Privacy Policy

PRIVACY NOTICE

Last Updated: 17/10/2016

This privacy policy explains how Adgager A.Ş. companies (“Adgager”, “we”, “our”) collect and use the personal information you provide to us on https://www.adgager.com/ and through our mobile application. It also explains your choices regarding our use of your personal information and how you can access and update this information.

General Privacy Commitment

Adgager is a comprehensive market research industry and idea evaluation platform. As an online data collection company focused on providing high-quality data for advertising agencies and consultants, we create and maintain large online consumer panels. Your privacy and the confidentiality of your information are our top priorities. All data collected by Adgager for research purposes is reported in aggregate form about groups, not individuals. Even though individual data flows are provided, the identities and personal information of users are not shared. Individual information is never examined or published without consent, as the data is not related to the research conducted by our clients. All individual information provided is kept confidential in accordance with this Privacy Policy.

Information We Collect

Participation in our panel and research is voluntary. You can join the panel by filling out the registration form on our website or mobile application at https://www.adgager.com/ or by clicking on links on the websites of our partners who collect some personal and general consumer information about you. By registering, you agree to share your personal information with ADGAGER A.Ş., a company based in Turkey, and that this information will be stored on Adgager A.Ş.’s servers located in the United States and Turkey. Adgager collects personal information when an individual registers to become a member of one of our panels. Participation in any of our panels or research is voluntary. After registration, we ask panel members to provide us with more personal information to be invited to suitable surveys. To become a panel member, we ask you to fill out a registration form to collect a certain amount of personal information and general consumer information. To send you email invitations to participate in upcoming research, we ask for your email address and mobile phone information. Other information such as your name, address, gender, birth date, and employment status is used to match you with suitable market research projects. Your birth date is used to automatically update your age so we can target marketing groups based on age. We ask for this information to see if you are eligible for specific projects. Emails from Adgager will be sent to the primary email address you provided during registration or, if you prefer, to your mobile phone. If you become a panel member, your information (name, address, city, state, and postal code) will also be used for incentive purposes. This information is necessary to ensure that we can send your reward to the correct address when GAG incentives are credited to your account, and you wish to redeem them. Sometimes, third parties may be used for the organization of sweepstakes or the delivery of prizes; your personal information will be used solely for the purpose of sending your prize.

After registration, we ask panel members to provide us with more personal information to be invited to suitable research. In some cases, Adgager may ask you to inform us about your sensitive personal information; if we are not legally permitted to process such special information, we will seek your explicit consent. Generally, sensitive information that may be collected by Adgager includes race or ethnic origin, political opinions, physical or mental health or condition, and sexual life. This information is not shared with third parties unless required by law or as part of the transfer of Adgager’s operations.

If you participate in research or provide us with your personal information without being a panel member, the personal information we will retain is limited to your email address, gender, age, ethnicity, postal code, machine ID, and IP address. We do this to communicate with you if you win a prize or qualify for an incentive, to direct you to suitable research, and to improve the user experience. If you are not selected to become a member of the Adgager panel, we will not contact you for any reason except to inform you that you have won a prize or qualified for an incentive. If you qualify for a prize or incentive, we will collect and retain your personal information as required by law or regulations.

Our website does not offer public logs or community forums and operates on a closed system.

Use of Collected Information

The information you provide will be used to create and maintain the panelist database for our market research studies. If you are a member of the Adgager panel, your information will be stored in our proprietary database to identify individuals suitable for specific research studies. Our database, operated by Adgager A.Ş. and its members, may be used worldwide by Adgager and its partner companies for research and studies. If we believe your profile makes you a candidate for a specific study, we will notify you of this opportunity via email or mobile phone if you prefer.

### Sharing Information

Adgager does not sell or transfer personally identifiable information about panel members or individuals participating in our research except under the following conditions:

While we strive to protect your privacy, we may disclose your personal information if required by law or in response to legal processes, such as a court order or subpoena, or in the case of a bankruptcy proceeding. We may also share your information to protect our rights, prevent fraud or other illegal activities, and ensure the safety of Adgager’s site and its users. Additionally, if you provide your consent or under reasonable circumstances where the information is indirectly disclosed to third parties.

Adgager may occasionally use third-party software for managing and sending email lists or for matching our panel members with other lists or panels and verifying the accuracy of the information you provide. We may use third parties to collect data about you and add it to your demographic profile. In such cases, third parties are given minimal information to perform their functions on our behalf. We may also share your information with service providers to deliver rewards or other incentives you earn through participation in our panels.

When transferring personal data from an Adgager entity within the European Union to countries like the United States that do not provide the same level of security, Adgager uses transfer agreements based on the European Commission’s standard contractual clauses.

Cookies on Our Site

Adgager uses cookies to recognize participants when they connect to the Adgager website, facilitate site management for statistical purposes (pages viewed, viewing dates and times, etc.), and provide participants with tailored surveys. This will not affect your computer’s performance but will offer you opportunities to receive surveys more relevant to your interests. Information collected by cookies is automatically collected from users of the site. If we collect personal information about site visitors, such information will only be accessible by Adgager.

Adgager may supplement data collected in surveys with additional data from third-party sources, such as data enrichment services. We use this additional information to enhance our products, services, and content.

By using the site, all users consent to the placement of cookies on their computers and their use by Adgager, its clients, service providers, and partners. Cookies will expire after one year.

Site users can disable or delete cookies placed by Adgager or its clients. To do this, you must adjust your browser settings; click the help section of your web browser and follow the instructions.

Analytical Cookies

Adgager uses analytical cookies to count the number of visitors to the site and analyze which parts of the website are most popular. We collect feedback to improve our website and better serve our users and members. For more information about Google Analytics’ security and privacy policy, please visit the Google Analytics page.

Other Tracking Technologies

Technologies such as cookies, web beacons, scripts, and tags are used by Adgager and its clients, partners, affiliates, and analytics service providers. These technologies are used to analyze trends, administer the site, track user movements on the website and the internet, and collect demographic information about users as a whole. Clients may combine your survey responses with your demographic information and web surfing habits to create “aggregate” reports. They may also create scientific reports based on modeled information, which uses your demographic and behavioral characteristics (such as your gender, age, and the websites you visit) to determine what users with similar profiles watch or purchase. We may receive reports based on the use of these technologies on an individual or aggregated basis.

We use Local Shared Objects such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our website or display advertising based on your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

Log Files

As with most websites, we automatically collect information and store it in log files. This information includes internet protocol (IP) addresses, browser types, internet service providers (ISP), referring/exit pages, operating systems, date/time stamps, and clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer, conduct logical analysis, and enhance marketing and site functionality.

Advertising

We partner with third parties to display advertisements on our website or other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites to provide you with advertising based on your browsing activities and interests. If you wish to opt out of having this information used for the purpose of serving you interest-based ads, you may email us at hello@adgager.com. You will still receive generic ads.

Digital Fingerprinting

In general, digital fingerprinting technologies assign a unique identifier or “Machine ID” to a computer to identify and track it. Adgager will not use digital fingerprinting technology (“Technology”) to collect personal information or monitor your online activities on your computer. The Technology will not interfere with the use or control of your computer, change or modify its settings or functionality. Adgager will use the Technology to ensure the integrity of its research results. The Technology collects publicly accessible data from your computer’s web browser and other data points, such as technical settings and IP address, to analyze and assign a unique identification number to your computer. The unique identifier consists of a series of letters and numbers. After generating the unique identifier, Adgager will not store the data used to create the Technology’s identifier. As part of its ongoing efforts to ensure and maintain the integrity of its research results, Adgager may (a) link your unique identifier to your personal information, (b) share your unique identifier with Adgager’s clients and other sample providers, and (c) obtain a unique identifier linked to you from a third party, including another sample provider or Adgager’s clients. Unique identifiers obtained or created by Adgager will be protected under this privacy policy.

Adgager will take commercially reasonable measures to ensure that its Technology is secure, safe, and does not contain privacy or data security risks.

Adgager will use and distribute the Technology in a professional and ethical manner and in compliance with (a) Adgager’s privacy policy, (b) notices and/or disclosures made by Adgager, and (c) applicable laws and regulations.

If Adgager detects or becomes aware of any unethical conduct related to the use of the Technology, or if the Technology is used inconsistently with Adgager’s notices and/or disclosures or in violation of applicable laws or regulations, Adgager will take immediate action to terminate such unethical conduct and ensure the proper use of its Technology.

Access to Information; Member Service Area/Update, Correct, Delete Information

You have the right to access and correct your data. To access this data, you can write to the address below or contact us at hello@adgager.com. Our site includes a gager profile section where you can update, correct, or request to delete your information. If you are a panel member and cancel your membership, your profile information will be permanently deleted but may be stored in our backup databases for any potential needs; in such cases, your information will not be used for any commercial purposes. Please note that it may take two or three business days to completely remove your information from our records, but please allow up to fifteen days.

Opt-Out Policy

As a member of the Adgager panel, you agree to receive emails inviting you to participate in research that we believe is relevant to your experiences or background. You also agree to the automatic creation of your personal rewards account. Occasionally, we will send email and SMS newsletters to inform you about new opportunities or contests on our site. You can update your registration information at any time. Please review the Opt-In/Correction/Update Policy below.

Opt-In/Correction/Update Policy

Adgager requires that users of its gager profile have only one profile and takes necessary measures to ensure single usage. Therefore, you will go through a three-step verification process. Outside of the verification process (Email-Phone Number-ID or Passport Number) and self-calculating information (Age, Children’s ages, etc.), if you need to correct or update any other profile information, you can do so automatically by navigating to the “Profile” section. Follow the relevant instructions, and your information will be automatically updated in our database.

Deletion/Deactivation Policy

If you wish to terminate your Adgager membership or request that we no longer use your personal information, you can do so by navigating to the “Profile” section, clicking on “Membership Termination Options” on the left side, and selecting “Cancel your account.” Follow the relevant instructions, and your record will be marked as “do not contact,” and you will no longer receive emails or SMS from Adgager. Additionally, you will forfeit any unclaimed GAG points up to the date you opt-out. In most cases, it takes two or three days to process this change, but please allow two weeks. You may still receive emails from us within this period. Alternatively, you can email hello@adgager.com directly to request the deletion of your account. Our site provides email links for you to contact us with any questions and complaints. All emails we receive are read and responded to individually; please allow two or three business days for us to get back to you.

We will retain your information as long as your account is active or as needed to provide you with services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Earning Policy and Privacy Guarantee

Gagers and other participants in our research earn GAGs for participating in surveys, polls, and other promotions, as specified in the research details. When the GAG points earned exceed the specified level, they can be requested for withdrawal to a bank account or used for participation in system lotteries. Winners of the lotteries will be notified of their winnings via email or SMS. For more information, please visit the Terms and Conditions page. Adgager may publish the names and surnames of lottery winners in the following locations: Adgager.com sites, Adgager-owned blogs, and Adgager newsletters.Notifications About Changes

If we decide to change our privacy policy, we will post those changes on the privacy notice on our homepage or other places we deem appropriate to inform you about what information we collect, how we use it, and under what circumstances we may disclose it. We reserve the right to modify this privacy notice at any time, so please review it frequently. If we make significant changes to this policy, we will notify you here, by email, or by means of a notice on our homepage before the change takes effect.

Security

Adgager takes strict measures to ensure that your information is kept secure. Only a limited number of personnel can access personal information. Our website security is regularly checked, and we follow a strict password policy. Adgager will never ask for your credit card information as part of our surveys. For GAG withdrawals to bank accounts or winning a lottery, we must request your social security number or a similar government ID due to legal regulations and our unique user policy. We use SSL encryption while receiving or transmitting sensitive information. Your profile information is confidential and will only be used by Adgager for sending emails or SMS regarding our activities, newsletters, notifications about winners, and incentive points, unless stated otherwise in this privacy policy.

Business Transfers

As our company continues to grow, we might sell or buy different assets. During such transactions, the right to contact Adgager users and the information you voluntarily provide in your user profile may be considered transferable business assets. The sale and transfer of Adgager or its business assets will be to an entity that has agreed to comply with the structural elements of our privacy policy. If such a change occurs, we will notify you via an email or a notice easily visible on our website.

Links

From time to time, we may offer visitors the opportunity to voluntarily link to other sites. Adgager does not review or take responsibility for the content and validity of the privacy policies of these sites.

Social Media Features

Our website includes Social Media Features such as the Facebook Like button and Widgets such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function correctly. Social Media Features and Widgets are either hosted by a third party or directly on our site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Single Sign-On

You can log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personal information with us to pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities on this website to your profile page to share with others in your network.

Invitations

If you choose to use our referral service to invite a friend to our site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting them to visit the site. Adgager stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Your friend may contact us at hello@adgager.com to request that we remove this information from our database.

Importing/Uploading Contacts

You can import contacts from your email account address books, such as Outlook, to invite them to become members of our site. We will collect the username and password for the email account you wish to import your contacts from and will use it only for that purpose.

Mobile Applications

When you download and use our mobile applications, we automatically collect system and performance information about the type of device you use, operating system version, CPU, RAM, storage, and application version.

Mobile Analytics

We use mobile analytics software to better understand the functionality of our mobile applications on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

Location Information

We collect location-based information to determine the country you are accessing the site from and direct you to the appropriate country’s site. We share this information with our mapping provider solely to provide you with the correct service. You can opt-out of location-based services at any time by emailing us at hello@adgager.com or adjusting the settings on your device.

SMS

We provide this service either directly or through third parties to receive messages on your mobile device via short message service (‘SMS Service’). Standard data and messaging rates from your service provider apply to all SMS communications. All charges will be billed by and payable to your mobile service provider. You represent that you are the owner or authorized user of the wireless device you use to sign up for the SMS Service and that you are authorized to approve the applicable charges. We may collect data such as your name, address, cell phone number, service provider’s name, and the date, time, and content of your messages in connection with this SMS Service. We will use this information in accordance with these principles. If charges are billed to your mobile bill, we may provide your carrier with the applicable information. Your mobile carrier and other service providers may also collect data about your mobile device usage, and their practices are governed by their policies. You acknowledge and agree that the SMS Service is provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We do not guarantee that your use of the SMS Service will be private or secure and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the SMS Service. You can opt-out of the SMS Service at any time by adjusting your preferences in your Profile settings. This process affects only the future delivery of SMS messages and does not affect messages already sent.

Legal Disclaimer

We may disclose your personal information as required by law or in the belief that such action is necessary to comply with legal obligations or to respond to legal claims.

Children’s Privacy

Adgager will not collect information from any child under the age of 13 without the consent of their parents or legal guardians.

Privacy Contact

Privacy Officer Adgager A.Ş