Privacy Policy
Who We Are and Why We Collect Your Information
Resource Systems Group, Inc. ("RSG," "we," "us," "our") conducts market research on behalf of both public and private sector clients using software applications, smartphones, websites, surveys, computers, tablets, and other means of collecting data (collectively, "Research Tools"). Ultimately, this research allows our clients to deliver better products and services. These products and services range from large infrastructure, like rail service and highways, to consumer products, like tractors or cars.
RSG is committed to protecting the confidentiality, integrity, and security of your personal information. We take this responsibility seriously. This Privacy Policy is intended to help you understand how we collect and safeguard your information. Additionally, prior to interacting with certain Research Tools, we may present you with a license agreement, a terms of use statement, instructions, and/or a privacy policy or information specific to the relevant research project (collectively, "Project-Specific Documentation"), which may contain further terms governing how we treat your information, as discussed more thoroughly in Section I below. By accepting the terms of this Privacy Policy, you hereby consent to our collection, use, and sharing of your information in the following ways:
I. What Does This Privacy Policy Cover?
This Privacy Policy covers our treatment of (1) personally identifiable information (“PII”) protected by data security and breach notification laws in the United States (“PII Laws”), (2) information protected by the California Consumer Privacy Act (“CCPA”), including as modified by the California Privacy Rights Act (“CPRA”), and California Online Privacy Protection Act (“CalOPPA”), if and to the extent those laws apply to information that we collect and process, (3) information protected by the Colorado Privacy Act (“CPA”), if and to the extent that law applies to information that we collect and process; (4) information protected by the Connecticut Personal Data Privacy and Online Monitoring Act (“CTDPA”) information protected by the New York Stop Hacks and Improve Electronic Data Security Act (“SHIELD Act”), if and to the extent that law applies to information that we collect and process; (5) personal data protected by the Virginia Consumer Data Protection Act (“CDPA”), if and to the extent that law applies to information that we collect and process; (6) information protected by Utah Consumer Privacy Act (“UCPA”), information protected by the European Union General Data Protection Regulation (“GDPR”), Canadian Personal Information Protection, and Electronics Documents Act, and Canadian Provincial corollaries of that Act (collectively, “PIPEDA”), the Australian Privacy Act 1988 (the "Australian Act"), and the Brazilian General Data Protection Law (“LGPD”), if and to the extent those laws apply to information that we collect and process, and (7) personal information the confidentiality, availability, or integrity of which is protected by applicable law (such laws collectively with the PII Laws, CCPA, CPRA, CPA, CTDPA, CalOPPA, the SHIELD Act, CDPA, UCPA, GDPR, PIPEDA, the Australian Act, and LGPD, the “Privacy Laws”) (collectively, “Personal Information”), which we gather when you are accessing, viewing, completing, or using and of our Research Tools. Where noted, the terms of this Privacy Policy are limited by the Privacy Laws that govern an individual’s or user’s jurisdiction, such that requirements created by the Privacy Laws of one jurisdiction with regard to Personal Information are not incorporated herein and made to apply to the Personal Information of an individual or user of another jurisdiction if such Privacy Laws would not otherwise govern. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or otherwise control.
Although this Privacy Policy is intended to govern our treatment of Personal Information generally, our Research Tools vary depending on the needs of our clients, and some Research Tools have Project-Specific Documentation that provides additional terms and conditions governing our treatment of your Personal Information. When that is the case, we will provide Project-Specific Documentation to you prior to collecting Personal Information via a Research Tool. In the event of a conflict between the terms of Project-Specific Documentation and the terms of this Privacy Policy, the terms in the Project-Specific Documentation will govern.
II. What Information Does RSG Collect?
RSG does not collect Personal Information indiscriminately. We limit the type of Personal Information and the amount of Personal Information to what is necessary to fulfill the purposes identified in this Privacy Policy and the Project-Specific Documentation. With that in mind, we collect the following types of information:
A. Information You Provide to Us:
We may collect Personal Information from you when (i) you contact us with questions or concerns, and (ii) you visit, interact with, or answer questions from any of our Research Tools. The information we collect depends on the parameters of the research we are conducting. Examples of Personal Information we may collect include the following: your name and contact information; demographic information like gender, age, and household income; home, work, school, and other locations; your travel habits; your opinions and preferences; additional demographic data (which may include race and/or ethnicity); or a user name or e-mail address in combination with a password or security question that would permit access to an RSG survey account you may establish as part of your participation in any survey or other Research Tool. You can choose not to provide us with certain information, although that may disqualify you from using or participating in a survey or other Research Tool.
B. Information Collected Automatically:
When you use a Research Tool, certain information is passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol (IP) addresses, cookies, and Global Positioning System (GPS) location data. These are described in more detail below:
- IP Addresses. RSG sites and Research Tools use IP addresses. An IP address is a number assigned to your computer by your internet service provider to access the internet. In most consumer cases an IP address is dynamic (changing each time you connect to the internet), and not static (unique to a particular user's computer).
- Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, and to provide information to the owners of the site. Most web browsers allow some control of cookies through browser settings. We collect the following information via cookies: aggregate statistical information, information related to your use of this site (including your password, the links you click on, your movement around the site, the pages you visit, the number of times you open a page, and which information is consulted), your IP address, and your browser type. You may be able to change the preferences on your browser or mobile device to send "do not track" signals or to prevent or limit your computer or device's acceptance of cookies, but this may change the functionality of this website or prevent you from participating in some Research Tools. If you click on a link to a third party website, such third party may also transmit cookies to you. This Privacy Policy does not cover the use of cookies by any third parties.
- GPS Location Data. RSG uses smartphone applications to obtain GPS location data passively while a person is part of a survey. These data trace a user's locations over the course of a day, week, month, or year, depending on the monitoring period identified in the Project-Specific Documentation.
Additionally, RSG may passively collect the advertising ID of your device. An advertising ID is a user resettable identification assigned by a device or operating environment. Third parties use it to send advertisements to your device and to track your movements and application usage. In the event RSG collects your advertising ID, we will only do so to the extent permitted by the terms and conditions that govern that device.
C. E-mail and Other Communications:
We may contact you, by email or other means; for example, we may send you promotional offers on behalf of RSG or other businesses, or communicate with you about the Research Tools. When we do this, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please indicate your preference by clicking on the unsubscribe link in any of our emails or by contacting us at:
Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Research Tools and this website, and you are responsible for reviewing such legal notices for changes.
D. Information Purchased from Third Parties
RSG purchases nonpersonal information about mobile device users from third parties, which informs the market research we conduct for our clients. The mobile device users are not identified in the datasets we acquire. The information in these datasets includes the devices' advertising IDs, GPS location data from the mobile devices, information regarding application usage on the mobile devices, and information about general usage of the mobile devices. Although the information in the third party datasets is not Personal Information when RSG acquires it, at times it becomes Personal Information after RSG combines it with the Personal Information we collect via the Research Tools because RSG is able to identify specific individuals in the datasets based on the Personal Information we collect, at which point the information in the datasets about the identified individuals becomes Personal Information that we retain. Please note that when RSG obtains advertising IDs from third parties, we only retain and use them to the extent permitted by the terms and conditions that govern the relevant devices.
E. Special Categories of Personal Information and Sensitive Personal Information:
RSG regularly collects precise geolocation data. At times, depending on the nature of the Research Tools you interact with, you may also provide us and we may collect Personal Information regarding children. With those exceptions, and except as stated otherwise in this Privacy Policy and Project-Specific Documentation, we do not knowingly collect special categories of Personal Information or sensitive Personal Information, including (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, (2) genetic data, biometric data, data concerning health, and data concerning a natural person's sex life or sexual orientation, and (3) government identifiers (such as Social Security numbers and driver’s licenses), financial account and login information (such as credit or debit card number together with login credentials), or content of nonpublic communications (mail, email and text messages), and (4) Personal Information concerning one or more known children. Where Project-Specific Documentation states that we collect and use such information, the Project-Specific Documentation will explain the collection of such Personal Information and request your informed consent.
F. Personal Information RSG Has Collected in the Last 12 Months
RSG has collected the following categories of Personal Information in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the bottom of this document: names; contact information; demographic information; locations where users of Research Tools have traveled; travel habits; opinions and preferences; user names and e-mail addresses in combination with passwords and security questions needed to access RSG survey accounts; IP addresses; information related to the use of RSG's website and the Research Tools; users' browser types; and confirmation when users have read RSG emails.
III. What Does RSG Do With Personal Information?
A. Use of Information
RSG collects your information to answer questions related to the research we are conducting. These questions and your responses allow us to qualify you for a survey, tailor survey questions to you, and ensure that our survey participants are a representative sample of the population we are researching. We will also use your Personal Information to provide market research and analysis to our clients (as described in Section IV.A below), which will allow our clients to improve the goods and services they provide, including, but not limited to, rail service, highway development, tractors, cars, and other consumer goods.
We may use Personal Information to: respond to inquiries and comments; to contact you with administrative communications and changes to this Privacy Policy and our other policies; to operate, maintain, develop and grow RSG; to investigate and resolve disputes and security issues; to comply with regulatory and legal obligations, and for any other lawful, legitimate business purpose.
In certain circumstances, before collecting Personal Information through a survey or software application, we may provide you in Project-Specific Documentation with the name of the client or the category of client, as well as a more detailed description of the purpose for which RSG and the client will use your Personal Information. We store Personal Information on cloud servers, governed by Microsoft Azure server policies, AWS server policies or on our own servers.
We may:
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- Share certain Personal Information with third parties (as described in this Section and in Section IV below);
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- Share with third parties statistics describing aggregate relationships from Personal Information as part of our research; and
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- Retain Personal Information for research purposes, which may include the development of proprietary or open source algorithms, applications, programs, or tools that analyze nonpersonal and Personal Information, assist with market research, or perform consumer modeling, among other functions.
We may use GPS information, other Personal Information collected via the Research Tools, and nonpersonal information acquired from third parties to infer other Personal Information about you, including your income, the advertising ID of your mobile device, and the location of your home, work, and school. We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our site, and administer and improve the site. We may use information collected by cookies to retrieve certain information you have previously provided (e.g., passwords), to help to determine what areas of our website you and other visitors find most valuable, to customize our website based on your preferences, to tell our website server information such as your IP address and your browser type, to improve navigation on this website, to indicate how many times a page is opened and what information is consulted, to improve the content of this website, to communicate information to visitors, to make our website more pleasant, to administer our website, and to track users' movements around our website. We may also use that information for system management and market research purposes.
We may convert Personal Information to nonpersonal information and store and use the nonpersonal information. For example, we may permanently delete the connection between a person's identifying information and location information and retain the location information and knowledge it pertains to a single (unidentifiable) individual. We may also disclose the nonpersonal information to third parties.
B. Storage of Information
Unless noted otherwise in this Privacy Policy or in Project-Specific Documentation, we store and process all electronic Personal Information that we collect from you on electronic information systems in the United States. Some nonpersonal information may remain on data storage systems in the country or territory where the information was originally provided. Hard copies of personal information generally remain in the country of origin.
For Canadian Residents Completing Research Tools in Canada: The previous paragraph notwithstanding, we store and process all electronic Personal Information that we collect in Canada from residents of Canada on electronic information systems in Canada.
IV. Will RSG Share Any of the Personal Information it Collects?
We share your Personal Information with third parties as described below and acknowledge our potential liability if any such third parties misuse your Personal Information.
A. Clients that Have Retained RSG to Perform Research
We disclose Personal Information, nonpersonal information that has been derived from Personal Information, and aggregate information to our client(s), unless such disclosures are specifically precluded by the Project-Specific Documentation. Our clients include, but are not limited to, municipalities, government agencies, political subdivisions, organizations that oversee transportation systems, and manufacturers of consumer goods. At times, we may provide you with more information in Project-Specific Documentation about one or more specific clients, the categories of one or more clients, and/or one or more clients' industry or sector. Our clients are typically based in the United States, Canada, the European Union, or Australia.
B. Third Party Businesses We Do Not Control
We employ other companies and people to perform tasks on our behalf and may need to share Personal Information with them to perform those tasks. In certain situations, we will share Personal Information with third party businesses that may contact you by email or phone to assist RSG to complete surveys and other Research Tools on behalf of our clients. RSG may disclose contact information, including your name, phone number, email address, and physical address, to such third party businesses to facilitate your completion of the Research Tools. Depending on the Research Tool, RSG may also share your contact information with third party businesses that we partner with to send rewards to individuals who complete certain surveys. The third party businesses described in this section are typically based in the United States. Unless we tell you differently, our agents and service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
C. Business Transfers
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.
D. Legal Obligations, Our Protection, and the Protection of Others
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of RSG, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. In addition, in certain situations, RSG may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. RSG will notify you of any such requests unless prohibited by law.
E. With Your Consent
Except as set forth above, we will obtain your consent before disclosing your Personal Information with third parties, and you will be able to prevent the sharing of this information.
F. Personal Information RSG Has Disclosed or Sold to Clients in the Last 12 Months
RSG has disclosed the following categories of Personal Information to our clients in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the bottom of this document: contact information; demographic information; locations where users of Research Tools have traveled; travel habits; opinions and preferences; and further Personal Information RSG infers based on Personal Information and nonpersonal RSG obtains. These disclosures are part of the services we provide to our clients, and such disclosures may qualify as a sale of Personal Information under applicable Privacy Laws, including the CCPA and the CPRA.
G. Personal Information RSG Has Disclosed to Third Parties in the Last 12 Months
RSG has disclosed the following categories of Personal Information to third parties for business purposes in the 12 months immediately preceding the Effective Date of this Privacy Policy, listed at the bottom of this document: names and contact information.
V. RSG's Legal Basis for Collecting and Using Your Personal Information
RSG collects and uses your Personal Information pursuant to your informed consent, which you have granted by (a) confirming the prompts produced by this website and/or for each Research Tool, and (b) continuing to use this website and each Research Tool, consistent with this Privacy Policy and any Project-Specific Documentation. Please note that without your consent to collect and use the Personal Information required in any particular survey or other Research Tool, RSG may disqualify you from using or participating in a survey or other Research Tool. If you have any questions concerning the terms of this Privacy Policy and the conditions of your consent, please contact us at:
To the extent that you provide RSG with the Personal Information of other people, you warrant and represent that each such person who is required under the Privacy Laws to give consent, or the person who is required to give consent, if the Privacy Laws require the consent of another person, has granted his or her consent to you sharing his or her Personal Information with RSG for the use described in this Privacy Policy and any Project-Specific Documentation. To the extent that you provide RSG with the Personal Information of one or more known children, you warrant and represent that you grant RSG verifiable parental consent to do so or have obtained verifiable parental consent to do so.
For individuals and Personal Information Subject to the GDPR: In addition to relying on informed consent, RSG reserves the right to process your Personal Information (1) in order to pursue our legitimate business interests in performing research for clients to deliver better products and services, including improved infrastructure, like rail service and highways, and consumer products, like tractors and cars, and/or (2) in order to perform a contract to which you are a party. Where the processing is based on a contractual requirement, your failure to provide the relevant Personal Data may result in RSG terminating the contract. Any one or more of these bases are the legal basis for RSG's collection and use of your Personal Information, depending on (x) how you use this website and the Research Tools, and (y) your relationship with RSG.
VI. How Long Will RSG Retain Your Personal Information?
Except upon the request of an individual, as explained in Section VII below, and except as the law permits and requires, RSG maintains Personal Information as follows:
a. When our contract with a client requires that we delete all information that we have collected and processed at the end of a project or after a defined period of time, we will do so.
b. Other than that, we will determine the retention period based on the following criteria:
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- The nature of our relationship with the relevant client;
- The existence of other ongoing or expected projects with the relevant client;
- The nature of the Personal Information in question; and
- Our internal research needs.
VII. What Are Your Rights to Control Your Personal Information?
To the extent required by the Privacy Laws, except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding RSG's collection and use of your Personal Information.
A. Requests to RSG:
You may request the following from RSG with respect to your Personal Information:
i. Correction, and updating, your Personal Information;
ii. Erasure or deletion of select portions of your Personal Information or all Personal Information;
iii. The categories of your Personal Information that RSG collects or processes;
iv. The categories of sources from which RSG collects or processes your Personal Information;
v. The expected period for which RSG will store your Personal Information, or if not possible, the criteria used to determine that period;
vi. The business or commercial purpose(s) that RSG collects and disclosing your Personal Information;
vii. A description of how RSG has used or is using your Personal Information;
viii. A copy of your Personal Information, including the specific pieces of Personal Information, in a format that is easily understandable to the average consumer, and to the extent technically feasible, in a structured, commonly used, machine-readable format, which also may be transmitted to another entity at your request without hindrance;
ix. Categories of third parties with whom RSG shares your Personal Information, and list of third parties with whom RSG has shared your Personal Information;
x. Object and opt-out of processing of your Personal Information;
xi. Limit processing of your Sensitive Personal information;
xii. Categories of your Personal Information that we have sold, traded, exchanged, brokered or shared with third parties, including Customer Employers, and the categories of third parties to which we have shared each particular category of Personal Information;
xii. Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties;
xiv. Your specific Personal Information RSG has collected, used, or disclosed.
If you request that your Personal Information be erased or deleted or that RSG otherwise restrict its collection and use of Personal Information, we reserve the right to terminate and/or limit your access to our website, the Research Tools, and any financial incentives we have provided, subject to the terms of Sections VII.H and VIII below. If RSG has not collected or processed your Personal Information, or has not shared your Personal Information with another party, RSG will inform you of that in response to any of the above requests. Some information may remain in RSG’s backup media after erasure or deletion for a period of time. When you request that RSG update information, RSG may retain a copy of the unrevised information in RSG’S records. RSG also may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
We will confirm receipt of all such requests, provide information about how RSG will process the request, and substantively respond to all such requests consistent with the Privacy Laws. There may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party.
Our verification process varies based on the source and nature of the request, but may include: comparing data in the request against Personal Information we retain; contacting you using other contact information; requesting further information, although we will avoid doing so to the extent possible; and the consideration of certain factors, including the type, sensitivity, and value of your Personal Information, the risk of harm to you posed by an unauthorized request, the likelihood that fraudulent or malicious actors would seek your Personal Information, the manner in which we interact with you, the available technology, and whether the information you have provided to verify your identity is sufficiently robust to protect against fraudulent requests. To the extent permitted by the Privacy Laws, RSG retains the right to deny any request if we cannot verify that it originated from you.
RSG retains records of all of the above requests and our responses as required by the Privacy Laws.
When you update information, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account.
RSG may use any anonymized aggregated statistical data derived from or incorporating Personal Information after it is updated, erased, or deleted, but not in a manner that would identify you.
Any of the above requests may be made by contacting us at:
For EEA Residents: Please contact our EU Representative at EURep@rsginc.com. Alternatively they can be reached by post (Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2) or +353 1 631 9460 www.dpocentre.com.
B. Authorized Agent
You may authorize an agent to take any of the acts permitted in this Section VII on your behalf. To do so, you must provide written and signed authority to the agent, and written and signed notice to RSG that RSG may act on such requests by that agent.
C. Withdrawal of Consent
You may withdraw your consent at any time by contacting us at:
Please be aware that such withdrawal does not affect the lawfulness of RSG's use of your Personal Information before such withdrawal. Withdrawal of consent may affect the functionality of this website and your ability to participate in surveys and other Research Tools. RSG reserves the right to revoke any financial incentives offered following your withdrawal of consent.
D. Object or Challenge
You may object, on grounds relating to your particular situation, at any time to the collection and use of your Personal Information based on RSG's legitimate interests or based on public interests, or otherwise challenge our compliance with the Privacy Laws, by contacting us at:
RSG shall respond as required by the Privacy Laws. Where such objection is received from an individual whose Personal Information RSG collects and uses as the processor for a controller pursuant to the GDPR, RSG shall inform the controller of the objection within a month of receipt.
E. Filing a Complaint
Regulatory authorities that oversee the Privacy Laws, including the Office of the Privacy Commissioner of Canada and the Office of the Australian Information Commissioner, advise individuals to file an objection or challenge with the relevant company before lodging a formal complaint with a regulatory authority. If you are dissatisfied with RSG's response to an objection or challenge filed under Section VII.D above, or you if wish to file a complaint with a regulatory authority first, you may do so as follows:
Under PIPEDA: You may file a complaint with the Office of the Privacy Commissioner of Canada.
Under GDPR: You may file a complaint with a supervisory authority in the relevant European Union member state.
Under PII Laws: You may file a complaint with the relevant state's Attorney General's office.
Under the CCPA/CPRA: You may file a complaint with the California Attorney General's Office.
Under CPA: You may file a complaint with the Colorado Attorney General’s Office.
Under CTDPA: You may file a complaint with the Connecticut’s Attorney General’s Office.
Under UCPA: You may file a complaint with the Utah Attorney General’s Office.
Under VCDPA: You may file a complaint with the Virginia Attorney General’s Office.
Under the Australian Act: You may file a complaint with the Office of the Australian Information Commissioner.
Under the Data Privacy Framework: Please see Section XV.
Please note that the links above are subject to change by the relevant regulatory authorities and that you may need to go to another site or contact the relevant authority in another way in order to properly file a complaint.
F. Prohibit Automated Processing
At your request, RSG will terminate any automated decision making, including profiling, that is the sole source of decisions that produce a legal effect concerning you or similarly significantly affect you. Please note that consistent with Section XIII, RSG does not employ any such automated decision making or profiling at this time.
G. "Do Not Sell or Share My Personal Information"
You may opt out of all disclosures of your Personal Information by completing the form at the following link:
We will act upon any request to opt out of all disclosure of your Personal Information, including notifying all third parties to whom we have disclosed, sold or shared your Personal Information and ceasing to disclose, selling or sharing your Personal Information, consistent with the requirements of the Privacy Laws.
If you exercise your right to opt out of all disclosures of your Personal Information, RSG will cease disclosing your Personal Information to clients and other third parties as of the date RSG receives the form at the link above. RSG will not contact you about opting in to disclosing your Personal Information for at least 12 months following receipt of the form. In the event you opt out of the disclosure of your Personal Information, we reserve the right to terminate or limit your access to this website and the Research Tools and to revoke any financial incentives offered.
H. Non-Discrimination
RSG will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws, including, but not limited to by:
1. Denying goods or services to you;
2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
3. Providing a different level or quality of goods or services to you; and
4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Consistent with Privacy Laws, RSG: (i) retains the right to charge you a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to RSG by your Personal Information; (ii) may offer financial incentives, including payments to you as compensation, for the collection, disclosure, or deletion of your Personal Information; (iii) may enter you into a financial incentive program only if RSG clearly describes the material terms of the financial incentive program, so long as you give RSG prior opt-in consent, which you may revoke at any time; and (iv) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.
VIII. What Financial Incentives Does RSG Offer?
RSG may offer rewards to individuals who complete certain Research Tools in their entirety. These rewards include gift cards or certificates. If you do not complete the Research Tool for which the reward is offered, in their entirety, RSG may not give you the reward. Any financial incentive offered represents a good-faith estimate of the value of the Personal Information collected by the relevant Research Tool based on our contract with the client.
Where a Research Tool offers a financial incentive for completion, the Project-Specific Documentation will provide more information. You may opt not to receive any offered financial incentives by following the instructions in the Project-Specific Documentation or by completing the form at the following link:
Consistent with our non-discrimination policy in Section VII.H above and the Privacy Laws, RSG retains the right to withdraw or withhold financial incentives if you opt out of the disclosure of your Personal Information to our clients.
IX. Is Personal Information About Me Secure?
We use appropriate technical, administrative, and physical safeguards to protect against loss, unauthorized access, destruction, misuse, modification, and improper disclosure of the personal information we collect, in both physical and electronic format. To that end, we use Secure Sockets Layer (SSL) encryption, Microsoft Azure cloud services and AWS cloud services, which comply with various globally recognized security practices and standards to protect the personal information submitted to us, both during transmission and once we receive it. We take reasonable and appropriate steps to contract for and monitor the services we use to determine that they remain compliant with such practices and standards. We also provide information security awareness training to our staff and conduct periodic quality assurance audits. We endeavor to protect the privacy of your Personal Information that we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of information at any time.
At times, your access to the Research Tools is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser.
Our website and the Research Tools may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site's privacy policy.
X. Children's Privacy
Except as stated otherwise in Project-Specific Documentation, we do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to participate in Research Tools. If you are under 18, please do not attempt to register for Research Tools or send any information about yourself to us, including your name, telephone number, or email address. No one under age 18 may provide any Personal Information to us or through the Research Tools. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible, except as provided below. If you believe that we might have any information from a child under age 18, please contact us at:
Please note that at times, depending on the nature of the Research Tools you interact with, you may also provide us and we may collect Personal Information regarding children, subject to verifiable parental consent, which you warrant per Section V above. Upon request, we will provide a parent or guardian who has provided proper identification with the following: (1) a description of the specific types of Personal Information collected from the child, (2) the opportunity to refuse or permit RSG's further collection and use of Personal Information from the child, and (3) a reasonable means for the parent or guardian to obtain any Personal Information collected from the child. If a parent or guardian does not permit RSG's continued collection and use of Personal Information from a child, RSG will delete the child's Personal Information and terminate the account of the child, as applicable.
XI. Contractual or Statutory Requirement
Except as noted in this Privacy Policy or in Project-Specific Documentation, RSG's collection and use of Personal Information is not a contractual or statutory requirement or a requirement necessary to enter into a contract.
XII. Failure to Provide Personal Information
You can always opt not to disclose information to us, but keep in mind some information may be needed to participate in some surveys or other Research Tools.
XIII. Automated Decision Making
RSG does not rely on automated decision making, including profiling, and will not subject you to decisions based solely on automated processing, that will produce legal effects concerning you or similarly significantly affect you.
XIV. Transfer of Data
A. Generally
If and to the extent RSG transfers Personal Information from another country into the United States, RSG does so in compliance with the Privacy Laws of the originating country and for purposes outlined in this Privacy Policy. If and to the extent we transfer Personal Information of individuals in the EEA, or the UK to the United States, we do so under the EU-U.S. DPF, and the UK Extension to the EU-U.S. DPF (as those terms are defined below). In addition, we also implement the Standard Contractual Clauses (approved by the European Commission) and the UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where appropriate. If you have any inquiry regarding our adherence to the Data Privacy Framework, see section XV below, or contact us as provided in section XVII below.
XV. Data Privacy Framework Notice
RSG complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce (collectively, the “Data Privacy Framework”) with respect to Personal Information we process from the EEA, and the UK and transfer to the United States.
RSG has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of Personal Information received from the European Union and the United Kingdom (and Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/.
The Federal Trade Commission has jurisdiction over RSG’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.
A. Liability for Onward Transfers
We remain responsible and liable for the Personal Information that we receive under the Data Privacy Framework and subsequently transfer or disclose to third parties for external processing on our behalf. RSG shall remain liable under the DPF Principles if such third parties process Personal Information in a manner inconsistent with the DPF Principles, unless RSG proves that it is not responsible for the event giving rise to the damage.
B. Compelled Disclosure
In certain situations, RSG may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. RSG will notify you of any such requests unless prohibited by law.
C. Recourse Mechanism and Binding Arbitration
In compliance with the Data Privacy Framework, we commit to resolve DPF Principles-related complaints about our processing of Personal Information. EU, and UK citizens with inquiries or complaints regarding our processing of Personal Information received in reliance on the Data Privacy Framework should first contact RSG. In the event such complaints concerning our processing of Personal information received in reliance on the Data Privacy Framework remain unresolved, EU, and UK citizens may refer such unresolved complaints to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you.
In case your complaint indicates a violation of obligations under the DPF Principles, and your complaint cannot be resolved directly with RSG, or through the independent dispute resolution mechanism stated above, you may have the right to invoke binding arbitration under certain circumstances. For additional information on this option, please see Annex I of the Data Privacy Framework.
D. Periodic Review and Verification
RSG will renew its Data Privacy Framework certification annually, unless we subsequently determine that we no longer need such certification or employ a different adequacy mechanism. Prior to such re-certification, RSG will conduct a self-assessment to ensure that our attestations and assertions with regard to processing of Personal Information is accurate and that RSG has appropriately implemented these practices.
XVI. Changes to this Privacy Policy
We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our website or sending you an email. You are bound by any changes to the Privacy Policy when you use this website or any Research Tool after such changes have been first posted.
XVII. Data Privacy Officer; Questions or Concerns; Contact Information
If you have any questions or concerns regarding our privacy policies, or about RSG’s processing of your Personal Information, please contact our data protection officer as follows:
Tim Young, CTO
Resource Systems Group, Inc.
55 Railroad Row, Suite 200
White River Junction, VT 05001
802.295.4999
Alternatively, you may contact us by sending us an email at dataprivacy@rsginc.com or contact us as follows:
We will make every effort to resolve your concerns.
XVIII. Translations
This Privacy Policy was originally published in English and has been translated into other languages. The content of the English original shall prevail in case of differences in the content or context of other language versions.
Effective Date: December 27, 2023
