Privacy Policy

Last updated: 20.07.2024.

1. Introduction

This Privacy Policy forms an integral part of Our Terms of Use. This Privacy Policy explains how We handle your personal data and ensure that you are informed of our privacy practices.

2. Scope of the Privacy Policy

This Privacy Policy specifies the types of personal data We obtain through Our website https://thumbsupsurvey.com/ and Our Services, how We may use that personal data, with whom We may share it and how You may exercise your rights relating to Our processing of that data. The Privacy Policy additionally describes the measures We take to secure your personal data and how You can contact Us to learn more about Our privacy practices. This Privacy Policy applies to all the services, websites and apps offered by Nexus Media Ltd, and its affiliates/partners, except where otherwise specified.

By accessing or browsing Our website and using Our Services or responding to surveys sent by Our Customers, You confirm that You have read, understood and agreed to this Privacy Policy in its entirety. If You do not agree with the practices described in this Privacy Policy, You should not use Our website or Services.

This Privacy Policy is applicable to three categories namely: (1) Customers and Users; (2) Respondents; (3) Subscribers/Visitors.

3. Definitions

Capitalized terms used in this Privacy Policy but not defined herein shall have the same meaning as defined in the Terms of Use. For the purposes of this Privacy Policy, the following definitions and rules of interpretation shall apply:

“Personal data” means any information that can be used to identify, locate, or contact an individual directly or indirectly which is obtained from or provided by You through the use of Our website and/or Our Services.

“Customer(s)” means an individual, a company or other legal entity who registers with Us to obtain an Account and have access to use Our Services.

“User” means an individual who is authorized by a Customer to use Our Services, for whom a Customer has purchased a subscription (or in the case of any Services provided by Us without charge, for whom a Service has been provisioned), and to whom a Customer (or, when applicable, Us at the request of a Customer) have supplied a user identification and password (for Services utilizing authentication). Users may include, for example, Customers’ employees, consultants, contractors, agents, and third parties with which the Customers transact business.

“Respondent” means and includes an individual who receives or responds to surveys sent by Our Customers and Users or otherwise interacts with Our Customers and through Our Services.

“Subscriber” means and includes anyone who subscribes to Our email notifications, newsletters, marketing campaigns etc.

“Visitor” means and includes anyone who visits and/or uses or otherwise interacts with Our website https://thumbsupsurvey.com/.

“Services” has the meaning given to it in the Terms of Use located at Our website.

“You” and “Your” means, depending on the context, either (1) Customers and Users; (2) Respondents; (3) Subscribers/Visitors or all of the above collectively.

4. Source of Collection of Information

We may collect, process and use information about You when You:

• Register with Us to obtain an Account and have access to use Our Services
• Interact with Our Services
• Connect to Our Services through third parties, including social media accounts, email accounts and business partners
• Contact Us for any support or information
• Respond to a Survey sent by Our Users
• Visit Our website https://thumbsupsurvey.com/

We collect certain information about You when You submit or provide it to Us directly. When You interact with Our Services online, We also automatically collect information about You and Your use of Our Services through the use of log processes, cookies and other similar tracking technologies. Certain other information is collected about You from third parties, such as when You connect through a third party service or business partner site.

5. Who this privacy policy applies to

This Privacy Policy applies to three categories, namely: (1) Customers and Users; (2) Respondents; (3) Subscribers/Visitors.

5.1 Customers and Users

For the purpose of this Section “You” and “Your” applies to Customers and Users.

You will be solely responsible to respond to requests raised by the respondents in exercise of their data protection rights.

5.1.1 What information about You do We collect?

5.1.1.1 Registration data and billing data

These are the data we collect about You when:

1. You register with Us to obtain an Account on our website  https://thumbsupsurvey.com/ and have access to use Our Services,
2. You launch a survey
3. You are paying for Our Services

The data We collect are the following:

• Email
• Full name
• Company name
• Country
• State
• Address
• City
• Zip code
• Tax id number
• Phone number
• Billing email
• IP address
• Location
• Device
• OS information

Payments are made by credit card, debit card or bank transfer. You will be requested to submit credit/debit card or bank account details for purposes of payment which are not accessed or stored by Us at any stage and are automatically submitted to Our external payment gateway operated by a third-party supplier, which is the cooperating bank. These data may include the following:

• Card number
• Expiration date
• Security code
• Name on card
• IBAN
• Bank address
• Account name
• Address
• Email

Please note that payment processing is handled by intermediary service providers on Our behalf, who collect Your payment information to process Your payment to Us. Paying with a credit/debit card or bank transfer is a totally secure payment method for Our Customers. We will never have access to Your card information or Your bank account. For the payment of Your order, We redirect you to the website of the cooperating bank, without ever coming into contact with the details and data of Your credit/debit card or bank account. These details are entered directly by You using an encrypted connection to the secure systems of the cooperating bank. The information remains encrypted and is not disclosed to any third party. Please refer to the respective cooperating bank regarding their Privacy Policy and how they process Your personal data.

5.1.1.2 Communication Data

If You choose to communicate with Us, We may collect and store such communication data, including the content of our communications.

5.1.1.3 Cookies

Our website https://thumbsupsurvey.com/ uses cookies. When You first visit Our website, We will provide You with a cookies permission banner seeking Your consent to use of cookies as required by law. Our Cookie Policy, incorporated by reference to this Agreement is located at Our website. Please refer to Our Cookie Policy for further information about how We use cookies.

5.1.1.4 Usage data and Account settings

Whenever You use Our website and Services, We may collect usage information about You like the webpages You visited within Our website, language preferences etc.

5.1.1.5 Other data

We may collect other data from You through testimonials, communication forms or information You intentionally share with Us in other contexts.

5.1.1.6 Navigational data

We collect data like IP address, geographical location, browser type, device information, length of visit and pages viewed, URL’s of the pages You visit, including those tracked by our browser extension, date and time stamps associated with such browsing, searches, and clicks.

5.1.1.7 Referral data

We collect data like the site/link or any place which led You to visit Our website, e.g. if You were on social media before clicking on a link to Our website, we record information about the source that referred You to Us.

5.1.1.8 Survey data

Your survey data (questions, responses and audience list) is stored with Us. Your survey data is Yours. We grant You the admin role to collect and export the responses as You wish. We do not sell or use survey responses collected by You.

In case the Respondents’ email addresses are collected, We will never use or sell them and We will never send an email to Your survey respondents without Your explicit permission or if required by law.

Survey data is stored on servers located in EU We will process Your survey data on Your behalf and under Your instructions.

5.1.1.9 Analytics

We may use Google Analytics to collect information regarding the behavior and demographics of those using Our services. To prevent Google Analytics from processing Your data, please visit https://tools.google.com/dlpage/gaoptout

5.2 Survey Respondents

For the purpose of this Section “You” and “Your” apply to Survey Respondents.

Surveys are administered by Our Customers and Users. They use Our Services to collect Your information which may or may not include Your personal data, which We do not use for any purposes other than what is required to provide Our Services to Our Customers and Users. We host the surveys on Our website and We act as an intermediary platform for Our Customers and Users to collect the responses that You submit to the survey creators. We don’t sell, misuse or share Your responses to third party advertisers or marketers. However, the policy might be different with the survey creator. We are not responsible for security and privacy practices of Our Customers and Users which may differ from what is set forth in this Privacy Policy. The anonymity of Your responses depends on how the survey creator has configured the survey. So You are advised to check the Privacy Policy of the survey creators as well.

We will not contact You unless directed by Our Customers and Users, in which case We will collect and use Your contact information like name, email address etc, as provided by Our Customers and Users.

If You have any questions about a survey You are taking, please contact the creator of the survey directly, as We are not responsible for the content of that survey or Your responses to it.

5.2.1 What information about You do we collect?

5.2.1.1 Contact Information

You might provide certain personal data like your email to Our Customers and Users when you opt to respond to their surveys. Such personal data is collected and processed by Us only if You have given your prior consent for such processing. However, We will not use your personal data to contact You unless Our Customers and Users direct Us to do so. If You choose to contact Us directly, We may use Your Personal data to communicate with You in response to Your queries.

5.1.1.2 Survey data

Your survey responses are stored with Us. We do not sell or use survey responses collected by You.

Your survey response data are collected, processed and stored anonymously and therefore there are no identifying values that can link the survey response data to You. In other words, We cannot identify that a specific response came from you.

However, if you give your consent, Your email address might be collected, processed and stored by Us, in which case your survey response data will be linked to your email address. In other words, We will be able to identify that a specific response came from You. We will always provide You with a permission banner seeking Your prior consent to collect, process and store your email. You can withdraw your consent anytime. For further information regarding how You can withdraw Your consent, please see clause “6.4 Your Data Protection Rights”.

5.2.1.3 Navigational data

When you visit Our website https://thumbsupsurvey.com/, we collect data like IP address, geographical location, browser type, device information, length of visit and pages viewed, URL’s of the pages You visit, including those tracked by our browser extension, date and time stamps associated with such browsing, searches, and clicks.

5.2.1.4 Referral data

When you visit Our website https://thumbsupsurvey.com/, we collect data like the site/link or any place which led You to visit Our website, e.g. if You were on social media before clicking on a link to Our website, we record information about the source that referred You to Us.

5.2.1.5 Usage data

When you visit Our website https://thumbsupsurvey.com/, we collect data like the webpages you visited within Our website and language preferences.

5.2.1.6 Cookies

Our website https://thumbsupsurvey.com/ uses cookies. When You first visit Our website We will provide You with a cookies permission banner seeking Your consent to use of cookies as required by law. Our cookie policy, incorporated by reference to this Agreement is located at Our website. Please refer to Our Cookie Policy for further information about how We use cookies.

5.2.1.7 Analytics

When you visit Our website https://thumbsupsurvey.com/, we may use Google Analytics to collect information regarding the behavior and demographics of those using Our services. To prevent Google Analytics from processing Your data, please visit https://tools.google.com/dlpage/gaoptout

5.3 Subscribers/Visitors

For the purpose of this section “You” or “Your” applies to Subscribers and Visitors to Our website.

5.3.1 What information about You do we collect?

5.3.1.1 Contact Information

We may collect and process Your Personal data like name, email address etc. that You provide to Us voluntarily when You visit Our website, fill in a contact form, express an interest in obtaining information about Us or otherwise contact Us.

5.3.1.2 Navigational data

We collect data like IP address, geographical location, browser type, device information, length of visit and pages viewed, URL’s of the pages You visit, including those tracked by our browser extension, date and time stamps associated with such browsing, searches, and clicks.

5.3.1.3 Referral data

We collect data like the site/link or any place which led You to visit Our website, e.g. if You were on social media before clicking on a link to Our website, We record information about the source that referred You to Us.

5.3.1.4 Usage data

We collect data like the webpages you visited within Our website and language preferences.

5.3.1.5 Cookies

Our website https://thumbsupsurvey.com/ uses cookies. When You first visit Our website We will provide You with a cookies permission banner seeking Your consent to use of cookies as required by law. Our Cookie Policy, incorporated by reference to this Agreement is located at Our website. Please refer to Our Cookie Policy for further information about how We use cookies.

5.3.1.6 Analytics

We may use Google Analytics to collect information regarding the behavior and demographics of those using Our services. To prevent Google Analytics from processing Your data, please visit https://tools.google.com/dlpage/gaoptout

6. General information

For the purpose of this Section “You” or “Your” refer to Users and Customers, Respondents, Subscribers and Visitors as applicable unless otherwise specifically mentioned.

6.1 Purposes of processing and legal bases for processing

6.1.1 We collect and process Your personal data mainly after You have provided consent to Us for such collection and processing. Your consent is the main legal basis of collection and processing, however, depending on the processing activity, We may further process Your data under legal bases other than Your consent as stated below.

6.1.2 We collect, store and process Your personal data for the following purposes:

(a) to provide to You the agreed Services, to execute Our contractual obligations towards You and Our Users and Customers and to communicate with You in response to Your queries. [Legal basis of processing activity: Your Consent/execution of contract].

(b) To provide to You, information about Ourselves and Our Services, which may be of interest to You. Processing for the above-mentioned purposes takes place only if and after You have provided specific consent by ticking the relevant box in the registration form. You can withdraw Your consent at any time. [Legal basis of processing activity: Your Consent/execution of contract]

(c) To manage and protect Our business (including in case of reorganization, sale of assets, merger or acquisition, liquidation and similar processes), for improving data security, fraud prevention, troubleshooting data and systems, system maintenance and testing, data hosting, managing Our offices and other facilities. [Legal basis of processing: legitimate interests]

(d) To comply with applicable laws in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity or other legal process. We also reserve the right to disclose data collected by Us, as We believe, in good faith, is appropriate or necessary to take precautions against liability; to protect Ourselves and others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend Ourselves against any claims or allegations; to assist government enforcement agencies; to protect the security or integrity of Our Services and Our other property; or to protect the rights, property, or safety of Us, Our users, or other persons or entities. [Legal bases of processing: legitimate interests/Legal or regulatory obligation]

(e) For further internal analyses and statistical purposes, related to the interaction between Us and Our Customers. [Legal base of processing: legitimate interests]

(f) To answer to Your requests and satisfy Your data protection related rights. [Legal base of processing: consent/execution of contract/Legal or regulatory obligation]

6.1.3 We will only use Your personal data for the purposes for which We collected it as detailed above. If We need to use Your personal data for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so.

6.2 Disclosure of Your personal data

6.2.1 We do not sell, trade, disclose, release, transfer, make available or otherwise communicate to outside parties Your personal data for monetary or other valuable consideration. This does not include website or service hosting partners and other parties who assist Us in operating Our website or Services, conducting Our business, or serving Our users. We may also disclose Your personal data when such disclosure is appropriate to comply with the law, enforce Our site policies, or protect Ours or others’ rights, property or safety. More specifically, we disclose or may disclose Your personal data to the following data-recipients who supply services to Us:

6.2.2 We require from all third parties with whom We share Your data to agree and warrant that all the processing operations in which they engage shall be lawful and compliant with applicable law, the provisions of the GDPR and any further Data Protection Legislation which may be applicable. We also require that they provide, in particular in terms of expert knowledge, reliability and resources, sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of applicable law and ensure the protection of the rights of the data subject.

6.3 Data Retention

We may retain Your personal data to fulfill the purposes outlined herein for as long as required in order to provide Our services to You, in order to comply with applicable law, in order to protect Our business and legal interests and in order to fulfill internal client/business record keeping purposes.

6.4 Your Data Protection Rights

6.4.1 In Your capacity as a data subject whose data is collected and processed by Us, You have the following rights:

(a) the right to withdraw Your consent at any time and without detriment, without affecting the lawfulness of processing based on consent before its withdrawal, by notifying such withdrawal to Us.

(b) the right to request from Us access to and rectification or erasure of personal data or restriction of processing concerning You and to object to processing as well as the right to data portability;

(c) the right to receive notifications regarding rectification or erasure of Your personal data or restriction of processing that takes place following Your request;

(d) the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects you, and

(e) to lodge a complaint with a supervisory authority, in particular in the Member State of Your habitual residence, place of work or place of the alleged infringement if You consider that the processing of personal data relating to You infringes the GDPR.

6.4.2 We reserve the right to not satisfy in whole or in part a request from You to exercise one of the aforementioned rights, if such non-satisfaction is grounded on the provisions of the GDPR.

6.4.3 If you wish to exercise Your rights under the applicable data protection law (GDPR) contact us by email at info@nexusmedialtd.com. We will respond to Your request without undue delay. Please describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

6.4.4 We cannot respond to Your request or provide You with personal information if we cannot verify Your identity or authority to make the request and confirm the personal data relates to You. For verification purposes We may request from You to provide to Us sufficient additional information. Making a verifiable request does not require You to create an account with Us. We will only use personal data provided in a verifiable request to verify the requestor’s identity or authority to make the request.

6.4.5 We do not charge a fee to process or respond to Your verifiable 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.

6.5 Third-party links

Occasionally, at Our discretion, We may include or offer third-party products or services on Our website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, We seek to protect the integrity of Our website and welcome any feedback about these sites.

6.6 Security

We implement appropriate technical and organizational measures to ensure the security of Your personal data, including protection against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access. In assessing the appropriate level of security, we take due account of the state of the art, the costs of implementation, the nature, scope, context and purpose(s) of processing of personal data and the risks involved in the processing for the data subject. The technical and organizational measures we implement include the following:

• pseudonymization and encryption of personal data
• ongoing confidentiality, integrity, availability and resilience of processing systems and services
• ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
• regularly testing, assessing and evaluating the effectiveness of technical and organizational measures in order to ensure the security of the processing
• protection of data during storage
• ensuring physical security of locations at which personal data are processed
• ensuring data minimization
• limited data retention
• ensuring accountability
• allowing data portability and ensuring erasure

6.7. Amendments to Privacy Policy

We may, at our sole discretion update, change or replace any part of this Privacy Policy according to clause 19 of the Terms of Use. Please note that Your continued use of Our Services following any modification or change to this Privacy Policy constitutes Your acceptance of the amendments to this Privacy Policy. 

6.8 Unsubscribe From Our Communications

If You want to unsubscribe from Our marketing communications, You can do so by clicking on the “Unsubscribe” link provided at the bottom of the emails, updating Your communication preferences, or by sending an email to info@nexusmedialtd.com.

Please note that Users and Customers cannot unsubscribe from transactional emails which relate to their account or Our Services to them.

The following applies only to Survey Respondents: If You provide consent for the processing of your email address and You receive any kind of emails from Our Customers, please note that Our Customers are solely responsible for their emails and communications. Therefore, We cannot unsubscribe You from their communications. You can unsubscribe from Our Customers’ communications either by using the “Unsubscribe” link provided at the end of their emails or by directly contacting them.

If you have any questions or concerns regarding Our Privacy Policy, feel free to send us an email at info@nexusmedialtd.com.