PanelConnect Privacy Policy Effective: April 8, 2019

This privacy policy ("Policy") describes the commitment that Kantar UK Limited (a/k/a "Kantar") ("Kantar", "Us" and "We") make to protect your privacy. Kantar works closely with our technology vendor, RealityMine, Ltd ("RealityMine") to collect information as described below to share with companies in the same corporate family as us (our "Affiliated Companies") for the purposes of consumer research and as set out in this Policy. This Policy applies to all panel members who agree to participate in this specific PanelConnect research programme ("Programme"). The Programme requires the panel member to download and install to their mobile device a software application for data collection called PanelConnect (the "Application", comprised of both the Meter and/or VPN, as described further below) made available by RealityMine on behalf of Kantar.

This Policy describes the data we collect from consumers who participate in the Programme and how we use that data. This Policy applies only to the operation of the Programme and not to any other application, website or service. While we encourage our partners to comply with best practices regarding consumer privacy, we are not responsible for the privacy practices of any third party product with which the Application may be bundled. By accepting this Policy and continuing to set-up the Application on your device you are consenting to us collecting and processing your personal data and sensitive personal data as set out in this Policy.

This Policy is divided into the following sub-topics:

• Information Collection
• Protecting Your Personal Data and Sensitive Personal Data
• Cookies
• Information Use and Sharing
• Additional Disclosures of your Information
• Application Removal & Opt-out
• Data Security
• Data Access Rights
• Data Retention
• Children's Privacy
• Privacy Policy Changes
• Data Stored in the United States
• Contact Us

Our Policy may change from time to time and you should review it regularly.

INFORMATION COLLECTION

Once you have installed the Application, we will collect both personal data and non-personal data from you as described below, including Clickstream data which is information generated by you and your device while surfing the Internet and interacting with various sites, services, apps and mobile device functions.

The Application will either install the "Meter" (a piece of software on your mobile device to collect the data described in this Policy) and/or will establish the "VPN" (a profile on your mobile device to direct all internet data generated by and for your mobile device through RealityMine to enable Us to collect the data), which individually and collectively are components of the Application. Regardless of whether data is collected via the Meter or the VPN, we will only use the data as described in this Policy.

The Application collects the following types of information:

1. Online Browsing: This includes the sites you visit and apps you use, including news sites/apps or social networks, and your interactions with them.
2. Online Activities: This includes the search terms you enter and the results of such searches, the videos you view, the products you shop for online, information you enter into forms, the materials you download or upload, the advertisements you see, information and content on sites or apps that you visit or use and with which you interact and may include personal, financial and health information (subject to the process described below in the section entitled "Protecting Personal Data & Sensitive Personal Data").
3. Information On Secure Pages/Apps: This includes information and content from protected, encrypted or secure pages or apps that you access, such as online accounts or the content of complete and incomplete consumer transactions when you are checking out through a service's shopping cart, even if the service makes this information unreadable to others.
4. System Information: This includes information about the device and system you are running on, including unique identifiers that may be stored in your mobile device's operating systems such as your device's unique identifier, IP address and phone number of the device, how the Application is operating, information about your accessing of mobile and wifi networks and which applications are installed or running
5. Mobile Usage Information: This includes information about your use of your mobile device. Please note this information is collected and transmitted to us 'in the background', and does not require any further activation on your part. We call this 'passive tracking'. This can include the following types of information:
   
   
   • Information about your internet browsing habits - how much time you spend browsing the internet on your mobile device, the sites you visit or apps you use, and the terms of any search you carry out.
   • Information about your usage of other apps and features on your mobile device, including the identity of the apps and features, when you downloaded them, how often you use them and for how long. This includes things like your use of the camera(s) (although we do not collect your photos) and the media player(s) (including the titles of the songs/tracks and videos)
   • Information about the type of mobile device you own, when and for how long you charge it, its battery status, whether it is switched on, off or in a stand-by or 'Airplane' mode.
   • Information about which mobile network you use, which wifi networks you connect to, and at what times.
   • Information about the volume of data downloaded to your mobile device, the times that you download that data and the method of connection you use (wifi or mobile network).
   • Information we can deduce from combining the above information - e.g., what apps you were using just before you searched for particular information using your mobile device's internet browser.

The above list sets out the categories of personal data, sensitive personal data and non-personal data that we will collect from you while you are participating in the Programme. As technology develops, we will still collect data from you that falls within these categories but the exact data elements collected may change.

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PROTECTING YOUR PERSONAL DATA AND SENSITIVE PERSONAL DATA

We take the security of your personal data and sensitive personal data seriously and take steps to ensure your personal data and sensitive personal data is treated securely and in accordance with this Policy. As part of this commitment we have established procedural and technical privacy rules designed to try to avoid the use of certain types of personally identifiable information that could be identified in the 'clickstream data' categories of information collection described above, such as credit card numbers, government identification numbers, email addresses and email content from most web-based email accounts. Procedures executed by our personnel and RealityMine are designed to prevent certain types of personally identifiable information being collected or used in the 'clickstream data' collection described above except as allowed by this Policy.

As part of our security program, we conduct regular checks to update and refresh these procedures and technical rules.

Despite our efforts, certain personally identifiable or sensitive information might get through the privacy rules and procedures, such as health and financial details. However, we do not knowingly use any inadvertently retained personally identifiable or sensitive information in our 'clickstream data' analysis services, and we make reasonable efforts to review and update our rules to keep up with any changes.

When your information is sent over the public Internet by the Application, it is transmitted through either a secure means of encryption, or the same means of transmission used by your device in the absence of the Application. For example, information normally sent by your device in an encrypted fashion is sent by the Application to Us and Our vendor in an encrypted fashion. Similarly, information normally sent by your device in an unencrypted fashion may be sent by the Application unencrypted, or we may choose to send it in an encrypted fashion. In other words, the Application does not reduce the security procedures that your device uses to transmit information.

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COOKIES

We may collect certain information in part through the use of a technology called a "cookie." A cookie is a small text file that is saved to your device using your browser, which allows sites to recognise you and store preferences and other information if you return to the site using the same device and browser.

We use temporary session cookies during the download and registration process to correctly identify the research panel that you have joined, enable the creation of a unique, anonymous identifier and to trigger the download process.

We may use cookies apart from the Application and link that data to other data in your profile, including data that is collected through your use of the Application.

You may remove cookies and/or control their operation by adjusting your browser settings. Please visit the 'help' section of your browser for more information.

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INFORMATION USE AND SHARING

We combine all the personal data, sensitive personal data and non-personal data we collect about you, whether as part of the Programme or through other collection points, such as if you take part in a survey and information provided by third parties. This combined information is then shared with our Affiliate Companies to allow them to provide services to their clients. Our Affiliated Companies only use your information as set forth in this Policy and we will remain responsible for their use of your information.

Typically, we and our Affiliate Companies combine panel members' data into consumer segments and report on the aggregated (or grouped) results. Consumer segments are pools of users who have common interests or characteristics, for example, "women between the ages of 28-34 interested in travel websites". Once aggregated, the results and consumer segments are shared with our clients and other parties as described in this Policy. In some circumstances, we or our Affiliate Companies may disclose your uniquely identifiable data, personal data and sensitive personal data to our clients. This will always be done in compliance with the relevant data protection laws and the clients shall be required to only use your information as set forth in this Policy. The following are examples of the kinds of services we provide, and how your data is used in these services:

• Advertising Research:
  
  Your data is combined with data from other users into a pool that is then analysed for exposure to certain advertising. Information about the combined pool, which does not identify any particular user, is shared with clients so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions. For example, by comparing the behaviors of a group of users who saw a particular online advertisement with another group of users who did not see that advertisement, we can help advertisers understand the effectiveness of their ads.
  
  
• Media Use Analysis:
  
  Your data is combined with data from other users to form consumer segments that are shared with clients without identifying any particular user. These segments are typically analysed on behalf of clients to understand where consumers go online and how consumers interact with digital media, which includes website content, apps and advertising that they see. For example, we help companies understand the effectiveness of their websites or apps by comparing how users are interacting with their websites or apps versus how users are interacting with their competitors' websites or apps.
  
  
• Profile Building:
  
  We may use the personal data you have provided to us in addition to the information collected by the Application, or an identifier associated with you that by itself is anonymous (such as an IP address or similar identifier) to get additional information about you from other public and private data sources. These third party data sources may provide us information on your purchases (both online and off-line), your household and lifestyle information, and broader demographic and personal history details. We may combine this information with other information to create and enhance profiles that are shared as described in this Policy. For example, by looking at both web browsing activity and in-store purchases, our research may identify a consumer segment whose members visit certain websites when they are in the process of researching a product (like a television, computer, or automobile) but are likely to make the actual purchase in a physical store. This data can help the manufacturer or seller of that product better understand where to find customers who may be interested in their products.
  
  
• Multi-program Data:
  
  If you participate in any other research panels or programmes run by us (whether directly or indirectly, and regardless of device and applicable policy for each such other program), by joining this Programme you agree that we may use any information we have about you to match the data collected through this Programme with the data collected through such other panels and programs (including data collected in the past), and use the combined "multi-device" data pursuant to the most restrictive applicable privacy policy.
  
  
• Consumer Analysis:
  
  We may use your data, including personal data we have obtained directly or through a trusted third party vendor, to enhance our or our customer's consumer segments explained above. We use personal data in this way when our customer already has this information because it is usually the only way to match our profiles with those of our customers. Sometimes we may gather information from your clickstream data, such as a session ID or site user ID, and share it with a third party in order to match your information with the information possessed by that third party as part of our services. Although in each of these cases we permit these other parties and our customers to use your information to enhance their broader consumer segments, to which they then may target advertising, we prohibit these parties from using your information to target advertising to you individually. So in the normal course of your online activities, you may be a member of a broader consumer segment that sees particular advertising that your data helped create.
  
  
• User-Level Data:
  
  On occasion, we may share user-level data we collected from you with third parties for purposes beyond the specific examples noted in this Policy. User-level data is information that is associated with your specific device and is not aggregated with other data. For example, we may share data with a third party that reveals that you have viewed certain sites or used certain apps or features, but you will not be personally identified with such information. Rather, the user-level data will be associated with an anonymous identifier (such as user 'X'). We prohibit the third parties with whom we share such user-level data from trying to uncover the actual identity of 'X', except as may be otherwise allowed under this Policy, such as in the "Profile Building" section above.
  
  
• Targeted Surveys:
  
  We may send you invitations to participate in surveys on the basis of your online behaviors collected by the Application, or merely based upon your participation in the Programme. For example, if you visit sites that suggest you enjoy travel, we may send you a survey regarding travel services. We may provide our clients with some or all of the responses to these surveys without directly identifying any particular user, including specific answers and quotes from individual respondents.
  
  

We may provide RealityMine with data collected through the Application for RealityMine's own internal use only to develop and enhance its general offerings, however, RealityMine is not authorised to provide any third party with access to or use of such data in any manner that identifies you.

As part of the registration process prior to installation of the Application or in connection with your participation in a survey or other service, we may directly collect information such as your name, telephone number, email address, birth year, household information, income, gender, and ethnicity. This information is part of your consumer profile and used as described above. Of course, the contact information you give also helps us reach you with information related to Application maintenance and upgrades and other service related communications.

When working with a third party (such as another data provider) to supplement your profile, we protect your privacy by having our partner sign a confidentiality agreement stating that they will not share personal data with unauthorised parties. We instruct them, and they are obligated, to maintain the confidentiality, security and integrity of the information we provide and not to use the information for any purpose other than those we explicitly authorise.

We may share information about you with authorised vendors and service providers, such as RealityMine Ltd., in connection with the services that they perform for us. These third parties are prohibited from using your information for other purposes.

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ADDITIONAL DISCLOSURES OF YOUR INFORMATION

In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information may be among the assets transferred.

We also reserve the right to disclose your information as required by law, court order, or legal process served on us, when we believe that disclosure is necessary to protect our rights, or to combat suspected fraudulent activities.

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APPLICATION REMOVAL & OPT-OUT

You can opt-out of this Programme at any time by removing the Application (which requires that you uninstall both the Meter and VPN) from your mobile device. You may uninstall the Application, by following all of the defined steps from the instructions set out here: https://www.shopandscan.com/panelconnect/index.html. Note that the two components of the Application (Meter and/or VPN) can exist separately on certain mobile devices and must be removed separately by following all defined steps of the Application Removal Instructions.

Our Application will continue to collect information about you as outlined in this Policy even when your web browser has a 'do not track' facility activated. If you want to opt-out of the Application collecting your information please follow the process set out above.

If you have set your browser to "private browsing" or a similar setting, the Application may still continue to operate and collect data to be sent to us. To completely stop the operation of the Application and the collection of data from your mobile device, you must follow the instructions above to remove the Application (which requires that you uninstall both the meter and VPN).

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DATA SECURITY

We have put in place reasonable administrative, technical, and physical safeguards to protect against unauthorised access to the information we collect. However, no security measures are 100% impenetrable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, and we are not responsible for the transmission of information over networks that we do not control. Your use of our Application demonstrates your assumption of these risks.

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DATA ACCESS RIGHTS

If you have any queries about how we use your information, or if you would like to modify or remove personal data about you that is being held by Us, then you should contact us with your specific requests using the information in the Contact Us section below. We will respond to your access request within 30 days. Such access rights do not include the ability to modify or remove clickstream data, information that has been inadvertently collected as described above in the Protecting Personal & Sensitive Information section or information that has already been shared with a third party as permitted by this Policy.

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DATA RETENTION

We will retain the information described above for as long as the information has value as part of the services we offer to our clients, or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. If you opt out of the Programme by following the directions to remove the Application as described above in the Application Removal & Opt-Out section, we will no longer collect data from you but we will retain and continue to use your data collected prior to your removal of the Application unless you contact us pursuant to the Data Access Rights section above.

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CHILDREN'S PRIVACY

We do not seek to collect personal information from users under the age of 16 for use in connection with our online research panels. If we do seek to collect personal information from users under 16 in the future, we will, when applicable, obtain verifiable parental consent and adhere to all appropriate data laws and regulations.

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PRIVACY POLICY CHANGES

If we are going to use your information in a manner materially different from that stated in our Policy at the time of collection, you will be notified via email or via the Application by Us or by our data partner directly. You will have a choice as to whether or not we use your information in this different manner and instructions for how to make that choice will be included in the notification.

If we make any changes to our privacy practices that do not materially affect information already stored in our database or for future collection, we will post a prominent notice on our website notifying our members that there is a change and pointing them to the revised privacy policy.

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DATA STORED IN THE UNITED STATES

Data is collected and transmitted by the Application from your mobile device to RealityMine, whose servers are located in the United Kingdom. Data is then transferred to Us. Our servers are maintained in the United States of America. By using the Application, you freely and specifically give us your consent to export your personally identifiable information and sensitive information to the USA and to store and use it in the USA as specified in this Policy. You understand that our data is subject to lawful requests by the courts or law enforcement authorities in the United States.

You consent to us transferring your information to other companies as described in the section "Information Use and Sharing", which may be in countries within the European Economic Area (EEA) or outside the EEA, only for the purposes mentioned above in the "Information Use and Sharing" section. We will take reasonable steps to keep your information confidential and secure and to treat it in accordance with this Privacy Policy.

Where information is transferred to a country outside the EEA, the laws of that country may not provide the same level of protection for information. In these cases, we will put in place measures to provide adequate protection for your information when transferred outside the EEA.

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CONTACT US

If you have any questions regarding our management of your personal data if you want to request information about our privacy policy you can email us or write to:

• Gillie Abbotts-Jones
  
• Data Protection Officer
  
• Panel Communications
  
• Kantar,
  
• Westgate,
  
• London,
  
• W5 1UA
  

ADDITIONAL TERMS FOR USERS OF ANDROID DEVICES

If you have downloaded the PanelConnect App via the Google Play, the following shall apply:

The Application uses Accessibility services and is using the respective permissions with active consent by the end-user. The Accessibility permissions are used for analysing the application and web usage on this device as part of an opt-in market research panel.

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