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RealityMeter Privacy Policy January 2025

This Privacy Policy (“Privacy Policy”, “Policy”) sets out the commitment of Kantar Media UK Ltd , 222 Gray’s Inn Road, London, England, WC1X 8HB, UK (“Kantar Media”, “we” or “us”), to the privacy of the members, users and participants of various panels and other sources (altogether “Participants”) who agree to participate in the RealityMeter program (“Program”) and governs Participants rights regarding privacy and data protection.

Kantar Media is the “data controller” and responsible business for the purposes of applicable data protection law. Kantar Media has engaged RealityMine Ltd to provide software applications and data processing services for the purposes set out in this Policy.

In order to participate in the Program, you are required to download and install a small software application called RealityMeter (the “Application”, which is comprised of the Meter and VPN, as described further below) made available by RealityMine Ltd, on behalf of Kantar Media, on your mobile phone, tablet or computer. The Application will either install the “Meter” (a piece of software on your device to collect the data described above) and/or will establish the “VPN” (a profile on your device to direct all internet data generated by and for your device through RealityMine to enable us to collect the data), which individually and collectively are components of the Application. Regardless of whether data is collected via the Meter or the VPN, we will only use the data as described in this Policy.

Participants are invited to the Program by various panels, communities, sites or any other sources, (altogether “Panels”) operated by third-party companies which are each the data controller of their respective data. Taking part in the Program is entirely voluntary.

By signing up to the Program, and by accepting these terms, you confirm that you have read and understood the terms of this Privacy Policy. We ask you to read this Privacy Policy carefully. For the purpose of this Privacy Policy, “personal data” means any information which relates to an identifiable living individual.

If you are upgrading the Application from an older version, re-joining the Program, or otherwise accepting the latest version of this Policy, you agree that after doing so, your data previously collected by us under your prior participation in the Program may be used as described in this Policy. You may always uninstall the Application (which requires that you uninstall both the Meter and VPN) by following all of the defined steps from the instructions.

This Policy does not replace the existing privacy policy of the Panels as that still applies to all Participants, whether or not they choose to participate in this Program. This Policy applies only to those Participants who choose to participate in the Program.

This Policy describes our data collection and use practices for consumers who download the Application. This Policy applies only to the operation of the Application and not to any other application, website or service. While we encourage our partners to comply with best practices regarding consumer privacy, we are not responsible for the privacy practices of any third-party product with which the Application may be bundled.

Lawful Collection and Use of Data

Kantar Media will respect your privacy and the confidentiality of your data will be maintained as described in this Privacy Policy.

Data covered by this Privacy Policy includes personal data collected from the following sources:

  • Personal data that we receive from the recruitment partner who invited you to participate in the survey, including basic demographic information (Age, Gender, Region, Social Grade), and a panellist ID that uniquely identifies you within the recruitment partner database. We may also receive personal data from the recruitment partner in respect to surveys you have previously undertaken with them (see the use cases named “Combine data with your answers to other surveys/programs” below).
  • Personal data collected from you via the Application. Examples are explained below and are related to “clickstream data”. Clickstream data is information generated by you and your device while surfing the Internet and interacting with various sites, services, apps, and device functions.

In greater detail, the Application collects the following types of information.

Data collected/processedDescription
Online BrowsingThis includes the sites you visit and apps you use, including news sites/apps or social networks, and your interactions with how you use them, how much time you spend browsing the internet and the terms of any search you carry out.          
Online ActivitiesThis includes the search terms you enter, the videos you view, the products you shop for online, the advertisements you see, information and content on sites or apps that you visit or use and with which you interact.
Information on secure pages/appsThis includes information and content from protected or secure pages or apps that you access, such as online accounts or the content of complete and incomplete consumer transactions when you are checking out through a service’s shopping cart, even if the service makes this information unreadable to others.
System InformationThis includes information about the device and system you are running on, including unique identifiers that may be stored in your device’s operating system such as your device’s unique identifier, IP address and phone number of the device. This also includes unique identifiers used by websites and apps and information about your access to cellular and Wi-Fi networks.
Mobile Device and Computer Usage InformationThis includes information about your use of your mobile phone, tablet or computer. device (mobile device or computer). Please note this information is collected and transmitted to us “in the background” and does not require any further activation on your part. We call this “passive tracking”.

This can include the following types of information:
  • Information about your internet browsing habits – how much time you spend browsing the internet on your mobile phone, tablet or computer or your mobile device, the sites you visit or apps you use, and the terms of any search you carry out.Information about your usage of other apps and features on your device, including the identity of the apps and features, when you downloaded them, how often you use them and for how long. This includes things like your use of the camera(s) (although we do not collect your photos) and the media player(s) (including the titles of songs/tracks and videos)
  • Information about the type of device you own.
  • Information we can deduct from combining the above information – e.g., what apps you were using just before you searched for particular information using your device’s internet browser
  • Operating system capabilities, such as Accessibility services, which is used to read information from the screen such as applications being used or content being viewed, such as videos shown on YouTube.

We use the personal data we receive or collect from you for the following purposes:

CasePurposeData collected/processedLegal Basis
Market researchThe general purpose of the Program is to process your “clickstream data” and demographic information to understand your choices and behaviour as a consumer and provide insights to our clients as part of our market research services.   Your personal data will ultimately be combined with other participants’ data, and aggregated and anonymised before being shared with our clients in market research reports.   These reports are used to understand the web browsing and device usage of different groups of people (for example, 10% of a particular age group uses website X), and will not contain any information from which you can be personally identified.Online Browsing, Online Activities, Mobile Device and Computer Usage Information, Demographic data from recruitment partner  Voluntary participation in the Program, and use of the Application, whereby we ask for your consent to use of your personal data.
Provide record-level data to our clientsWe also provide clients with access to “clickstream data” at an individual level, not aggregated with the survey responses of other participants. As with the above use case, this data is used to understand the web browsing and device usage of different groups of people (for example, 10% of a particular age group uses website X). Our clients import the data at an individual record level in order to perform more detailed statistical analysis for the purposes of understanding group behaviours and attitudes. You will not be personally identified within this data. We have contractual agreements in place with all clients prohibiting them from identifying you.Online Browsing, Online Activities, Mobile Device and Computer Usage Information, Demographic data from recruitment partner  Voluntary participation in the Program, and use of the Application, whereby we ask for your consent to use of your personal data.
Contact you regarding follow-up studiesWe may ask the recruitment partner that invited you to participate in our program to contact you for further studies. Your participation in these further studies is entirely voluntary. In order to effectively target these further studies, Kantar Media may use your “clickstream data” to identify relevant surveys for you (for example, if collected data indicating you use an online news app, we may send you a survey on reading news online).      Panellist ID, Online Browsing, Online Activities, Mobile Device and Computer Usage InformationVoluntary participation in the Program, and use of the Application, whereby we ask for your consent to use of your personal data.
Customer database enrichment and Advertising targetingWe use your personal data to help our clients and data partners identify people who are similar to you, in order to make inferences about their characteristics and make decisions about the advertising these people see. Our clients and data partners use statistics derived from your data to predict the behaviours and interests of other individuals – by looking at the patterns in Kantar Media’s data or the patterns that result from matching Kantar Media’s data to the data of those other individuals. We include contractual safeguards to ensure that you will not automatically be contacted or targeted for commercial purposes, as a result of your data being used to help create a lookalike audience, and that our data partners cannot use your data for any other purpose.Panellist IDVoluntary participation in the Program, and use of the Application, whereby we ask for your consent to use of your personal data.
Combine data with your answers to other surveys/programsIf you have opted in to allow combined data use from multiple devices or multiple research programs administered by us (whether directly or indirectly, and regardless of device and applicable policy for any other program), we may use any information we have about you to match the data collected through this Program with the data collected through such other Panels and programs (including data collected in the past), and use the combined “multi-use” data pursuant to this Policy.  Panellist ID, survey data, Online Browsing, Online Activities, Mobile Device and Computer Usage InformationVoluntary participation in the Program, and use of the Application, whereby we ask for your consent to use of your personal data.
Operating the Application and Fraud Protection  We also may use your information for purposes of maintaining the configuration and proper functioning of the Application, for database or Application services (such as customer support, email, or surveys), and for purposes of data quality and data cleansing. We also use this information for the protection of our business interests against fraudulent behaviour   We may provide RealityMine with data collected through the Application for RealityMine’s own internal use only to develop and enhance its general offerings; however, RealityMine is not authorized to provide any third party with access to, or use of, such data in any manner that identifies you.Online Browsing, Online Activities, Mobile Device and Computer Usage Information, System Information Legitimate interests to operate the Application securely and efficiently,to improve the quality of our data and insights from market research, and to protect our business against fraud or other prohibited behaviou
Program registration and managementAs part of the registration process prior to installation of the Application or in connection with your participation in a survey or other service, we may directly collect information such as your email address. The contact information you give helps us reach you with information related to Application maintenance and upgrades and other service related communications. Email address, Panellist IDVoluntary participation in the Program, and use of the Application, whereby we ask for your consent to use of your personal data. Where you have left the panel and/or withdrawn your consent, we may rely on our legitimate interest to continue to process your personal data, for example keeping records of any complaints received.
Business TransactionsWe may need to manage a business transition or financial transaction, such as a merger, acquisition, divestiture, restructuring, reorganisation, dissolution or sale of all or some of our assetsAll personal data described within this Policy which relates to your participation on the ProgramLegitimate interest or where necessary to comply with a legal obligation

Third parties and data transfer across borders:

Your personal data may be collected, stored, transferred or processed by third-party service providers for research-related purposes. This may involve data processing both within and outside the UK and the EEA. All parties are contractually bound to keep any information they collect and disclose to us or, we collect and disclose to them, confidential and must protect it with security standards and practices that are equivalent to our own. If your personal data has been transferred to, stored, or otherwise processed to a territory outside the UK or EEA (as applicable) and that territory has not been recognised as providing an adequate level of protection of personal data, we will put in place an appropriate legal safeguard. For example, standard contractual clauses approved by the European Commission and other relevant authorities, working with parties that have implemented binding corporate rules or other intra-group processes, obtaining your consent to transfer personal data, where the transfer is necessary for the performance of a contract between us or where a contract was entered into on your behalf, or where the transfer is necessary to establish, exercise or defend legal claims.

Data is collected and transmitted by the Application from your device to RealityMine, whose servers are located in the European Union. Data is then transferred to us. Our servers are maintained in the United Kingdom and European Union.

Kantar Media and RealityMine use the following third-party vendors for the processing of your personal information:

  • Microsoft Azure
    Microsoft stores your data in the following locations: Netherlands and Ireland https://www.microsoft.com/
    Contact: tele 400 820 3800, or visit website to complete a contact form
    6880 Sierra Center Parkway Reno, Nevada 89511, United States
    Processing: data hosting only (cloud services)
  • Amazon Web Services
    Amazon stores your data in the following locations: Ireland and Sweden
    https://aws.amazon.com/
    Contact: tele 352 2789 0057, or visit website to complete a contact form 38 Avenue John F. Kennedy, L-1855, Luxembourg
    Processing: data hosting only (cloud services)

We may share information about you with authorized vendors and service providers, such as RealityMine Ltd., in connection with the services that they perform for us. These third parties are prohibited from using your information for other purposes.

Confidentiality, security and industry requirements

We have appropriate technological and organisational measures in place to protect your personal data and take all reasonable steps to ensure your personal data is processed securely. All information you provide us is stored in secure servers and environments. Once we receive your transmission, we will take reasonable steps to ensure our systems are secure.

All our third party contractors, site service providers and employees are contractually obliged to follow our policies and procedures regarding confidentiality, security and privacy. We adhere to the MRS and ESOMAR professional codes of conduct and in the UK hold MRS Company partner accreditation,

Cookies are small text files stored on your computer or mobile device by a website that assigns a numerical user ID and stores certain information about your online browsing. They are used to help users navigate websites efficiently and perform certain functions. The website sends information to the browser which then creates a text file on the user’s computer or mobile device. Every time the user goes back to the same website, the browser retrieves and sends this file to the website’s server.

We do not use non-essential cookies on the website that hosts our legal documents within the application, or in our provisioning server (which is used to generate application download links).

Accuracy

We take reasonable steps to keep personal data in our possession or control accurate, complete and current, based on the most recent information made available to us by you and/or by our client.

We rely on you to help us keep your personal data accurate, complete and current by answering our questions honestly. You are responsible for ensuring that you notify us of any changes to your personal data.

Children’s Data

Kantar Media recognizes the need to provide further privacy protections with respect to personal data collected from children. We never knowingly invite children under the age of 16 years to participate in research studies without parental permission. If it is necessary and appropriate to a particular project to directly involve children under the legal age, we take measures to ensure we have been given permission by their parent or legal guardian. We do not sell children’s personal data.

Sensitive/special category data collection

We do not intentionally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.  However, such data may be collected in connection with the collection of other information (e.g., website visits, search terms entered, etc.) and may be processed and used in connection with our services to or for our client(s). While the app is active on your device, please do not enter data/information or use apps or the internet in a way that will lead to the collection and processing of sensitive personal data.

Data Processing Procedures

We have established specific procedural and technical privacy rules and processes designed to avoid as much as possible the processing of personally identifiable information and sensitive information that can be identified by those processes, such as but not limited to credit card numbers, email addresses, email content from most web-based email accounts or health data. The processes are executed routinely prior to the insertion of such data in our database.

Despite our efforts, some information might get through our rules and processes. Our rules and processes are reviewed and upgraded periodically by our analysts to identify new types of personally identifiable information and sensitive information and to prevent them from being inserted in our database. If it happens that we identify such information in our database, this information will be immediately deleted.

Most applications encrypt personally identifiable information and sensitive information in line with most data protection regulations in the world. If you use an application which doesn’t respect these requirements, you may transfer your data in an unencrypted format through the Internet. Your data may be captured as is by our Application. The detection of such situations is also part of our procedures and we will delete your data immediately if we identify such case.

Rights of Individuals

You have the following rights in relation to your personal data:

  1. Right to change your mind and to withdraw your consent
  2. Right to access your personal data
  3. Right to rectify your personal data
  4. Right to erase your personal data from our systems, unless we have legitimate interest reasons for continuing to process the information
  5. Right to port your personal data (portability right)
  6. Right to restrict processing of your personal data
  7. Right to object to the processing of your personal data

We shall also notify third parties to whom we have transferred your personal data of any changes that we make on your request. Note that while Kantar Media communicates to these third parties, Kantar Media is not responsible for the actions taken by these third parties to answer your request. You may be able to access your personal data held by these third parties and correct, amend or delete it where it is inaccurate.

Accessing Personal Data Rights

To request access to personal data that we hold about you, please see the contact details in the “How to Contact Us” section. If you contact us using an email address or contact details for which we do not hold a record of, we may also request you provide a copy of a valid government issued or official identification (such as drivers licence or passport) to verify your request. We do not discriminate against you for exercising any of the rights listed above or any other rights you may have.

You may be entitled to use a third party to submit a request to us on your behalf (sometimes referred to as an ‘authorised agent’ or similar). For this purpose, we will require proof that you gave that third party signed permission to submit the request, which may be in the form of a power of attorney. We may also require additional verification, such as the identity of the third-party individual.

We aim to respond to your requests to access your personal data rights as soon as possible. However, we will respond within the timeframes determined by the applicable data protection law.

We will not charge you for your reasonable requests in principle. However, where permissible under application laws, a fee to reflect the cost will be imposed as appropriate on repeated requests beyond reasonable scope. As for repeated requests that are groundless and need excessive technological means (e.g. developing a new system or fundamentally changing the current practices) to fulfil, involve risks to others’ legitimate rights and interests or are impractical (e.g. involving information stored on a backup disk), we may reject your request, subject to applicable data protection laws.

Data Storage and Retention

Personal data will be retained only for such period as is appropriate for its intended and lawful use, in this case we shall retain data for no longer than 4 years, unless otherwise required to do so by law. Personal data that is no longer required will be disposed of in ways that ensure their confidential nature is not compromised.

If you opt out from the Program by following the instructions to remove the Application (which requires that you uninstall both the Meter and VPN) we no longer will collect data from you but we will retain and continue to use your data collected prior to your removal of the Application unless you contact us. We are not able to modify or remove clickstream data, information that has been collected or information that has already been shared with a third party as permitted by this Policy.

If you have set your browser to “private browsing” or a similar setting, the Application may still continue to operate and collect data to be sent to us. To completely stop the operation of the Application and the collection of data from your device, you must follow the instructions to remove the Application (which requires that you uninstall both the meter and VPN).

As part of the Company Business Continuity Plan and in certain instances the law, our electronic systems are backed up and archived. These archives are retained for a defined period of time in a strictly controlled environment. Once expired, the data is deleted and destroyed to ensure the data is erased completely.

Notification of Material Change

We keep our privacy policy under regular review, and it may be amended from time to time. We will always have the most up-to-date policy on this web page. We will record when the policy was last revised.

Last updated: January 2025

Automated decision making / profiling:

In certain circumstances we may carry out automated decision making or profiling about you. However, in the majority of cases this will not result in any legally significant decisions being made about you. You have the right to appeal if any automated decision made about you is legally significant. If you have any questions about this, please contact us.

How to contact us

If you have any questions, comments or requests related to this privacy policy, you can contact us by emailing privacy-media@kantar.com. or writing to Privacy Enquiries, Kantar Media UK Ltd, 222 Gray’s Inn Road, London WC1X 8HB.

If you have any questions or comments you may contact Kantar Media’s Data Protection Officer, please email dataprotection@kantar.com.

Please quote project reference: National Buying Survey – RealityMeter

Complaints & Country Specific Disclosure

If you are not satisfied with how we handle and protect personal data, you have the right to complain to the Information Commissioner’s Office via: https://ico.org.uk/make-a-complaint/ , by emailing: casework@ico.org.uk, or by post to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Kantar Media UK Limited is a company registered in England and Wales (Company No. 00275304) and its registered address is 222 Gray’s Inn Road, London, England, WC1X 8HB

Additional Terms for Users of Android Devices

If you have downloaded the RealityMeter App via Google Play, the following shall apply:

The Application uses Accessibility services and is using the respective permissions with active consent by the end-user. The Accessibility permissions are used for analysing the application and web usage on this device as part of an opt-in market research panel.