EU and Switzerland Privacy Policy

Effective Date: September 4, 2012

Last Revised: August 7, 2014

Sentient Services, LP, d/b/a icanmakeitbetter.com (“icanmakeitbetter.com”, “we” or “our”) respects your privacy and is committed to protecting your personal information. We perform market research and other services on behalf of our customers. Specifically, our platform enables Site Users and Business Subscribers to create, share and act upon ideas to drive innovation and make everything, and every day better. A “Site User” is defined as any entity accessing icanmakeitbetter.com, any icanmakeitbetter.com subdomain (e.g., “domain.icanmakeitbetter.com”) or survey (via mobile, website or other form administered by icanmakeitbetter.com) to create an account, post content, view or interact with the aforementioned icanmakeitbetter.com domains, subdomains, surveys and properties. A “Business Subscriber” is defined as a Site User that is a business or entity subscribing to Company services in order to create a subdomain (e.g., “Business Subscriber”.icanmakeitbetter.com) and manage and administer the platform for the use of their customers, employees or community. For clarity, references to this Website in these Terms and Conditions also include any Business Subscriber’s subdomain. Unless we distinguish otherwise, the terms “you”, “your”, “user”, or “users” for purposes of these Terms and Conditions, mean anyone accessing the Website for any reason, including Site Users and Business Subscribers, you in your individual capacity, and the company or other business entity that you represent and on whose behalf you use the Website under actual or apparent authority.

On our Website, we also may provide opportunities for interested persons to share ideas with us, for, example, through a blog. Although there are myriad ways in which interested persons may participate in our Website, for simplicity, we refer to the various surveys, forums, blogs, focus groups, and any other activity on our website as collectively “Surveys and Forums”.

In this (“Policy”), we describe the information that we collect from any visitor to our website, http://www.icanmakeitbetter.com, as well to our websites operated by us, e.g., www.icanmakeitbetter.com (where the icanmakeitbetter name will vary based upon our customer and the domain you are using - collectively these entities are referred to as “Website” in this Privacy Policy). Unless we distinguish otherwise, references to “you” include all visitors to our Website. This Policy is incorporated by reference into our Terms and Conditions of our Website, available at https://app.icanmakeitbetter.com/terms-and-conditions/eu.

How icanmakeitbetter.com Works

Business Subscribers will engage icanmakeitbetter.com for a variety of products and services, including to create Surveys and Forums.

icanmakeitbetter.com will send an invitation to you (using contact information that the Site User provides to us) to participate in the Surveys and Forums, which may include, for example, responding to a survey, posting a comment, or sharing an idea.

Information We Collect

We may collect information about you from a variety of sources, including information that we collect from you directly when you create a user profile or participate in any Surveys and Forums. We collect information from a variety of sources, including information we collect from you directly when you create an account, visit our Website, use our services, register to make comments on Forums or blogs, or request information from us.

Information We Collect Directly From You

You are required to create an account with us if you would like to participate in any Surveys and Forums. To create an account, we require you to provide us with your email address and to create a user name and password. You will have the opportunity—but are not required—to respond to create a user profile; the items requested in the user profile will vary based on the Business Subscriber, but may include your name, contact information, gender and interests.

You also may have the option to log onto our Website through third-party social networks such as Facebook, Twitter, Google+, and LinkedIn, among others, which may change from time to time. The third-party social networking sites determine what information will be collected from you during the log in process. Depending upon the particular social networking site, we may request certain permissions from you. For example, if you log in through Facebook Connect, we request your permission to: access your basic information, including, your name, profile picture, gender, list of friends and user ids, email address, date of birth, and any other information you have set to public or to be shared on your account; send email directly to you; post to your wall; and access your data at any time even if you are not using Facebook.. Please note, if you allow us to have access to this information, then we will have access to this information even if you have chosen not to make that information public. For information about how a particular social networking site may disclose your information, including any information you make public, please consult the site’s Privacy Policy. We have no control over how these sites use or disclose the personal information you provide to them. We store the information that we receive from them along with other information that we collect from you or receive about you.

Information We Collect From Third Parties

We may collect information about you from third parties, such as your name and email address, so that we may contact you and ask you to participate in our Surveys and Forums.

Information We Collect When You Visit Our Website

When you interact with our Website, we strive to make your experience meaningful and easy. We may use or engage others to use cookies, clear gifs, or other tracking technologies to track user activity and to collect Website data. Specifically, when you visit our Website and use our Services, we may collect the following information: IP addresses, browser type, operating system, date and time of visit, time spent on and/or logged onto the Website, browser referral header or other mechanism by which you came to our Website, and links clicked on in our Website. We may combine this information with your personal information that you provide to us by using the Website.

In the following paragraphs, we provide additional information about our use of tracking devices:

Cookies

When you access our Website, we use cookies. Cookies are alphanumeric identifiers that we (and other third party website operators) transfer to your computer’s hard-drive through your web browser for record-keeping purposes. There are two types of cookies; session-based and persistent-based cookies. We also may permit certain third party cookies to be placed on our Website.

Some of the cookies we use are essential for parts of our Website to operate and have already been set.

You may delete and block all cookies from our Website (most web browsers allow some control of most cookies through the browser settings), but you may not be able to access all or parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our Website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

For detailed information about cookies and how they are used on our website, see our Cookie Policy.

Disabling Cookies

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Website visitors who disable their web browsers’ ability to accept cookies will be able to browse the Website; however, you must enable cookies to use most of our Services.

Clear Gifs (Web Beacons/Web Bugs)

We or the third parties we engage to track and analyse Website data may employ clear gifs (a.k.a. Web Beacons/Web Bugs) to help us better manage content on the Website. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on Web pages.

IP Addresses

An IP address is a computer's numeric address, by which it can be located within a network. We may record your IP address when you visit or use services or features on the Website. We may use your IP address for the purposes noted above below, and also to help diagnose problems with our server, or to administer the Website. We may also use your IP address to identify you when we feel it is necessary to enforce compliance with this Policy, the terms and conditions and/or cookie policy, or to protect the Website, systems, information, employees, service providers, business partners, users, customers and others.

Using Your Information

Subject to the limitation on how we use your survey responses discussed in the section entitled “Additional Information about Surveys and Forums,” we use the information that we collect from you through your participation in our Services, including our Surveys and Forums for several purposes:

We may combine all of the information that you submit through our Website, including, for example, your profile information along with your responses to our surveys. We also will use your information to provide Services to our Business Subscribers. This may include compiling and reviewing your responses to our Surveys and Forums. Below we describe what information we share with Business Subscribers.

Sharing your Information

We may share information about you as described herein.

Site Users:

If you choose to participate in our Surveys and Forums, we will share the information with the Business Subscriber. This will include your responses to the Surveys and Forums, as well as your contact information and profile information, unless you participated in our Surveys and Forums on an anonymous basis. The Business Subscriber may use your information, at a minimum, for purposes consistent with this Policy, which may include for market research, for sales and marketing, and for other purposes described herein. The Business Subscriber, however, also may maintain its own privacy policy; if the Business Subscriber invited you to participate in its Surveys and Forums, then the information that you submit also may be subject to that privacy policy. The Business Subscribers may contact you directly if you respond to our Surveys and Forums unless you respond on an anonymous basis.

Partners and Subsidiaries/Vendor Companies:

We may disclose your personal information to our holding company, subsidiaries or affiliates and to third parties whom we instruct to provide services on our behalf, including, but not limited to, support services, website services, delivering promotional materials, and other promotions, and answering customer questions about our products and services. We will only provide those third parties with the personal information that they need to deliver the services to us and/or on our behalf.

We may share your information with our partners and subsidiaries as well as hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and to assist us in providing the products and services that you request from us. We only provide those service providers with the information necessary to perform the requested service.

If you choose to participate in our Surveys and Forums, we may share your contact information and non-personally identifiable information (such as information obtained through cookies) with our partners and subsidiaries. We also may combine such information. Our partners and subsidiaries will use your information consistent with the purposes described in this Policy.

Other Visitors to Our Website:

Depending upon the particular Site Activity, your responses also may be viewable by any other visitor to that website. For example, if you participate in a blog or forum, your responses will be viewable by other visitors to that website.

Sale/Transfer of Business

icanmakeitbetter.com reserves the right to disclose your information if it licenses, sells, or otherwise transfers its technology or business, or a portion thereof, to third parties , including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitisation or financing involving us.

To Protect Ourselves/For Legal Purposes

We also may disclose your personal information to protect our rights and property, to prevent against fraud and abuse, and to protect other users of our services. We also may disclose your information as permitted or required by law, for example, in response to court orders, subpoenas, or other requests from government agencies.

Additional Information About Surveys and Forums

We administer Surveys and Forums on behalf of our Business Subscribers. We may create the Surveys and Forums on behalf of the Business Subscriber, or the Business Subscriber will create the Surveys and Forums itself, and provide to us to administer. Regardless of which entity authors the Surveys and Forums, we will host the Surveys and Forums on our Website and collect the responses that you submit. Your participation in our Site Activity (e.g., completing surveys, forum/blog responses, votes, ideas, comments, etc.) will be shared with the Business Subscriber.

In some circumstances, we also will analyse the data and provide that analysis to the company, and in other situations, we turn the survey responses in their entirety to the company. We do not share your individual survey responses with any person or entity other than the company that engaged us to create the survey. We may, however, provide your contact information and aggregate information to our partners and subsidiaries, but we will not provide your actual survey responses to our partners or subsidiaries.

Please note that we also will provide the Business Subscriber with your profile information, subject to the exception below pertaining to anonymous information. If you have any questions about how your information will be treated, please contact info@icanmakeitbetter.com. We are not responsible for any information that you submit through this website. If the Business Subscriber invited you to participate in our Surveys and Forums, then that Business Subscriber may have its own privacy policy, which will govern the collection and use of your information.

Whether your participation response to a particular Survey or Forum is anonymous depends upon the Business Subscriber. Some Surveys and Forums will permit you to respond anonymously, whereas other Surveys and Forums will require your name. We will notify you on the Surveys and Forums if you are permitted to respond anonymously.

We do not sell your responses to Surveys and Forums to third parties. We may, however, transfer your information (e.g., contact/profile information) to a third party in the event of a transfer, corporate reorganization, bankruptcy, or other similar event, but we will not sell your survey responses under any circumstances. We merely act as a custodian for your responses on behalf of the Business Subscriber.

Third Party Sites

Please note that the Website may, from time to time, contain links to other third party websites that are not controlled or operated by us. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please review these policies before you disclose any personal information when visiting such third party websites.

Security

We take precautions to ensure the security of your personal information. However, we cannot guarantee that hackers or unauthorised persons may gain access to your personal information despite our efforts. You should note that in using the icanmakeitbetter.com service, your information will travel through third party infrastructures that are not under our control.

We cannot protect, nor does this Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information to other users.

Children/Minors

You must be at least 18 years of age to use this Website. The services available on this Website are not intended for persons under 18, including, in particular, children under 13, and we do not knowingly collect information from persons under 18 years of age.

User Generated Content

Portions of our Website permit users to engage in Surveys and Forums and are therefore not confidential and are specifically available for public viewing. We are not responsible for the privacy of any information that you choose to submit through a public forum, such as a blog, or for the accuracy of any information contained in those postings. Any information that you disclose becomes public information. We cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. Please refer to the terms and conditions for additional information relating to user submissions that might apply to you.

Retention of Your Personal information

The personal information that you provide will be retained by us in accordance with applicable laws. However, we will take reasonable steps to destroy or permanently de-identify personal information it holds if it is no longer needed for our business purposes.

Storage and Transfers/Safe Harbor Certification

The data that we collect from you (including, but not limited to Survey data) may be transferred to, stored at, and processed in a destination outside the European Economic Area ("EEA") and Switzerland, including (but not limited to) the United States. This information may be accessed by the courts, law enforcement, and national security authorities of that jurisdiction. By submitting your personal information, you agree to this transfer, storing or processing by icanmakeitbetter.com in the United States.

Sentient Services has certified its adherence to the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. As part of this, Sentient Services adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/.

EU data subjects who have any questions, complaints or disputes about the personal data we process about them should contact us at: info@icanmakeitbetter.com, ATTN: Privacy Compliance Officer. Sentient Services will promptly investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Policy.

With respect to any complaints related to this privacy policy that cannot be resolved through our internal process, we agree to participate in the dispute resolution procedures set forth by JAMS. More information about the JAMS International Safe Harbor Program is available here: http://www.jamsadr.com/safeharbor/.

In the event that we or the appointed arbitrator(s) conclude that we did not comply with the Policy, we will take appropriate steps to address any adverse effects and assure our future compliance.

Access

You have the right to access the personal information that we collect about you. If you create an account with us, then you may access and update your account information by logging into your account. Please check your account regularly to ensure that we hold accurate personal information about you. Once you enter information into a survey, however, you are unable to change your survey responses except by contacting the survey creator.

You have the right to ask what personal information is held by us about you. Upon your written request, subject to certain exceptions, we will inform you of the existence, use and disclosure of your personal information and give you access to that information.

Changes

We may periodically update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the email address specified in your primary Site User account or by placing a prominent notice on this Website or blog.

Questions

Any questions about this Privacy Policy should be addressed to support@icanmakeitbetter.com or by mail at:

icanmakeitbetter.com
1705 South Lamar,
Austin, TX 78704