Effective Date August 15, 2016
Before getting into the details, know that all data captured through and stored in the Lumière application are protected in ways specified in our Security Policy.
Privacy Shield Certification
Latitude Labs, LLC has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles through BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
Latitude Labs, LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Disclosure of Personal Information to Third Parties
Latitude Labs, LLC does not sell or otherwise transfer collected data to third parties. The only entities that are able to access your data through the Lumière software (the sole means of access) are Latitude Labs, LLC and Lumière subscribers, who engage with you on a purely opt-in basis for the purposes of collecting feedback on their video content. (For rights and responsibilities related to our customers and to you as a participant in their research activities, see more below).
In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Latitude Labs, LLC is potentially liable.
Data Collection, Access, and Choice
We aim to be completely transparent about the types of data collected (or potentially collected) in Lumière, your rights to access those data, and your choice to contribute data through the software. Specific guidelines for Account Holders and Participants follow below, but for all parties:
- You have the choice to opt out of contributing data through Lumière. As an account holder, this means you have the option to not divulge your personal contact details, though given that accounts are linked to email addresses, this means you effectively opt out of using the software. As a participant, you may choose not to participate in a Lumière video feedback activity, including activities that you’re invited to through a shared link and activities that are embedded on websites. Since Lumière only collects and stores data that you have willingly provided, you always have the choice to not participate. Know that, in the event that you’re incentivized to participate (for instance, panel rewards or some other form of monetary or non-monetary compensation) opting out of participation could mean that you forfeit your right to any participation incentives. These economic arrangements are a matter between you and the company inviting your participation, and Latitude Labs, LLC has no involvement.
- All participants and account holders from the European Union have a right, through the EU-US Privacy Shield Framework, to access all personal data that Latitude Labs, LLC holds about them through their usage of the Lumière software. All inquiries related to data access may be directed to email@example.com, and if for any reason you are not satisfied with our response to your request – either in timeliness or in substance – you may elect to raise your issue through the BBB EU PRIVACY SHIELD dispute resolution program, as described earlier in this policy.
Policy for Lumière Account Holders
What data we collect directly from you, and why:
- Billing contact information, including the name, phone number, email address, and physical address for the billing contact on your account. We never share or sell this information with third parties, and it may be used solely for billing and administrative purposes (such as account modifications and change of billing contact). At this time, we do not store or process any payment information within the Lumière application.
- Names and email addresses for account holders, which are used solely to support logins and assign authorship to Lumière activities.
- Video media and related metadata, including descriptions and tags. We serve as custodians of these media only and claim no rights to them.
- Activity setup information and related metadata, including associated videos; data collection features enabled; scheduling information; activity titles, tags, categorization, and descriptions; and activity authors; as needed to define and distribute viewing activities.
- Externally uploaded data, potentially including personally identifiable information such as names and email addresses. Account holders may upload such information for the purpose of generating unique activity links for email distribution to specific, pre-identified participants, and for use in analyzing externally generated data alongside data generated through Lumière viewing activities. We use these data only to the extent necessary to support the functions mentioned above, and never distribute this information to third parties.
- Data generated through Lumière activities, which we securely store and deliver to client-side browsers for the purposes of data visualization and analysis. We use these data to the extent needed to provide core services to our users.
- Passively collected usage data, including logs of account access, activity creation and distribution, browsers used to access the Lumière software, and other information. These data are used solely for diagnostic and security purposes.
- Cookies are issued to registered users when logging into Lumière. The session cookie holds encrypted authentication information for the duration of a logged in session and does not include sensitive data.
Your Rights and Responsibilities (and ours, too)
- You have the right to modify contact information on your account at any time, subject to the terms and conditions of the Lumière licensing agreement.
- To the extent that you feel your personal data (for instance, any of the name and contact information referenced in the section above) are errant or misrepresented, and you do not have the means to directly modify it within the Lumière application, you may send a request to firstname.lastname@example.org for changes to your data.
- You own your data and may export it whenever you want, however many times you want, using our data export feature. If you choose to close your Lumière account, you may request a full export of all activity data generated through your subscription term, which we will provide in a format that can interoperate with numerous applications.
- We will not sell, or otherwise provide access to, your data without being legally compelled, such as through subpoena.
- Per the terms of our licensing agreement, we reserve the right to explore Lumière data at a high level (anonymized, and not specific to individual participants, activities, or customers) for the purposes of aggregate data analysis -- such as for the creation of normative data and macro-level media trends reports. We also reserve the right to access customer and participant data for diagnostic and quality assurance purposes.
- Lumière is, primarily, an enabler of video-based research and a custodian of data generated through that research. As such, our system has been designed to be agnostic with regard to the types of data collected and the types of video content used in viewing activities. It is your responsibility to:
- Secure, in accordance with any privacy and data collection regulations that pertain to you, the necessary consents/opt-ins from participants and/or their parents (in the event of youth research governed by regulations such as COPPA)
Policy for Lumière Participants
What data we collect directly from you, and why:
- The Lumière application is designed to flexibly collect a variety of information about participants and their responses to video content they view. While the specifics of this information is up to the activity creator, information captured might include:
- Information about you, including demographic data and, in certain cases, other personal information such as your name or email address.
- Ratings, comments, and question responses related to the video you’ve been invited to watch
- Information about your viewing behaviors (play, pause, re-watch, video switching)
- These data are collected solely for the purpose of gathering and displaying your data to activity creators in order to analyze your responses. We never share or sell this information to third parties.
- In addition, the Lumière application logs usage information in the background whenever you participate in a viewing activity. This information can include device type, operating system, and browser used, which we use solely for diagnostic purposes. None of this information is ever shared with, or sold to, third parties.
Your Rights and Responsibilities (and ours, too)
- You have the right to opt out of participating in a Lumière viewing activity, and you may leave an activity at any time and refrain from providing any information that you do not feel comfortable sharing. Your participation is voluntary. If you choose to participate in, and complete, a viewing activity, we consider that a de facto opt-in, though we strongly encourage activity creators to collect formal participant opt-ins prior to beginning their activities. In the event of your participation, the activity creator may use any of your submitted data for analytical purposes.
- If you are 13 years old or younger, parental consent may be required for you to participate in an activity, depending on where you live. Activity creators are responsible for ensuring that parental consent is provided, but if you are a young respondent, and parental consent has not been explicitly asked for or given, we ask that you not participate and contact us at email@example.com.
- If you feel like you have misrepresented yourself, would like to request that the activity creator not use your data, or would like to modify your responses, or otherwise make changes to your submitted data, you may contact the activity creator (i.e., the company that has invited you to participate in a Lumière activity). If no contact information is provided, you may send a request to firstname.lastname@example.org, and we may attempt to contact the activity creator on your behalf or process your request ourselves, in the event that a) the activity creator does not respond, or b) the activity creator is not sufficiently timely in responding.
- Some of the video that you watch and react to within Lumière might be sensitive to the activity creator. For instance, you might be asked to watch an episode of a television program, film trailer, or advertisement that has not yet aired. By participating in Lumière activities, you are agreeing to hold what you’ve watched in confidence, unless otherwise directed.