|Last Updated: 12/26/2019
The ClientSmart platform (the "Platform"), is a web-based application that provides services for mystery shopping companies (the "Affiliates") to manage, schedule, collect, and report on the results of mystery shops contracted by their business customers. As a part of that function, the Platform provides a mechanism to manage information about individuals who participate in mystery shops on behalf of the Affiliates.
The Platform is created, maintained, and operated by Nucleus Medical Media, Inc. (the "Provider"), a U.S. corporation based in the state of Georgia.
Our Commitment to Privacy
Notice To California Residents
If you are a California resident, please see the section below titled Additional Information for California Residents.
The Information We Collect
When you use the Platform, you may provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis and web site use information collected on an aggregate basis as you and others use the Platform.
- Account Information:
In order to allow for your participation in the services provided through the Platform, you must maintain an account with us and provide basic contact information, including the following: your name, mailing address, email address, and phone number.
- Profile and Demographic Information
Further, in order to appropriately match you to mystery shopping opportunities available through the Platform, you may choose to provide (or be required to provide) certain demographic information. Any provided demographic information and your name, photo, and any other information that you choose to add to your profile on the Platform can be viewed only by representatives of the Affilliate with which you have registered and by representatives of the Provider.
- Your Answers to Shop Surveys
Your answers to surveys completed on the Platform in association with shops you complete are shared (without personally-identifiable information) either in aggregate or individual shop form, with businesses that have contracted with Affiliates for mystery shopping services. Your answers provide those businesses with information necessary for them to improve their operations.
- Your Communications With Us
In addition to providing the foregoing information, if you choose to correspond further with us through email or other formats, we may retain the content of your communications together with our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.
- Web Site Use Information
Our Use of the Information That You Provide to Us
We use information collected from you in the following ways:
- To Provide Our Services:
In aggregated, non-personally-identifiable form, to provide demographic context for mystery shopping results as presented to businesses who have contracted for mystery shopping services through Affiliates of the Platform. The Platform is utilized by various Affiliates to operate their business. As a result, information you enter into the Platform is available to the Affiliates with which you registered as a shopper. Your information is NOT shared with any other Affiliates which may also use the the Platform.
- For Updates, Marketing, and Promotions:
To notify you about important changes to the Platform, and for marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you, including information about third-party products and services.
- For Analytics:
- To Comply with Law:
To comply with legal obligations when we, in good faith, believe that the law requires it or for the protection of our legal rights.
- To Prevent Misuse:
How We Share Your Information
We share information as set forth below and where individuals have otherwise consented:
- Service Providers: We may share your information with third-party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, and customer service and support providers.
- Business Transfers: We may disclose or transfer information, including personal information, as part of any merger, sale, or transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
- Legally Required: We may disclose your information if we are required to do so by law.
- Protection of Rights: We may disclose information where we believe it necessary to respond to claims asserted against us or to comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and to protect the rights, property, or safety of the Platform, its users, or others.
- Your Demographic Information: Your demographic information (not including personally identifiable elements) may be made available to companies that have contracted for mystery shopping services through Affiliates, but only in association with shops in which you have participated. No personally identifiable information is shared. Examples of items that are NOT shared include your name, email address, phone number, street address, and social security number.
- Anonymized and Aggregated Data: We may share aggregated or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
Cookies are a feature of web browser software that allows web servers to recognize the computer used to access a web site. Cookies are small pieces of data that are stored by a user's web browser on the user's hard drive. Cookies can remember what information a user accesses on one web page to simplify subsequent interactions with that web site by the same user or to use the information to streamline the user's transactions on related web pages. This makes it easier for a user to move from web page to web page and to complete commercial transactions over the internet. Cookies should make your online experience easier and more personalized.
We use web site browser software tools such as cookies and web server logs to gather information about the Platform's users' browsing activities, in order to constantly improve and better serve our customers. This information assists us to design and arrange our web pages in the most user-friendly manner and to continually improve in order to better meet the needs of our customers and prospective customers. Web server logs allow us to count how many people visit the Platform and evaluate the Platform's visitor capacity. We do not use these technologies to capture your individual email address or any personally identifying information about you.
Security of Information Transmissions
All interactions with the Platform are secured by SSL, which encrypts all information you input before it is sent to us. The information is scrambled en route and decoded once it reaches us.
Emails that you may send to us or our Affiliates may not be secure unless we advise you that security measures will be in place prior to your transmitting the information. For that reason, we ask that you do not send confidential information such as Social Security or account numbers to us or our Affiliates through unsecured email.
Protection of Your Information
We protect your information in the following ways:
- Information Security:
We utilize encryption/security software to safeguard the confidentiality of personal information we collect from unauthorized access or disclosure and accidental loss, alteration or destruction.
- Evaluation of Information Protection Practices:
Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality, and quality of our information.
- Employee Access, Training and Expectations:
Our corporate values, ethical standards, policies, and practices are committed to the protection of customer information. In general, our business practices limit employee access to confidential information, and limit the use and disclosure of such information to authorized persons, processes, and transactions.
- Transferring Your Data:
The Provider is headquartered in the United States, and has Affiliates and partners in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
- Other Web Sites Linked to the Platform:
Accessing and Correcting Your Information
You may correct any of your personal information on the Platform by logging in to your account. You may request access to all your personally identifiable information that we collect online and maintain in our database by emailing email@example.com.
Additional Information for California Residents
This section provides information organized in accordance with the California Consumer Privacy Act (“CCPA”) for residents of California about how we handle certain personal information we have collected over the past 12 months.
Categories of Personal Information
The section above entitled The Information We Collect discloses the categories of personal information that we collect, which include your account and profile information, your survey answers, your communications with us, information about your activity on the Platform, and how you engage with the Platform.
The section above entitled Our Use of the Information That You Provide to Us discloses that the categories of personal information we collect are used to provide our services, to inform you of changes to our platform, to promote our services to you, to analyze how our services are used, to comply with law, and to prevent misuse of the Platform.
The section above entitled How We Share Your Information discloses that we share your personal information with service providers, Affiliates, law enforcement authorities, and as needed with third parties to provide our services. We do not sell your personal information to third parties. We may share your personal information with third parties and third parties may collect your personal information as described above in the How We Share Your Information section. We do not collect personal information from consumers that we know are younger than 16 years old.
Requests for Deletion, Copy, and Right to Know Your Information
California consumers have the right to make the following requests, which we endeavor to honor from non-California residents as well:
You have the right to request deletion of personal information that we have collected about you.
- Copy and Right to Know:
You have the right to request a copy of the specific pieces of personal information that we have collected about you over the past 12 months, including the categories of information, sources, and purposes of collection, as well as categories of third parties we have shared it with.
- Designated Agent:
You may designate an agent to make a request on your behalf. That agent must have access to your account in order for us to verify the request.
You may submit deletion, copy, and right to know requests by emailing us at firstname.lastname@example.org. You will need access to the email account associated with your platform account in order to verify your identity and complete this process.
The Platform will not discriminate against you, including by denying or providing a different level or quality of goods or services should you choose to exercise your options under the CCPA.
Your California Privacy Rights under California’s Shine-the-Light Law
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to email@example.com.