Tourism Consumer Insights Privacy Policy (formerly LJ Research)

EFFECTIVE 25 MAY 2018

Who We Are
• Tourism Consumer Insights (TCI) is a division of the STR Group, which is comprised of STR, Inc. (U.S.), STR Global, Ltd. (U.K.) and its affiliates (collectively, the “STR Group”). TCI is also a Company Partner of the Market Research Society (MRS) and all research complies with the MRS Code of Conduct.
• TCI and the STR Group are privacy conscious global organisations. This means we are committed to protecting the privacy of all individuals who interact with us, including those who participate in one of our research projects. This approach to privacy applies to all personal information, whether in electronic, paper or verbal form. It also applies to our website and online surveys and how we use the websites and surveys to collect information, how we use that information, and the choices that are available to you regarding our use of your personal information.

Privacy Shield
• The STR Group, through STR, Inc. in the U.S., has applied to participate in and is certifying to the U.S. Department of Commerce (DOC), which has jurisdiction over us, that it will operate with the Department in compliance with the EU-US Privacy Shield Framework (the “Privacy Shield”). The STR Group has stated to the DOC that it is committed to ensuring that all personal information that is received or transferred to us from the member countries of the European Union and the European Economic Area is and will continue to be handled according to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
• General information about the Privacy Shield and the Privacy Shield Principles, as well as information about binding Privacy Shield arbitration, can be found at www.privacyshield.gov.

What Information Do We Collect From You and When?
• TCI collects personal information about you when you agree to participate in and when you complete one of our surveys or other research methods which we conduct on behalf of third party companies or our own behalf.
• The personal information we collect usually consists of your name, an email address, phone number, and mailing address, as well as more sensitive information such as gender preference, age, occupation, household income, post code / ZIP code, residency or other personal information to achieve our research objectives.
• At the outset of the research process, either by ourselves or via professionals who we sub-contract services to, we provide respondents with clear information on the background of the research we are undertaking and, if applicable, the reasons for collecting and processing personal data.
• Similarly, when undertaking research we ensure that respondents are aware that 1. their participation in the research is voluntary; 2.they have a right to withdraw consent or object to processing at any time; 3. they may access their data upon request;, and 4. they may exit and/or unsubscribe entirely from the research at any stage, should they wish to.
• In all research STR undertakes, unless agreed otherwise, the identity of all respondents will remain confidential; responses will not be identifiable when passed to the client.
• We may obtain personal information about you from organisations to which you belong or are a member or from other sources when there is a legitimate interest to invite you to participate in research. To the extent we combine information obtained from these sources with other information we may have collected about you, we will treat the combined information as personal information under this Privacy Policy. Of course, we are not responsible for the accuracy of any information provided to us by a third party.
• Also, to ensure that our websites are well managed and to facilitate improved navigation within the sites, we or our service provider(s) use cookies (small text files stored in a user’s browser), web beacons (electronic images that allow the websites to count visitors who have accessed a particular page and to access certain cookies), or similar tracking technologies (collectively, “Tracking Technologies”) to collect aggregate data. Specifically, we use such Tracking Technologies to track information on our systems and identify categories of visitors by items such as IP address, domain, browser type and pages visited. These Tracking Technologies do not collect any additional personal information about you. We do not link the information collected by these Tracking Technologies to your IP address or anything that could be considered personally identifiable information.
• The Tracking Technologies includes Google Analytics for tracking, as well as a “pop-up” application provided by Tawk.to which gives those visitors the option to engage with us in real time.
• You may learn more about how Google uses the information it collects by visiting the following site “How Google uses data when you use our partners’ sites or apps” (located at https://www.google.com/policies/privacy/partners/). Google’s ability to use and share information collected by Google Analytics about your visits to our websites is restricted by the Google Privacy Policy (located at https://www.google.com/policies/privacy/). Tawk.to functionalities and other information may be found at https://www.tawk.to/.

Why Do We Need The Information That We Collect from You?
• We undertake research on our own behalf and for a variety of clients. We and our client look forward to hearing what you have to say, learning more about you and understanding your behaviour and attitudes relating to our research topics. Gathering this information helps us and our clients, among other things, to improve products and services and to inform business decision making.
• Often our research includes providing verbatim comments to our clients. To reassure you, unless you agree otherwise, no personal details are attached to any of these comments. This safeguards the privacy of all those who participate in our research. In the instances when you agree otherwise (which will be made explicitly clear), only enter your name and contact details if you would like a response to your comments.
• If an email address is given for any other purpose within our surveys it will be used only to inform the winner(s) of a prize draw or, upon your active consent, to receive marketing information from our client and/or to participate in future research. It will never be passed to the client or passed to any third party for any other purpose and, to summarise the above, it will only ever be used as instructed by you.

You May Access Your Information, Correct It And Delete It
• We are dedicated to providing reasonable access to individuals who wish to review the personal information we have retained so that they may correct any inaccuracies it may contain or opt to delete the information.
• If you wish to see the information about you that we have in our possession, if you wish to correct this information or if you wish to have it deleted in its entirety from our systems, please email us at infotci@str.com or telephone number +44 131 6236236.
• While we will respond to your request as quickly as possible, please allow us no more than 30 days for any personal information about you to be accessed, extracted, modified or deleted from our servers, and those of our third party vendors/sub-contractors.
• We will certainly respect and fulfil your request to have your information removed from our system. However, please note that such removal may result in you no longer being able to take part in ongoing research in which you have previously indicated you wish to be a participant.
Also, please bear in mind that, even if we delete your information, it may still persist on back up tapes and archival documents or electronic media on which other business critical information is stored and which TCI must retain for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes. Access to such archival information is limited to only authorised personnel who are under an obligation to maintain its confidentiality.

How Do We Protect Your Information?
• TCI and the entire STR Group takes appropriate administrative, physical, and technical measures (collectively “Security Measures”) to protect your personal information from loss, misuse, unauthorised access or disclosure, alteration and destruction.
• Some non-research related data collected by STR Group is transferred to the U.S. However, in order to keep your personal information as secure as possible, all data collected by TCI is stored within the European Economic Area.
• To ensure business continuity, TCI backs-up all data and systems on a regular basis and backed-up files are retained in multiple locations to enable recovery of files/data, as required.
• TCI works with software developers and IT specialists to support and constantly improve our business systems. Our systems have been specially programmed and are hosted on secure servers operated by datacentres that hold ISO27001 accreditation for their information security management. The datacentres used offer perpetual on-site support in case of hardware issues with our servers, and their communications backbones provide connectivity to the internet in excess of 99.9% of time.
• In addition to our specially programmed systems, we use secure systems and servers provided by third party organisations to process, protect, store and back up our data.
• The hardware and network infrastructure deployed by our IT specialists is designed to eliminate or minimise disruption to TCI should faults arise. As our applications and data are backed up in multiple locations, we can redeploy remotely to alternative datacentres or on a local network as an intranet solution, if required.
• IT specialists for TCI and STR Group are able to operate from disaster recovery sites to provide a continual service to clients should their or our offices be inaccessible or office communications be rendered inoperable.
• No method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of information that is transmitted to us electronically. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. If you have questions about the security of your personal information, our websites or other systems on which your personal information may be transmitted, please do not hesitate to contact us.

Future Changes to Our Privacy Policy
• This Privacy Policy was last revised in May 2018. The law and technology is always changing, as is how we interact with you. Therefore, TCI and the STR Group may need to modify or amend this privacy statement at any time. If so, we will notify you. Any changes to this Privacy Policy will be in effect as of the “Last Updated” date referenced in this Privacy Policy.

For Complaints or Further Enquiries
• If you have any questions about our privacy policy and practices or if you have a complaint about how your data has been handled by the STR Group, please contact us at: infotci@str.com or telephone number +44 131 6236236.