Last Updated: April 10, 2023

 

VG Voice is provided to you by Circana, Inc. and Circana Group, LLC (“Circana,” the “Company,” “we,” or “us”). Circana has been conducting market research for over 50 years. Circana’s clients encompass over 2,000 businesses, including many Fortune 500 companies. In addition to being a committed leader in market research, we are committed to protecting the privacy and security of your information. This Privacy Policy (“Policy”) describes how the Company collects, uses, discloses and otherwise processes the personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information.

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For information about the privacy choices you have regarding your personal information, review Section 7. Your Privacy Choices below, as well as Section 12. Additional Privacy Information for Certain Jurisdictions, which includes additional information about privacy rights for residents of certain states. If you are a resident of California, please also refer to Section 12.B Additional Privacy Information for California Residents below for information about the categories of personal information we collect and your rights under California privacy laws.

Your use of the Services (defined below), and any dispute over privacy, is subject to this Policy and the Terms of Service, available at https://www.vgvoice.com/terms-of-use.

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1.Scope

Except as otherwise noted below, this Policy applies to the personal information that VG Voice processes related to:  

• users of this website where this Policy is posted, including https://www.vgvoice.com/privacy and the services we provide through the website (collectively, the “Services”). Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites;

• individuals who are subscribed to receive news, information and marketing communications from us related to the Services;

• individuals who participate in contests, sweepstakes, surveys and research conducted by us related to the Services; and

• individuals that communicate with us or otherwise engage with us related to the Services.

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2.Personal Information Collected

Information That You Submit To Circana

1.  Personal Information

In order to register to become a member of VG Voice, you must first complete the registration form.  This requires you to provide certain information including your name, e-mail address, date of birth, gender, zip code, type of internet connected XBox Live® and/or PlayStation Network gaming system (“Gaming System”) and the Gaming System username (“Gaming Account”). 

2.  Demographic Information

We may also ask you to provide certain demographic information (e.g., race and ethnic origin; household income; household size, number of children in the household and education). 

3.  Survey Responses

We may send you e-mails containing links to surveys in which we would like you to participate. Survey questions may ask you about things such as purchases you have made and your opinions about products or services. If you participate in these surveys, we will collect your answers to the surveys.

Information Collected From Third Parties

We may receive additional information about you, such as demographic data or fraud detection information from third-party service providers and/or partners and combine it with information we have about you. We also may receive information about you and your activities through Circana’s partnerships.

Automatically Tracked Data

When you accept Circana’s “friend” request and play games on your Gaming Account, Circana’s authorized data management platform provider, currently Vearsa Limited (including any successor provider(s), the “Authorized Platform Provider”) will automatically collect certain information about you on our behalf, in order to determine the titles of games played, amount of time spent playing each game title, cumulative amount of time spent gaming, media content viewed and amount of time spent viewing media content (“Game Play Information”).

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3.Purposes of Use and Processing

Generally, we collect, use, disclose and otherwise process the personal information we collect for the following purposes:

• Generally, in our market research business to help clients and commercial partners better understand consumer behavior.

• To communicate with you about your use of the Services, to respond to your inquiries, and for other customer service purposes.

• For notifications and reminders.  For example, we may use your information, such as your e-mail address, for special offers, and promotions, or to otherwise contact you about information we think may interest you.

• To fulfill and administer sweepstakes.

• To better understand how users access and use the Services, both on an aggregated and individualized basis, in order to improve the Services and respond to user desires and preferences, and for other Circana research and analytical purposes, such as in Circana’s market research business to help clients and commercial partners better understand consumer behavior (see Section 4 below for more detail).

• To comply with federal, state or other applicable laws and regulations.

• To manage, protect against and investigate fraud, risk exposure, claims and other liabilities.

• To the extent we deem it necessary or appropriate, to enforce or apply rights under our agreement with our users, and/or protect the property, rights or safety of our users, Circana, or others.

 

4.Disclosures of Personal Information

We may disclose the personal information in aggregate form that we collect for the purposes described above, in order to provide the Services to you, to respond to and fulfil your orders and requests, as otherwise directed or consented to by you, and as follows: 

 

• Service Providers. We may disclose the information we collect from you to third-party vendors, technology and other service providers, contractors or agents, including the Authorized Platform Provider, who perform functions on our behalf, or are engaged with us.  For example, we use service providers to provide data append services, data validation services, data classification services, fraud prevention, data integrity, incentive fulfillment and sweepstakes related services.    These service providers are allowed to access and use the information we make available to them only as needed to perform their functions and for no other purposes.

• Commercial Partners. (a) In connection with our business, we may disclose demographic information (e.g., gender) to commercial partners and other third parties in aggregate summary form and may also provide other aggregate or de-identified information to such third parties.  Singular summary includes demographic information about a person without specifically identifying the person. For example, this summary does not contain directly identifiable information such as an e-mail address, nor does the combination of demographic information make it readily possible to identify the person.  Aggregate summary information is anonymous and includes demographic information about a group of persons without specifically or indirectly identifying any person within the group; or (b) We may also provide your information, including your Game Play Information and your Personal Information, to commercial partners and other third parties, such as retailers or brands, for marketing research and analytics purposes.  In such cases set forth in the above clauses (a) and (b), we will take steps designed to ensure that your Personal Information is handled securely and is treated at least as protectively as under this Policy.  We will not, however, allow such commercial properties or other third parties to use this information for the purposes of individually marketing to you or to contact you.

• Affiliates. We may disclose the information we collect from you to Circana’s corporate affiliates or subsidiaries; however, if we do so, their use and disclosure of your Personal Information will be subject to this Policy.

• Business Transfers. If we are acquired by or merged with another company, if substantially all of Circana’s assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.

• In Response to Legal Process. We also may provide the information we collect from you in order to comply with the law, a legal proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

• To Protect Us and Others. We also may provide the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of the Terms, the Sweepstakes Rules or this Policy, or as evidence in litigation in which Circana is involved.

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5.Aggregate Data and Non-identifiable Data

We may also receive, use, and disclose aggregate and other non-identifiable data related to our business and the Services for quality control, analytics, research, development, and other purposes. Some of this information may be considered “de-identified” under U.S. privacy laws (i.e., data that is no longer linked or reasonably linkable to an identified or identifiable consumer). Where we rely on data that has been “de-identified” as defined by U.S. privacy laws, we will maintain and use such information in de-identified form and will not attempt to reidentify such information, except in order to determine whether Circana’s de-identification processes are reasonable and adequate or as otherwise set forth by applicable law.

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6.Cookies and Analytics

We and our third-party service providers may use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect information browsing, activity, device and similar information within the Services. We use this information to, for example, analyze and understand how users access, use the Services, as well to identify and resolve bugs and errors in the Services and to assess secure, protect, optimize and improve the performance of the Services. For more information on the types of personal information we collect via cookies and similar mechanisms, please see Section 2. Personal Information Collected.

Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate the Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service. 

Pixel tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with the Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Local storage objects. Local storage is a web storage mechanism that allows us to store data on a browser that persists even after the browser window is closed. Local storage may be used by our web servers to cache certain information in order enable faster loading of pages and content when you return to our websites. You can clear data stored in local storage through your browser. Please consult your browser help menu for more information.

Third-Party Analytics and Tools. We may use third-party tools, such as Firebase, which are operated by third-party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about the Services in order to provide us with reports and metrics that help us to evaluate usage of the Services and improve performance and user experiences. You can also download the Google Analytics Opt out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Custom Lists and Matching. We may share or make available certain participant list information (such as your name, e-mail address and other contact information) with third parties for analytical and research purposes.

 

Managing Your Preferences. We make available ways for you to manage your preferences regarding cookies within the Services. These are browser and device specific, which means that you need to set the preference for each browser and device you use to access the Services; in addition, if you delete or block cookies, you may need to reapply these preferences.

 

• Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to the Services who disable cookies will be able to browse the Site, but some features may not function.

 

7.Your Privacy Choices

We make available a number of ways that you can manage your privacy choices and submit privacy requests related to your personal information. These include:

• To opt out of e-mails, please follow the opt out instructions contained in the e-mail or send an e-mail to vgvoice.support@circana.com.  If you opt out of receiving e-mails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any requests you have made to us.  Please note that it may take up to 10 business days for us to process opt out requests.

• To opt out of being a member of VG Voice, please go to the Services, click on "Opt Out" in the footer of the Services and follow the instructions; or send an e-mail to vgvoice.support@circana.com and request to be deactivated.  Please note that it may take up to 10 business days for us to process opt out requests.

Residents of certain jurisdictions have additional rights, as set forth below, in Section 12. Additional Privacy Information for Certain Jurisdictions. Further, if you are a California resident, please review Section 12.B Additional Privacy Information for California Residents below, for specific information about your California Privacy Rights and how to exercise them.

 

For more information about Circana’s privacy practices and your privacy choices, you may contact us as set forth in the ‘Contact Us’ section below.

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8.Children/Minors

We comply with all applicable laws and codes pertaining to the protection of children’s privacy, including, without limitation, the Children's Online Privacy Protection Act of 1998 (as amended). We do not knowingly collect Personal Information from participants who are under the age of 13.  If you are under 13 years old, you may not participate in VG Voice.  If we become aware that we inadvertently collected Personal Information from anyone under the age of 13 or if you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us and we will promptly delete such Personal Information and will terminate the account from Circana’s databases.

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9.Security

 

We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite Circana’s efforts, no data security measures can guarantee security.

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10.Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy on the Site as well as make it available through the Services. If we make material changes to how we collect, use and disclose the personal information we have previously collected about you, we will endeavor to provide you prior notice, such as by e-mailing you or posting prominent notice through on our website or within the Services.

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11.Contact Us

If you wish to exercise any of the options described above, or if you have any questions about Circana’s privacy practices, or the Site, please contact:

VG Voice – Member Services                          Circana - Privacy Office

900 West Shore Road                                      203 N LaSalle St. Suite 1500

Port Washington, NY 11050                             Chicago, IL 60601

vgvoice.support@circana.com; or                   privacy@circana.com

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12.Additional Privacy Information for Certain Jurisdictions

Residents of certain states have additional rights under applicable privacy laws, as described in this section. 

Please review Subsection A. below for additional information about rights residents of certain U.S. states, including Colorado, Connecticut, Utah and Virginia, may have under applicable state privacy laws.

If you are a resident of California, please review Subsection B. below for additional information about the categories of personal information we collect about you and your privacy rights under applicable California privacy laws.

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12.A  State Privacy Rights

Residents of certain states, including Colorado, Connecticut, Utah, and Virginia, have additional rights under applicable privacy laws, subject to certain limitations, which may include:

 

• Correction. The right to correct inaccuracies in their personal information, taking into account the nature and purposes of the processing of the personal information.

• Deletion. To delete their personal information provided to or obtained by us.

• Access: To confirm whether we are processing their personal information and to obtain a copy of their personal information in a portable and, to the extent technically feasible, readily usable format.

• Opt Out: To opt out of certain types of processing, including:

• the “sale” of their personal information.

• targeted advertising by us.

• any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.

You can submit requests for access to and deletion of your information online by submitting a request via webform or by contacting us at vgvoice.support@circana.com. See Section 7. Your Privacy Choices for additional information about the privacy choices we provide and how to exercise them. We will respond to your request as required under the applicable privacy law(s). If we deny your request, you may appeal Circana’s decision by contacting us at vgvoice.support@circana.com or privacy@circana.com 

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12.B  Additional Privacy Information for California Residents

This subsection provides California residents with additional information regarding Circana’s collection, use and disclosure of their personal information, as well as their privacy rights, under California privacy laws. 

In this subsection, we provide additional information to California residents about how we handle their personal information, as required by the California Consumer Privacy Act (“CCPA”). This section does not address or apply to Circana’s handling of publicly available information or other personal information that is exempt under the CCPA. 

 

Categories of Personal Information Collected and Disclosed. While Circana’s processing of personal information varies based upon Circana’s relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we have collected about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose.

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