Privacy Policy

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, as defined by numerous statutes in the United States, including the California Online Privacy Protection Act (such statutes, the “PII Laws”), (2) personal information, as defined by the California Consumer Privacy Act (the “CCPA”), (3) personal data, as defined by the European Union General Data Protection Regulation (the “GDPR”), (4) personal information, as defined by the Australian Privacy Act 1988 (the “Australian Act”), and (5) personal information, as defined by Canada’s Personal Information Protection and Electronics Documents Act (“PIPEDA”, and collectively with the PII Laws, CCPA, GDPR, and the Australian Act, the “Privacy Laws”) (collectively, “Personal Information”), which we gather when you are accessing, viewing, completing, or using any of our Research Tools. 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 manage.

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.
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:

Attn: Data Protection Officer
RSG
55 Railroad Row
White River Junction, VT 05001 USA
(802) 295-4999
dataprivacy@rsginc.com

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. Special Categories of Personal Information:

Except as stated otherwise in this Privacy Policy and Project-Specific Documentation, we do not knowingly collect special categories of Personal Information, including (1) Personal Information revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, and (2) genetic data, biometric data, data concerning health, and data concerning a natural person’s sex life or sexual orientation. 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.

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. 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, or on our own servers.

We may:

  • Share certain Personal Information with third parties (as described in this Section and in Section IV below);
  • Share with third parties statistics describing aggregate relationships from Personal Information as part of our research; and
  • Retain Personal Information for research purposes.

We may use GPS information and other Personal Information collected via the Research Tools to infer other Personal Information about you, including your income 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.

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:

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.

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.

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.

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:

Attn: Data Protection Officer
RSG
55 Railroad Row
White River Junction, VT 05001 USA
(802) 295-4999
dataprivacy@rsginc.com

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.

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:

    1. The nature of our relationship with the relevant client;
    2. The existence of other ongoing or expected projects with the relevant client;
    3. The nature of the Personal Information in question; and
    4. Our internal research needs.

VII. What Are Your Rights to Control Your Personal Information?

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 (1) the correction, updating, deletion, or restriction of collection and use of your Personal Information, (2) the categories of Personal Information RSG has collected, (3) the categories of sources from which RSG has collected your Personal Information, (4) the business purpose(s) for collecting and disclosing your Personal Information, (5) an account of how RSG has used or is using your Personal Information, (6) a copy of your Personal Information retained by RSG, to be delivered in a structured, commonly used and machine readable format to review or to transfer or transmit to another entity without hindrance, to the extent that that is technically feasible, (7) the categories of third parties with whom RSG shares your Personal Information, (8) the categories of Personal Information which we share with third parties, and the contact information for such affiliates and/or third parties, and (9) a list of all third parties that have received your Personal Information from RSG. We will respond to all such requests within 45 days, although there may be a brief delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your Personal Information be deleted, we reserve the right to terminate and/or limit your access to our website and/or Research Tools. If we do not have your Personal Information, have not collected your Personal Information, or have not disclosed or transferred your Personal Information to another party, we will inform you in response to a request regarding your Personal Information. Any of the above requests may be made by contacting us at:

Attn: Data Protection Officer
RSG
55 Railroad Row
White River Junction, VT 05001 USA
(802) 295-4999
dataprivacy@rsginc.com

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. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

B. Withdrawal of Consent:

You may withdraw your consent at any time by contacting us at:

Attn: Data Protection Officer
RSG
55 Railroad Row
White River Junction, VT 05001 USA
(802) 295-4999
dataprivacy@rsginc.com

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.

C. 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:

Attn: Data Protection Officer
RSG
55 Railroad Row
White River Junction, VT 05001 USA
(802) 295-4999
dataprivacy@rsginc.com

RSG shall respond within 45 days. Where such objection is received from an individual whose Personal Information RSG collects and uses as the processor for a controller (as those terms are defined in the GDPR), RSG shall inform the controller of the objection within 45 days.

D. 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.C 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: You may file a complaint with the California Attorney General’s Office, although please note that the CCPA is not effective as of the date of this Privacy Policy and that the rules governing the CCPA and the formal complaint mechanism have yet to be established.

Under the Australian Act: You may file a complaint with the Office of the Australian Information Commissioner.

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.

E. 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 XII, RSG does not employ any such automated decision making or profiling at this time.

VIII. 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 and Microsoft Azure 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.

IX. 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 16 or knowingly allow such persons to participate in Research Tools. If you are under 16, 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 16 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 16 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 16, please contact us at:

Attn: Data Protection Officer
RSG
55 Railroad Row
White River Junction, VT 05001 USA
(802) 295-4999
dataprivacy@rsginc.com

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.

X. 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.

 

XI. 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.

 

XII. Automated Decision Making

RSG does not rely on automated decision making, including profiling, that will produce legal effects concerning you or similarly significantly affect you. Per Article 4(4) of the GDPR, profiling is defined as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.”

 

XIII. Transfer of Data

When we transfer personal information from a country of origin to the United States, we do so in compliance with all laws of the originating country. Consistent with the GDPR, we comply with the EU-US Privacy Shield Framework.

 

XIV. 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.

 

XV. Questions or Concerns; Contact Information

If you have any questions or concerns regarding our privacy policies, please contact our data protection officer by sending a detailed message to dataprivacy@rsginc.com. Alternatively, you may contact us by telephone or postal service as follows:

Attn: Data Protection Officer
RSG
55 Railroad Row
White River Junction, VT 05001 USA
(802) 295-4999

We will make every effort to resolve your concerns.

 

XVI. 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: May 1, 2019