your activity on our Website.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes: 

• To provide our services and our Website to you if you are a client or fulfill any purpose for which you provide it.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To notify you about changes to our Website or services we offer if you are a client or in response to a request for information on the services we provide.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website’ users is among the assets transferred. 

We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

We may also use your information to contact you about our own services that may be of interest to you. If you do not want us to use your information in this way, please email us at privacy@bera.ai.

Your Rights and Choices 

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of Personal Information we collected about you.

• The categories of sources for the Personal Information we collected about you.

• Our business or commercial purpose for collecting that Personal Information.

• The categories of third parties with whom we share that Personal Information.

• The specific pieces of Personal Information we collected about you (also called a data portability request).

• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:

• sales, identifying the Personal Information categories that each category of recipient purchased; and 

• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. 

Deletion Request Rights 

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by: 

• Emailing us at privacy@bera.ai; or

• Sending a letter to BERA.ai LLC at 225 W Wacker Dr, Suite 1900, Chicago, IL 60606.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. 

Making a verifiable consumer request does not require you to create an account with us. 

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within thirty (30) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Policy

It is our policy to accompany any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the home pages of the Website. If we make material changes to how we treat Personal Information, we will notify you by email to the primary email address specified in your account if you are a client and/or through a notice on the Website’ home pages. The date the Privacy Policy was last revised is identified at the top of the page. Clients are responsible for for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@bera.ai.

FOR CALIFORNIA, VIRGINIA, CONNECTICUT, COLORADO AND UTAH RESIDENTS:

Your Rights

Residents of certain states, notably California, Virginia, Connecticut, Colorado, and Utah, have certain rights found under those states’ laws.  Many of those rights are parallel to the rights already described above, but BERA wishes to reiterate those laws specifically for these states.  You can contact BERA to exercise the rights described below with respect to certain personal information that BERA might hold. To the extent those rights apply to you, they are described below. BERA also handles certain personal information it might receive from BERA contractors.  For the most part, this information has been “de-identified”, as stated above, but to the extent it remains personal information as defined by applicable laws, the information in this Privacy Policy pertains to that information as well.

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide you with details about the personal information we collect, use, disclose and sell. You can submit a verifiable consumer request by emailing BERA at privacy@bera.ai., or you can also submit your request via our toll-free number (866) 775-2372.  BERA reserves the right to verify your identity to our satisfaction.

You are entitled to receive the following:

• The categories of your personal information that BERA has collected in the preceding 12 months

• The categories of sources from which that information was collected

• The business/commercial purpose for the collection or selling

• The categories of third parties with whom BERA shares personal information

• The specific pieces of personal information BERA has collected about you (subject to some exceptions)

BERA does not sell or disclose (as those words are defined in the Applicable Law) personal information to third parties.  Any personal information used by BERA in reports to BERA customers is de-identified before those customers receive it.  In fact, those customer reports are an amalgamation of all responses received from individuals to surveys by BERA or its contractors, and thus customers do not receive any information about individuals or their personal information.    

Right to Request Deletion of Personal Information

Because BERA does not retain personal information, BERA is not able to delete personal information, for the simple reason that BERA would have no way of connecting any data in its possession to an individual requesting deletion.  However, if an individual believes that a third party contracted by BERA to undertake surveys has failed to respond adequately to that individual’s request to delete personal information, please submit your request as described above, and we reserve the right to conduct the verification described above.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive unlawful discriminatory treatment by BERA for the exercise of your privacy rights under the Applicable Law.

Right to Opt-Out of Sale of Personal Information or to Limit the Use and Disclosure of Sensitive Personal Information

To the extent that BERA might have your personal information either as a result of its activities or those of its contractors, you have the right to opt-out of the sale of your personal information or to limit the use and disclosure of sensitive personal information by or to BERA. You can submit a verifiable consumer as described above.  Again, BERA does not retain personal information and in fact de-identifies any personal information it has, so be aware that BERA might respond that it is not selling your personal information or disclosing it.

List of Categories of Personal Information to be Collected and May Have Been Sold or Disclosed

Categories of Personal Information Collected

BERA collects personal information from research participants during and after registration with a panel, including, without limitation, during participation in a survey and in connection with the receipt and redemption of rewards and incentives and/or during the Application/Services registration and download process.

The categories of personal information we may collect include:

• Behavioral information related to brand perceptions and purchasing habits

• Professional or employment-related information, including occupation

• Education information

• Characteristics of potentially protected classifications under California, federal or international law (e.g., health and medical conditions, sexual orientation or sexual life, political opinions/views, race/ethnic origin, gender, religious and philosophical beliefs and trade-union membership)

• Demographic information

• “Sensitive personal information” as defined by Applicable Law

All of the information above was collected for the purposes described here. In Applicable Law terms, these purposes, which are described further in that section of our Privacy Policy, include but are not limited to the following examples:

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with the Applicable Law and other standards;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

• Debugging to identify and repair errors that impair existing intended functionality;

• Short-term, transient uses;

• Performing or using services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing or using advertising or marketing services, providing or using analytic services, or providing or using similar services;

• Undertaking internal research for technological development and demonstration;

• Undertaking activities to verify or maintain the quality or safety of services and devices, and to improve, upgrade, or enhance services and devices; and

• Facilitating the operational purposes of BERA or our service providers.

Categories of Personal Information that May Have Been Sold

BERA sold all of the above categories of personal information in the last 12 months.

Categories of Personal Information that Were Disclosed

BERA disclosed all of the above categories of personal information in the last 12 months.

Categories of Third Parties with whom Personal Information may have been Shared

BERA shares information, which is deidentified or not considered Personal Information under law, with third party unaffiliated businesses to provide additional functionalities to its customers.  The following categories of third parties are engaged for these services:

Audience Activation Providers

Who can I contact with questions about this Policy?

If you wish to:

– receive a copy of the information we hold about you;

– communicate an opt-out request to BERA;

– request access to, or the correction, blocking or deletion of, your personal data;

– make a complaint about our privacy practice;

– appeal an action we take with regard to a consumer request

– opt out of certain uses of your PII;

or have any questions regarding BERA’s privacy practices and/or this Policy, please contact us via email at privacy@BERA.ai

BERA’s IT Department is responsible for BERA’s compliance with this Policy.

Are there any companies within the BERA Group that may collect, store and process PII?

No.  BERA does not have any affiliates or subsidiaries.