Effective Date: March 14, 2023

Curion, LLC (“Curion” or “we,” “us,” or “our”) is committed to privacy and will only use information that identifies, relates to, or could reasonably be linked with a particular individual (“Personal Information”) in accordance with the terms of this Privacy Policy (“Policy”).

Curion collects and processes Personal Information in different circumstances, including about individuals who agree to sit on our panels (“Panelists”), about employees, and about visitors to our websites.

As set out in greater detail in this Policy, when you join the Curion panel, we collect certain personal information (contact information, general demographics like gender and date of birth) from you at registration and then your views as part of particular projects. Your profile with your identifying information is strictly confidential. Your personal information such as name, address and phone number is never sold or released to the companies that we conduct projects for. Please read this Policy carefully. If you have any questions about this Policy, please contact us through the contact information provided on our Panelist Support page or by emailing us at: privacy@curioninsights.com.

The Information We Collect

This section describes what Personal Information we collect and the different ways we collect it. Please note, Personal Information does not include information that is publicly available from government records or de-identified or aggregated consumer information. Generally in the past 12 months, we have collected the following categories of Personal Information:

More specifically, we may collect the following Personal Information from or about you:

Information We Collect From You

When you become a panelist, we ask you to provide certain Personal Information and to register for an account. Some Personal Information we request is required to be a Panelist, and some is optional. If you do not provide the Personal Information, you may not be able to be a Panelist if that information is necessary or we are legally required to collect it.

When you join the Curion panel, we may access and collect the Personal Information you provide, such as your name, email address, gender, birth date, state of residence and employment status. If your compensation from Curion for participation in Curion studies exceeds $599 in a calendar year, we will collect certain information required by law, including your social security number, in order to issue you a 1099. Keep in mind, it is your responsibility to track your annual earnings from Curion as panelists are not employees of Curion.

If you participate in a Curion study, you are eligible for the prize or incentive established for that study. Information regarding drawings, incentive, or other prizes will be explained to you when you qualify for a study. At times, Curion may request additional information such as your mailing address and/or any information required by law for reporting purposes, such as your social security number.

We also collect information from our employees relevant to their employment relationship and benefits.

Information Automatically Collected

When you use some of our Services, including our websites and other online services (our “Sites”), our servers automatically record information that your browser or device sends whenever you visit a website or utilize an application. This information may include your IP address, the type of device you are using, the internet service provider or mobile carrier you are using, your device identifiers, your mobile telephone number, your geographic location and your activities within the Services, including the links you click, the pages or screens you view, your session time, the number of times you click a page/screen or use a feature of the Services, the date and time you click on a page or use a feature and the amount of time you spend on a page or using a feature.

Like many websites, our Sites use “cookie” technology to collect additional website usage data and to improve our websites, online services and other Services. A cookie is a small data file that we transfer to your computer’s hard disk. A session cookie enables certain features of our websites and other online services and is deleted from your computer when you disconnect from or leave our Sites. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Sites. We may use both session and persistent cookies to better understand how you interact with our Sites, to monitor aggregate usage by our uses and web traffic routing on out Sites, and to improve our Sites and Services. You may also be able to configure your computer or mobile device to limit the collection of these “cookies,” but that limitation may also limit our ability to provide all of the services or functionalities of the Sites. For more information about cookies, including how to set your internet browser to reject cookies, please go to: www.allaboutcookies.org.

Please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

How We Use the Information We Collect

Non-Marketing Purposes

We may use the Personal Information we collect for non-marketing purposes including (1) validating your identity; (2) sending you emails or text messages to provide you with alerts and updates about your participation in studies; (3) conducting statistical or demographic analysis; (4) complying with legal and regulatory requirements; (5) customizing your experience with the services; (6) protecting and defending Curion and its affiliates against legal actions or claims; (7) preventing fraud; (8) satisfying contractual obligations; (9) cooperating with law enforcement or other government agencies for purposes of investigations, national security, public safety or matters of public importance when we believe that disclosure of Personal Information is necessary or appropriate to protect the public interest; and (10) for other business purposes permitted under applicable law.

Text Messages from Curion

IF YOU PROVIDE A CELL PHONE NUMBER AND EXPRESSLY CONSENT TO RECEIVE TEXT MESSAGES FROM CURION, YOU EXPRESSLY CONSENT TO RECEIVING RECURRING INFORMATIONAL TEXTS—INCLUDING TEXTS MADE USING AN AUTODIALER—FROM OR ON BEHALF OF CURION TO THE NUMBER YOU PROVIDED. YOUR CONSENT TO MARKETING MESSAGES IS NOT REQUIRED TO PURCHASE ANY PRODUCTS OR SERVICES. BY PROVIDING A CELL PHONE NUMBER AND EXPRESSLY CONSENTING TO RECEIVE SMS MESSAGES FROM CURION, YOU WARRANT AND REPRESENT THAT YOU ARE EITHER THE ACCOUNT OWNER OF THE CELL PHONE NUMBER YOU PROVIDE TO US, OR YOU HAVE THE EXPRESS PERMISSION OF THE ACCOUNT HOLDER TO PROVIDE THE NUMBER. ALTHOUGH THERE IS NO FEE ASSOCIATED WITH THIS SERVICE, YOUR CARRIER MAY CHARGE YOU FOR EACH MESSAGE YOU RECEIVE IN ACCORDANCE WITH YOUR CALLING PLAN. YOU AGREE THAT WE ARE NOT RESPONSIBLE IN ANY WAY FOR SUCH CHARGES. YOU CAN STOP RECEIVING TEXT MESSAGES FROM CURION AT ANY TIME. JUST TEXT “STOP” IN RESPONSE TO ANY SMS MESSAGE YOU RECEIVE FROM CURION. AFTER YOU SEND THE SMS MESSAGE “STOP” TO US, WE WILL SEND YOU A SINGLE SMS MESSAGE TO CONFIRM THAT YOU HAVE BEEN UNSUBSCRIBED. AFTER THIS, YOU WILL NO LONGER RECEIVE TEXT MESSAGES FROM US. IF YOU WANT TO JOIN AGAIN TO RECEIVE MESSAGES, JUST SIGN UP AS YOU DID THE FIRST TIME, AND WE WILL START SENDING MESSAGES TO YOU AGAIN.

Other Purposes

We may also use information in the aggregate to conduct research studies and for other purposes. Curion will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated or incompatible purposes without providing you notice.

Employment

For our employees, including prospective employees, we use information in managing our employment relationship, evaluating performance, making employment decisions, and providing benefits to you and eligible family members.

Who We Share Personal Information With

Your Personal Information is stored in our proprietary database. Your Personal Information is never sold to other companies for their marketing or other purposes. We do not share your identifying information as part of studies. However, we may share Personal Information we receive from and about you, and about your relationship with us, with our affiliates and certain third parties for business purposes such as for the third party to provide services to Curion. This section describes the types of third parties we may share your Personal Information with and the purposes for that sharing. Generally, in the past 12 months, we have disclosed the following categories of Personal Information to third parties for business purposes:

Third-Party Service Providers

Your Personal Information may be shared with or collected by third-party service providers who provide us with services, including data hosting and processing. We require these third-party service providers to exercise reasonable care to protect your Personal Information and restrict their use of your Personal Information to the purposes for which it was provided to them.

Anonymous Information

We may provide anonymized (including aggregated) information to third parties. Any anonymized information we provide to third parties is not considered Personal Information and is not subject to the terms of this Policy.

Sale of Our Business; Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, we may transfer or allow third parties to use information owned or controlled by us. We reserve the right, in connection with these types of transactions, to transfer or assign your information and other information we have collected from our customers to third parties or to authorize third parties to use any such information retained by us. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Compliance with Laws and Law Enforcement

Curion cooperates with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties to the extent permitted under applicable law, as we believe is necessary or appropriate to investigate, respond to, and defend against legal claims, for legal process (including subpoenas), to protect the property and rights of Curion or a third party, to protect Curion against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Services and our Sites and any equipment used to make the Services or Sites available, or to comply with applicable law.

Selling Your Personal Information

We do not sell your Personal Information and have not done so in the past 12 months. Please note that we do provide reports with the results of our studies to the sponsors of the studies, and such reports include aggregated and de-identified information from Panelists, which is not Personal Information.

Managing Your Personal Information

You may decline to share certain information with us, in which case, we may not be able to permit you to participate in some studies. To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times.

Updating Profile Information

Periodically, Curion will send you an email request to update your profile or you can update your basic profile information at any time by logging into your account or contacting us through the contact information provided on our Panelist Support page.

Opt-Out Policy

If at any time you wish to opt out of receiving communications from Curion, please contact us through the contact information provided on our Panelist Support page or log on to your account profile to unsubscribe via the unsubscribe link. Once you unsubscribe, you will no longer receive email invitations from Curion.

Employment Information

Employees and job applicants can manage their personal information by contacting our HR department through our internal communication system or at: jobs@curioninsights.com.

Security

Curion is committed to protecting the security of the Personal Information you provide to us and that we collect about you. We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Information that you provide to us. Nevertheless, when disclosing Personal Information, you should remain mindful that there is an inherent risk in the use of email and the internet. Your information may be intercepted without our consent, collected illegally and used by others without your consent. We cannot guarantee the security of any information you disclose online, and you do so at your own risk.

Children’s Privacy

We do not knowingly collect or allow the collection of Personal Information via the Services from persons under the age of 18, except with the explicit permission of the child’s parent. If we learn that we have collected the Personal Information of someone under the age of 18 without parental permission, we will take appropriate steps to delete this information. If you are a parent or guardian of someone under the age of 18 and discover that your child has submitted Personal Information, you may contact us through the contact information provided on our Panelist Support page or by emailing us at privacy@curioninsights.com and ask us to remove your child’s Personal Information from our systems.

Notice to Individuals Outside the United States

Curion’s directly conducts studies only in the United States, and our Services are only intended for residents of the United States. If you are not a resident of the United States, please do not provide us with any Personal Information through the Services. Curion does work with third-party partners in other countries on some international studies. Any information collected in such studies are done in compliance with local privacy laws. If you are a panelist in an international study, please contact the company you enrolled as a panelist with to manage your information. 

Rights Under California’s Shine the Light Law

Under California’s Shine the Light Law, you have the right, once per calendar year, to request information from us regarding the manner in which we share certain categories of Personal Information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California’s Shine the Light Law, you have the right to send us a request at the designated email address listed below to receive the following information:

• the categories of Personal Information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
• the names and addresses of the third parties that received the information; and
• if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized form that is not specific to you. The designated email address for these requests is: privacy@curioninsights.com.

Curion does not share Personal Information with others for their direct marketing purposes.

Access Requests. You may request that Curion disclose certain information to you about our collection and use of Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request as provided below, we will disclose to you, based on what you request:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business and/or commercial purposes for collecting or selling that Personal Information.
• The categories of third parties with whom we shared that Personal Information.
• The specific pieces of Personal Information we collected about you (also known as a data portability request).
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: (1) sales, identifying the Personal Information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Requests. You may request that Curion delete Personal Information that we collected from or about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request as provided below, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our services providers to:

• Complete the transaction for which we collected the Personal Information, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
• Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes. Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical or statistical research in the public interest that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the ability to complete such research, if you previously provided informed consent.
• To enable solely internal uses that are reasonably aligned with your expectations based on the your relationship with us and compatible with the context in which the you provided the information. Comply with a legal obligation.

How to Submit a Request. To submit an access, data portability or deletion request, please submit a verifiable consumer request to us by:

• Contacting us through our Panelist Support page;
• Emailing us at: privacy@curioninsights.com; or
• For employees, contacting HR.

Only you, or a person that you authorize in writing to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable information request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 

When submitting a verifiable consumer request you must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your requests if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Responses to Requests. We attempt to respond to verifiable consumer requests within 45 days. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period prior to the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Rights Regarding the Sale of Personal Information. California law defines the sale of personal information broadly, and requires companies to disclose whether they sell Personal Information and if they do, offer a mechanism to opt-out of the sale. Curion does not sell any Personal Information as defined by California law. Please note that we do provide reports with the results of our studies to the sponsors of the studies, and such reports include aggregated and de-identified information from Panelists, which is not Personal Information.

Changes to this Policy

We may revise this Policy from time to time in our sole discretion. We will notify you of any material revisions to this Policy, our reward policy or ownership of a specific panel directly via email and may also place notice of the revised Policy on our website or any place through which you access or engage with the Services. Your continued access or engagement with the Services following any amendments to the Policy (or notice of amendments to the Policy) constitutes your acceptance of the Policy as amended. It is your sole responsibility to monitor our Sites for changes to the Policy.

Contact Us

If you have questions regarding our Privacy Policy or the use of Personal Information collected or used by Curion, please contact us through the contact information provided on our Panelist Support page or by emailing us at: privacy@curioninsights.com.