Information We Collect
Personal information is any information relating to an identified or identifiable natural person. In other words, it is information through which an individual can be identified (either directly or indirectly) and it includes name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a person. Anonymized or aggregated information that cannot be used to identify a specific natural person is not considered personal information. Hanover Research collects personal information through several different online and offline channels, including, but not limited to the following: via our website on any form completed, over the phone, via email when communicating with you, in person, via internal and third-party web-based survey tools, through our customer portals, and from third-party list providers. The types of personal information we generally collect includes, but are not limited to:
- Client or Potential Client Information: If you use our services, or express interest in our services, you may provide this information via our website or other means, in person or remotely. This data includes: name; employer name; telephone number; email address; mailing address; other contact information; billing, tax, and payroll information; employee background check information; inquiries about actual or potential projects; publicly available social media posts and profiles, and any other information you choose to provide us. We also may maintain documentation of discussions with current or prospective clients, either in person or remotely. We also collect any other information that you choose to provide to us via email, website, phone, in person, or any other means.
- Survey or Research Information: If you participate in one of our research projects (e.g. respond to a survey), we will collect your name, email address, IP address, company name, job title, demographic information (such as race, ethnicity, gender, and age), educational information, responses to our survey questions, and any other information that you provide to us, online, over the phone, or in person. You may provide this information to us via a third-party research platform, such as Qualtrics or SurveyGizmo.
- Recruitment Information: If you applied for a job at Hanover Research, we will collect employment-related information, such as your name, age, demographics, email address, resume information, job roles, work history, compensation data, benefits information, performance metrics and reviews, background checks, assessments, and any other information that you provide to us or we gather during the course of your candidacy.
- Third-party sources: We also collect data from third-party sources. This third-party information includes contact lists of potential survey respondents provided by our clients or other third party services such as research panel providers; contact information about potential clients from directories and databases of companies; and information that is available on the Internet, for research or business relations purposes, such as publicly available social media posts. Social media (e.g., Twitter, LinkedIn, Facebook) is analyzed based on publicly available posts and engagement (including opens, clicks, shares, etc.) subject to the individual privacy policies of the respective social media platforms. Hanover uses the data from such third-party sources primarily to provide research services. Hanover is not liable for any security breaches that may occur on any social media platform.
Information About Children 13 Years Old
Although this website is not directed to children under 13 years old, Hanover Research’s clients, which include school districts and corporate clients, may ask Hanover Research to use online services to conduct surveys of children under 13 years old. When clients request that Hanover Research conduct surveys of children under 13 years old, the clients typically provide the children with links to Hanover Research-created surveys, usually hosted on a third-party site. Hanover Research collects and processes the children’s responses to the surveys. The information that Hanover Research collects may include their school, grade, and IP address. Students who are surveyed on behalf of school districts usually take the surveys on school computers. Hanover Research’s surveys typically do not result in the collection of personal information, as defined by the Children’s Online Privacy Protection Act (COPPA). Out of an abundance of caution, however, Hanover Research will only conduct surveys of students under 13 years old upon receiving consent from either the student’s school, school district, or parent. If the survey of a child under 13 years old is conducted on behalf of a corporate client, Hanover Research will obtain verifiable consent from the child’s parent. Hanover Research’s online services do not enable a child under 13 years old to make personal information publicly available. Hanover Research only uses information collected from children under 13 years old to produce research reports for the school districts and corporate clients that requested the survey be conducted. The information in the report does not contain personally identifiable information about any children under 13. For any inquiries concerning Hanover Research’s privacy policies and use of children’s information, contact: Hanover Research, Attention: Privacy & Data Protection, 4401 Wilson Boulevard, 4th Floor, Arlington, VA 22203; (202) 559-0050 email@example.com
. In the rare event that Hanover Research has collected personal information, as defined by COPPA, from a child under 13 years old, the child’s parent can contact Hanover Research to request a review or deletion of the child’s personal information, or to refuse to permit further collection of personal information.
Uses of Personal Information
Below is a summary of the ways that we use your personal information, the purposes for those uses, and the legal bases for the uses: We will use your personal information if the use is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. Such uses and purposes include:
- If you provide us with personal information requesting services or products from us, we will use that information to respond to your request.
- We will use your personal information to provide any services that you have requested. For example, if you are a client and you provide us with your phone number, we may call you. If you provided us with payment information, we may process that information. If you apply for a job, we will use your information to assess your suitability for current or future job opportunities with Hanover Research.
We will use your personal information for purposes identified at the time the personal information is collected. We may also use your personal information if the use is necessary for the purposes of our client’s or our legitimate interests, provided that these interests are not overridden by your interests or fundamental rights and freedoms.
We may use any information you provide to us to detect, prevent, mitigate, and investigate any potentially prohibited or illegal activities. We may use your personal information to comply with a legal obligation. We may use any data for which you have given consent for the processing, such as when individuals provide their information when downloading content from our website. You may withdraw this consent at any time by emailing Hanover at firstname.lastname@example.org.
- Hanover Research may use any information that survey respondents voluntarily provide to Hanover Research, in combination with any other information, to provide research and insights to clients. Please note that depending on the specific contractual relationship with the client, Hanover may be acting as either a data controller or a data processor, or both.
Sharing Personal Information
We may transfer or disclose your personal information to the following types of third parties:
- Clients: Hanover Research conducts research on behalf of clients, primarily through the use of surveys. We may share any information that we collect as part of our research, including responses to surveys, with our clients in accordance with the notice provided to you at the outset of the survey.
- Hanover Research Affiliates: Hanover Research shares personal information with any parent company, subsidiary, or corporate affiliate that is owned or controlled by the same owner.
- Service Providers: To provide our research services, communicate with new and prospective clients, maintain our daily operations, provide information about our services, and improve our services, we provide personal information to third-party service providers (which may include our parent company, subsidiaries or corporate affiliates). Such providers include data processing services, cloud storage, business process outsourcers, transcription services, and marketing outreach partners. Such third-party service providers are required to maintain the confidentiality of the information we provide to them and are prohibited from using the information for their own purposes. We do not share your personal information with service providers for their own promotional use.
- Law Enforcement and Legal Proceedings: We will provide personal information to third parties, such as law enforcement or government agencies, if required to do so by applicable law or valid legal process, or if we determine that such sharing is necessary to protect the rights and safety of anyone. We will also provide personal information to parties to a legal proceeding, if we receive a subpoena or similar valid legal process.
- Corporate Transactions, Mergers, Sales, and Acquisitions: In the event of a prospective or actual merger, sale or acquisition of our company, your personal information may be disclosed to third parties as part of the transaction.
We maintain reasonable security protocols to help protect and secure your personal information against loss, misuse and unauthorized access, disclosure, alteration or destruction while in transmission and storage. We require our service providers to adhere to industry best practices to safeguard the personal information they handle. However, no method of data transmission or storage is 100% secure, therefore, we cannot guarantee its absolute security.
We retain your personal information for as long as necessary to fulfill the purposes for which the data was collected or to otherwise meet a valid business or legal requirement. Once the personal information no longer is necessary to fulfill any of these purposes or retained under our retention policies, we will securely dispose of it. Among the factors that we consider in determining whether to retain personal information are: whether the project for which the data was collected has ended; the sensitivity of the personal information; and whether the information could be anonymized or aggregated.
Additional Information for Individuals Located in the European Union
- To the extent that any of Hanover Research’s use of your personal information is based on consent, you may request to withdraw that consent.
- To the extent that the processing of your personal information is based on the legitimate interests of Hanover Research or a Hanover Research client, you may object to this processing at any time. We will no longer process this personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise, or defense of claims.
- You have a right to access your personal data, including: information about the purposes of processing; the categories of personal data concerned; the recipients of the personal data; and where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period. This right of access may be subject to legal limitations, of which we would advise you.
- You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- You have a right to obtain the erasure of personal data concerning you without undue delay, if one of the following grounds applies:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- If the processing was based on your consent, you withdraw your consent;
- You have a legal right to object to this processing, and there are no overriding legitimate grounds for the processing;
- The personal data has been unlawfully processed; or
- Erasure is necessary to fulfill a legal obligation of Hanover Research.
The right to erasure does not apply to the extent that processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation of Hanover Research or a Hanover Research client, for archiving purposes in the public interests, or for the establishment, exercise, or defense of legal claims.
- You may request that we transfer your personal information to another controller, if technically feasible and the processing is based on your consent or a contract performance.
Your California Privacy Rights
Information We May Collect
|Identifiers||Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers||Yes|
|Categories of personal information described in Cal. Civ. Code 1798.80(e)||Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information||Yes|
|Characteristics of protected classifications under California or federal law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||Yes|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies||Yes|
|Biometric information||Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information||No|
|Internet or other electronic network activity information||Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.||Yes|
|Geolocation data||Physical location or movements||No|
|Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information||No|
|Professional or employment-related information||Current or past job history or performance evaluations||Yes|
|Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||Yes|
|Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
Sources of California Personal Information
We obtain the above categories of personal information from the following categories of sources:
- Directly from you: For instance, you may provide us with information when signing up for an account
- Indirectly from you: For example, we may observe your interactions on our website
- From third parties: For example, a school or company with whom you conduct business may provide us with information related to the services that we provide.
- From publicly available information.
Use of California Personal Information
We may use any of the above categories of collected User information to provide requested services, maintain and improve our services, communicate with Clients about Hanover Research Services and affiliated third-party services, market Hanover Research Services, prevent potentially illegal activities, protect the rights and property of Hanover Research and third parties, respond to inquiries of Clients, and for any other purpose to which the individual data subject has consented. Our use and disclosure of California Personal Information is more fully described above, in the section entitled “How We Use This Information”.
Sharing California Personal Information
We may disclose your personal information to a third party, as more fully described in the section above entitled “Sharing Personal Information). The vast majority of data that Hanover Research collects and discloses to its clients is in its capacity as a service provider, as defined by CCPA. Accordingly, Hanover Research does not typically “sell” CCPA-covered personal information. In the past 12 months, Hanover Research has disclosed the following categories of personal information for a business purpose:
- Categories of personal information described in Cal. Civ. Code 1798.80(e)
- Characteristics of protected classifications under California or federal law
- Commercial Information
- Internet or other electronic network activity information
In the past 12 months Hanover Research has disclosed personal information to the following categories of third parties:
Your rights under the CCPA
Some of the personal information that Hanover Research collects is related to employees. Most of the rights provided under the CCPA do not currently apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. The CCPA also currently exempts personal information reflecting a written or verbal business-to-business communication from many of its requirements. Moreover, Hanover Research typically acts as a service provider to its Clients. The Clients solely determine the purposes and means of processing Clients’ personal information. To the extent that Hanover Research collects or processes CCPA-covered personal information in its capacity as a service provider, requests for access to CCPA-covered data and deletion must be directed to the Hanover Research Client. In the rare instance that the CCPA rights apply to the personal information and Hanover Research does not collect or process data in its capacity as a service provider, you have the following rights:
Access to Personal Information Collected or Sold and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Your Rights” section), we will disclose to you:
- The categories of personal information we collected about you;
- The categories of sources for the personal information we collected about you;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we share that personal information;
- The specific pieces of personal information we collected about you (also called a data portability request;
If we disclosed your personal information for a business purpose, a separate list disclosing disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Deletion of Personal Information: You have the right to request deletion of personal information. If you wish to do so, please contact us at any method listed below. The right to deletion is subject to certain exceptions, such as if we need the personal information to provide Services or comply with legal obligation. No Discrimination: You will not be subject to discrimination for exercising any of your privacy rights. To exercise any applicable access, data portability, and deletion rights, please submit a verifiable consumer request by: sending mail to Hanover Research, 4401 Wilson Boulevard, 4th Floor, Arlington, VA 22203, calling (202) 559-0050, or emailing email@example.com. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Your name
- Additional information depending upon the type of request and the sensitivity of the information.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. You may designate an authorized agent to make a request under the CCPA on your behalf. The California Shine the Light Law requires companies to disclose certain information about information shared with third parties that is used for the third parties’ direct marketing purposes. If you are a California resident, you may request information about the disclosure of your personal information to third parties for the third parties’ direct marketing purposes by emailing firstname.lastname@example.org
Links to Third-Party Websites
Our site provides links to third-party websites, such as those of our clients. Hanover Research does not control and is not responsible for the information policies or practices of these third parties. You should review the privacy policies governing these third parties and their websites to learn more about how they collect and use your personal information.
International Transfers of Personal Information
- in the case of transfers to US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
- in the case of transfers to entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us using the details below.
How to Opt Out of Communications with Hanover Research
If you would like to opt out of further marketing communications from us, please unsubscribe at the following link: https://www.hanoverresearch.com/optout
. Please note that you may continue to receive certain transactional or account-related communications from us.
Access to Personal Information
In accordance with applicable law, you may access, update and correct inaccuracies in your personal information in our custody or control at any time, subject to limited exceptions prescribed by law. You can request access, corrections or updates to all personal information by contacting us as set out in the Contact Us section below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.