Effective Date: February 15, 2024

Notice for California and Virginia residents: In this Privacy Policy, we describe the categories of personal information we collect directly from you, and the business or commercial purposes for which we may use and share that information.

This Privacy Policy (the “Policy”) describes how Emerald Research Group. and its affiliates, including The Stagwell Group (collectively, “Emerald”, “we” “our” or “us”) collect, use, and share personal information about you (“you” “your”) and the choices that are available to you with respect to our handling of such personal information. We at the Emerald care deeply about privacy and strive to ensure that we process personal information about you responsibly and honor your privacy choices.

In this Policy, we use the term “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. This Policy applies to personal information that we collect or receive (A) when you interact with us online (for example, through our website at nationalresearchgroup.com or other online properties that link to this Policy (individually, a “Site” and collectively, the “Sites”), through surveys we administer, or through emails we send or receive from you), or (B) offline (for example, over the phone, in person, when you visit our premises, participate in focus groups, or attend film screening events. This Policy also applies to personal information we collect from third parties, although it does not apply to the information collection, use, or sharing practices of companies we do not control.

We may update this Policy from time to time to reflect changes in our business practices, to make clarifications, or for other legal reasons. We will inform you of these changes by including a “last updated” date on this page. In some cases, we may inform you directly of these changes by sending you an email (if we have your email address), or by posting a notice on our homepage. We encourage you to check this page from time to time to remain updated on any such changes.

1. What does Emerald Research Group do?
Emerald Research Group is a full-service market research consultancy. We conduct a wide variety of market research, including through surveys, interviews, and other methods, and we use that research to advise advertisers and marketers (our “Customers”) on how to more effectively engage with their audiences and provide related products and services to our Customers (we refer to all of these activities collectively as the “Services” we offer to our Customers). When we do that, we may provide those Customer with personal information, including personal information related to you.
 
2. What kind of personal information do we collect, and how do we collect it?
In order to provide our Services, we collect personal information, using different methods and sources, which are described in detail below.

1. Personal information that you provide directly to us. If you choose to participate in our research projects (including, but not limited to our surveys, focus groups, online communities, in-depth interviews, ethnographies, screenings, etc.); visit our premises; register for our screenings database; to provide your email or contact us by email; apply for a job; or otherwise communicate or interact with us, we collect the information you provide when taking those actions. This may include:

• Your first and last name
• Your contact information, such as your email address, telephone number, or physical address
• Demographic information, including but not limited to your sex, gender, age, ethnicity, nationality, income, location, marital status, parental status, etc.
• Education information, such as your level of educational attainment, schools attended, etc.
• Professional information, such as your employment status, professional field, occupation, title, and other similar information.
• Information about other members of your household, when you choose to provide it to us.
• If you visit our premises, your likeness via CCTV (which may be subject to certain other consents and agreements between you and us).
• Images you may choose to upload and share with us through a survey or our Sites.
• When you agree to participate in a passive metering study, information about your use of a digital device.
• When you agree to it as part of participating in an interview or focus group, video recordings of those events, which we may further analyze to collect information about eye movements and facial expressions to understand the attention and effect of participants.
• Any other information you choose to provide to us (for example, information you provide about your characteristics, interests, or attitudes when responding to a survey).

2. We collect information automatically from your web browser or other internet-connected device. When you interact with us through our Sites; through online surveys we administer; or through emails we send to or receive from you, we may collect certain information automatically using technologies such as pixels, web beacons, local storage, JavaScript, Software Development Kits (SDKs), Application Programming Interfaces (APIs), and other similar technologies. Some of these technologies (such as cookies) involve storing unique identifiers or other information on your browser or device for later use. If we (or our service providers) begin using other similar technologies, we may also gather information using those methods. The information we collect or may collect this way includes:

• Online identifiers, such as IP address, cookie IDs, mobile advertising IDs (“MAIDs”, e.g., IDFAs from iOS devices or Advertising IDs from Android devices), hashed email address or other hashed IDs, or other similar device or online identifiers.
• Information about the browser or device you are using, including operating system, device type, system activity and settings, and information about your internet connection.
• General geographic location (for example, the city or state in which you are located, which may be inferred from IP address)
• Internet and app-usage data, including date/time stamps associated with the use of particular websites or apps, and patterns of user activity within websites or apps (including, for example, search terms input and app or site features used)

3. We collect information that is provided to us by third parties. Third parties (such as other companies) that have collected personal information about you may also share that information with us. The types of personal information we collect from third parties may include:

• Your first and last name
• Your contact information, such as your email address, telephone number, or physical address
• Demographic information, including but not limited to your sex, gender, age, ethnicity, nationality, income, etc.
• Education information, such as your level of educational attainment, schools attended, etc.
• Professional information, such as your professional field, occupation, title, and other similar information.
• Online identifiers, such as IP address, cookie IDs, mobile advertising IDs (e.g., IDFAs from iOS devices or Advertising IDs from Android devices), television or OTT IDs, hashed email address or other hashed IDs, or other similar device or online identifiers.
• Information about the media you view (for example, on the web, in mobile apps, or on TVs), and how you interact with it.
• Location information (for example, point-of-interest visits inferred from your mobile device’s location services through the use of technologies such as GPS, Wi-Fi, and Bluetooth).
• Information about your consumer behavior (including for example, shopping and purchase data).
• Information about your inferred or self-reported interests.

The collection, use, and sharing of personal information by third parties is governed by their privacy policies, not this Policy. We have no control of, and assume no liability for, the privacy practices of third parties.

3. How do we use the information we collect?
We use the information we collect to provide our Services, for our internal business purposes, and as required or permitted by law, including:

• Inviting you to participate in research projects
• To communicate with you, including to contact you with follow-up questions from past research projects, or to provide information you request
• Analyzing data obtained during research projects for market research and advertising purposes
• Paying out incentives for participating in research projects
• To combine and analyze information we collect from different sources (including from our affiliates and unaffiliated third parties)
• To generate inferences about your consumer interests and behaviors, and to create consumer profiles and audience segments based on those inferences
• To create links between and among different web browsers, mobile devices, or other internet-connected devices you use, or that are used in your household
• For our own advertising and marketing purposes
• To maintain, provide, operate, and improve our website and our Services
• To create aggregated or de-identified information
• Cooperating with law enforcement
• Complying with and enforcing applicable legal obligations
• Responding to legitimate governmental requests
• Providing customer support and responding to your requests
• Authenticating your identity
• Maintaining the safety and security of our Sites; our Services; and our physical premises

We may link various types of information and identifiers we collect with others, or with information we obtain from vendors. For instance, we may link IP addresses or cookie identifiers with hashed email identifiers, or other information (whether derived offline or online, whether identified or deidentified): when we do this, we may use various hashing methods to protect consumer privacy. We may also work with vendors and third parties (including data platforms and aggregators) to link our identifiers with theirs, or use our individual or combined data to identify users across multiple devices or channels – for example, to help “find” a user on a device or browser based on an IP address or hashed email identifier.

4. Who do we share your personal information with, and why?
We may share the personal information we collect with the following categories of recipients, and in the following circumstances. In certain circumstances, these activities may qualify as “sales” of personal information under the California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). California and Virginia residents can learn more about their privacy rights and opt out of “sales” by going to Section 8.E of this Policy:

• At your direction: If you direct us to share information you provide with a third party (such as our service providers, vendors, or Customers) in order to provide our Services, to provide an incentive to you for completing a survey, or for other purposes you agree to, we will share the information you provide as directed and with your consent.
• With our affiliates: We may share the information collected with our affiliates in order to assist us with providing the Services or for their own business purposes.
• With our vendors or service providers: We may share information with our third-party vendors and service providers to assist us in providing or improving the Sites and Services (including, but not limited to panel management companies, qualitative or quantitative research vendors, survey programming vendors, open-ended coding vendors, technology companies, and data processing companies).
• With Our Customers: We may disclose information to our Customers for marketing, advertising, and research purposes (whether for their own products or for other marketing purposes and services they may provide).
• Corporate Transactions. We may disclose your personal information for purposes of evaluating or entering into a transaction where all or a portion of our business or assets change ownership, are sold, or are transferred, including for purposes of due diligence leading up to such a transaction.
• For legal purposes: We may disclose information we collect in connection with legal investigation; in order to comply with laws or to respond to legal process (e.g., valid subpoenas or warrants); to protect or defend our rights or property, Site users, Service users, our Customers; or to investigate or assist in preventing any violation or potential violation of the law, this Policy, or any associated terms of use.

5. Your Choices

We provide several ways for you to exercise control over how we and certain third parties use information about you, described below.

Opting out of personalized advertising.
The information we collect through for use with our Sites and Services may be used to customize the advertisements you see online based on your interests. For example, audience segments we create for our Customers, based on information we collect, may be used to select advertisements that are more tailored or “targeted” to consumers’ likely interests. This is sometimes called “interest-based” advertising. You can control how information about you is used for these purposes as follows:

On the web.

• Interest-based advertising opt out. To learn more about this type of advertising or to opt out of participating companies, please visit the Digital Advertising Alliance’s opt-out program at https://www.aboutads.info/. (We make no representation about the accuracy or effectiveness of this opt out mechanism, as it is operated by third parties, through an industry consortium.)
• Browser settings. Some digital advertising is carried out using cookies. You may be able to adjust your browser settings to refuse or to allow certain types of cookies, or to notify you when they are being used. Some browsers offer similar settings for HTML5 local storage and other technologies. Please consult the “Help” section of your browser for more information. However, if you block or otherwise reject cookies or other similar technologies, certain websites (including our Sites) may not function as expected. Because we and third parties may use non-cookie technologies with your browser or device, browser settings that block cookies used in isolation may not affect the functioning of those technologies.

On mobile devices.

You can adjust your mobile device settings to control how your device collects and shares your device’s MAID for advertising purposes, in particular, for behavioral or “cross-app” advertising. We honor opt outs on mobile devices by removing opted-out devices from advertising segments we may share with our Partners or Customers for interest-based advertising on a going-forward basis. Depending on the kind of mobile device you use, you may adjust your device settings to avoid interest-based advertising. Please visit the Network Advertising Initiatives “mobile choices” page to learn about your various choices regarding this type of advertising and data usage: https://www.networkadvertising.org/mobile-choice/.

Note that adjusting the settings on your mobile device or browser, or opting out of interest-based advertising using your web browser, may have different results depending on factors including the type of device you are using, the type of web browser you are using, and the version of the device operating system you are running. Opting out of interest-based advertising alone generally will not prevent you from seeing advertising online; it is simply less likely that the ads you see will use data to tailor the ads you see to your interests. Opting out is generally effective only on a device-by-device, or browser-by-browser basis. If you use more than one browser or device, the effect of any opt-out mechanism you use may be limited to the device on which you used it.

Email Marketing
You may opt out of or unsubscribe from our marketing emails using the links provided in the footer of those emails

Your Consent
When you provide information to us through your participation in our surveys or other studies, we use and share that information in reliance on your direction and consent. However, you are not required to provide consent and can withhold it if you do not wish to participate. While there is no penalty for withholding your consent, you will not be able to participate in any Emerald studies/surveys unless we have your consent. We nonetheless may permit you to withdraw consent at any time and request that your information be deleted (or subject to do “do not sell” request) in accordance with applicable law. We will not discriminate against your for refusing to provide consent, withdrawing consent or exercising any rights under this Policy.

6. How long do we keep personal information?
We generally retain personal information we collect under this Policy for as long as is required for the purposes set forth in this Policy, or the purposes for which it was collected, unless a longer retention period is required for us to meet our legal obligations.

7. Do we collect personal information from children?
Emerald Research Group does not seek to collect data from children under 13 years old without explicit parental consent. If you are under the age of 18 (and 16 in certain jurisdictions), you must have your parent or guardian’s explicit consent in order to participate in any of our studies or surveys. If you are a parent and guardian and you learn that your child has provided us with their information without your consent, please contact us.

8. I am a California and Virginia resident. What are my rights with respect to my personal information?
In addition to the other rights described in this Policy, California and Virginia residents are also entitled to certain rights under the California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”) with respect to their personal information. If you are a resident of California or Virginia (a “Consumer” as defined by the CCPA and VCDPA), this section of the Policy applies to you. If you are not a Consumer, this section does not apply to you and you should not rely on it.

The Right to Access
Consumers have the right to request certain details about the personal information we have collected about them (generally, within the past 12 months). Specifically, Consumers have the right to request that we provide them with:

• the specific pieces of personal information and the categories of personal information that we have collected about them
• what categories of the personal information we sold or disclosed for business purposes; and the categories of third parties to whom we sold or disclosed that information for a business purpose
• the categories of sources from which we collected personal information
• categories of third parties with whom we have shared personal information.

The Right to Deletion
Consumers have the right to request that we delete the personal information we have collected from them. In certain circumstances, however, the CCPA and VCDPA allow us to retain information for particular purposes (for example, if we need to retain the information to meet our legal obligations, and for certain other limited reasons set forth by the CCPA and VCDPA).

How to Exercise Access and Deletion Rights
Consumers may submit requests for access to or deletion of their personal information using any of the following methods:

• Call the following number and leave a message: 585-236-8759
• Email your request to privacy.inquiries@harrisinsights.com

For security purposes, we will attempt to verify your identity prior to fulfilling your request. To verify your identity, we may need to respond or otherwise contact you to request additional information from you (including, but not limited to your name, email address, and mobile advertising ID).

If we are able to verify your identity, we will respond to your request to the extent we are able to and as required by law. If we cannot verify your identity, we may request additional information from you or we may deny your request. If we are unable to fulfill your request(s) in their entirety, we will provide further information to you about the reasons that we could not comply with your request.

The right to nondiscrimination.
Consumers have the right not to be discriminated against for exercising their CCPA rights. We will not deny, charge different prices for, or provide a different level of quality of goods or services with respect to consumers who choose to exercise their CCPA rights.

The Right to Opt Out of Sales of Personal Information
Consumers have the right to opt out of “sales” of their personal information under the CCPA. According to the CCPA, and subject to certain exceptions, a business “sells” personal information when it sells, rents, releases, discloses, disseminates, makes available, transfers, or otherwise communicates orally, in writing, or by electronic or other means, a consumer’s personal information to another business or a third party for monetary or other valuable consideration.

Consumers may submit requests to opt out of sales of their personal information using any of the following methods

• Call the following number and leave a message: 585-236-8759
• Email your request to privacy.inquiries@harrisinsights.com

Authorized Agents
Consumers may designate an agent to make CCPA requests on their behalf. For Consumers who do so, we will take steps to verify both the identity of the consumer seeking to exercise their rights as described above, and to verify that the consumer’s agent has been authorized by them to make a request on their behalf by requesting a signed written authorization or a copy of a power of attorney.

9. I am a resident of the European Economic Area (“EEA”), Switzerland, or the UK. What are my rights with respect to my personal information?

GDPR Information: For residents of the European Union, the United Kingdom, and EEA Countries

We provide this notice in order to comply with particular obligations of the General Data Protection Regulation (GDPR) and similar laws, and to provide you information about our legal bases for processing personal data, and how we comply with data subject rights. We encourage you to review the entirety of the Privacy Policy to learn more about how we process data and what choices you may have.

a. Our Legal Bases for Use of Your Information
Under applicable law (for instance, the GDPR, and other laws that adhere to this distinction), Emerald Research Group is considered the “data controller” of the personal data we handle under the Emerald Research Group Poll’s Privacy Policy. In other words, The Emerald Research Group Poll (“Emerald Research Group” “we” “our”) is responsible for deciding how to collect, use and disclose this data, subject to applicable law. Our contact information appears at the end of this GDPR Notice. Certain terms we use here, such as our “Services,” are defined in our Privacy Policy.
European privacy laws require data controllers to inform you about the legal ground or grounds (also referred to as a “legal basis”) that they rely on for using, sharing, or disclosing of your information. To the extent those laws (or other similar laws) apply, our legal grounds are as follows:

• Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to or with you.
• With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent (and if “special categories” or sensitive data is being collected, such as but not limited to information about your health, political views, ethnicity, or religion, “explicit” consent). For instance, when we collect your information via a survey, we may ask you to consent to its use by us or our customers.
• Legitimate Interests: In certain cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Services, preventing fraud, for our billing and records purposes, and managing legal issues.
• Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

b. Our data retention policies:
We reserve the right to retain your personal data so long as we have a legitimate reason (and a legal basis) for it, or until you request its deletion in writing. However, we will not retain personal data in a form which permits identification of data subjects for longer than is necessary for the purpose for which the personal data are processed. We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. This does not apply to anonymised data. We have policies in line with ISO 20252 as to the maximum retention periods for personal data, but seek to reduce such retention periods whenever possible.

c. Your Rights and Choices Under the GDPR and Similar National Privacy Laws
If you are a European resident, or a resident of a country that grants similar privacy rights, you may have certain rights and choices with respect to your information such as:

• Marketing Communications: If we send emails or similar marketing communications, you may ask us to stop. You can decline promotional communications at the point information is requested or, by following the unsubscribe instructions on communications sent to you. You can also contact us as described in the “How to Contact Us With Privacy Inquiries” section below.
• Cookies & Analytics: You can opt out of certain cookie-related and analytics processing by following the instructions in Section 5 of our Privacy Policy, titled “Your Choices.” For instance, when you visit the Emerald Research Group website (such as to consider a business relationship with us), we may work with service providers who place cookies on your browser, in order to retarget you with ads or information about our Services.

d. Additional Legal Rights Under European and Other National Privacy Laws
European (and certain other national) privacy laws also generally permit you to request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
• update information which is out of date or incorrect;
• delete certain information that we are holding about you;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third-party provider of services; and
• revoke your consent for the processing of your information.

Please note, however, that to the extent you have such rights, certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may in our sole discretion reject requests if we are not required by law to respond, or if we deem such request to be unreasonable or impractical, such as if it would require disproportionate technological effort or expose us to operational risks. We also may request you provide us with information necessary to verify or confirm your identity before responding to your request.

To request to exercise any of these rights, please contact us as described in the “How to Contact Us” section below. In addition to those rights, if you are a European resident you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

e. Notice to residents of jurisdictions outside of the United States
We operate our Services in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to, stored in and/or accessed within the United States. The recipients of information described in the relevant “How We Share Information” sections above may be located in the United States. This information may be subject to United States law, including laws that may require disclosure of personal information to government authorities. We may rely on Standard Contractual Clauses (the “SCCs”), set forth here (or in some cases the IDTA and Addendums, set forth here, as to transfers from the United Kingdom) in order to effectuate transfers of personal data from European nations into the United States.

f. How to Contact Us With Privacy Inquiries

Emerald Research Group
2311 Wilson Blvd #300
Arlington, VA 22209
United States

Data Protection Officer (DPO)
David Hazelden
David.Hazelden@stagwellgtg.com

For more Information about our DPO: please click here.

10. What security measures do we take?
To help ensure that we process your data accurately, maintain its confidentiality, and only collect the data we need to achieve our purposes, we use administrative, organizational, technical, and physical safeguards. While no data protection methods are 100% secure, we commit to treating your personal information with care and integrity.

11. How to Contact Us
If you have any questions, concerns or requests in relation to this Privacy Policy, please contact us using the contact details below:

Privacy Officer
Emerald Research Group
957 Panorama Trail S.
Suite 190
Rochester, NY 14625