Privacy Statement for Customers: Customer Satisfaction Survey

Transparency is a strong principle for a trusting cooperation with our customers. We therefore inform you about how we process survey response data and how you can exercise your rights under the applicable legislation relating to privacy and data protection, including without limitation (i) the EU General Data Protection Regulation (EU GDPR), (ii) the California Consumer Privacy Act (CCPA) (iii) the UK General Data Protection Regulations (iv) any applicable laws and any binding guidance issued by a Supervisory Authority relating to the processing of personal data and/or the protection of an individual’s privacy, and (v) any other law in force from time to time with regards to the processing of personal data and privacy, which may apply to either legal entity in the Mood Media Group in respect of its processing activities under this Policy.

It is important that you read this notice together with any other privacy notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are processing personal data. This notice supplements the other privacy notices of Mood Media and is not intended to override them.

What this Privacy Statement covers
This Privacy Statement covers the customer data that we collect from clients in the context of our customer satisfaction surveys. Therefore, this Privacy Statement aims to give you information on how Mood Media collects and processes personal data during customer experience surveys and further analysis of it. The insights we get from the survey responses help us continuously improve and drive customer satisfaction to higher levels.

About Us
Mood Media means Mood Media Corporation/Mood Media Group, its subsidiaries and affiliates around the globe (hereinafter referred to as “Joint Controllers”, “we,” “us,” “our”) which jointly process your personal data according to the specific purposes mentioned below. Each member entity in the Mood Media network is a separate legal entity.

Data Controller and Data Protection Officer
Mood Media Corporation (hereinafter ‘Mood Media’)
2100 S IH 35 Frontage Rd, Suite 201
Austin, TX 78704
800 345.5000

As Mood Media operates globally, we have appointed a Data Protection Representative within the EEA. You can contact our EEA Data Protection Representative by sending an email to [email protected].

Information we collect
Personal data you provide to us through customer feedback surveys. We periodically seek customer satisfaction feedback to better understand if our customers are happy with the products and services we provide and how we might improve. Therefore, as part of customer experience processes, we gather, use, store and transfer personal data attributes as below:

Contact data: customer email address, first name, last name, company name, phone number;
IP addresses and other similar technical information typically received from a browser or device automatically when visiting or interacting with our website. For detailed information about the use of cookies on our website and how to manage your cookie settings, please read our Cookie Policy.

How we collect and receive information
We collect data directly from you. Participation in any customer satisfaction survey launched by Mood Media is voluntary. Mood Media’s clients are under no obligation to complete the surveys.

Purposes for which we will use your data. Legal grounds for processing your data.
We use the information you submit through our customer feedback surveys for the following purposes:

measuring customer satisfaction;
improving the services provided to our clients;
complaint monitoring;
customizing the products and services subject to clients’ requirements;
for statistical purposes, pursuant to Article 89 (1) of the EU GDPR, provided that the results of the processing for statistical purposes contains aggregate data. As such, we may anonymise customer data for statistical purposes. Responses will not be linked back to personal information unless a respondent specifically asks to be contacted about their account when choosing to add additional feedback as part of their submission. Data that has been included in an anonymised form at aggregate level falls outside the scope of the EU GDPR.

Article 6 (1) letter f. of the EU GDPR forms the legal basis for sending survey links to our customers via email. Mood Media has a legitimate interest in seeking your feedback to help us understand how well we are meeting the needs of our clients and to find ways to improve. As such, the purpose of the survey is to collect information to improve our products and services within the framework of a temporary digital customer satisfaction survey of existing customers.

The collection, processing or use of data is not carried out for market research or/and direct marketing purposes. Where consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given, informed and explicit. Information regarding such processing will be provided to you at the time that consent is requested, along with the impact of not providing any such consent, if any.

In the following cases we process your personal data on the basis of your consent, pursuant to Article 6 paragraph (1) letter (a) of the EU GDPR:

Sending our e-mail newsletter;
Sending you product information, special promotions or offers;
Market research.

Storage Periods
The personal data you provide through the customer satisfaction surveys will be stored for no longer than two years after the conclusion of the final contract or until you exercise your rights under the applicable legislation relating to privacy and data protection. You can object to the use of your personal data for sending you survey links via email at any time without incurring any costs. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Mood Media will, on a regular basis, review all data held electronically to decide whether to delete any personal data once the purpose for which it has been collected is no longer relevant. Overall responsibility falls to the Marketing department which will constantly review the contents of the databases of Mood Media website, in case you complete the customer satisfaction survey on our website.

Storage location
Mood Media international websites are hosted in Europe, Amsterdam.

Subscribe/Unsubscribe
You can object to the use of your personal data for sending you survey links via email at any time without incurring any costs. Pursuant to Art. 21 para. 1 of the EU GDPR, you have the right to object at any time to the processing of your personal data on the basis of Article 6 para.1 lit. f of the EU GDPR (data processing to protect a legitimate interest). In the event of your objection, we will no longer process your personal data unless we can prove compelling grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

However, if you have any account for our Services, we will still send you non-promotional communications, like service-related emails.

Where the collection, processing or use of your data is carried out for market research or/and direct marketing purposes based on your consent, we will provide you with details on how to opt-in to or opt-out of receiving messages from us. You can withdraw your consent at any time by following the instructions provided with each communication you receive, by unsubscribing or by notifying us.

Security
Mood Media takes reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in the processing and the nature of the personal data.

We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:

administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
technological security measures, including firewalls, encryption and antivirus software;
physical security measures, such as security passes to access our premises; and
data protection policies and procedures.

Access to your data is only possible for a few authorised persons. These are responsible for the commercial, editorial or technical support of the servers. Survey response data will only be used by in-house departments and exclusively for the purposes mentioned above; Survey results are evaluated and processed internally by the Marketing department.

Also, as part of such measures, your personal data submitted through the Site is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed for the purposes stated in this Privacy Statement.

If you complete the customer satisfaction survey on our website, please be aware that no method of transmission over the internet or method of storage is ever fully secure or error-free. So, while we strive to protect your data, we cannot guarantee absolute security.

Sharing of data/recipients of customer data
In accordance with applicable law, we may share your data with our parent companies, subsidiaries and/or affiliates. All data is collected for internal use only and exclusively for the intended purpose and based on our legitimate interest. Survey response data is made available to better understand if our customers are happy with the products and services we provide and how we might improve.

In limited circumstances, we may pass on your email address to email service providers to send out the emails with the survey link by entering into appropriate data processing agreements with such third-parties that comply with applicable legislation relating to privacy or data protection and that provide sufficient data protection guarantees.

Mood Media is not in the business of selling or renting your information to others and will not share customer data with third parties except as described in this Privacy Statement or as otherwise permitted by law.

Cross-border transfers
In order to comply with the EU GDPR restrictions in respect of the international transfers provided by art. 44 et seq. from the EU GDPR, Mood Media is continuously reviewing and strengthening the protection measures regarding the international transfers, while keeping in mind the guidelines and recommendations of the EU authorities.

Therefore, the transfer of survey response data to countries outside the EEA, where Mood Media, its affiliates, subsidiaries or third-party service providers maintain operations, is regulated by the Standard Contractual Clauses. The European Commission approved Standard Contractual Clauses are available here.

In addition to using the Standard Contractual Clauses above, Mood Media is continuously taking steps towards ensuring additional protection measures of the data subjects rights, guaranteed under the applicable privacy laws.

By providing information for any of the purposes stated herein, you acknowledge that your information will be transferred outside the EEA.

Your legal rights in connection with the processing of your data
The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. Therefore, under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data;
Request correction of your personal data;
Request erasure of your personal data;
Object to processing of your personal data;
Request restriction of processing your personal data;
Portability of your personal data, including transfer of your personal data;
The right to withdraw your consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent;
The right to be informed. This Privacy Policy informs you how we process your personal data, in accordance with the provisions of Art. 13 of the EU GDPR. If you want to find out information regarding the processing other than that specified herein, please send us a request in this regard.
The right not to be subject to a decision based solely on automated means, including on profiling. In this regard, we hereby inform you that Mood Media does not carry out automated decision-making based on the processing of your personal data, such as profiling. Your personal data are not subject to an automated individual decision-making process, including profiling, as mentioned under article 22 paragraphs (1) and (4), in Regulation (EU) no. 679 of 27 April 2016;
The right to lodge a complaint with the Supervisory Authority for data protection issues, but also to address the issues to competent authorities.
1. Residents of the EEA may file a complaint with the EDPS (the EDPS is the EU’s independent data protection authority). The data protection authority will require you first attempt to resolve any complaint with us; please see the Contact Information section below to file a complaint with Mood Media.
2. To find the contact details of the Data Protection Authority in your country of residence, please visit link.
3. If you believe that Mood Media has not complied in accordance with the UK GDPR, please contact the DPO in the first instance. You also have the right to make a complaint to the Information Commissioner’s Office (ICO) here. The ICO is the UK’s independent data protection supervisory authority.

Assertion of your rights
To exercise your rights, you can contact the Data Protection Officer at [email protected]. We will process your enquiries in accordance with legal requirements and inform you of the measures we have taken within one month. Occasionally it could take us longer than a month if your request is particularly complex. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Court of competent jurisdiction
You may direct any questions or complaints about this Privacy Statement by contacting us at [email protected]. As regards the website visitors, any disputes arising out of or related to this Privacy Statement will be handled in accordance with the Terms of Use.

Modifications and amendments
This Privacy Statement may be modified or amended, as required. For instance, due to new case law on data protection issues. If we change our data protection practices, we may modify and/or amend this Privacy Statement accordingly. We recommend visiting our website and reviewing our Privacy Statement on a regular basis in order to read the most current information on our data protection practices.

English version controls
Non-English translations of this Privacy Statement are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.

Updated by Mood Media on September, 2022