Last updated: 01st January 2020
Who are we?
We are Toluna (“we” “our” “us” or “Service Provider”) and have been engaged by SoCalGas as the platform service provider for SoCalGas Insiders Community. We operate this website https://www.socalgasinsiders.com/ (the “site”) on SoCalGas’ behalf. You can find out more about Toluna by visiting their website: www.tolunacorporate.com
Alter Agents: https://alteragents.com/
Toluna Insights: https://www.tolunainsights.com/
SoCalGas has engaged Alter Agents to perform market research surveys on their behalf. You can find out more about Alter Agents by visiting their website www.alteragents.com
What is our Privacy Commitment to you?
We respect your privacy and are committed to protecting your personal information. This privacy notice describes how we collect, use, share and protect personal information that you provide on the site when you become a community member and participate in our surveys and/or research studies (“surveys”). It also explains your privacy rights and how laws that are applicable to you may protect you.
This Privacy Notice tells you about:
- Who are we?
- What is our Privacy Commitment to you?
- What personal data do we collect about you and how do we use your personal information?
- Who do we share your personal information with?
- What cookies do Toluna use on the site?
- What other tracking technologies do Toluna use?
- How do you access your information; use the member services area and/or update, correct or delete your information?
- How do you opt out from your community membership?
- How do you ask a question or make a complaint?
- What is our winner's policy?
- What security measures do we undertake to protect your personal information?
- How do you opt out from your community membership?
- What are our data retention and destruction policies?
- Children’s privacy?
- Your legal rights in California
- Changes to the privacy notice and your duty to inform us of changes
- Privacy contact details
What personal information do we collect about you and how do we use your personal information?
When you agree to become one of our community members and complete the registration form on the site, you are able to participate in our surveys. As part of your registration, you will provide us with your Identity data and Contact data and we will through your participation in the Surveys obtain, use and share certain other data about you, such as; Demographic/Profile data, Technical data and Pseudonymized data.
We use your Identity data and Contact data for:
- Contacting you for any reason connected with your panel community membership;
- Incentive fulfilment - when you earn incentive points through your participation in the surveys, the points are deposited into your account. When you wish to redeem them, we will use your Identity data and Contact data to send you your rewards.
- Sending you invitations for your participation in surveys - to ask you if you are interested in participating in our upcoming surveys. We may also make you aware via your online community membership account of surveys you may be suitable to participate in, based on our knowledge of your personal information.
- Understanding more about you and the insights you provide us - our platform service provider (Toluna) will with your consent provide us with your Identity data and Contact data, so we can understand more about you.
We use your Demographic/Profile data for matching you with appropriate surveys to see if you qualify for particular surveys and your birth date is automatically updated so that we may ensure we select individuals, based on their age as may be required for the relevant survey.
We use the personal information collected about you via the site to match and link with data we previously collected about you.
Public forums and blogs
The site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
Personal testimonials of satisfied customers are displayed on the site in addition to other endorsements. With your consent, we may post such testimonials along with your first name and first letter of your surname. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
You should be aware that any personal information you choose to make public on the site, in the Community area (under a message on your wall, as an opinion, topic, battle, thumb it) can be read, collected, stored and/or used by other users and could be used to send you unsolicited messages. We strongly discourage you from disclosing any of your personal information in the community area that you may find on the site and in particular, we would never ask you to provide your Contact data or Identity data on a public community area as part of a survey. We cannot guarantee that third parties with whom you share your personal information via those community areas will keep them secure and confidential. Please be aware that we are not responsible for the personal information you choose to submit or make public. In addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines.
Categories of personal information we may process about you
(A) Identity data – name (includes first, last, maiden and married names), date of birth, marital status, gender, member id and username.
(B) Demographic/Profile data – interests, preferences, feedback and survey responses and including, but not limited to; age, marital status, gender, birthday, household size, income, education and employment status.
(C) Contact data – postal address, email address and telephone number.
(D) Technical data includes internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
(E) "Pseudonymised data" is identifiable data as unique identifiers such as member ID’s are used, however direct identifiers, such as; name and Contact data are removed.
Who do we share your personal information with?
We have appointed Toluna as our service provider to host the site on its online platforms for us. Toluna help us to recruit online community members - like you and they build and manage the site and process all personal information we collect from you as part of your community membership. We require Toluna to respect the security and confidentiality of your personal information and to treat it in accordance with the law. We do not allow Toluna to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Toluna has engaged Amazon Web Services (AWS) (located in Ireland) to host the Community platform and to provide backup services.
From time to time we may engage third parties to issue you with cheques or processing the delivery of your rewards and they will need to use your Identity data and Contact data for those purposes.
From time to time, Toluna may use third-party software for fraud, quality checking and validation purposes, including, but not limited to speeding,
Though we make every effort to preserve your privacy, we may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud or breaches of the site terms, or to respond to a government request.
What Cookies do Toluna use on the site?
What other Tracking Technologies do Toluna use?
Server log files: Toluna may collect Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This Technical data may be combined with other information collected about you for the purposes of improving our services, site functionality and collecting analytical data.
Fingerprinting technologies: In general, digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and track your personal information device (“Technology”). The Technology will analyze publicly available information and data obtained from your computer's web browser and from other publicly available data points, including the technical settings of your computer, the characteristics of your computer, and its IP Address, to create a unique identifier, which will be assigned to your personal information device. Toluna uses the Technology for quality control, validation, and fraud detection and prevention purposes, including assisting us in ensuring the integrity of survey results. Appropriate technical and operational processes and procedures will be put in place to ensure that the Technology is safe, secure and does not cause undue privacy or data security risks and the Technology will be used and distributed in a professional and ethical manner and in accordance with (a) this privacy notice, (b) any other statements and/or disclosures made to you as a member of the community and (c) applicable laws and market research codes of practice. In the event any unethical conduct is discovered in connection with the use of the Technology, or that the Technology is being used in a manner that is inconsistent with privacy notice, immediate action will be taken to prohibit such unethical conduct and to ensure the proper administration of the Technology.
How do you access your information; use the member services area and/or update, correct or delete your information?
Upon request, we will provide you with information about personal information, what personal information we may hold about you. If you are based in California, you should refer to the section entitled Your legal rights in California to understand more about your rights. You may access, correct, or request deletion of your personal information, or terminate your membership by logging into your Community Account. By following the appropriate directions, your information should be automatically updated in our database. For these purposes, and if you are unable to correct your personal information yourself via your Community Account you may write to us at the mailing address found at the end of this Privacy notice, or contact us by email at email@example.com. We will respond to all requests within a reasonable time-frame.
How do you opt out from your community membership?
If you choose to end your membership with the Community or require us to cease processing your personal information, you may discontinue your membership by going to “Account” and selecting “Unsubscribe Options” in the footer. By following the appropriate directions, your record will be marked as "do not contact", and you will no longer receive invites to participate in future Surveys from Toluna. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalized. Please note that you may continue to receive communications during this short period after changing your preferences while our systems are fully updated.
You may also send an email directly to firstname.lastname@example.org requesting to be removed. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.
If you decide to terminate your membership, we will no longer use your Identity data or Contact data, except for archival purposes and we will process your personal information in accordance with our back-up procedures. Your personal information will eventually be destroyed, in accordance with our Data Retention and Destruction Policies and we will continue to employ the security procedures and technologies to keep your personal information safe.
How do you ask a question or make a complaint?
You can direct any questions or complaints about the use or disclosure of your personal information to our Privacy Contact. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal information within 30 days of receiving your complaint.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
What is our winner's policy?
Community members either receive points for their participation in surveys and as being a member of the community or are randomly selected to may win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. For more information, please visit our Terms and Conditions page. Toluna shall post the usernames or first name and first initial of last name of winners on the Reward Page or communicate them via newsletter to all members. For more information about earning points, please visit our Terms and Conditions page..
What security measures do we undertake to protect your personal information?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information in accordance with our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator or supervisory authority of a breach where we are legally required to do so.
What are our data retention and destruction policies?
How long will you use my personal data for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you are a citizen or resident of California, or we are processing your personal information in California, in some circumstances you can ask us to delete your data: see the section entitled Your legal rights in California below for further information.
As the results of the surveys and other aggregated or Pseudonymized data are used for research and/or statistical purposes, we and other third parties may use this information in accordance with the terms indefinitely without further notice to you.
From time to time we may offer visitors the ability to voluntarily link to other sites. Toluna does not review and is not responsible for, the content or effect of the privacy policies of these sites.
Children’s privacy?Toluna will not knowingly collect any information online from any child under the age 16 without permission from his/her parents, legal guardian or an adult responsible for the care of the child. We comply with COPPA, the California Consumer Privacy Act 2018 (“CCPA”) and the ESOMAR guidelines in relation to online surveys concerning children and young people.
Your legal rights in California
If you are a resident or citizen of California, you have rights under the CCPA in relation to your personal information and you may exercise any of these rights set out below, via your online account or may contact us by contacting us using the Privacy Contact details below.
You have the following rights:
- Request access to your personal information and we may conduct ID checks before we can respond to your request.
- Have your personal information erased, corrected or restricted if it is inaccurate or requires updating. You may also have the right under certain circumstances to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors. You can update your account information via your Account or by contacting us at the address given below.
You can exercise the above rights by:
- going to your “Account” and selecting the relevant options. By following the appropriate directions, we will comply with your request, within 30 days. Please note you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalized. Please note that you may continue to receive communications and/or we may continue to process your personal information during this short period after changing your preferences while our systems are fully updated.
- writing to us or contacting us using the contact details given under the Privacy Contact Details.
- Calling us on the toll free no [insert]
If you wish to opt out of our Membership program, you may do so in accordance with the process under the paragraph How do you terminate your Community Membership? above. Once you make an opt-out request, we will remove you from our Community Membership and we will not contact you again, unless you decide to re-register with us.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not exclude you from participating in any Surveys you may be eligible for on the basis of you exercising your CCPA rights.
Changes to the privacy notice and your duty to inform us of changes
If we decide to change our privacy notice, we will post those changes to this privacy statement on the homepage, or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.
It is important that the personal information we hold about you is accurate and current. Please keep your Account details updated if your personal information changes during your relationship with us.
Privacy contact details
You may contact us by writing to:
SoCalGas c/o Toluna USA Inc.
Attn: The Data Protection Officer ("DPO")
21 River Road
Wilton, Connecticut 06897