Privacy Policy

Updated on 2023-11-30

Lartey Research and Management, LLC (“LarteyResearch”, “SurveyLartey”, “we”, “us”) values the user’s (“you”, “your”) privacy. We understand and take seriously your concern and care about your personal information and how it is used, stored, and disclosed. We are committed to protecting the privacy of our users and providing you with transparency on the use, storage, and manipulation of your personal information.

This Privacy Policy (“Policy”) describes how we and our affiliates (collectively, “we”, “our”, and “us”) collect, use, process, store, retain, disclose, or transfer your personal information when you use the SurveyLartey website at https//surveylartey.com (“website”, “app”,  “services”) or when you download the SurveyLartey mobile app (“app”, “mobile app”, “services”) through the relevant app store such as Apple Store and Google Play and create your account (“Account”) to use the app and other tools and services offered (“Services”). By using our app or website, you agree to the terms of this Privacy Policy.

This Policy applies to your use of our services and covers only information collected in connection with your access to and use of our services. Please read this Privacy Notice carefully. By continuing to interact with our Services, you are consenting to the practices described in this Privacy Notice. We reserve the right to make changes to this policy at any given time and update accordingly on our website and mobile app.

Please note that this Policy does not govern the collection and use of information by companies that we do not control, nor by individuals not employed or managed by us. As such, if you visit a web site or use an application that we mention or link to, make sure to review their privacy policy prior to providing them with any of your information.

This Policy will inform you of the following:

  1. Information we collect about you
  2. How we collect your information
  3. Use of Your Personal Information
  4. Disclosure of Personal Information
  5. Cookies and other automated technologies
  6. Third party analytics services
  7. How long we keep your information
  8. Your rights and choices
  9. Children’s privacy
  10. Rights of California residents
  11. Information security
  12. Data storage
  13. Changes to the Policy
  14. How to contact us

INFORMATION WE COLLECT ABOUT YOU

In order to provide you the Services or support you expect from us, we need to collect information about you. Specifically, we collect various categories of information from you, as presented in what follows.

Information you provide to access our services.

When you sign up for our services by creating your account, you provide us with your information. You also provide additional personal information when going through the authentication and account verification processes, when you communicate with us, respond to our surveys, participate in contests and promotions offered by us or our partners, and when you visit or use our services in general.

When you use our Services, we collect the following categories of information about you:

  • Initial identification information when creating or accessing your account include your first and last names, email address, alias, phone number, password, personal identification number (PIN), and IP address.
  • Additional identification information to verify your identity include your date of birth, your social security number, full mailing address, a government issued identification (passport, driver’s license, national or state identification card, or other government issued ID), a proof of address (any utility bill, a government mail received, an insurance mail, or any other mail), you job title optionally, an optional personal message to show to everyone, your photograph, and any facial scan and biometrics extracted from these documents.
  • Financial information includes bank account information and credit card numbers used for making payments.
  • Transaction information is gathered when you use our Services to make, request, or accept payment. We collect information such as the date and time of transaction, the name of transacting parties, description of the transaction, the paid or transferred amounts, the payment methods used, the devices used to request, accept, or make payments.
  • Contact information collected includes information we collect from you related to your contacts or audience, intended recipients of payments, and possible people you could sponsor or invite to create their accounts with us.
  • Other information you provide, including survey questions, survey responses, participation in contests, prospective marketing forms, suggestions for improvement, referrals, comments, product reviews, testimonials, information you provide us for customer service (including chat) and other content, and other actions you choose to perform while using our Services.

Information we collect while you use our Services.

In addition to the information you provide to us or collected during your transactions, we collect information about you and the devices you use to access the services, such as your computer, mobile phone, or tablet. This information includes:

  • Geolocation information which contains the geographical location of your device, including your IP address, device language, and location of your network provider. Such information could include precise geolocation information from your device.
  • Device information: we also collect information about your device and it’s interactions with our services, including: the device’s unique identifier, name, brand, manufacturer, model, brand, year, type of processor, operating system (OS), OS version, OS build, mobile network information, and browser agent.
  • Network activity information is collected when you use our servicesThis includes authentication information, log-in and log-out date and time, IP address, device information, your internet service provider, pages visited on our website, features you use, country and language setting on your device, and your browser type.
  • Inference Information, include any information we may infer from all information described above.

HOW WE COLLECT YOUR INFORMATION

We need to collect your information in order to provide you the services and support you expect from us. We collect and/or have collected information about you during at least the 12-month period preceding the effective date of this Policy, through various means and sources.

Directly from your: We collect your personal information directly from you. This is information you provide to access our services, create your user account, update your profile, contact us by email or via chat, respond to surveys, participate in contests and sweepstakes, post reviews, and any other information you share with us while using our app or website, or through third-party partners.

From your devices: When you use our app or website, the device you use provides us information about you, such as the type of browser you use, your device’s operating system, and other information presented later in this Policy.

From a user, partner, affiliate, or third-party organization: We can collect information related to you from our users, partners, and third-party companies. For example, a user on our platform could provide us with your name and email when inviting you to join our platform, even if you are not yet a registered user. They could also provide your country, state, city, and other information when uploading the contacts from their mobile devices into their profile.

Using cookies and other automated data collection technologies: We may collect information about you using cookies, web server logs, and other automated processes when you visit our Website, use our App, click links or buttons in emails we send, or interact with our advertisements.

From other sources: We may obtain information about you from other sources, such as social media platforms, marketing or advertising providers, data analytics organizations, publicly available sources, fraud prevention or identity verification service providers, electronic databases, credit reporting companies, or any other vendor providing services on our behalf or that of our partners.

USE OF YOUR PERSONAL INFORMATION

There are many reasons for collecting, using, and sharing information about you. Most of the reasons are presented in what follows.

Providing, enhancing, or updating our Services: We use your personal information in order to provide you with our Services. We need to make sure we are providing the appropriate services to the appropriate user. For that, we need to collect and validate your information. Your personal information allows us to determine if our Services are available in your country, to process your transactions, maintain and manage your account, provide products and features you select to use, process payment transactions including money transfers, show your transaction history, develop new products and services, enhance your experience in using our Services, measure trends and usage for the proper performance of our Services.

Communicating with you: We use your personal information to communicate with you, such as respond to your requests, issues, inquiries, or feedback; provide customer service; send you surveys and receiving your feedback; or sending you useful information about updates to our products and services.

Security and fraud prevention: We use your personal information to detect, investigate, prevent, and take action on possible deceptive, malicious, illegal, or fraudulent activities. Such activities include fraudulent transactions, attempts to manipulate data, violate our policies, procedures, and terms of use, or any attempt to harm the rights, properties, or safety of our consumers, users, employees, partners, stakeholders, brand, or others. Your information allows us to handle fraud through prevention, detection, investigation, and fraud recovery by identifying misrepresentation, incidents, security breaches, malicious or illegal activities, and other potentially prohibited activities. This helps us protect your account, including charge-back disputes on your behalf, protecting your rights and properties, and debugging and fixing errors that can impair your use of our products and Services.

Complying with applicable laws: We use your personal information to comply with applicable laws and regulations, such as anti-money laundering laws, current legislation, various related regulatory rules, and guidance associated with risk investigation, risk scoring, fraud, counter-terrorism financing, consumer protection, anti-money laundering, complaint handling, anti-discrimination, and other existing legal requirements.

Marketing and promotional purposes: We use your information for marketing and promotional purposes, including sending advertising, marketing, and promotional communication by email, postal mail, text messages, or notifications. We also use your information to show you advertisements for products and services tailored to you, from us or from our partners, including offers from other companies, websites, and social media sites. We can also use your information to send and manage promotions, sweepstakes, contests, and other similar advertisements or marketing activities.

Analytics and personalization: We use your personal information to understand how you use our Services, conduct analysis and market research, improve our product and Services, and enhance and grow our offerings. We also use your information to understand how you interact with our mobile app, websites, advertisements, and communications. This allows us to be responsive to your habits and expectations by personalizing your experience, saving you time when you use our Services, and customizing our marketing and advertising options presented to you.

Other usage: We might use your information for other reasons not presented here, but we will make sure to update our Policy to reflect such use within twelve months from the time we start conducting such activity, including trial and testing period. Your consent will be required for the continued use of your information in such manner.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose the information we collect about you with your consent or to complete any transaction or provide any product or service you have authorized. We also share your information with our controlled affiliates, partners, and subsidiaries, with vendors working on our or your behalf, when required by law, or to respond to legal entities or processes. In addition to the situations discussed in this Policy, we may disclose your personal information under various circumstances with the following:

Users of our Services: We may share your personal information with other users of our Services. For example, if a person sends you reward points or money to for our services, we will display your first and last name for that transaction. As such, we share some of your information with other users with whom you transact when you send or receive money or points, or request, make, or accept such. We do not share your information with the other transacting user when you make anonymous payment or donations. When sharing your information with other users, the goal is to help them confirm the person with whom they are transacting. We may also make some of your information such as your name and prior related transactions available to other users with whom you transact through our Services to help them confirm that they are transacting with the right person.

Partners and affiliate organizations: We may disclose your personal information with our companies, corporate affiliates, and third-party partners that work with us on joint productions, promotions, or product and service creation and offering. For example, we may share your information internally to help us build Services tailored to your preferences or to troubleshoot issues affecting your use of our Services. We could also share information such as your email with a partner conducting surveys on our behalf or when we use their platform to conduct such surveys.

Service providers and third-party partners: We may share your information with service providers who help us provide, improve, and maintain our products and Services. Such vendors provide services including fee collection, identity verification, fraud prevention, financial services, credit card services, money transfer, investing, brokerage, and other services that help us serve you or improve our Services. In some situations, your information exchanged with a bank, credit card company, or fraud prevention or detection provider could be governed by the privacy policy of such third party, requiring your consent and approval.

Business transactions: In case we became involved in a consolidation, a merger, an acquisition, restructuring, or any other business transaction involving the transfer of some or all of our business assets, your personal information could be shared with businesses or people involved in the negotiations related to these transactions.

Legal, safety, and compliance with the law: We may disclose your personal information in response to legal requests or requirements such as warrants, subpoenas, court orders, government inquiries and investigations, and other legal processes requiring us to disclose your information. We may also disclose your information to protect our rights or the right of others, to defend against a legal claim, to comply with applicable laws, regulations, and legal or governmental requests, to protect our customers’ rights or properties as well as ours, to protect the security and integrity of our Services, to protect our users, ourselves, our Services, and the public from harm, fraud, or potentially prohibited or illegal activities or violations of our policies.

Social media and other websites: Your information can be shared with your consent in situations where you authorize a third-party application or website to access it on our servers. In such case, the use of your information by the third party is not governed by this Policy.

COOKIES AND OTHER AUTOMATED TECHNOLOGIES

When you interact with our online services, you consent to the use of cookies and tracking technologies. When you visit our website or open emails we send you, we may obtain certain information using automated technologies, such as cookies, web server logs, web beacons, and other technologies. A cookie is a text file a visited website places on a user’s computer or other internet-connected device to uniquely identify the visitor’s browser, to store information or settings, and to remember the user’s preferences and personalize their experience. A web beacon, also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our websites or emails. Other automated technologies include tracking script that could be used by our Services. All these technologies are used to collect information about your device and how you interact with our services. We use cookies and other similar automated technologies for the following purposes:

  • To personalize your experience and remember your preferences so you don’t have to re-enter them every time you want to use our services. For example, once you login on a device, do not need to login back for some time or until you logout, as the use of this technology allows you to stay logged in.
  • To analyze how you use or interact with our Services, emails, and App, and improve our service offerings, including for marketing and advertising.
  • To prevent fraud and protect the security of our services.
  • To comply with legal obligations

Some of these automated technologies are set by us, but others are set by third parties we use in providing our Services or who deliver services on our behalf. We may use the following types of cookies and similar automated technologies:

Essential cookies: These cookies are necessary for the operation of our website and mobile app. They enable you to use our services and access certain features.

Analytical cookies: These cookies are used to collect information about how you use our website and mobile app. They help us understand how our services are used and how we can improve them.

Functionality cookies: These cookies are used to remember your preferences and personalize your experience. For example, they may remember your login information or language preferences.

Advertising cookies: These cookies are used to track your activity on our website and mobile app for marketing and advertising purposes. They may be used by us or by third-party advertising partners.

Most web browsers allow you to control cookies through their settings. You can choose to accept or reject cookies, or to receive a notification when a cookie is set. You can also delete cookies from your browser's settings.

However, please note that disabling cookies may prevent you from accessing certain features of our website or App.

THIRD PARTY ANALYTICS SERVICES

We may use third-party analytics services, such as Google Analytics, to collect information about your use of our website or mobile app. These analytics services use cookies and other similar technologies to collect information about your device and how you interact with our services.

What information do third-party analytics services collect?

  • Third-party analytics services may collect the following types of information:
  • Information about your device, such as your IP address, browser type, and operating system
  • Information about your use of our website or mobile app, such as the pages you visit and the features you use.
  • Information about your location, if you have enabled location tracking on your device

How do we use information collected by third-party analytics services?

  • We use information collected by third-party analytics services for the following purposes:
  • To understand how you use our website or mobile app and improve our services.
  • To analyze trends and patterns in user behavior
  • To measure the effectiveness of our marketing and advertising campaigns
  • To comply with legal obligations

How do third-party analytics services use information?

  • Third-party analytics services may use information collected from our website or mobile app for their own purposes, such as to improve their own services or to target advertising to you based on your interests.
  • However, we do not allow third-party analytics services to use information collected from our website or mobile app for any other purpose than to provide analytics services to us.

How to opt-out of third-party analytics services

  • You can opt-out of third-party analytics services by disabling cookies in your web browser. You can also use tools provided by the analytics services themselves to opt out of data collection.
  • Please note that disabling cookies or opting out of data collection may prevent you from using certain features of our website or mobile app.

HOW LONG WE KEEP YOUR INFORMATION

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. How long we keep your data depends on the type of data and the purpose for which it was collected. We will retain your account information for as long as you have an active account with us. If you delete your account, we will still retain copies of information about you and any transaction or services in which you may have participated for a period of time that is consistent with applicable laws, legal or regulatory processes, statute of limitation, governmental requests, and other reasons such as payments processing and compliance with financial reporting requirements, collection of fees owed, dispute resolution, fraud prevention, or to analyze trends and patterns in user behavior and improve our services. We may also retain your marketing information for as long as you have not opted out of receiving marketing communications from us. If you opt out, we will retain your contact information as long as necessary to ensure that we do not send you any further marketing communications. In some cases, the deletion of your information could consist of anonymization of the associated data when such deletion could corrupt other existing data. For example, we cannot delete a transaction in which you were a part of, as it would affect the other user in the transaction. In such case, we would make your portion of the transaction become anonymous.

YOUR RIGHTS AND CHOICES

As a user of our website or mobile app, you have certain rights and choices regarding the use and disclosure of your personal data. We respect your privacy and strive to provide you with the tools and information you need to exercise your rights and make informed choices.

Accessing, Correcting, or Deleting Your Personal Data: You have the right to access, correct, or delete your personal data at any time. You can do so by logging into your account or by contacting us at privacy@surveylartey.com. We will respond to your request within fourteen days and will take reasonable steps to verify your identity before fulfilling your request. Please note that we may be required by law to retain certain information, even if you request its deletion.

Opting-Out of Marketing Communications: You have the right to opt-out of receiving marketing communications from us at any time. You can do so by clicking the "unsubscribe" link in our emails, by using the settings provided by our website or mobile app, or by contacting us at privacy@surveylartey.com. We will promptly honor your request and remove you from our mailing list.

Controlling Cookies and Similar Technologies: You have the right to control cookies and other similar technologies used on our website or mobile app. You can do so by adjusting your browser settings or by using the settings provided by our website or mobile app. Please note that disabling cookies may prevent you from using certain features of our website or mobile app.

Objecting to Processing: You have the right to object to the processing of your personal data under certain circumstances, such as if you believe that your data is being processed unlawfully or if you believe that the processing is no longer necessary for the purposes for which it was collected. You can do so by contacting us at privacy@surveylartey.com. We will promptly review your objection and respond to you in accordance with applicable law.

Complaints: If you believe we have violated your rights under applicable data protection laws, you have the right to lodge a complaint with the relevant data protection authority. However, we encourage you to contact us first, so that we can try to resolve the issue informally.

CHILDREN’S PRIVACY

Our website and mobile app are intended for use by individuals who are 13 years of age or older. We do not knowingly collect or solicit personal information from children under the age of 13. If we become aware that we have collected personal information from a child under the age of 13, we will take reasonable steps to promptly delete the information from our records.

  • If you are a parent or guardian and believe that your child under the age of 13 has provided personal information to us, please contact us immediately at privacy@surveylartey.com. We will take reasonable steps to promptly delete the information from our records.
  • If you are between the ages of 13 and 18, please obtain permission from your parent or guardian before using our mobile app.

RIGHTS OF CALIFORNIA RESIDENTS

This section applies solely to California residents in accordance with the California Consumer Privacy Act of 2018 (CCPA).

Personal Information Collection and Disclosure: In the preceding 12 months, we have collected the following categories of personal information from California residents:

  • Identifiers such as name, email address, phone number, and IP address
  • Personal information categories listed in the California Customer Records statute, such as name, address, and payment information
  • Commercial information such as purchase history and products or services obtained
  • Internet or other electronic network activity information, such as browsing history and interactions with our website or mobile app
  • Geolocation data, such as location information from your device or IP address
  • Inferences drawn from any of the above information, such as preferences and characteristics
  • We collect this personal information for the purposes described in the "Use of Your Personal Information" section of our privacy policy.
  • We may disclose this personal information to the categories of third parties described in the "Disclosure of Personal Information" section of our privacy policy.

Right to Know and Right to Delete: California residents have the right to know and request the following information from us:

  • The categories of personal information we have collected about you
  • The categories of sources from which we have collected your personal information
  • The business or commercial purpose for collecting or selling your personal information
  • The categories of third parties with whom we share your personal information
  • The specific pieces of personal information we have collected about you
  • California residents also have the right to request that we delete their personal information, subject to certain exceptions.
  • To exercise your right to know or your right to delete, please submit a verifiable consumer request to us at privacy@surveylartey.com. We will respond and will take reasonable steps to verify your identity before fulfilling your request.

Right to Opt-Out of Sale: California residents have the right to opt-out of the sale of their personal information. We do not sell your personal information to third parties.

Right to Non-Discrimination: California residents have the right to not be discriminated against for exercising their rights under the CCPA.

Authorized Agents: California residents may use an authorized agent to submit a request on their behalf. The authorized agent must provide a written authorization signed by the California resident and must verify their own identity with us.

INFORMATION SECURITY

We take the security of your personal information seriously and have implemented reasonable technical and organizational measures to protect it from unauthorized access, use, disclosure, alteration, or destruction. We regularly review and update our security practices to ensure that your personal information is protected at all times.

Encryption and Access Controls: We use encryption technologies to protect your personal information during transmission and storage. We also restrict access to your personal information to authorized personnel who have a legitimate business need to access it.

Third-Party Service Providers: We may engage third-party service providers to help us provide our services, such as hosting or payment processing providers. We require these providers to maintain reasonable security measures and to protect your personal information in accordance with applicable laws and regulations.

Data Breach Notification: In the event of a data breach that affects your personal information, we will take all necessary steps to mitigate the effects of the breach and to notify you as required by applicable laws and regulations.

User Responsibilities: You also play a critical role in maintaining the security of your personal information. We encourage you to use strong passwords and to keep your account information confidential. We also recommend that you log out of your account and close your browser when you have finished using our services to prevent unauthorized access to your account.

Please note that no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security."

Regular Risk Assessments and Audits: We regularly assess the risks to the security of your personal information and conduct periodic audits to ensure that our security measures are effective and up to date.

Employee Training: We provide regular training to our employees on the importance of protecting your personal information and the specific security measures and protocols that we have implemented.

Security Incident Response Plan: We have established a security incident response plan that outlines the steps we will take in the event of a security incident or breach, including notification to affected users and relevant authorities.

Secure Data Centers and Infrastructure: We use secure data centers and infrastructure to store and process your personal information. We also monitor our systems for potential security threats and vulnerabilities and take prompt action to address any issues that are identified.

Compliance with Applicable Laws and Regulations: We comply with all applicable laws and regulations governing the protection of personal information, including data protection laws and regulations in the jurisdictions where we operate.

DATA STORAGE

We store your personal information in secure data centers and servers located in various jurisdictions, including but not limited to the United States. We take reasonable measures to ensure that your personal information is protected against unauthorized access, use, disclosure, alteration, or destruction.

Data Replication and Backup: To ensure the availability and durability of your personal information, we may replicate and backup your data on servers located anywhere in the world. We require these servers to maintain the same level of security measures and protection for your personal information as our primary data centers and servers.

Data Retention: We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, as described in this privacy policy, or as required by applicable laws and regulations. When we no longer need your personal information, we will securely delete or anonymize it.

Third-Party Service Providers: We may engage third-party service providers to store your personal information on our behalf, such as cloud storage providers. We require these providers to maintain reasonable security measures and to protect your personal information in accordance with applicable laws and regulations.

International Data Transfers: Your personal information may be transferred to, and stored in, countries other than your own, including the United States. These countries may have different data protection laws than your own. Where we transfer your personal information to countries outside the European Economic Area, we ensure that appropriate safeguards are in place to protect your personal information, such as appropriate contractual clauses.

User Responsibilities: You also have a role to play in protecting your personal information. We recommend that you use strong passwords and that you keep your account information confidential. We also recommend that you log out of your account and close your browser when you have finished using our services to prevent unauthorized access to your account.

CHANGES IN THE POLICY

We may update this privacy policy from time to time to reflect changes in our practices, technologies, legal requirements, or other reasons. We encourage you to review this policy periodically to stay informed about how we collect, use, and protect your personal information. When we make significant changes to this policy, we will notify you by posting a notice on our website or by sending you an email. We may also seek your consent to the changes if required by applicable laws and regulations.

HOW TO CONTACT US

If you have any questions or concerns about our privacy practices or this privacy policy, please contact us by email at privacy@surveylartey.com. We will respond to your inquiry as soon as possible. If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information infringes on your rights under applicable data protection laws. Please note that this privacy policy only applies to our website and services, and not to third-party websites or services that may be linked from our website. We encourage you to review the privacy policies of these third-party websites and services before providing any personal information to them.

 

 


 
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