PRIVACY POLICY FOR SURVEY RESPONDENTS
46 Market values your privacy and is dedicated to the establishment of a fully transparent relationship between us, with regards
to the ways we collect and process your Personal Data. This Policy describes in detail what data we collect and process about
you, the purposes of processing, our processing activities, possible disclosures of your Personal Data to third parties as well as
your rights and opt-out options.
1. WHO WE ARE
46 Market Pte. Ltd. (hereinafter "46 Market ") is a Singaporean company (ACRA: 202031576G) registered at 111 North Bridge
Road #04-03 Peninsula Plaza Singapore 179098.
2. WHAT WE DO
2.1 46 Market operates an on-line survey respondent exchange, through which survey buyers (the "Buyers") may match with respondents to complete surveys (the “Respondents”). 46 Market connects with database owners (collectively "Databases"),
in order to access members of such Databases to match them with Buyers.
More specifically, cooperating Databases integrate with a 46 Market API, through which, every time Respondent connects to the Buyer, a certain set of anonymous automatically received data (please see section 3.1 of this Policy), are sent to 46 Market.
46 Market then processes such automatically received data in order to discern whether a Respondent is eligible for survey
tendering.
46 Market may also target such Respondents and tender to them sociodemographic (please see section 3.2 of this Policy) questionnaires, in order to better understand the sociodemographic profile of a Respondent, with the purpose of better
discerning whether such Respondent would satisfy the audience segment criteria set by a Buyer, according to the procedure described in section 2.2 below.
2.2 By connecting to 46 Market , a Buyer can send a survey questionnaire (or provide a link to an existing questionnaire) to
specific audience segments. The Buyer sets the targeting criteria and 46 Market distributes the surveys to the audience
segments which meet the targeting criteria set by the Buyer. 46 Market distributes the surveys created by the Buyer,
collects the survey responses of Respondents who have agreed to take a 46 Market survey
(the "46 Market Survey Respondents") and provides the Researcher with reports which consist of:
(a) Certain anonymous statistical and socio-demographic data pertaining to the statistical and socio-demographic profile of anonymous 46 Market Survey Respondents who have participated successfully in the Survey Process.
Following specific request by the Buyer, and where the Respondents are reached via mobile 46 Market may also provide
the Buyer with a 46 Market Survey Respondent electronic identifier which may consist of:
(a) the Survey Respondent Device ID
3. WHAT INFORMATION ABOUT YOU DO WE COLLECT?
3.1 Sociodemographic Data
These are data received by 46 Market , when 46 Market sends to Respondent a sociodemographic questionnaire (the "46 Market Internal Sociodemographic Survey"), operated and administered internally by 46 Market itself (i.e. not on behalf of a Buyer
or other 46 Market client) in order to better understand the sociodemographic profile of a Respondent and thus discern whether
this Respondent would be eligible for survey tendering according to certain general or specific audience segment criteria as set
each time by the Buyer.
Information collected through this process consist of the following information;
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gender
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age
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education
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income level
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race
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spoken languages
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organization role
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organization size
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year of birth
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marital status
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employment
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career
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number of employees
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zip code
3.2 Communication Data
If you choose to communicate with us (e.g. when you choose to exercise your Rights under this Policy), we may collect and
process such communication data, including the content of our communications, but such collection and processing is strictly
limited to the purpose of re-communicating with you about the subject of your initial communication.
4. What measures do we take to protect the anonymity of the information collected?
All data collected and processed under section 3 of this Policy is anonymous.
Despite the fact that 46 Market , by collecting and processing the Respondent’s Sociodemographic data and by correlating/associating such data with the other categories of data collected, is considered, under law, to process
"Personal Data" of the 46 Market Respondents, 46 Market takes additional measures, in a best effort basis, to ensure and
protect the anonymity of such data.
In that sense, 46 Market does not collect or process and does not allow Buyers
(through the survey questionnaires drafted by them) to ask questions about and/or collect real identifiers or direct personally identifiable information of a 46 Market Respondent, such as;
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surname or full name
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address
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telephone number
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billing address
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e-mail
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identity card number
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insurance number
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driver's license number
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passport number
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social security number
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credit/debit card number
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and/or any similar identifiers which are able to lead directly to the real-life identity of a data-subject.
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Please note that if you choose to communicate with us for any reason (e.g. for exercising your Data Protection related rights,
or for any other reason, we do collect and process personally identifiable information submitted by you (e.g. name, e-mail,
address etc.) but such collection and processing is strictly limited to the purpose of re-communicating with you about the subject
of your initial communication.
5. CONSENT
We collect and process your personal data only after you have provided clear opt-in consent to us for such collection and
processing. Your consent is the main legal basis of collection and processing, however, depending on the processing activity,
(please see section 6 of this Policy) we may further process your data under legal bases other than your consent.
By accepting this Privacy Policy, you grant to us your (revocable at any time) consent for the collection and processing of your Personal Data in accordance to this Policy. Furthermore, your explicit opt-in consent is provided to us in all stages of 46 Market interaction with you.
6. PROCESSING ACTIVITIES AND LEGAL BASES FOR PROCESSING
6.1 46 Market collects, stores and processes your personal data for the following purposes:
(a) to be able to discern survey tendering eligibility. For this purpose, we collect, store and process automatically received data
and sociodemographic data about your person, we correlate, associate and analyse this data and proceed to market profiling or
other statistical processing and sociodemographic grouping. [Legal basis of processing activity: Your Consent].
(b) to provide services and execute our contractual obligations towards our Researcher Clients. For this purpose we collect, store
and process the automatically received data, the sociodemographic data and the content data about your person and provide our Researcher Clients with Survey Reports which may include your Device ID/Advertising ID (only for mobile Respondents, and only
if specifically requested by the Researcher Client), the sociodemographic data and the Content Data (the answers to the
Researcher Client tendered questionnaires). [Legal basis of processing activity: Your Consent].
(c) to provide services and execute our contractual obligations towards our Mediation Partners. For this purpose, we share with
our Mediation Partners your Device ID/Advertising ID, along with the sociodemographic data, in order for them to be able to
discern survey tendering eligibility of a 46 Market Respondent and then serve Mediation Surveys to 46 Market Respondents.
[Legal basis of processing: Your Consent]
(d) to provide services and execute our contractual obligations towards the "Other 46 Market Clients". Such other 46 Market
clients may consist of data brokers, data aggregators, advertisers, marketeers or data analysts, interested in obtaining
anonymous information about you, for purposes such as: conducting marketing campaigns, re-conducting data analyses, data matching, data validation, data append and coding, data segmentation, Respondent incentivisation, conduct of promotional campaigns, conducting internet security or anti-fraud analyses, serving you advertisements which may be of specific interest
to you, conducting consumer profiling analyses, developing audience insights and/or look-alike models, performing analytics, providing marketing intelligence. [legal basis of processing: Your Consent]
(d) To manage and protect our business (including in case of reorganization, sale of assets, merger or acquisition, liquidation and similar processes), for improving data security, fraud prevention, troubleshooting data and systems, system maintenance and
testing, data hosting, managing our offices and other facilities. [legal basis of processing: legitimate interests]
(e) to comply with state and federal laws in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity or other legal process. We also reserve the right to disclose data collected
by us, as we believe, in good faith, is appropriate or necessary to take precautions against liability; to protect 46 Market and
others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any claims or
allegations; to assist government enforcement agencies; to protect the security or integrity of the Service and our other property;
or to protect the rights, property, or safety of us, our Respondents, or other persons or entities. [legal bases of processing:
legitimate interests/Legal or regulatory obligation]
(f) for further internal analyses and statistical purposes, related to the interaction between 46 Market and Respondents and/or 46 Market Respondents [legal basis of processing: legitimate interests]
(g) to answer to your requests and satisfy your data protection related rights [legal basis of processing: Legal or regulatory
obligation]
6.2 We will only use your personal data for the purposes for which we collected it as detailed in Section 6.1 above. If we need to
use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
7. DISCLOSURES OF YOUR PERSONAL DATA
7.1 We disclose or may disclose your personal data to Third Parties.
7.3 We require from all third parties with whom we share your data to agree and warrant that all the processing operations in
which they engage shall be lawful and compliant with the provisions of the Data Privacy Act and/or the EU-US/SWISS-US
Privacy Shield (and/or provide warranties that processing from their part shall take place under the same level of protection and under the same principles as set-out in the Data Privacy Act and the EU-US/SWISS-US Privacy Shield) and any further Data Protection Legislation which may be applicable to their business.
We also require that they provide, in particular in terms of expert knowledge, reliability and resources, sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements the
Data Privacy Act and/or the EU-US/SWISS-US Privacy Shield (or provide equal level of protection) and ensure the protection of
the rights of the data subject.
7.4 46 Market does not itself collect (and does not allow third parties to directly collect e.g. via third party cookies), Respondent
multi-site or cross-app data through the operation of the 46 Market platform. However, 46 Market may share or license
46 Market -collected data with third entities which, after having received 46 Market data, may themselves associate them with
other data (including multi-site data or cross-app data) previously collected/owned by them or licensed to them by other
(non-46 Market and non-46 Market -affiliated) sources.
Such third-party entities, depending on their business scope, may engage in Online Behavioral and Interest based Advertising, allowing advertisers to infer interests and serve ads to Respondents based on their activity and location over time. For the
transfer or licensing of 46 Market -collected Data to aforementioned entities (although such transferred/licensed data does
not in itself include any cross-app or multi-site data) we require from clients to be compliant:
with the DAA (Digital Advertising Alliance) to be found at http://www.aboutads.info/ (as each set of principles may be amended
from time to time by the DAA or any successor entity to the DAA, and all interpretations of the DAA's Self-Regulatory Principles, whether by the DAA itself or by the Council of Better Business Bureaus in an accountability proceeding or otherwise)
the NAI self-regulatory principles to be found at http://www.networkadvertising.org/ (as the Code may be amended from time to
time by the NAI or any successor entity to the NAI, and all interpretations of the NAI's Code of Conduct by the NAI itself or any successor entity to the NAI)
the Principles of the European Interactive Digital Alliance ("EDAA"), currently available at
(http://www.edaa.eu/european-principles/), as each set of principles may be amended from time to time by the EDAA or any successor entity to the EDAA any other relevant FTC, NAI or DAA code, principles or other guidance relating to the collection
and use of data or serving of advertising or other Targeted content in the mobile environment
all United States Federal Trade Commission ("FTC") rules and guidelines regarding the collection, use or disclosure of
information from or about a unique Respondent of a website, application or mobile website and/or the device associated with
such Respondent.
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7.5 By accepting this Privacy Policy you grant your consent for the sharing of your personal information as described in this
section 7.2. However, you can at all times withdraw your consent with regards to such sharing, by using the opt-out options
provided to you under section 8 of this Policy or by submitting a request under section 14 of this Policy.
8. OPT-OUT OPTIONS AND MANAGEMENT OF YOUR PERSONAL DATA
46 Market respects your right to opt-out at any time by contacting janerik.wagner@wwlt.com.au with your opt-out request.
9. INTERNATIONAL TRANSFERS
We may transfer the Personal Information we collect about you to Singapore, where we are headquartered, and by accepting this Privacy Policy you explicitly permit us to do so.
10. DATA RETENTION
We may retain your Personal Data to fulfill the purposes outlined in this Policy for three (3) years from collection date ("Retention Period"). After the expiration of the Retention period we may retain the data in fully de-identified form for statistical purposes
only.
12. PROTECTION OF MINORS
46 Market takes all necessary actions to comply with COPPA and the Data Privacy Act and protect the rights and safety of
children under 16 years old (Minors). We make efforts to exclude Minors from any collection of data and therefore we delete any information and data that has come to our attention that is related with Minors without any notice.
More specifically, 46 Market does not knowingly direct surveys to any person under the age of 16.
46 Market makes all reasonable efforts to identify, through its own audience screening procedures, the age of an eligible
respondent. If an eligible respondent is identified to be under the age of 16, 46 Market will block such respondent from any
survey tendering and shall mark such respondent as ineligible, with the aim of safeguarding that no child under the age of 16 is
ever knowingly targeted by 46 Market in the future.
If, despite our screening efforts, it has come to your attention anything regarding this issue please contact us immediately.
11. CCPA COMPLIANCE
46 Market complies with the CCPA (California Consumer Privacy Act) 46 Market has decided to incorporate CCPA requirements
in its general policies and use a uniform set of rules for all 46 Market Respondents irrespective of their place of residence.
Therefore, the information provided in this section applies for California as well as for non-California residents alike.
12. 46 Market AND THE DATA PRIVACY ACT OF 2012
46 Market processes Personal Data in accordance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of
2012 (hereinafter referred to as the “Data Privacy Act”).
In particular, 46 Market processes personal data only in accordance with Data Privacy Act data protection principles and Data
Privacy Act data protection provisions.
46 Market also implements appropriate technical and organisational measures and demonstrates compliance and ensures that
both in the planning and implementation of processing activities, data protection principles and appropriate safeguards are addressed and implemented (data protection by design and default).
13. PRIVACY - 46 Market AND THE EU-US PRIVACY SHIELD/SWISS-U.S. PRIVACY SHIELD
46 Market complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by
the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the
European Union and Switzerland to the United States.
46 Market has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn
more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
46 Market 's participation in the Privacy Shield applies to all personal data that is subject to the 46 Market Privacy Statement
and is received from the European Union, European Economic Area, and Switzerland. 46 Market will comply with the Privacy
Shield Principles in respect of such personal data. 46 Market is also affirmatively committed to comply with the Swiss – U.S.
Privacy Shield Framework.
In compliance with the Privacy Shield Principles, 46 Market 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 46 Market at: janerik.wagner@wwlt.com.au
46 Market commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities
with regard to human resources data transferred from the EU in the context of the employment relationship.
46 Market 's accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party
is described in the Privacy Shield Principles. 46 Market is liable in cases of onward transfers to third parties. For the type or
identity of third parties to which 46 Market discloses personal information and the purposes for which it does so, please see
section 5 "Recipients of Data" above.
In particular, 46 Market remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages
to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless 46 Market proves that it is
not responsible for the event giving rise to the damage.
Similarly, transfers to third parties acting as data controllers also complies to the Privacy Shield Principles and in particular the Notice and Choice principles.
46 Market has entered into contracts with such third-party controllers that provide that such data may only be processed for
limited and specified purposes consistent with the consent provided by the individual and that the third-party controller will
provide the same level of protection as the Privacy Shield principles and will notify 46 Market if it makes a determination that it
can no longer meet this obligation.
You have the right to access your personal data. The choices and means 46 Market offers to you for limiting the use and
disclosure of your data is described in section 14 ("Your Privacy Rights") and section 8 ("Opt-out options") above. 46 Market
may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security of law enforcement requirements.
46 Market has further committed to refer unresolved Privacy Shield complaints to panel of EU Data Protection Authorities under
the EU-U.S. Privacy Shield Framework and/or the Swiss Federal Data Protection and Information Commissioner under the
Swiss-U.S. Privacy Shield Framework, an alternative dispute resolution provider located in the EU.
If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU Data Protection Authorities for more information or to file a complaint. The services of panel
of the EU Data Protection Authorities under the EU-U.S. Privacy Shield Framework and/or the Swiss Federal Data Protection and Information Commissioner under the Swiss-U.S. Privacy Shield Framework are provided at no cost to you.
As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to
address residual complaints not resolved by any other means.
46 Market is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) and the FTC has jurisdiction over 46 Market 's compliance with the Privacy Shield.
14. YOUR PRIVACY RIGHTS
14.1 In addition to the opt-out options provided to you under section 8 of this Policy, and In your capacity as a data subject whose
data is collected and processed by 46 Market , we inform you that you have the following rights:
(a) the right to withdraw your consent at any time and without detriment, without affecting the lawfulness of processing based on consent before its withdrawal, by notifying such withdrawal to us.
(b) the right to request from 46 Market access to and rectification or erasure of personal data or restriction of processing
concerning you and to object to processing as well as the right to data portability;
(c) the right to receive notification regarding rectification or erasure of your personal data or restriction of processing that is
takes place following your request;
(d) the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal
effects concerning you or similarly significantly affects you, and
(e) to lodge a complaint with a supervisory authority.
We reserve the right to not satisfy in whole or in part a request under this section 14.1, if such non-satisfaction is grounded on
the provisions of the Data Privacy Act (for EU citizens) or the CCPA (for California residents).
Where we receive an erasure request, we will so inform all 46 Market Clients with whom we have shared your personal
information in the past, so that they also erase such data from their systems and providing us with a formal attestation in writing
that they have so acted.
Without limiting the foregoing, we may not satisfy a request for data erasure in the following cases:
(a) under the Data Privacy Act, for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest in the area of public health, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes and for the establishment, exercise or defense of legal claims.
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(b) under the CCPA, to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute
those responsible for such activities, to debug products to identify and repair errors that impair existing intended functionality, to exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right
provided for by law, to Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.),
to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the
research's achievement, if you previously provided informed consent, to enable solely internal uses that are reasonably aligned
with consumer expectations based on your relationship with us, to comply with a legal obligation and to make other internal and lawful uses of that information that are compatible with the context in which you provided it.
14.2 As regards your rights to specific information and data portability, you are informed of the following: once we receive a
verifiable data access request from you, we will disclose to you all and any information you request from us to disclose to you,
without any time limitations (e.g. we will disclose to you all information we collected and processed about you, not only for the preceding 12months or other limited preceding time period but for the whole time-period extending from the date of collection to
the date of request).
According to request and among other information you may request to be provided to you, disclosures will include the following information: the categories and the specific pieces of personal information we collected about you (including copies of data processed), the categories and the identity of sources for the personal information we collected about you, the business or commercial purpose for collecting or selling that personal information, the categories and the identity of third parties with whom
we share that personal information, and, if we sold or disclosed your personal information for a business purpose, two separate
lists disclosing
(a) sales, identifying the personal information categories and the specific pieces of data that each category of recipient
purchased as well as the identity of each recipient and
(b) disclosures for a business purpose, identifying the personal information categories and the specific pieces of data that each category of recipient obtained, as well as the identity of each recipient. Furthermore, we will disclose to you the recipients or categories of recipients in third countries or international organisations (i.e. outside the EEA) to whom the personal data have
been or will be disclosed, the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of
the Data Privacy Act and, at least in those cases, meaningful information about the logic involved, as well as the significance and
the envisaged consequences of such processing for the data subject.
Finally, information disclosed to you, shall include, according to request, the appropriate safeguards pursuant to Article 46 of the
Data Privacy Act relating to the transfer of data outside the EEA.
14.3 We will respond to a data request according to section 14.3 of this Policy, without undue delay, and in any event within one
month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
Where you make the request by electronic form means, the information shall be provided to you by electronic means where
possible, unless otherwise requested by you.
14.2 CONTACT US
To exercise your rights under section 14.1 of this Privacy Policy please submit a verifiable request to us by either:
Calling us at +65 8741 75 34
Sending us an e-mail at: janerik.wagner@wwlt.com.au
Please describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to
make the request and confirm the personal information relates to you. For verification purposes we may request from you to
provide to us sufficient additional information. Making a verifiable request does not require you to create an account with us.
We will only use personal information provided in a verifiable request to verify the requestor's identity or authority to make the request.
We do not charge a fee to process or respond to your verifiable 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.
15. FURTHER 46 Market CONTACT INFO/REPRESENTATIVE IN THE EU/DATA PROTECTION OFFICER
Please contact us with any questions or comments about this Policy, your personal information, our third-party disclosure
practices, or your consent choices by email: janerik.wagner@wwlt.com.au
16. YOUR CONFIDENTIALITY OBLIGATIONS.
You understand that, when you agree to take a survey, any such survey shown to you will include information, in content and
form (including but not limited to the survey concept, ideas, questions, designs, features, question sequence, Researcher logos, names, marks, brand and product info, potential offers, Researcher contact info etc.) which is proprietary information of the Researcher.
All rights to such information are vested in the Researcher and are confidential information of such Researcher (hereinafter the “Confidential Information”).
For the avoidance of doubt, Confidential Information includes also the existence and distribution of a survey (i.e. the fact that a Researcher has opted to engage in marketing research activity) and all and any accompanying information of such survey,
directly or indirectly inferred (e.g. Researcher’s brand strategy, product development etc.) from the survey, without any
restriction whatsoever, and including but not limited to the Researcher’s identity, the duration of the survey, the survey date, the answers you provided to certain questions, the distribution channels of the survey such as web, mobile phone etc.
You hereby explicitly agree to keep the Confidential Information strictly confidential and not, whether orally or in writing or by
any other means, directly or indirectly, use in any manner and form (except from limited use strictly necessary in order to take
the survey, such permitted use ending with the submission of your answers to the survey shown to you) disclose, divulge,
provide or make accessible to any other person (the term "person/s" being broadly interpreted to include, without limitation, any corporation, company, partnership and individual as well), any Confidential Information.
Your confidentiality obligations set-out in this clause shall be in addition to any further obligations you may have regarding the confidential and non-infringing treatment of such information, stemming directly from any applicable Intellectual Property, Trade-Secrets and non-competition Laws, rules and regulations.
You further understand and agree that, in case of breach of this clause 16, Researcher shall have all legal right to directly protect
his Confidential Information and all his legal interests attached thereto, including direct enforcement of such rights against you
or any third-party which has gained unauthorized access to Confidential Information.
17. CHANGES AND UPDATES TO THIS POLICY
46 Market reserves the right to modify the terms and conditions of this Policy or alter or end its Services at any time at its sole discretion. You are responsible for ensuring that you will regularly review the present Policy. If you choose to continue using 46 Market Services after any modifications to the present Policy is made, you will be considered to have fully and unconditionally accepted the aforementioned modifications to this Agreement.