IMUR Questionnaire System Privacy Policy

Last Updated: 2021.01.15

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Survey?

Survey Data: If you are a Creator, you are the data controller of the personal information collected in a Survey. More Information.

Non-Survey Data: We process Non-Survey Data if you register an account or use the Service (except where you provide Survey Data as a Respondent). We are the data controller for Non-Survey Data.

If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?

Survey Data: We process Survey Data on a Creator’s behalf and on their instructions in order to enable a Respondent participate in a Survey. More Information.

Non-Survey Data: We use the information a Creator or Respondent provides to create an account and to provide the Services. More Information.

Who do we share your information with?

We do not share personal information with any third parties, except where we are instructed to by the Creator, a court, authority or compelled by law. More Information.

Where do we process your information?

Our servers are located in Singapore. Our support, engineering and other teams are located in our offices around the world. More Information.

How long do we keep hold of your information?

Survey Data: We retain Survey Data for one year, unless otherwise requested by the Creator. More Information.

Non-Survey DataWe retain such information for the lifetime of the Service (i.e. until account deletion), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. To exercise your rights as a Respondent in relation to Survey Data, please contact the Creator. Where we are the Creator, you may contact us here. More Information.

How to get in touch with us

If you want to exercise any rights you may have in relation to a Survey you participated in as a Respondent or Survey Data, please contact the Creator directly, who is the data controller.

If you have any questions about anything in this privacy policy, or want to exercise any rights you may have in relation to Non-Survey Data, please contact us here. How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the policy here. More Information.

Contact Information

EU Representative: Tencent International Service Europe B.V. | Email: eudataprotection@tencent.com

Turkey Representative: Özdağıstanli Ekici Avukatlık Ortaklığı. | Email: tencent@iptech-legal.com (Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorized for any other matters such as in-Game/Service conduct, bans, investigations, civil or criminal complaints.

Korea Representative: Tencent Korea Yuhan Hoesa |Email: DPO_imursurvey@weisurvey.com

Welcome to the IMUR Survey!

This privacy policy explains the when, how and why when it comes to the processing of personal information in connection with a survey (each, a “Survey”) created by a Creator on our service (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and do not participate in a Survey. Where applicable, by participating in the Survey you are accepting our rules regarding your personal information as described in this privacy policy.

Survey Data

The Creator is the data controller in respect of Survey Data. We process such Survey Data on the Creator’s behalf and upon Creator’s instructions. For more information, please see our Data Processing Agreement here.

Please contact the relevant Creator directly if you (as a Respondent) have any questions or concerns regarding the collection and processing of Survey Data.

Non-Survey Data

This Service is operated by Proxima Beta Pte. Limited (“we”, “us”, “our”). We are the entity that will be offering the Service to you and for the purpose of EU data protection laws, we are the data controller in respect of Non-Survey Data .

Proxima Beta Pte. Limited is a company registered in Singapore with its office located at 10 Anson Road #21-07 International Plaza, Singapore (079903). Our data protection officer can be contacted at DPO_imursurvey@weisurvey.com.

Our representatives in certain jurisdictions are as follows:

EU Tencent International Service Europe B.V Gustav Mahlerplein 2, 1082 MA, Amsterdam, the Netherlands eudataprotection@tencent.com
Korea Tencent Korea Yuhan Hoesa 152, Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea DPO_imursurvey@weisurvey.com
Turkey Özdağıstanli Ekici Avukatlık Ortaklığı. Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey tencent@iptech-legal.com

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at DPO_imursurvey@weisurvey.com.

The Types of Personal Information We Use

This section describes the different types of personal information collected from Respondents and Creators and how they are collected. If you would like to know more about specific types of data and how that data is used, please see the section entitled “How We Use Your Personal Information” below.

The following is a high level summary of the types of personal information we process:

1) Survey Data (Information Respondent provides Creator directly as part of the Survey)

Creator is the data controller and we are the data processor in respect of such Survey Data.

2) Non-Survey Data (Information we collect when Respondent uses the Service)

We act as the data controller in respect of such Device Data and Account Registration Information.

Creator is the data controller and we are the data processor in respect of such Device Data (App).

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Survey, to which you may be directed if you use the Survey’s customer support features. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Survey (or part of the Survey) may be unable to operate as designed.

For more information about our Cookies policy, click here.

Children

The Service is not intended for children. Children must not use the Service or participate in a Survey. By children, we mean users under the age of 16 years old; or in the case of users located in the countries specified below, the relevant minimum age.

If you are over the age of 16 years old but under the relevant minimum age stipulated below for the country where you are located, you need the consent of your parent or guardian before using the Service.

Country/region Minimum age
European Economic Area, United Kingdom, Switzerland 16
USA 16
Korea 14
Japan 20
Thailand 20
Indonesia 21
Vietnam 16
India 18
Brazil 18
Russia 14
Turkey 18

We do not knowingly collect personal information from children under these ages for any purpose without the consent of a parent or guardian. If you believe that we have personal information of a child under this age, please contact us and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information collected from you, and why. For users who live in the European Economic Area, United Kingdom, Switzerland, Thailand, Turkey or Brazil (“Relevant Jurisdictions”), it also identifies the legal basis under which we process your data.

Personal Information Use Legal Basis (only relevant if you are located in a Relevant Jurisdiction)
Survey Data
Information Respondent provides to Creator as part of the Survey
Response Information: the data contained in Respondent’s responses to the Survey, which may include Respondent’s gender, age (or age range), year of birth, country or region of residency, income, education, occupation, phone number, email address, nickname, WeChat ID, QQ ID and any other information which Respondent chooses to provide in a Survey.

We process this information on behalf of Creator’s instructions to enable Respondent to participate in the Survey.

Where we act as the Creator, we may also use this information to contact Respondent for follow up queries regarding Respondent’s responses

We process this data with Respondent’s consent.
Non-Survey Data
Information we collect during the use of the Service
Device data:browser information and user agent information such as IP address, browser version, device settings and operating system version. We use this information to deliver the Survey to your particular device, with relevant localisation/languages, and to improve our services. It is in our legitimate interest to ensure the Survey is made available to Respondents and Creators in an efficient and error-free manner.
Device data (App): User ID and Open ID We use this information to deliver the Survey to your device in association with the linked app in accordance with your request. Necessary to perform our contract with Respondents to provide the Service via a linked app.
Account Registration data: email address, company name (if applicable), user name, password and account settings We use this information to create an account for the Service in accordance with your request. Necessary to perform our contract with Respondents and Creators to provide the Service.

How We Store and Share Your Personal Information

We operate around the world. Pursuant to our contract with you to provide you with the Service, personal information will be processed on servers that may not be located where you live. If you are a Creator, please see our Data Processing Agreement here for the terms on how we may process personal information on your behalf and upon your instructions. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers used for the storage of personal information are located in Singapore.

Our support, engineering and other teams are located in our offices around the world, including Singapore.

Only where necessary will we share personal information with third parties. Situations where this occur are:

o comply with a legal obligation, process or request;

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

We may provide links to and from the websites and/or applications of our partners and affiliates. If you follow a link to any of these websites, please note that these websites and/or applications have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites and/or applications. Your acceptance or consent to this privacy policy does not cover your acceptance or consent to any other privacy policies.

Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information* Retention Policy

Survey Data: Response Information

Non-Survey Data: Device Data (App)

Stored for one year unless otherwise instructed by the Creator, after which it will be deleted.

If Respondent would like to request deletion of this data prior to such date, please contact the relevant Creator directly.

Non-Survey Data:

• Device Data

• Account Registration data

Stored for the lifetime of the Service (i.e. until account deletion in accordance with your request, after which it will be deleted immediately).

Please see the section above titled “How We Use Your Personal Information” for a full description of each category of data.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rights

Survey Data

In relation to Survey Data, please contact the relevant Creator directly, who is the data controller, for more information on Respondent’s data subject rights.

Where we act as the Creator, you may contact us at DPO_imursurvey@weisurvey.com.

Non-Survey Data

Some jurisdictions’ laws grant specific rights to users of this Survey, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the Relevant Jurisdictions. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Brazil, Canada and Russia.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though where applicable law permits, this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at DPO_imursurvey@weisurvey.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any personal information about you, please contact us at DPO_imursurvey@weisurvey.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at DPO_imursurvey@weisurvey.com.

Erasure

If there is any personal information you believe we process that you would like us to erase, please contact us at DPO_imursurvey@weisurvey.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at DPO_imursurvey@weisurvey.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at DPO_imursurvey@weisurvey.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend Surveys for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Contact & Complaints

Survey Data

Please contact the relevant Creator directly, who is the data controller, for any questions, comments and requests regarding Survey Data.

Where we act as the Creator, you may contact us at DPO_imursurvey@weisurvey.com.

Non-Survey Data

Questions, comments and requests regarding this policy are welcomed and should be addressed to DPO_imursurvey@weisurvey.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at DPO_imursurvey@weisurvey.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy, we will post the updated privacy policy here. Please check this page frequently to see any updates or changes to this privacy policy.

Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this privacy policy, the English version shall prevail.

SUPPLEMENTAL TERMS FOR USERS IN CERTAIN JURISDICTIONS

Some countries’ laws contain additional terms for users participating in a Survey, which are set out in this section.

If you are a user located in one of the countries listed below, then the terms set out below under the name of your country apply to you.

Brazil

This section applies to users located in Brazil:

Consent Revocation

Whenever we use your personal information based on your consent, you may revoke consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact DPO_imursurvey@weisurvey.com. This may affect our provision of the Service to you.

Parental and Guardian Consent

If you are under the age of 18, you should not use the Service for any purpose without first obtaining parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact our Data Protection Officer if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at DPO_imursurvey@weisurvey.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

India

Sensitive Personal Information

Your Sensitive Personal Information shall mean passwords, financial information such as bank account or credit card or debit card or other payment instrument details, biometric data, physical or mental health, sex life or sexual orientation, and/ or medical records or history, and similar information, but does not include information available in the public domain, or provided under Indian laws, including the Right to Information Act, 2005.

Sharing of your Personal Information

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

Age Restrictions

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parental consent is required for children under the age of 18 years to avail our services.

Withdrawal Of Consent

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at DPO_imursurvey@weisurvey.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Indonesia

Consent

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your Information in accordance with this privacy policy, as revised from time to time. If you do not agree to this privacy policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to participate in a Survey.

Data Subject Rights

You have the right to access, update, correct and request for erasure of personal information provided as part of a Survey from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information, we will notify you through the contact information provided by you, to the extent required by local laws and regulations, at the latest fourteen (14) days since we acknowledge the breach of confidentiality.

Data Retention

Notwithstanding the provision on the erasure of personal information, to the extent required by local laws and regulations, we will retain your personal information, at the latest for 5 years.

Notification to Amendment of this Privacy Policy

In the event we amend this Privacy Policy, we will provide a notification to you regarding the effective date of the changes at the latest fourteen (14) days prior to the effective date, through (i) a notice to be posted on the landing page of our website, pop-up notification, or the splash screen of our mobile app or (ii) the contact information you provided to us. If you fail to explicitly express your objection to the amended privacy policy within the above notification period, you will be considered as accepting the changes and agreed to the new privacy policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Service at any time, if you cease to agree with the amended privacy policy.

Data Accuracy and third party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

Minimum Age

You are at least 20 years of age to be able to use the Service. Otherwise, parental consent is necessary.

Consent

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore.

Your Rights

This section applies only to users that are located in Japan.

You may request us to notify purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at DPO_imursurvey@weisurvey.com.

Republic of Korea

How We Store and Share Your Personal Information

Delegation of Processing

For the performance of the services detailed in this privacy policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee Descriptions of Delegated Services

Aceville Pte. Ltd.

Cloud storage and processing

Data Destruction

Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

Your Rights

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”).

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right.

However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as PIPA.

You can also withdraw you consent or demand a suspension of the personal information processing at any time.

Domestic Privacy Representative (if applicable)

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA the information regarding the domestic agent is as follows:

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Russia

If you are using this Survey in Russia, by using this Survey:

The sub-sections “Access”, “Correction”, “Erasure”, “Restriction of Processing to Storage Only” and “Objection” of the section “Your Rights” above apply to users in the Russian Federation.

We will not implement any material changes to the way we process your personal information, as described in the Privacy Policy, unless we have notified you. We will notify you of any such material changes and may request you to acknowledge such changes. Unless we require the acknowledgment, you shall be deemed to have agreed to the changes, if you continue using the Service upon the notification.

As regards the representative for Russia, you can contact us at DPO_imursurvey@weisurvey.com. Please include the word “Russia” in the subject line of your email.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not participate in a Survey.

We will give you notice by email of any changes to this privacy policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

You have the right to withdraw your earlier provided consent to the processing of your personal information. You may also request us to complete, correct and update your personal information, for data portability of any and all of your personal information which is stored by us and to lodge a complaint, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at DPO_imursurvey@weisurvey.com.

Turkey

Our Data Controller Representative in Turkey is Özdağıstanli Ekici Avukatlık Ortaklığı for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations can be contacted at tencent@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (and to the extent permitted under applicable laws and regulations):

United Arab Emirates

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note also that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

Vietnam

By accepting this privacy policy, you expressly agree and authorize us to collect, use, store, and process your Personal Information, including, lawfully disclosing and transferring it to third parties, as described in this privacy policy.

We maintain international standards and security practices for data protection. When your Personal Information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

Your Personal Information, if required to be disclosed to the competent law enforcement agencies, public authorities or other judicial bodies and organisations, will be disclosed upon receipt of written request from such organizations.

Where required by the law and regulatory requirements of your jurisdiction from time to time, we may retain part or all of your Personal Information for a period longer than described above in this privacy policy.

Your Rights

You have the right to access, correct, and erase the Personal Information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop processing or providing your Personal Information to a third party.