Last Updated June 8, 2017
INFORMATION WE COLLECT AND HOW WE USE IT.
govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/
As used herein, “personal information” means information relating to an identified or identifiable natural person transferred to the United States from the European Union and Switzerland or the European Economic Area.
WHAT INFORMATION ABOUT ME IS COLLECTED THROUGH THE SERVICES?
Depending on your use of and/or interaction with the Services, we may collect two types of information: personally identifiable information and non-personally identifiable information.
Personally Identifiable Information
Personally identifiable information is information that identifies you or can be used to identify or contact you. The categories of personally identifiable information we may collect include but are not limited to your name, address, email address, telephone number, photograph, and audio/visual recording.
Non-Personally Identifiable Information
Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you. The categories of non-personally identifiable information we may collect include but are not limited to demographic information (such as age, profession, gender, location, zip code, birth date, or year of birth), IP addresses, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and other statistical data involving use of the Services. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered non- personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences).
Information provided by you
We will collect personally identifiable, non-personally identifiable, and personal information that you submit to us through any mechanism (including online and offline channels). As an example, in connection with conducting research studies and providing services to others, we may collect all manner of information through direct interviews (often with the support of videos, photos, and recorders), questionnaires, and surveys (including through third-party online survey providers). As another example, we may obtain your personally identifiable and other information from you if you identify yourself to us by sending us an email with questions or comments.
Cookies and Action Tags
We may collect non-personally identifiable information passively using “cookies” and “action tags.” By using cookies and action tags together, we are able to gain valuable information to improve the Services.
For the avoidance of doubt, this Site uses third-party service platforms (including to help analyze how users use the Site, to provide more personalized Services to you, and to facilitate marketing and employment recruiting processes). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.
Here are links to the main third-party platforms we use:
“Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Services or email sent on our behalf may contain action tags.
We also collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Services. This information may be used to analyze trends, to administer the Services, to monitor the use of the Services, and to gather general demographic information. We may link this information to personally identifiable information for these and other purposes such as personalizing your experience on the Services and evaluating the Services in general.
Any information you share in a Public Area (including personally identifiable and personal information) is by design open to the public and is not private. You should think carefully before posting any information in any Public Area. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot control or predict. As with any public forum on any website, the information you post may also show up in third-party search engines like Google, Yahoo, MSN, and Bing. If you mistakenly post personally-identifiable or personal information in a Public Area you can send us an e-mail to request that we remove it by contacting us at email@example.com. You should understand that in some cases, we may not be able to remove your personally identifiable or personal information.
IS INFORMATION SUBMITTED TO THE PUBLIC AREAS OF THE SERVICES PRIVATE?
DOES CONTINUUM COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?
We are committed to protecting the privacy of children. The Services are not designed for or directed to children under the age of 13. We do not collect personally identifiable information from any person we actually know is under the age of 13.
FOR WHAT PURPOSES IS THE INFORMATION (INCLUDING PERSONAL INFORMATION) COLLECTED?
In general, we use the information collected through the Services (including your personal information) to provide the Services to you and others (including conducting research studies and providing other services to our clients), to help us understand who uses the Services, to improve the Services, for internal operations such as operating and improving the Services, and, if you “opt in”, so that we (and third parties on our behalf) may contact you about matters that may be of interest to you.
We may use your information (including your personal information) to send you a welcoming email that may confirm your user name and password. If you “opt in,” we (and third parties on our behalf) may send you electronic newsletters, contact you about the Services products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences. In addition, if you identify yourself to us by sending us an email with questions or comments, we may use your information (including personally identifiable and personal information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference. We may also use the information collected to send you important service announcements and updates regarding the Services. You will not be able to unsubscribe from these service announcements and updates as they contain important information relevant to your use of the Services.
We may also use the information gathered through the Services (including your personal information) to perform statistical analysis of user behavior or to evaluate and improve the Services. We may link some of this information to personally identifiable information for internal purposes or to improve your experience with the Services.
WHEN, AND TO WHAT TYPES OF THIRD PARTIES, DOES CONTINUUM DISCLOSE INFORMATION (INCLUDING PERSONAL INFORMATION)?
Laws and Legal Rights
Third Parties Generally
We may provide to third parties non-personally identifiable information, including where such information is combined with similar information of other users of the Services. For example, we might inform third parties regarding the number of unique users who visit the Site or use or interact with the Services, or the demographic breakdown of our registered users of the Services. In addition to the above, when users use our Services, third parties (including without limitation third-party analytics, marketing, and employment recruiting service providers and commercial partners) may directly collect personally identifiable, non-personally identifiable, and personal information about our users, including about our users’ online activities over time and across different websites. The third parties to which we may provide or who may directly collect personally identifiable, non-personally identifiable, and personal information may include analytics, marketing, and employment recruiting service providers, vendors and website tracking services, affiliates, actual or potential commercial partners, affiliates, sponsors, licensees, researchers, and other similar parties.
Please note in particular that the Services use Google Analytics, including its free app. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site “How Google uses data when you use our partners' sites or apps”, currently located at www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google’s website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.
Third Parties in Connection with Research Studies
If you are a participant in a research study, we may provide personally identifiable, non- personally identifiable, and personal information collected from you through your participation in such research study (including without limitation through any interviews) and/or through the Services to all manner of third parties in order to conduct the research study and utilize the results; the third parties to which we may provide your personally identifiable, non-personally identifiable, and personal information may include our clients, vendors, affiliates, actual or potential commercial partners, researchers, and others.
Sale of Business or Bankruptcy
Transborder Hosting and Transfer of Information
Personally identifiable information collected on the Services may be transferred from time to time to Continuum offices or personnel, or to third parties, located throughout the world, including offices located outside the European Union and the European Economic Area, and the Services may be viewed and hosted anywhere in the world, including countries (such as the United States) that may not have laws of general applicability regulating the use and transfer of such data. By using the Services and submitting such information on it, you voluntarily consent to such trans border transfer and hosting of such information. For specific information regarding how we handle personal information transferred to the United States from the European Union and the European Economic Area, please see the section below titled “Additional Provisions For Personal Information Received From The European Union (Including Switzerland) And The European Economic Area.”
IS THE INFORMATION COLLECTED THROUGH THE SERVICES SECURE?
We want your information (including personally identifiable and personal information) to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with industry standards and to employ administrative, physical, and electronic measures designed to protect your personally identifiable and personal information from loss, misuse, and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved and the nature of the information. Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information, both over the Internet and through other online and offline channels. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.
WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?
DO NOT TRACK
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.
WHAT CHOICES DO I HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION?
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personally identifiable information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personally identifiable information stored in databases we actively use and other readily searchable media, as appropriate, as soon as and to the extent reasonably practicable.
ADDITIONAL PROVISIONS FOR PERSONAL INFORMATION RECEIVED FROM THE EUROPEAN UNION (INCLUDING SWITZERLAND) AND THE EUROPEAN ECONOMIC AREA.
Types of Personal Information Collected
As described above, personal information is information relating to an identified or identifiable natural person transferred to the United States from the European Union, Switzerland and the European Economic Area. The types of personal information we collect could include personally identifiable as well as non-personally identifiable information, such as name, address, email address, telephone number, photograph, audio/visual recording, demographic information (such as age, profession, gender, location, zip code, birth date, or year of birth), IP addresses, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, and domain names. To further clarify, we conduct research studies and provide services to others across a broad range of industries. In connection with these research studies and provision of services, we may collect all manner of personal information (depending on the nature of the study and the services we are providing) including Sensitive Information (as defined below), which may include but is not limited to, health, medical, and financial information.
If you no longer wish to have your personal information disclosed to third parties, you may choose to "opt out" by notifying us that you want your personal information removed. To do so, send an email to firstname.lastname@example.org. Please be aware that your personal information may have been disclosed to third parties prior to removal. Also, Continuum will provide you with notice before using your personal information for a purpose other than that for which it was originally collected or subsequently authorized by you, and you may choose to “opt out” of such use by following the directions provided in the notice. However, even after any “opt-out” or removal of your personal information, we reserve the right to disclose your personal information to a third party when we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process.
If we collect information from you specifying medical or health conditions, racial or ethnic origin, political opinions, religious, ideological, or philosophical beliefs, trade union membership, information on social security measures or administrative or criminal proceedings or sanctions (which are treated outside pending proceedings), or information with respect to personal sexuality (“Sensitive Information”), we will not (a) disclose such Sensitive Information to a third party or (b) use such Sensitive Information for a purpose other than those for which it was originally collected or subsequently authorized by you without obtaining your affirmative “opt-in” (unless we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process). In addition, Continuum will treat as sensitive any personal information received from a third party where the third party identifies and treats it as sensitive.
Before we disclose any of your personal information to a third party we will require that such third party provide the same level of privacy protection as is required by the Privacy Shield Principles. Continuum’s accountability for personal information that it receives under the Privacy Shield and transfers to a third party is outlined in the Privacy Shield Principles. In particular, Continuum remains liable under the Privacy Shield Principles if third-party agents that it retains to process personal information on Continuum’s behalf process such personal information in a manner inconsistent with the Privacy Shield Principles, unless Continuum can prove that it is not responsible for the event giving rise to the damage.
Data Integrity and Purpose Limitation
Except as may be authorized by you, we use your personal information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for these purposes, we take reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.
You have the right to access your personal information held by us and you may correct, amend, or delete such personal information, to the extent that it is inaccurate or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where the rights of persons other than the individual would be violated or as otherwise described in the Principles. If you wish to access your personal information, please contact us in either of the ways described below (under Recourse, Enforcement, and Liability).
Recourse, Enforcement, and Liability
In compliance with the Privacy Shield Principles, Continuum commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Continuum at:
Continuum has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
With respect to the Privacy Shield Principles, the panel established by the DPAs is the independent dispute resolution body designed to address complaints and provide appropriate recourse to you free of charge.
As further described in the Privacy Shield Principles, a binding arbitration option will be made available to you in order to address residual complaints that have not been resolved by other means. Continuum is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Adherence by Continuum to the Principles and the above-set forth provisions may be limited (a) to the extent necessary to meet national security, public interest or law enforcement requirements; (b) by statute, government regulation, or case law that creates conflicting obligations or explicit authorizations; or (c) if the effect of the EU Data Protection Directive 95/46/EC or Member State law is to allow exceptions or derogations, provided that such exceptions or derogations are applied in comparable contexts.
WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?
By email: email@example.com
By postal mail or courier:
21 Drydock Avenue, Suite 410W Boston, MA 02210 USA
Attn: Legal Department