Privacy Policy

Effective Date: 28 May 2023

Last Revised: 28 May 2023

This Privacy Policy defines how Inginit Pte. Ltd. (“Inginit”) uses (collects, stores, uses and discloses and otherwise uses) your Personal Data (“Personal Data” which may also be referred to as Personally Identifiable Information or “PII”) and other information described in this Privacy Policy for the members of its panel website elspur.com and mobile app Elspur.


Inginit Pte. Ltd. is established in the Singapore and the information in this Privacy Policy is based on the European Union General Data Protection Regulation (2016/679) or GDPR, which provides a high standard with respect to the protection of Personal Data. However, depending on where you live, other privacy laws and regulations may apply as well. This Privacy Policy applies to residents of every country worldwide.


Inginit will cause its affiliates to, establish and maintain business procedures that are consistent with this Privacy Policy.


ABOUT INGINIT
 

Inginit is a global online market research company that owns and operates elspur panel for its panel members and market researchers, brands for the sharing of consumer opinions and data. Headquartered in Singapore, Inginit has offices in India.

Individuals participate in market research on the elspur platform either via their membership in the elspur panel or via one of our partners who direct participants to a survey or other market research program. Panel Members and Participants participate in surveys or other market research programs for the opportunity to receive and redeem rewards and incentives for their participation.

Inginit by virtue of owning elspur platform is the Data Controller and Data Processor.

Your Personal Data may be used for a number of purposes that are explained below along with examples of categories of Personal information for each purpose. Specific details on the use of Personal information might also be described further within a survey or other market research program. If you would like more information you are always welcome to contact us as described in the “CONTACT US” section below.

INGINIT PROTECTS YOUR PRIVACY
 

Registration and participation in elspur panel owned by Inginit, is subject to Inginit’s Terms and Conditions. You can find Inginit’s Terms and Conditions here.

Your participation in a survey or other market research program is completely voluntary and Inginit’s use of your Personal Data is carried out with your consent. Surveys and other market research programs administered by Inginit’s Clients, Partners or other third parties and the data collected in connection with those surveys and other market research programs are not subject to this Privacy Policy.|

Inginit is committed to the protection of the privacy of Personal Data. Inginit strives to conform its privacy practices to applicable laws, codes, and regulations, and the codes of standards of applicable market and opinion survey research associations, including, without limitation ESOMAR (www.esomar.org) and the Insights Association (www.insightsassociation.org).

HOW IS YOUR PERSONAL DATA COLLECTED ?
 

Your Personal Data will always be collected by fair and lawful means, for specific purposes. For example, Inginit may collect your Personal Data when you register for or participate in our survey panel, complete a survey, participate in another market research program or via automated means or other methods as described in the “WHAT INFORMATION IS COLLECTED BY AUTOMATED TECHNOLOGIES?” section below.

Inginit only collects Personal Data for market research purposes.

WHAT PERSONAL DATA IS COLLECTED AND PROCESSED ?
 

The Personal Data that is processed may include your name, address, telephone number, e-mail address, date of birth, and other similar information. Inginit may collect Personal Data directly from you when you voluntarily provide it to Inginit or Inginit may obtain Personal Data from other Panel Owners, Clients or market research firms who have obtained a Participant’s consent.

Inginit may also obtain Personal Data from database owners who have assured us that their databases comprise only individuals who have consented to be included and have their Personal Data shared. Finally, Inginit may collect and use Personal Data obtained from publicly available sources, such as telephone directories.

From time to time Inginit may collect Sensitive Personal Data which depending on the country in which you live may include, racial or ethnic origin, health records, financial information, political opinions and religious or philosophical beliefs. If Inginit collects your Sensitive Personal Data, Inginit will always obtain your explicit consent.

You may also submit, upload or transmit content or material, including photos, videos, and/or any other similar or related content or material which may include your Personal Data, for example, when participating in surveys or other market research programs. Such Personal data may be used and disclosed as described in this Privacy Policy and should not include audio, video, images, or the likeness of anyone other than you.

HOW IS PERSONAL DATA COLLECTED AND PROCESSED ?
 

Inginit may collect and process your Personal Data for a variety of reasons, including :

Enable your participation in elspur panel gather.

Profiling information about you so Inginit can better target specific surveys and other market research programs to you.

Contact you to invite you to participate in surveys or other market research programs.

Update our records of your Personal Data.

Manage our incentives programs and fulfill your requests for such incentives.

Allow you to participate in sweepstakes (if permitted).

To respond to any messages or requests you may send to us.

Validate your profiling information or answers you provided to a survey or other market research program.

Provide service and support to you; detect and prevent violation of our Terms & Conditions; to investigate suspected fraudulent activity or violation of another party’s rights; to respond to duly authorized information requests of governmental authorities or where required by law; in connection with the sale, assignment, or other transfer of our business, in which case Inginit will make commercially reasonable efforts to ensure that any such buyer agrees to treat Personal Data in accordance with this Privacy Policy; or as otherwise authorized by you.

From time to time Inginit may collect Sensitive Personal Data which depending on the country in which you live may include, racial or ethnic origin, health records, financial information, political opinions and religious or philosophical beliefs. If Inginit collects your Sensitive Personal Data, Inginit will always obtain your explicit consent.

Please note that receiving email communications may be a requirement of your participation in our surveys or other market research programs. You can opt out from receiving these emails by unsubscribing from surveys or other market research programs.

Inginit always ensures that it is permitted to process your Personal Data. Inginit generally does this by obtaining your consent, however, in limited cases, Inginit may use a statutory condition to process Personal Data.

If a statutory condition applies allowing Inginit to process your Personal Data and you withdraw consent to process your Personal Data this will not necessarily mean that Inginit will cease to process your Personal Data as it may, for example, be under a statutory duty to continue to process your Personal Data for some purposes, e.g. to keep copies of commercial transactions for a minimum of seven years.Inginit always ensures that it is permitted to process your Personal Data. Inginit generally does this by obtaining your consent, however, in limited cases, Inginit may use a statutory condition to process Personal Data.

WHAT INFORMATION IS COLLECTED BY AUTOMATED TECHNOLOGIES ?
 

Inginit may collect certain information automatically. Depending on the country in which you live, such information may be considered Personal Data. Such information includes, but is not limited to information about your device and device capabilities including, but without limitation, the device operating system, the other applications on your device, cookie information, IP address, device network provider, device type, time zone, network status, browser type, browser identifier, unique device identification number (such as Identifiers for analytics or advertising), network provider user ID (a number uniquely allocated to you by your network provider), Media Access Control (MAC) address, mobile advertising identifier, location and other information that alone or in combination may be used to uniquely identify your device. Specific technology is specified below :

Cookies:

A cookie is simply a small text file containing information about the user that is placed by a website on a user’s computer or device. Inginit places cookies on your computer or device for survey and other market research program control and fraud prevention purposes.

Inginit may also use tracking cookies, tags, and scripts to track certain information about you based on your activity on our site or third party sites. Inginit may use this information to determine whether you have seen, clicked on, or otherwise interacted with an online ad or promotion that Inginit is working on to help evaluate for one of our research Clients. Subject to your consent, Inginit may also select you for a survey or other market research program where cookies will be used to expose you to specific advertising or promotions before the survey or other market research program activity for the evaluation of such specific advertising or promotions.

With your consent, Inginit’s Clients or Partners may also place cookies on your computer or device and use those cookies, tags and scripts to track certain information about your activity on certain websites. Inginit’s Clients or Partners may use this information for various market research activities.

If you wish, you can choose not to consent to cookies or choose not to accept cookies by adjusting your web browser’s privacy settings to delete cookies upon exiting websites or when you close your browser. You may also configure your browser to block cookies. Not providing consent, deleting cookies or blocking cookies may exclude you from participating in surveys or other market research programs or negatively impact your user experience. For information on how to opt-out of cookies please refer to the section titled ”HOW DO I OPT-OUT?”

Inginit’s use of cookies is always with your consent.

Mobile Advertising Identifiers :

A mobile advertising identifier is a string of numbers and letters that identifies an individual smartphone or tablet. On iOS, a mobile advertising identifier is called the “Identity For Advertisers” (IDFA, or IFA for short). On Android, the mobile advertising identifier is the GPS ADID (or Google Play Services ID for Android). Inginit may collect mobile advertising identifiers or obtain them from a Partner. Inginit may use mobile advertising identifiers in our market research programs or to share your data with Clients or Partners. Subject to your consent, Inginit may also select you for a survey or other market research program where mobile advertising identifiers will be used to expose you to specific advertising or promotions before the survey or other market research program activity for the evaluation of such specific advertising or promotions.

Inginit will only collect or obtain mobile advertising identifiers with your consent.

Web Beacons :

A web beacon (also known as a tag, clear gif or 1×1 pixel) consists of a small string of code that is embedded within a web page or email. They may or may not be a visible graphic image associated with the web beacon, and often the image is designed to blend into the background of a web page or email.

Inginit may use web beacons in our email messages to help determine whether our messages are opened and to verify any clicks through to links within the email or in advertising or website research to determine if a Participant has viewed ads or other online content that Inginit is measuring. Inginit and our authorized agents may link Personal Data to web beacons for operational and research purposes.

Geo-Location Data :

Inginit may collect geo-location information from your computer or device. Inginit may use your geo-location data for fraud prevention or for market research purposes, including but not limited to advertising research or other tracking-based market research activities. Inginit will obtain your consent if Inginit collects or uses your geo-location information.

Digital Fingerprinting :

Inginit may use digital fingerprinting technology to gather certain data about you and/or your computer or device. This data may include Personal Data such as an IP address, as well as non-Personal Data such as a computer operating system or browser version number. This technology creates a unique computer identifier that may be used for fraud prevention or to identify and track your participation in a survey or other market research program and limit participation in accordance with the requirements of a specific survey or other market research program.

Social Media Information :

You may also be offered the opportunity to participate in surveys and other market research programs through or with social media platforms. If you choose to participate in surveys or other market research programs through or with social media platforms, Inginit may, with your consent, collect certain profile information stored in your social media platform account.

Log Files :

Inginit automatically gathers and stores certain information during survey and other market research program participation. Our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, browser language, the date and time of your request and one or more that may uniquely identify your browser. This information is periodically deleted as part of normal maintenance routines.

Information Inginit Collects from Third Parties :

Inginit may obtain Personal Data, behavioral and/or demographic information from third parties, including, without limitation, data management platforms, ad networks, information service bureaus, other market research suppliers and/or social media platforms. Inginit may use the Personal Data, behavioral and/or demographic data received from these third parties for various purposes, including, but without limitation, data validation, data append, development of marketing insights, fraud detection purposes.

WITH WHO DOES INGINIT SHARE PERSONAL DATA ?
 

Inginit will not make your Personal Data available to any third party without your consent, unless it is required by law, as further specified below.

If a survey or other market research program or other activity includes making Personal Data available to a third party, Inginit will only share your Personal Data with your consent. If data collected is used for statistical modeling to better understand trends and preferences amongst specific groups or audiences within the general population, only limited Personal Data shared will be used only for market research purposes and again only with your consent.

Inginit may disclose your Personal Data, profiling data, or other research data to third parties as follows :
 

In connection with market research services (including our incentives programs), to our agents, contractors or Partners that facilitate such services; provided, however, such parties are restricted from using your Personal Data in any way other than to provide services to Inginit.

With agents, contractors or Partners of Inginit in connection with services that these individuals or entities perform for, or with, Inginit. These agents, contractors or Partners are restricted from using this information in any way other than to provide services for Inginit. Inginit may, for example, provide Personal Data to agents, contractors or Partners for hosting our survey websites, for data collection or processing services, or for sending you information that you requested, but those parties cannot use your Personal Data for their own purposes unrelated to the work they are doing for us.

With Clients of Inginit, but in these cases your Personal Data will only be shared with Clients:
 

i) with your consent or ii) for permitted research purposes in accordance with the codes of the Insights Association and ESOMAR.

In connection with the request or requirement of any lawful request by public authorities, to meet national security or law enforcement requirements.

Pursuant to required legal process, to the related compelling party

When Inginit believes that disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with suspected or actual illegal activity.

In connection with the sale, assignment, or other transfer of Inginit, in which case Inginit will require any such buyer to agree to treat Personal Data in accordance with this Privacy Policy. In the event that a sale, assignment, or other transfer of Inginit is not consummated with a prospective buyer, Inginit will require the third party not to use or disclose your Personal Data in any manner whatsoever and to completely erase the same; or as otherwise authorized by you.

Inginit may license certain limited Personal Data to third parties (e.g., data brokers, data aggregators, etc.) for market research purposes, including, but without limitation, the licensing of individual-level and/or aggregated-level data (e.g., product and/or service purchasing or usage activity, website visitation data, internet search history, etc.) for the development of audience insights and/or look-alike models, for the purpose of sale of such data to the third party’s customers for the purpose of performing analytics and providing marketing intelligence. This information may be shared via a cookie (cookie ID), a mobile advertising identifier, an email address or other method. After look-alike modeling or aggregation have been performed, Personal Data is deleted.

Additionally, identifying information and information collected by automated means may be provided to third parties, including, without limitation, Clients, Partners, agents and/or vendors for the purposes of identifying respondents for re-contact surveys or communications, fraud detection and/or prevention, database matching, data validation, data append, coding, data segmentation, and reward, incentive, and/or sweepstakes or promotion related services.

Inginit may maintain Personal Data or machine identifiable information in order to satisfy your requests and/or Inginit’s business requirements. For instance, Inginit may retain the email address of Participants who opted out to ensure Inginit conform to any such wish. Any retention of Personal Data is done in compliance with applicable laws and regulations. |

Again, Inginit will only share your personal data with your consent.

DOES INGINIT COLLECT INFORMATION FROM CHILDREN ?
 

Inginit does not knowingly collect Personal Data from children below the age where parental consent is required. If Inginit becomes aware that Inginit has inadvertently collected Personal Data from a child below the age where parental consent is required, Inginit will delete such Personal Data from our database.

WHAT SAFEGUARDS HAS INGINIT IMPLEMENTED TO HELP ENSURE THE SECURITY OF YOUR PERSONAL DATA ?
 

The security of your Personal Data is very important to us. Accordingly, Inginit has put in place reasonable technical, physical, and administrative safeguards to protect the information Inginit collects. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Data.

Despite the safeguards Inginit implements, transmissions over the Internet and/or a mobile network are not totally secure and Inginit does not guarantee the security of online transmissions. Inginit is not responsible for any errors by individuals in submitting Personal Data to Inginit.

RETENTION OF PERSONAL DATA :
 

Inginit will store Personal Data no longer than necessary for the purpose of the processing activity or as authorized by you. This period may also be based on Inginit or one of our Partner’s contractual commitments to you, applicable periods of limitation (to bring claims) or according to applicable law.

YOUR RIGHTS :
 

You have the right to review, correct, or delete your Personal Data, subject to applicable laws and regulations. Specifically:

Right of access — You have the right to obtain confirmation and information about the processing of your Personal Data

Right to rectification — You have the right to have any inaccuracies about your Personal Data corrected

Right to erasure — You have the right to have your Personal Data deleted (this right is limited to data which according to law and regulation may only be processed with your consent, if you withdraw your consent for processing)

Right to restriction of data processing — You have the right to require that the processing of your Personal Data be restricted (during the course of any investigation into honoring your request, Inginit’s access your Personal Data will be limited)

Right to data portability — You have the right to have your Personal Data transferred to another party (this right is limited to data provided by you)

If you want to exercise any of your rights, you may contact us with such a request using the contact details provided in the “CONTACT US” section.

Upon receiving a request from an individual, Inginit will attempt to provide the requested information within 30 days, providing that the request is such that it can be reasonably be responded to in that time frame. If more time is required, Inginit will notify you within thirty days

In certain situations, however, Inginit may not be able to provide access to some Personal Data. This may occur when :
 

Providing access to Personal Data would be likely to reveal Personal Data about a third party.

Disclosing the information would reveal confidential commercial information or The information has been collected for the purposes of a legal investigation.

If Inginit denies an individual’s request for access to their Personal Data, Inginit will advise the individual of the reason for the refusal.

HOW DO I OPT-OUT ?
 

Your decision to participate in a survey or other market research program, respond to any specific survey question or provide Personal Data, including Sensitive Personal Data, will always be respected.

You may choose whether or not to participate in a particular survey or other market research program, refuse to answer certain questions or discontinue participation at any time

However, failure to provide certain information or fully participate in a particular survey may preclude you from receiving incentive compensation or participation in future certain research studies. For more information about incentives, please refer to Inginit’s Terms and Conditions by clicking here.

Panel Members of elspur that no longer want to participate in surveys, other market research programs or be subject to the use of automated technologies or other activities, including cookies, can opt-out by visiting the Privacy Settings page of the member portal. The Privacy Settings page can also be reached by clicking on the opt-out links on survey invitations. Finally, Panel Members and Participants can contact us by using the contact details provided in the “CONTACT US” section below.

TRANSBORDER POLICY :
 

As a global organization, Inginit may collect, process, store or transfer your Personal Data outside your originating country.

The (EU) and the European Economic Area (EEA) :

Inginit has contracts in place with service providers and other business providers that require the contracting parties to respect the confidentiality of your Personal Data and to handle European Personal Data in accordance with applicable European data protection laws.

LINKS TO THIRD PARTY WEBSITES :
 

This Privacy Policy applies solely to our surveys and other market research programs, and not to any other product or service. Our surveys or other market research programs may contain links to a number of third party websites that Inginit believes may offer useful information. The policies and procedures Inginit describes here do not apply to those websites. Inginit recommends that you carefully read the privacy policys or policies of each site that you visit for information on their privacy, security, data collection and distribution policies. By participating in any of our surveys or other market research programs or any of our websites following any Privacy Policy change, you freely and specifically give us your consent to collect, use, transfer and disclose your Personal Information in the manner specified in such then-current Privacy Policy.

FOR CALIFORNIA RESIDENTS :
 

Your Rights Under the California Consumer Protection Act of 2018 (“CCPA”) :

Pursuant to the California Consumer Protection Act of 2018 (“CCPA”), and subject to certain exceptions and limitations, Californians can contact Inginit to exercise the rights described below with respect to certain personal information that Inginit holds about them. To the extent those rights apply to you, they are described below. Inginit also handles certain personal information on behalf of Inginit customers. You should contact those customers to exercise any rights you may have with respect to that personal information.

Your Rights :

You have the right to request that we provide details about the personal information we collect, use, disclose and sell. You can submit your request via email to privacy@inginit.com. Inginit reserves the right to verify your identity to our satisfaction, including by asking you to log into your account if you have one.

You are entitled to receive the following :

The categories of your personal information that Inginit has collected in the preceding 12 months.

The categories of sources from which that information was collected.

The business/commercial purpose for the collection or selling.

The categories of third parties with whom Inginit shares personal information.

The specific pieces of personal information Inginit has collected about you (subject to some exceptions).

Because Inginit has disclosed or sold (as those words are defined in the CCPA) personal information to third parties in the last 12 months, you are also entitled to receive: The categories of personal information that Inginit has disclosed or sold in the past 12 months.

Right to Request Deletion of Personal Information :
 

You have the right to request deletion of the personal information we have collected about you (subject to some exceptions). You can submit your request as described above, and we reserve the right to conduct the verification described above.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights :
 

You have the right not to receive unlawful discriminatory treatment by Inginit for the exercise of your privacy rights under the CCPA.

Right to Opt-Out of Sale of Personal Information :
 

You have the right to opt-out of the sale of your personal information by Inginit. You can submit a verifiable consumer request by email at privacy@inginit.com.

List of Categories of Personal Information to be Collected and May Have Been Sold or Disclosed :

Categories of Personal Information Collected :
 

Inginit collects personal information from research participants during and after registration with a panel, including, without limitation, during participation in a survey and in connection with the receipt and redemption of rewards and incentives and/or during the Application/Services registration and download process.

The categories of personal information we may collect include :

“Identifiers” such as :
 

Name, Address(es), Telephone number(s) (including home, cell, and/or business telephone numbers), Email address(es), Date of birth, IP address, Unique device identification number (such as identifiers for analytics or advertising), Network provider user ID (a number uniquely allocated to you by your network provider), Media Access Control (MAC) address, International Mobile Equipment Identity, Unique cookie identifiers, Internet or other electronic network activity information, and other information collected through automated means, such as: Information about your device (e.g., device operating system, the other applications on your device, device network provider, device type, time zone, network status, browser type, browser identifier and other information that alone or in combination may be used to uniquely identify your device), Geolocation, Cookies and similar technology, Social media information, Log files, Digital fingerprinting, Watermarking, Browsing activity, Other behavioral information, Professional or employment-related information, including occupation, Education information, Additional content/material you submit, including photos, videos and/or similar content, Characteristics of potentially protected classifications under California, federal or international law (e.g., health and medical conditions, sexual orientation or sexual life, political opinions/views, race/ethnic origin, gender, religious and philosophical beliefs and trade-union membership), Other medical information, and demographic information.

All of the information above is collected for the purposes described below. In CCPA terms, these purposes include but are not limited to the following examples:

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with the CCPA and other standards.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging to identify and repair errors that impair existing intended functionality.

Short-term, transient uses.

Performing or using services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing or using advertising or marketing services, providing or using analytic services, or providing or using similar services.

Undertaking internal research for technological development and demonstration.

Undertaking activities to verify or maintain the quality or safety of services and devices, and to improve, upgrade, or enhance services and devices, and

Facilitating the operational purposes of Inginit or our service providers.

Categories of Personal Information that May Have Been Sold :
 

Inginit has sold all of the above categories of personal information in the last 12 months.

Categories of Personal Information that Were Disclosed :
 

Inginit has disclosed all of the above categories of personal information in the last 12 months.

CONTACT US :
 

Inginit very much values your opinion and feedback. If you want to review, correct, or delete your Personal Data or have questions, comments or suggestions, or if you would like to opt-out of our surveys or other market research programs or have questions about your Personal Data, please contact us:


Via email at: privacy@inginit.com


Or via postal mail at:


Inginit Pte. Ltd.

Attn: Data Protection Officer (DPO)
14, Robinson Road, #08-01A, Far East Finance building,
Singapore 048545