Storewards Privacy Notice

 

Effective Date: August 2020

 

Thank you for using the Storewards mobile application. For decades, Nielsen has set the global standard for market and consumer insight research. Our insights are based on representative samples of the population and help our clients (e.g., manufacturers, retailers, media companies, non-profit organizations, and government bodies) learn about what consumers watch, listen to, and buy. Your participation in our research  helps companies understand consumers’ behaviors and preferences, which often helps them provide better consumer products and services.

 

As the controller of personal data processed in connection with your use of the Storewards mobile application (the “Mobile App”), AC Nielsen Company Limited, Nielsen House, John Smith Drive, Oxford, OX4 2WB (“Nielsen,” “we,” or “us”), is committed to protecting your privacy and handling your personal data in an open and transparent manner. This Privacy Notice explains how we use, share, and protect the data we collect from or about you in connection with your use of the Mobile App. This Privacy Notice also explains your legal rights in relation to such data.

 

Please note that this Privacy Notice applies only to data collected and processed in connection with your use of and interaction with the Mobile App. This Privacy Notice does not apply to your participation in any other Nielsen panels, studies, or surveys or your interaction with or use of any other websites, applications, or online services administered or provided by us or any other entity within the Nielsen group of companies. Other Nielsen panels, studies, surveys, websites, applications, and online services are governed by their own privacy notices, and we encourage you to review those privacy notices before disclosing any data.

 

To learn more about the Nielsen group of companies, one or more of which may also process your data in connection with your use of the Mobile App, please click here.

 

Your use of the Mobile App is always voluntary. If you have any questions about the Mobile App, this Privacy Notice, or our data-handling practices, please refer to the “Contact Us” section below for our contact information.

 

1. OUR PRIVACY COMMITMENT

 

Nielsen is a privacy-conscious organisation and complies with all applicable data protection and privacy laws, including the EU General Data Protection Regulation. Indeed, it is crucial for us to maintain the confidentiality of data about our users in order to prevent any third-party interference that could affect their behaviour and the accuracy of our data and insights. We also will not use data that identifies you to advertise, promote, market, or sell third-party goods or services directly to you, and we will not allow our clients to use data that identifies you for such purposes.

 

2. COLLECTION OF YOUR DATA

 

As a user of the Mobile App, we will collect or otherwise obtain data relating to you in a variety of ways. Such data may include personal data (i.e., data that alone or in combination with other data identifies you as an individual, such as your name, email address, phone number, and other data that can be reasonably linked to you as an individual). 

 

Additional details about the data we will gather about you in connection with your use of the Mobile App and the sources of such data can be found below.

 

A. Data provided by you 

 

During the user registration process, we will gather data about you that you voluntarily provide to us. Specifically, in order to create your user account for the Mobile App, we will ask for your name, email address, physical address, phone number.Please note that if you do not provide us with this data, we will not be able to create an account for you. Once your user account has been created,you will have the ability to scan and send us images of your receipts. Uploading receipts from your purchases will help us learn  about your behavior (e.g., when, why, or how you purchase certain products) and preferences(e.g.,  which types of products you choose to purchase). In order to scan and send us images of your receipts, we will need to access features of your mobile device such as the camera and/or stored images.

Furthermore, you may be requested to authorize access by the Mobile App to your Email account, for the sole purpose of improving our service. Should you provide such access, the Mobile App will only collect information regarding purchases made by you for which you receive receipts or confirmation by email. The Mobile App will extract information about such purchases and submit it for you in the same manner as receipts uploaded by you. Such information obtained from your Emails will be used in the same manner as receipts that you upload to the Mobile App, and this Privacy Policy shall apply to such information in the same manner that it applies to all other Data and information. Storewards use and transfers to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements

 

While you have an active user account, we may, from time to time, ask you  to respond to questions and/or participate in surveys in the Mobile App and provide us with additional data, including demographic data (e.g., your gender, education level, occupation, household size, marital status, number of children, etc.) as well as data relating to your behavior and preferences. This additional data will help us better understand consumer behavior and trends. 

 

Some of the data that we request and collect may be considered “special” or “sensitive” personal data (i.e., data revealing your racial or ethnic origin, political opinions, religious or other similar beliefs, philosophical beliefs, health or medical conditions, or sexual orientation). If you voluntarily share any “special” or “sensitive” personal data with us for any reason, we will use it in the ways described in this Privacy Notice or as described in a separate notice provided at the point where such data is requested from you as well as in accordance with applicable law. 

 

B. Data collected in connection with your use of the Mobile App

We (or third parties on our behalf) will collect certain data during your use of the Mobile App (“Usage Information”). This Usage Information includes session information, event information, and geolocation information.

 

  • Session information includes information about your device and your device’s interaction with the Mobile App. Information collected includes your device brand, device name, operating system and browser, IP address (and coarse, non-precise geolocation generated from the IP address), device or mobile app identifiers (including, for example, a UUID/installation ID unique to a mobile application, Apple’s Unique ID for Advertisers ("IDFA") or Google AdID, (“ADID”)),  the number of times the Mobile App is opened, language preference, performance information (e.g., crash reports, including crash traces and associated logs), and session duration.

 

  • Event information includes transaction information about your use of the Mobile App (e.g., features used, access dates and times, requests to redeem rewards, and amount of rewards redeemed).

 

  • Geolocation information includes latitude and longitude information. If you give us permission, the Mobile App uses location-enabled services to obtain geolocation information, but only accesses coarse location information. The Mobile App uses Google Location Services, which combines Wi-Fi, mobile cell data, or both, to determine the device’s location. This returns data with an accuracy equivalent to a city block.

 

Certain data collected via the Mobile App depends on your device settings and permissions. Depending on your mobile device (and operating system), device settings provide the ability to restrict the collection of certain device data. You can reset or restrict your device advertising ID through your device settings. You can also modify or disable your mobile device’s location functionality, access to the camera, receipt of push notifications, or other features used by the Mobile App through your mobile device’s settings. If you disable access to your mobile device’s camera, you will be unable to upload images of receipts via the Mobile App. If you turn off ‘push’ notifications or alerts through your device’s privacy settings, you will no longer receive ‘push’ notifications.
 

C. Data we obtain from other sources

 

After you have become a registered user of the App, we may collect or obtain additional data about you from other sources.This may include data about your demographic characteristics; what you watch, research, or buy; and your exposure to certain content or advertising. The sources of this data may include, for example: 

  • third party analytics vendors who gather information about how users interact with the Mobile App. These third party analytics vendors also provide us with additional information about users of the Mobile App they possess, such as information about age range, gender, and a user’s interests (see Section 5, “Cookies and Similar Technologies”);

  • public sources (e.g., public databases, social media, etc.);

  • the manufacturers and sellers of goods and services that you or your household purchase or use;

  • operators/owners of third-party websites or mobile apps that you use and are authorised to share data with us;

  • third-party (non-Nielsen) panels of which you or your household are a member;

  • companies and retailers that offer "customer loyalty" programs; and

  • data providers and data-matching service providers.

 

We may combine the data that we collect or otherwise obtain about you (as described above) with data from other sources. We will use the data only for the purposes described in this Privacy Notice. By using the App, you acknowledge that we may obtain data about you from sources such as those listed above and combine it with other data that we hold about you. 

D. Data we do not collect

 

We do not collect government-issued identification numbers (e.g., passport or national identity numbers),  financial information (e.g., bank account or credit card numbers), or account passwords.
 

3. USE OF YOUR DATA AND BASIS FOR PROCESSING 

 

We will use your  data for the following purposes:

 

To Manage your Account: We will use your data to create your account, provide you with access to the Mobile App and its contents (including its interactive features and functionality), deliver the services you have requested, fulfill your requests, and carry out any  customer service and support. We will also use your data to track, process, post, and fulfill rewards you earn.

 

We process your personal data for this purpose on the basis of your agreement with us or to take steps at your request prior to entering into an agreement with you (the Terms of Use & Application Rules) pursuant to Article 6(1) lit. b, GDPR.

 

For Market Research Purposes: Once you create an account and provide us with images of receipts, we will  extractdata from the receipts (i.e., items purchased, price, quantity, store) and combine it with demographic information, location information (collected via Google Location Services to help us understand where receipts are uploaded), your responses to questions and/or surveys that you complete, and data we have obtained from other sources, in order to help us create a variety of market research insights for our clients. These insights, in turn, help our clients make informed decisions about various topics, such as the products that they manufacture or stock in their stores, which advertising method(s) to use (e.g., online/digital advertising, mobile advertising, print advertising, broadcast advertising, etc.). Our clients may also use our insights to understand, among other things, the types of products consumers in different demographic groups would be likely to buy and whether residents in a particular neighborhood would be likely to shop at a specialty store if it were nearby.

 

When we prepare reports and share insights with our clients, we use tools and methods that are designed to ensure that there is no reasonable possibility for them of identifying you or other users of the Mobile App. For example, we will combine data about you with data about other users of the Mobile App in order to produce reports with aggregated data from which you cannot be identified.

 

We also create reports based upon “modeled data” (i.e., projections based on demographic and behavioral characteristics, such as age, gender, product purchases, or TV watching habits) that look at a sample group of people and predict what people with similar characteristics or preferences might watch or buy. This allows advertisers, for instance, to identify the likely audience for a marketing campaign.

 

We process your personal data for this purpose on the basis of your agreement with us pursuant to Article 6(1) lit. b, GDPR (Terms of Use), or because we have a legitimate interest pursuant to Article 6(1) lit. f, GDPR, in performing research to generate insights (to the extent such interest is not overridden by your interests or fundamental rights and freedoms).

 

To Contact You: We will use your data for customer service purposes and to notify you when updates to the Mobile App are available or changes to any products or services offered through the Mobile App are made. Depending on your device settings, the Mobile App utilizes push notifications to notify you of updates or changes or deliver other relevant information to you. A push notification is a way for the Mobile App to send information via badges, alerts, or pop-up messages.

 

We will also contact you with information about our business, services, and events as well as other information that may be of interest to you, such as offers to participate in other panels, studies, or surveys administered by us or other Nielsen entities (subject to obtaining your consent to the extent required by applicable law).

 

We will process your personal data for this purpose on the basis of your agreement with us (Terms of Use & Application Rules) pursuant to Article 6(1) lit. b, GDPR, or because we have a legitimate interest pursuant to Article 6(1) lit. f, GDPR, in communicating with you about your use of the Mobile App (to the extent such interest is not overridden by your interests or fundamental rights and freedoms). Where required, we will obtain your consent pursuant to Article 6 (1) lit. a, GDPR.

 

For Fraud Prevention and Detection: We will use your data for purposes of fraud prevention and detection. When you initiate a request to redeem rewards, the Mobile App automatically reviews your account, considering the frequency of redemption (e.g., coins collected, number and amount of cashouts), location information (collected via Google Location Services), and trends regarding receipt submission. If the foregoing values are high, your account may be flagged for manual review. If we identify evidence in violation of the Terms of Service your account will be blocked.

 

We will process your personal data for this purpose on the basis of our legitimate interest pursuant to Article 6(1) lit. f, GDPR, in identifying, preventing, and remediating fraud (to the extent such interest is not overridden by your interests or fundamental rights and freedoms).

 

Other Purposes: In addition to using your data for the purposes described above, we may use your data to:

 

  • operate and manage our IT and security systems, including to monitor such systems and identify and respond to security events;

  • conduct research for quality assurance and product, service, and business development purposes, including to improve the quality and design of the Mobile App and create new features, functionality, and services;

  • facilitate the day-to-day operations and financial management of the Nielsen group of companies and any corporate transactions (e.g., a reorganization, merger, sale, joint venture, assignment, transfer, etc.);

  • protect the rights, safety, property, or operations of one or more Nielsen entities, you, or others;

  • comply with applicable laws and regulations and establish, exercise, and/or defend the legal rights of one or more Nielsen entities; and

  • respond to requests and communications from law enforcement authorities or other government officials.

 

We will process your personal data for these purposes on the basis of our: 

  • legitimate interests pursuant to Article 6(1) lit. f, GDPR (to the extent the following legitimate interests are not overridden by your interest or fundamental rights and freedoms) in (i) managing and operating our business and day-to-day affairs; (ii) managing and enhancing protection against fraud, spam, harassment, intellectual property infringement, and risks to which we are exposed (e.g., crime and security risks); (iii) conducting research and improving our products and services; (iv) managing risks to which we are exposed and  providing a safe and secure environment for users of the Mobile App; (v) complying with laws and regulations to which one or more entities within the Nielsen group of companies is subject, including, where applicable, laws and regulations of countries other than your country of residence; and (vi) meeting our obligations and enforcing our legal rights; or

  • need to comply with a legal obligation arising under applicable law to which we are subject.

 

We will also de-identify data about you and use it or allow others to use it for historical, academic, or longitudinal research. We make sure in such cases that there is no reasonable possibility of identifying you from the data used.

 

Please note that because we are continually adapting our services to evolving consumer and media consumption patterns, we may use your data in ways that we have not developed yet, in which case, we will provide you with additional information as our practices change.

 

4. COOKIES AND OTHER SIMILAR TECHNOLOGIES

 

The Mobile App includes technology provided by third parties to operate the Mobile App and provide services. The Mobile App incorporates technology provided by third parties to enable push notifications, for crash reporting, and for analytics.

 

For example, the Mobile App includes Google Analytics for Firebase. Google Analytics for Firebase is an app measurement solution that provides insight on app usage and user engagement to help us understand how the Mobile App is used. Google Analytics for Firebase captures a number of events and user properties to provide detailed insights about the Mobile App, such as active users, demographics, and commonly used features. You can find more information about Google Analytics’s data practices here: https://support.google.com/analytics/answer/6004245.For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout

 

Technologies used in mobile applications to identify a device or application are not-browser based like cookies and cannot be controlled by browser settings. Rather, they will store data in your device and access pre-existing features of your device. Some use device advertising IDs or other device identifiers to associate user activity to a particular app and  track user activity across mobile apps. For example, the Mobile App and third-party technology we use assign a unique identifier (in practice: a series of numbers and letters such as a mobile app instance ID) to the Mobile App so we (and third parties) can identify the same user of the device. This is important to make sure content is delivered to the correct mobile app, to assist in providing automatic updates, to facilitate the delivery and receipt of push notifications, and to compute metrics. Our analytics provider also uses Android’s Advertiser ID – or AdID – where available to improve the accuracy of identifying unique devices. Google Analytics for Firebase will also use the Android Advertiser ID to provide us with additional demographic information about users of the Mobile App, such as age range, gender, and interests.

 

Where required by applicable law, we will ask for your permission before storing and/or accessing data on your mobile device. 

 

5. DISCLOSURES AND TRANSFERS OF YOUR DATA

 

In connection with one or more of the purposes outlined above, we may disclose your data to:

 

  • other entities within the Nielsen group of companies;

  • our clients and other third parties, such as market research companies (in accordance with market research industry ethical guidelines) as well as organizations and institutions engaged in historical, academic, or longitudinal research;

  • third-party service providers (commonly called ‘data processors’), including providers of the following services (among others): website or application hosting, management, or support; data analysis or processing; data backup; data security and storage; data matching; panelist recruitment; product development; and other services (subject to binding contractual obligations of confidentiality and security and restrictions on the use of data for any purpose other than carrying out the services that they are performing for us);

  • relevant third parties as part of a corporate transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); 

  • competent governmental and public authorities,in each case to comply with legal or regulatory obligations or requests or for the purposes of reporting any actual or suspected breach of applicable law; and

  • other third parties as we believe to be necessary (e.g., in order to protect the rights, property, operations, health, or safety of you, us, or others) or appropriate for legal purposes (e.g., in connection with claims, disputes, or litigation or in order to enforce our legal rights.

 

We limit how our clients and other third parties may use personal data that we share with them in order to prevent them from tracing aggregated data back to the individual to whom it relates and prevent personal data from being used in a way that is inconsistent with this Privacy Notice.

 

The disclosures described above may result in the transfer of your personal data to countries or regions with data protection laws that differ from those in your country of residence and do not provide an “adequate level” of data protection, including countries that have not been recognized by the European Commission (or equivalent United Kingdom (UK) body in the event of the UK’s exit from the EU) as providing an adequate level of data protection, such as the United States, India, or other locations where the Nielsen group of companies has facilities. 

 

When we transfer personal data outside the European Union to countries not deemed “adequate,” we take steps to ensure that appropriate safeguards are in place  in compliance with  EU data protection law.  Such safeguards may include a data transfer agreement with the data recipient that includes standard contractual clauses approved by the European Commission (or equivalent UK body in the event of the UK’s exit from the EU) for transfers of personal data to countries not providing an adequate level of data protection. 

 

For further details relating to the transfers described above and the safeguards used with respect to such transfers, please contact us at connect.privacy@nielsen.com.

 

6. YOUR CHOICES AND LEGAL RIGHTS

Use of the Mobile App is always voluntary. If at any time you wish to stop all data collection by the Mobile App, you can uninstall the Mobile App using your device’s standard uninstall process. Please note that uninstalling the Mobile App will not delete your account.

 

We are also committed to providing you with reasonable access to your personal data and the ability to review and limit the use of such data in accordance with applicable law. Under applicable law, you may have the right to:

 

  • request and obtain confirmation as to whether or not we are processing personal data about you, and, where that is the case, access a copy of the personal data held about you;

  • request that we update the personal data we hold about you or correct such data that is inaccurate or incomplete;

  •  request that certain data about you is erased (note that this right is not absolute, but applies in certain cases);

  • object to our processing of personal data about you where we process personal data ;

  • propose other restrictions on the processing of personal data about you if there is a disagreement about its accuracy or we are not lawfully allowed to process it; 

  • withdraw the consent that you have given us to process your personal data (where we process your personal data on the basis of your consent); and

  • request that certain personal data is transferred to another organization in a structured, commonly used, and machine-readable format (to the extent applicable).

If you are interested in exercising one or more of the rights described above, please submit your request using the form here or contact us using the contact information below.  Because we want to avoid taking action regarding your personal data at the direction of someone other than you, please note that we may request information to verify your identity before we give effect to these rights.

 

If you have questions or concerns about our collection or use of your personal data, you can contact usat connect.privacy@nielsen.com

 

If you are unsatisfied with the way in which we have handled your  personal data or any privacy query or request that you have raised to us, you have the right to complain to the Supervisory Authority in your country of residence or where the activity that is the subject of the complaint occurred (current contact information for the Supervisory Authorities is available here).

7. MINORS’ PRIVACY

 

We understand the importance of protecting minors’ privacy, especially in the online environment. The Mobile App is not designed for or intentionally targeted at  anyone under the age of 18, and we do not intend to collect personal data from anyone under the age of 18 via the App. If we become aware that we have collected personal data relating to a minor, we will take reasonable steps to delete it.

 

8. DATA SECURITY

 

We have in place reasonable organisational, technical, and administrative measures that are designed to protect your personal data from loss, misuse, and unauthorized access, disclosure, destruction, and other forms of unlawful processing while it is under our control.

 

9. DATA RETENTION

 

We will retain your personal data for as long as needed for the fulfillment of the purposes described in this Privacy Notice, unless applicable law or professional or legal obligations require a longer retention period. 


 

10. UPDATES TO THIS PRIVACY NOTICE

 

Changes in our business or personal data processing practices,technology, and/or legal requirements may require us to update or make changes to this Privacy Notice from time to time. Please take a look at the “Effective Date” at the beginning of this Privacy Notice to see when it was last revised. If we were to make a “material” change (i.e., a change to the way we use your data that might make you reconsider participating in the Panel), we will notify you at the most recent mailing address or email address we have on file at least 30 calendar days before implementing the change, thereby giving you time to withdraw your participation in the Mobile App.

 

The most current version of this Privacy Notice will always be available in the Mobile App.. We encourage you to  review this Privacy Notice  periodically to remain informed about how we are using and protecting your personal data.

 

11. CONTACT US

If you have questions about this Privacy Notice or our data handling practices, please email us at connect.privacy@nielsen.com or write us at the address below.
 

Nielsen

Nielsen House

Oxford Business Park South John Smith Drive

Oxford OX4 2WB UK

Attn: Legal Dept.
 

This Privacy Notice replaces any other statement, whether written or oral, made to you about our practices with respect to Nielsen’s collection and use of personal data  in connection with the Mobile App.

 

THANK YOU – WE APPRECIATE AND VALUE YOUR PARTICIPATION!

 

Nielsen Holdings plc (NYSE: NLSN) is a global performance management company that provides a comprehensive understanding of what consumers Watch and Buy. Nielsen's Watch segment provides media and advertising clients with Total Audience measurement services across all devices where content - video, audio and text - is consumed. The Buy segment offers consumer packaged goods manufacturers and retailers the industry's only global view of retail performance measurement. By integrating information from its Watch and Buy segments and other data sources, Nielsen provides its clients with both world- class measurement as well as analytics that help improve performance. Nielsen, an S&P 500 company, has operations in over 100 countries that cover more than 90 percent of the world's population. For more information, please visit www.nielsen.com.