Privacy Statement

This is the General Privacy Statement. If you are a member of a GDPR country, there is a separate privacy statement that applies. View the GDPR Privacy Statement.

Secret Shopper® Privacy Statement

Sights on Service Inc. (“Secret Shopper”, “us”, “our” or “we”) takes your privacy very seriously and treats all your personal information with great care. This document sets out Secret Shopper’s privacy statement for the use of the websites (secretshopper.com and validateddata.com), which are also available through the Secret Shopper mobile application (collectively “the Website(s)”). It is recommended that you read this Privacy Statement carefully.

If you have additional questions or would like to receive further information on your personal data protection, please feel free to contact us at privacy@secretshopper.com.

Use of This Website by Children

The website is not directed to individuals under the age of eighteen (18). Secret Shopper does not knowingly collect data relating to individuals less than the age of eighteen.

1. About Secret Shopper®

Secret Shopper is specialized in providing tailored market research and analyses regarding customer satisfaction for businesses. For that purpose, Secret Shopper collects secret shopping evaluations, provides audits, and consultancy services (“the Services”). These Services are provided online, on-site, and on the telephone.

2. What personal data does Secret Shopper collect and process?

“Personal data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, e-mail addresses or any other information relation to that person or a combination of information, which, if put together, means that the person may be identified.

We may have collected the following categories of personal information. Inclusion of a category indicates that we may collect some information in that category. It does not mean that we collect all information listed in that category in all situations.

SMS consent-sharing limitation. All of the above categories exclude mobile numbers, text messaging originator opt-in data, and consent from sharing for third-party or affiliate marketing purposes. Mobile numbers, SMS opt-in data, and consent will not be shared with any third parties or affiliates for their own marketing or other independent marketing purposes. This information may be shared only with aggregators, carriers, platform providers, and other service providers that are necessary to provide and operate the Text Message services, or as otherwise required by law.

Below you will find examples of the personal data and purposes for which Secret Shopper collects your personal data depending on the type of Service. The legal basis for the processing of this data is indicated in each instance. Please contact us if you need further details regarding the specific legal ground.

2.1 Client Portal

Personal data: In order to make use of the client portal, Secret Shopper creates an account for you. Secret Shopper may collect the following information:

• Identifiers, such as first and last name, e-mail address, address, postal code, city and country
• Personal Information, such as financial information relative to processing of payments

Purpose: We process this data to create an account for you so that you can use our Services and to identify you as a user of the account.

Legal basis: This information is necessary for the performance of the agreement with you and necessary for our legitimate business interests. Without an account, you will not be able to use Secret Shopper’s client services.

2.2 Independent Contractor Shopper Portal

Personal data: In order to make use of the independent contractor shopper portal and to apply for your independent contractor shopper services, you need to create a shopper profile. Secret Shopper may ask you to provide information relative to the following personal information categories, depending on the type of Services and your location:

• Identifiers
• Personal Information
• Protected classification characteristics
• Commercial information
• Biometric information
• Internet or other electronic network activity information
• Sensory data
• Geolocation data
• Non-public education information
• Sensitive personal information
• Other information such as lifestyle information, for example, household income, marital status, education level, number of dependents under the age of 18, language preferences, home ownership, vehicle ownership, mobile phone usage, and other types of data that may be relevant to our Services
• Information related to the use of WIC (Special Supplemental Nutrition Program for Women, Infants, and Children)
• Other information you provide to us when you fill in forms or communicate with us, whether face-to-face, by telephone, email, online or otherwise.

Purpose: We process this data to create an independent contractor account for you so that you can use our Services and to identify you as the user of the account. Demographic information is collected to match you to and provide you with relevant shops in our system. Upon successful completion of your independent contractor shopper profile, Secret Shopper assigns you a Shopper ID number.

We do not disclose or share your personal information with our clients. If a client requires your information (known as a “reveal shop”), you will be notified when signing up for the survey, or personally contacted afterwards for permission before any information is disclosed. Secret Shopper will not provide information without prior consent.

You have the right to choose not to disclose information to a client; however, your choice not to disclose information may make you ineligible for “reveal shops” in the future.

If you fail or refuse to provide certain personal data when requested, we may not be able to match you to and provide you with relevant shops in our system. If this happens, we may have to cancel a product or service you have with us or you may not be eligible for some or all shops.

Legal basis: This information is necessary for the performance of the independent contractor agreement with you and to provide the Services. Without an account, you cannot perform shopper services. It is also necessary for our legitimate interests to keep our records updated, to evaluate how you use the Services, to comply with a legal obligation and to prevent fraud.

2.3 Payment Processing and Payment Information

Secret Shopper uses third-party payment service providers to facilitate payments to shoppers and other recipients. When you elect to receive payment through an available payment method, we and our payment service providers may collect and process information necessary to establish and maintain your payment profile, verify your identity, comply with applicable financial and regulatory requirements, and process payments. This information may include your name, contact information, address, tax information, banking or other payment account information, identification information, and other information required to complete or verify a payment.

We currently use Trolley Technologies Inc. and its affiliates (“Trolley”) to provide certain payment-processing, recipient-management, tax-compliance, identity-verification, and related services. Information provided in connection with payments may be transmitted to Trolley and to financial institutions, payment processors, verification providers, and other service providers involved in processing or administering the payment. These parties may process information in accordance with their own privacy policies, contractual obligations, and legal requirements.

We use payment-related information only as reasonably necessary to administer our payment program, process payments, maintain appropriate records, prevent fraud, verify identity, comply with tax and financial regulations, and meet other legal obligations.

2.4 Customer Service Contacts

Personal data: If you contact Secret Shopper through the Website, Secret Shopper will process identifiers and other information you provide in connection with your inquiry.

Purpose: The information collected in this way is used for answering questions and handling complaints.

Legal basis: This processing is necessary for the protection of Secret Shopper’s legitimate interests in serving you efficiently, optimizing the Services, performing an agreement with you, keeping our records updated, and evaluating how you use the Services.

2.5 Quote Request

Personal data: If you submit a quote request through the Website, Secret Shopper processes your identifiers and other company and contact information.

Purpose: Secret Shopper uses your contact details to contact you and respond to your request.

Legal basis: This processing is necessary for the protection of Secret Shopper’s legitimate interests in serving you efficiently, keeping our records updated, and evaluating how you may use the Services.

2.6 Website

Personal data: Secret Shopper automatically collects information about you during your use of the Website. This internet or other electronic network activity information may include:

• Your IP address
• The type of browser you use
• The browser language
• The computer system that you use
• The pages you visit
• The duration of a session

Purpose: This information is collected in order to improve your experience on the Website of Secret Shopper and to solve technical problems and security issues.

Legal basis: This processing is necessary for the legitimate interests of Secret Shopper to secure its Website and to make the Services as user-friendly as possible.

3. How We Use Your Information

We will only use your information if we have your permission or we have another legal reason for using it. These reasons may include:

• If we need to pursue our legitimate business interests;
• To create or perform an agreement we have with you;
• Ensure security and integrity to the extent personal information is reasonably necessary and proportionate to these purposes;
• Where required by law;
• To verify or maintain the quality or safety of the Services;
• To establish, utilize or defend our legal rights.

We may use your personal information to:

• Create and maintain an account for you so that you can use our Services;
• Identify you as a user of the account;
• Make use of the shopper portal and apply for shopper services;
• Create a shopper profile;
• Manage our relationship with you;
• Provide customer service;
• Process payments;
• Market our products, services or opportunities to you;
• Provide you with products and services as otherwise set forth in this Privacy Statement.

Sensitive personal information is collected only as necessary to perform the independent contractor agreement with you and provide the Services, process payments, maintain or service your independent contractor account, ensure security and integrity regarding the use of such personal information, and verify or maintain the safety and quality of the Services. Sensitive personal information is not collected with the purpose of inferring characteristics about you.

The data remains part of our records until we determine the information is no longer needed, or we are required by law to delete such information. We will collect the minimum amount of data necessary to perform these Services.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. We do not sell and will not sell your personal information.

4. Sale of Personal Information

We do not sell and will not sell your personal information.

5. How We Collect Your Information

We collect most of this personal information directly from our clients and independent contractors for whom we provide Services, as well as from you by telephone, written correspondence through the mail, email or fax, or other information available online. However, we may also collect information:

• From your transactions with us;
• From our shopper portal;
• From our client portal;
• From activity on our Website.

6. How We Share Your Information

Secret Shopper may share personally identifiable information it collects with its employees who need to know that information to provide services to you. Except as provided below, Secret Shopper does not share or disclose any personally identifiable information to any company or marketing group external to Secret Shopper. Secret Shopper may, however, share aggregate information with other persons or entities for purposes determined by Secret Shopper to be appropriate under the law.

For example, Secret Shopper may share your personal information with third parties to the extent it is reasonably necessary to manage or service your account, process payment, fulfill a transaction, provide customer service, or as otherwise authorized by law. Aggregated information may be derived from your personal data but does not directly or indirectly reveal your identity.

Text messaging exception. Notwithstanding the foregoing, mobile numbers, SMS opt-in data, and text messaging consent will not be shared with any third parties or affiliates for their own marketing or other independent marketing purposes. Such information may be shared only with aggregators, carriers, platform providers, and other service providers that are necessary to provide and operate the Text Message services, or as otherwise required by law.

Further, Secret Shopper may disclose personally identifiable information (i) to another entity with which Secret Shopper enters or reasonably may enter into a corporate transaction, such as a merger, consolidation, acquisition, or asset purchase, (ii) to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or in connection with litigation brought against, or on behalf of, Secret Shopper, where appropriate, (iii) to a third party if determined by Secret Shopper in its sole judgment that such disclosure is appropriate to protect the life, health, or property of Secret Shopper or any other person or entity, all in compliance with applicable law, (iv) to third parties as authorized or designated by you, or (v) to conduct any other legitimate business activity not otherwise prohibited by law. The foregoing is not intended to obviate or displace any legal obligations or duties applicable to Secret Shopper, and does not alter the text messaging opt-in restriction stated above.

7. Hyperlinks (Third-party links)

The Website contains hyperlinks that allow you to leave the Website and go to the website of a third party. Secret Shopper has no control over the services and/or websites of third parties that are linked to. The use of these services and/or websites of third parties may be subject to a different privacy statement and/or conditions. This Privacy Statement only relates to personal data obtained within the framework of the Services of Secret Shopper or the Website.

Secret Shopper does not accept any responsibility or liability for the operation, content, and/or privacy practices of services and/or websites of third parties. We suggest you review the privacy policies of any linked websites you visit.

8. How We Use Cookies

We (or companies acting on our behalf) may collect certain computer and browser information through automated technologies such as cookies and web beacons when you visit our Website. Cookies are small pieces of text information that are sent to your browser when you visit the Website to identify the browser or to store information or settings in the browser. They are then stored on the hard disk or in the memory of your equipment.

The browser can send this information back on your next visit to the Website. The cookies placed via the Website cannot damage your equipment or the files stored on it. Web beacons (also known as internet tags, pixel tags, or clear GIFs) link web pages to web servers and their cookies may be used to transmit information collected back to a web server.

We or companies acting on our behalf may collect certain computer and browser information through automated technologies such as cookies and web beacons when you visit the Website. Please see our Cookie Policy for more details.

9. How does Secret Shopper protect your data?

Secret Shopper greatly values the security of your personal data. Secret Shopper has implemented physical, technical and administrative security safeguards to protect against the unauthorized release of or access to personal information. We employ internal and external system safeguards designed to protect confidentiality and security of personal information.

10. Can this privacy statement be changed?

This Privacy Statement is subject to change at any time. Notice of any new or revised Privacy Statement, as well as the location of the new or revised statement, will be posted on the Website after the change. It is the obligation of users visiting the Website to review changes to the Privacy Statement since their last visit.

11. How long does Secret Shopper keep your personal data?

Secret Shopper does not retain your personal data for longer than is necessary to fulfill the purposes described in this Privacy Statement or as otherwise required for legal compliance purposes.

12. Your Legal Rights

• The right to access personal information: You have the right to submit a verifiable request for access to your personal information that we collected about you, subject to certain exceptions. This may include the categories and specific pieces of information collected, the sources of that information and the business or commercial purpose for the collection or disclosure of that information.
• The right to request correction: You may request correction of incomplete or inaccurate personal data we hold about you, though we may need to verify the accuracy of the new data you provide.
• The right to request deletion: You may request that we delete your personal information; however, state and federal law may prohibit us from deleting certain information. You may also ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law.
• The right to object to processing: Where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground, you may have the right to object. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds to process your information which override your rights and freedoms.
• The right to request restriction of processing: You may ask us to suspend processing in certain circumstances, including while accuracy is being established, where use is unlawful but you do not want erasure, where you need us to retain information for legal claims, or while an objection is being evaluated.
• The right to request transfer: Where applicable, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. This right generally applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• The right to withdraw consent: Where we rely on consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before withdrawal. If you withdraw consent, we may not be able to provide certain products or services to you.
• Rights related to automated decision making and profiling: We may use automated decision making to match you to and provide you with relevant shops in our system. Subject to applicable law, you may have rights not to be subject to certain decisions based solely on automated processing, and to obtain human intervention or contest a decision.
• The right to non-discrimination: We will not discriminate against you if you exercise any applicable privacy right.
• The right to an authorized agent: You can designate an authorized agent to make certain privacy requests by providing express written authorization. We must be able to verify your identity and the agent’s authority.

13. How to Exercise Your Rights

If you wish to exercise any of these rights or have any questions or comments about this Privacy Statement, please contact Secret Shopper by doing one of the following:

• Send your request to privacy@secretshopper.com.
• Call us at (763) 525-1460 or toll free at 1 (800) 582-4079.
• Submit the request on our website at https://www.secretshopper.com/info/data-privacy-request-form/

Secret Shopper shall respond to your request without undue delay and within the time required by applicable law. That period may be extended where permitted, considering the complexity and number of requests, and we will notify you of any extension and the reasons for the delay.

If you contact us directly, you may need to provide enough information to identify you, proof of identity and address where appropriate, and sufficient detail to allow us to understand, evaluate and respond to your request. We may request additional information if necessary to complete the verification process.

You will not have to pay a fee to access your personal data or exercise other rights unless permitted by law, such as where a request is clearly unfounded, repetitive or excessive. If you would like to appeal our decision with respect to your exercise of applicable rights, an appeal may be sent to the data controller using the same process for submitting initial requests.

14. Data Controller

If you have any questions about this Privacy Statement, including any requests to exercise your legal rights, please send an e-mail to privacy@secretshopper.com or send correspondence to:

Secret Shopper Data Protection Officer
3535 Vadnais Center Dr., Suite 170
Vadnais Heights, MN 55110

15. Changes to this Policy

We will update this Privacy Statement when necessary to reflect feedback, changes in our Services, or legal changes. When we post changes, we will revise the “Last Updated” date.

If there are material changes to the Privacy Statement or in how we will use your personal data, we will notify you by prominently posting a notice of such changes before they take effect or by directly sending you a notification where required. We encourage you to periodically review this Privacy Statement to learn how Secret Shopper is using your information.

Effective Date: February 2, 2023

Last Updated: November 4, 2026