Last updated: July 2020

National Geographic Partners LLC (“National Geographic Partners”, “we”, “our” or “us”) has appointed Toluna UK Limited (“Toluna”) to host the National Geographiccommunity (“Community”) on its online platforms for this survey submission for which they assisted with the online community recruitment. This includes Community management and the processing of all personal data collected from you as part of your Community membership. We require Toluna to respect the security and confidentiality of your personal data and to treat it in accordance with National Geographic Partners’ policies and the law. Toluna will not use your personal data for their own purposes and is only permitted to process your personal data for specified purposes and in accordance with our instructions.

Eligibility

Membership to this Community is free and is open to individuals only (not corporations or other business entities) that are at least eighteen (18) years of age.

Being a Community Member

When you agree to become a Community member and complete the registration form on the Community, you are able to participate in our Surveys. As part of your registration, you will provide us with your Identity data and Contact data and we will through your participation in the Surveys obtain, use and share certain other data about you, such as; Demographic/Profile data, Technical data and Pseudonymised data.

We use your Identity data and Contact data for:

• Contacting you for any reason connected with your Community membership;
• Sending you invitations for your participation in surveys - to ask you if you are interested in participating in our upcoming surveys. We may also make you aware via your online Community membership account of surveys you may be suitable to participate in, based on our knowledge of your personal data.
• Understanding more about you and the insights you provide us – our platform provider (Toluna) will with your consent provide us with your Identity data and Contact data, so we can understand more about you.

Your Member Account

While you may access this Community without registering for a member account, in order for an account to be established in your name and for you to participate in any Surveys (as defined below), you must complete the provided online registration. To open a member account, you must provide us with complete and valid contact information, including your full legal name, valid e-mail address, and all other requested information. Your account must have a unique and valid e-mail address and password.

You agree to provide only accurate, current and complete registration information and to keep that information updated in order to maintain its accuracy.

You may use only one (1) password to open and access your account, and you may not use another account holder's password or allow anyone else to use your password, for any reason. You are solely responsible for the security of your username and password and any activity that occurs under your member account, whether authorised or unauthorised. We will not be responsible for any losses incurred through the use of your password by a third party, except when unauthorised use is directly attributable to our gross negligence or wilful misconduct. You agree to immediately notify us of any unauthorised use or breach of your member account.

Should you forget your password, you may request that we send it to you via e-mail by either contacting us at support@NatGeoCommunity.com and requesting a new password, or clicking on the ‘forgot password’ hyperlink in your online portal and we will send you a new one. This procedure assumes that mention is made of your username, and that the e-mail address provided by you when registering is used (or the new one provided in the event of an update).

By registering as a member of this Community, you agree to receive e-mail invitations to participate in surveys and panels conducted by us or our third-party partners (“Surveys”). We do not guarantee that you will receive a certain minimum volume of invitations or any invitations at all. Your participation in any Surveys and your disclosure of any personal data is completely voluntary.

We retain the right to monitor all member activity within the Community. If required by law, if you have violated our Code of Conduct below, in the event that your member account shows signs of fraud, abuse or suspicious activity or as otherwise deemed necessary by us, for instance where you do not respond to a reasonable number of requests to participate in Surveys , your member account may be terminated. If you have conducted any fraudulent activity, we reserve the right to take any necessary legal action and may have grounds to confiscate any rewards redeemed as a result of such activity. In addition, you may be liable for monetary losses to us, including litigation costs and damages, and you will not be allowed to participate in the Community in the future.

WE MAY TERMINATE YOUR MEMBER ACCOUNT AT ANY TIME FOR ANY REASON.

You may cancel your account at any time by contacting at support@NatGeoCommunity.com or you may also send an email directly to contact@toluna.com requesting to be removed.

Member Code of Conduct

The Community is an online community dedicated to making your voice heard and allowing you to tell leading providers of products and services what you think. When you use and post content to this Community you must observe the following rules:

• Only one member account per person. Any duplicate accounts will be terminated.
• Be courteous and respect the opinions of others and behave in a manner that supports a safe and comfortable environment for all members.
• Do not post any of the following:
  • Material that advocates illegal activity or political, religious or ideological beliefs.
  • Personal attacks or anything (including "jokes" that may be misconstrued) obscene, vulgar, illegal, harmful, discriminatory, racist, xenophobic, insulting, threatening, abusive, harassing, defamatory, libellous, untrue, misleading or invasive of someone else's privacy or anything that is in any way pornographic or paedophiliac or that refers directly or indirectly to pornographic or paedophiliac sites.
  • Advertising and solicitations - Do not use any Community areas to buy or solicit for goods, services, or money, or to advertise or sell products or services to others. For example, do not post any advertising, referrals, promotional materials, junk mail, "spam," chain letters, pyramid schemes or any other form of solicitation.
  • Any content that infringes any patent, copyright, trademark, trade secret or other intellectual property right of another or that, without prior written permission, mentions any third party brand or personality or uses any third party content.
  • Any statement that expresses or implies that any actions you take are endorsed by us or our clients.
• Act in good faith when taking Surveys, so your answers should be true to the best of your knowledge and belief and genuine, e.g. your answers should be your own opinion (and not others) and you should take care not to speed through a Survey or answer each question the same way. We reserve the right to withhold awarding rewards to you if, in our reasonable view, your Survey responses are untruthful or not well considered.
• Do not access or use any part of the Community for anything other than your personal, non-commercial use.
• Do not access or use any part of the Community in any way that may violate any applicable law, regulation, or other governmental requirement and/or principles of good conduct.
• Do not resell, barter, trade or otherwise attempt to generate income by providing access to your member account to others.
• Do not impersonate any individual or entity, including, without limitation, a National Geographic Partners employee, agent or client, or other Community members or otherwise misrepresent your affiliation with any person or entity, including by "framing" any portion of this Community to make it look like you have a relationship with us or that we have endorsed you for any purpose.
• Do not attempt to circumvent the Community or any security measures used on the Community, including by requesting rankings from other members or posting content which does not respond to or pose any question in order to garner rewards.
• Do not release, publish or otherwise disclose or make reference to any Survey or Community content in any media without our prior written permission.
• Do not collect or store any personal data about other members of this Community and in particular do not obtain email addresses of other Community members or third parties with a view to sending unsolicited emails, for whatever reason or purpose.
• Do not attempt to access any service or area of the Community or any Surveys, the server on which our Community is stored or any server, computer or database connected to our Community that you are not authorised to access.
• Do not use any robot, spider, scraper or other automated means or interface not provided by us to access the Community or extract data.
• Do not misuse our Community by knowingly introducing, or sending to or otherwise impact us or this Community (or anything or anyone else) with harmful, illegal, deceptive or disruptive code such as a virus, "spyware", "adware" or other code that could adversely impact this Community or any recipient or take any action, such as a denial of service attack, that might impose a burden on this Community's infrastructure or interfere with the ordinary operation of this Community. You must not attack our Community via a denial-of-service attack or a distributed denial-of service attack.
• Do not re-post on the Community any statements you receive from the Community Help Desk or Customer Support.
• Do not communicate with the Community help desk in a manner which is obscene, vulgar, harmful, insulting, threatening, abusive, harassing, defamatory, libellous, untrue or misleading.
• Do not engage in any other activity that wer may reasonably deem improper or abusive. Failure to comply with this Code of Conduct may result in termination of your member account.
• By breaching any of these provisions in this Code of Conduct, you may be committing a criminal offence under local applicable law. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Community will cease immediately.

Confidentiality of Surveys

National Geographic Partners and/or Toluna on our behalf may disclose confidential and/or proprietary information and materials to you as part of Surveys, and such information and materials shall remain our sole and exclusive property. This confidential information may include, but is not limited to, new product ideas or concepts, packaging concepts, advertising and movie or television concepts or trailers, and the text, visual images and sounds related thereto. By becoming a member, you agree that you will keep the contents and materials disclosed to you as part of all Surveys in which you participate confidential and not disclose or use the confidential information for any purpose except for the sole purpose of completing the Surveys.

All of the responses we collect from you via our Surveys are collected by us in aggregated or pseudonymised form. This means that information is provided about groups of individuals and not on an individual level but may include Pseudonymised data.

Toluna’s Involvement

We have appointed Toluna to host the Community on its online platforms for us. Toluna build and manage the Community and process all personal data we collect from you as part of your Community membership. We require Toluna to respect the security and confidentiality of your personal data and to treat it in accordance with the law. We do not allow Toluna to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Toluna has engaged Amazon Web Services (AWS) (located in Ireland) to host the Community platform and to provide back-up services.

From time to time your personal data is transferred and/or accessed from a Toluna company that is located in a different country. Toluna has put in place transfer agreements using the standard contractual clauses for the transfer of personal data to third countries as decreed by the European Commission.

Toluna USA Inc., - EU-U.S. Privacy Shield Framework

Toluna USA Inc., (“Toluna USA”) is a member of the ITWP group of companies and all data that Toluna uses are accessed by Toluna USA for Community management support. Toluna USA recognises that the European Economic Area (EEA) have established strict protections regarding the handling of personal data from the EEA, including requirements to provide adequate protection for such personal data transferred outside of the EEA. Toluna ensures that it provides adequate protection for certain EEA personal data about individuals (including about you and Toluna corporate clients, suppliers, business partners, job applicants and employees. Toluna USA has therefore elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). Toluna USA is a data processor on behalf of National Geographic Partners. Toluna USA is responsible for the processing of personal data it receives on behalf of National Geographic, under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf for the purposes of providing back up services to ensure the security of your personal data. Toluna USA adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the terms of this privacy notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

For the purposes of enforcing compliance with the Privacy Shield, Toluna is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at https://www.privacyshield.gov. To review Toluna’s representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at https://www.privacyshield.gov/list.

What Cookies do Toluna use on the Community?

Cookies are used on the Community to distinguish you from other users of the Community, helping National Geographic Partners and Toluna to provide you with a good experience when you browse the Community and Toluna improving their Community. For detailed information on the cookies used and the purposes for which they are used, see the applicable Community Cookie Policy.

What other Tracking Technologies do Toluna use?

Automated technologies or interactions. As you interact with the Community, Toluna will automatically collect Technical data about your equipment, browsing actions and patterns. Toluna collects this Technical data by using cookies, server logs, digital finger printing technologies and other similar technologies. Toluna may also receive Technical data about you if you visit other websites employing its cookies.

Server log files: Toluna may collect Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This Technical data may be combined with other information collected about you for the purposes of improving our services, Community functionality and collecting analytical data.

Fingerprint technologies: In general, digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and track your device (“Technology”). The Technology will analyse publicly available information and data obtained from your computer's web browser and from other publicly available data points, including the technical settings of your computer, the characteristics of your computer, and its IP Address, to create a unique identifier, which will be assigned to your device. Toluna uses the Technology for quality control, validation, and fraud detection and prevention purposes, including assisting us in ensuring the integrity of survey results. Appropriate technical and operational processes and procedures will be put in place to ensure that the Technology is safe, secure and does not cause undue privacy or data security risks and the Technology will be used and distributed in a professional and ethical manner and in accordance with (a) this privacy notice, (b) any other statements and/or disclosures made to you as a member of the Community and (c) applicable laws and market research codes of practice. In the event any unethical conduct is discovered in connection with the use of the Technology, or that the Technology is being used in a manner that is inconsistent with privacy notice, immediate action will be taken to prohibit such unethical conduct and to ensure the proper administration of the Technology.

How do you access your information; use the member services area and/or update, correct or delete your information?

Upon request, we will provide you with information about what personal data we may hold about you. You may access, correct, or request deletion of your personal data, or terminate your membership by logging into your Community Account. By following the appropriate directions, your information should be automatically updated in our database. For these purposes, and if you are unable to correct your personal data yourself via your Community Account you may contact us by email at Support@natgeocommunity.com

We will respond to all requests within a reasonable timeframe.

How do you opt out from your Community membership?

If you choose to end your membership with the Community or require us to cease processing your personal data, you may discontinue your membership by going to “Account” and selecting “Unsubscribe Options” in the footer. By following the appropriate directions, your record will be marked as "do not contact", and you will no longer receive invites to participate in future Surveys from Toluna. Please note that you may continue to receive communications after changing your preferences for 2 – 3 weeks until our systems are fully updated.

You may also send an email directly to contact@toluna.com requesting to be removed. Email links are provided on the Community so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.

How long will you use my data for?

If you decide to terminate your membership, we will no longer use your personal data to contact you, but in accordance with our backup procedures, we will retain your personal data until your personal data are eventually destroyed in accordance with our Data Retention and Destruction Policies and we will continue to employ the security procedures and technologies to keep your personal data safe.

How do you ask a question or make a complaint?

You can direct any questions or complaints about the use or disclosure of your personal data to Support@natgeocommunity.com We will investigate and attempt to resolve any complaints or disputes within 30 days of receiving your complaint.