This is the GDPR Privacy Statement. If you are not a member of a GDPR country, the general privacy statement applies. Click here to view the General 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 ChildrenThe 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.
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.
“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, it 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.
| Categories of Personal Information | Examples of Specific Types of Personal Information Collected | Collected | Purpose |
|---|---|---|---|
| Identifiers | A real name, alias, postal address, email address, telephone numbers, Internet Protocol address, account number, Social Security number, date of birth, or other similar identifiers. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (d) Prevent fraud |
| Personal Information categories | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (d) Prevent fraud |
| Protected classification characteristics | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (d) Prevent fraud |
| Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
| Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
| Internet or other electronic network activity information | Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. | Yes | Necessary for our legitimate interests to evaluate how the website is used, grow our business and for marketing purposes |
| Geolocation data | Physical location or movements. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary for our legitimate interests |
| Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
| Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
| Sensitive Personal Information | Government-issued identifying numbers, such as a driver’s license, passport or social security number, financial account details that allow access to an account, such as a credit card number and access code, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, contents of mail email or text messages, biometric data related to your unique identification, health data, and sexual orientation, when collected or analyzed. | Yes |
(a) Performance of our agreement with you or to provide the Services (b) Maintain and service your account (c) Process payments to you (d) ensure security and integrity regarding the use of such personal information (e) verify or maintain the safety and quality of the Services |
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.
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:
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.
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 following personal information categories, depending on the type of Services and your location:
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 disclosure 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 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.
Personal data: If you contact Secret Shopper through the Website, Secret Shopper will process the following data:
Purpose: The information collected in this way is used for answering the questions and handling complaints.
Legal basis: This processing of your data is necessary for the protection of Secret Shopper's legitimate interests of being able to serve you efficiently as a customer, to optimize the Services, and to perform an agreement with you. It is also necessary for our legitimate interests to keep our records updated and to evaluate how you use the Services.
Personal data: If you submit a quote request through the Website, Secret Shopper processes your contact details:
Purpose: Secret Shopper uses your contact details to contact you and respond to your demo request.
Legal basis: This processing of your data is necessary for the protection of Secret Shopper's legitimate interests of being able to serve you efficiently as a customer. It is also necessary for our legitimate interests to keep our records updated and to evaluate how you may use the Services.
Personal data: Secret Shopper automatically collects information about you during your use of the Website. This internet or other electronic network activity information may consist of the following:
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 of your data is necessary for the legitimate interests of Secret Shopper to secure its Website and to make the Services as user-friendly as possible.
We will only use your information if we have your permission or we have another legal reason for using it. These reasons may include:
We may use your personal information to:
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, to ensure security and integrity regarding the use of such personal information, and to 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.
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:
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.
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, for example, 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.
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 of Secret Shopper 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.
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.
If Secret Shopper transfers or stores your personal data outside the EEA, it will do so in compliance with the applicable legal requirements. We may need to transfer your information in this way to carry out our contract with you, fulfill a legal obligation, to protect a public interest and/or for our legitimate interests. In this instance, Secret Shopper will provide appropriate safeguards that, in accordance with the EU’s General Data Protection Regulation (“GDPR”), provide an adequate level of protection for your rights and freedoms as to your personal 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.
This privacy statement is subject to change at any time. Notice of any new or revised Privacy Notice, 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 before the change to learn of changes to the Privacy Notice since their last visit.
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. Secret Shopper’s retention policy is as follows:
You have a number of rights in relation to your personal information. You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any Automated Decision Making and Profiling or the basis for international transfers. You may also exercise a right to complain to your Supervisory Authority. More information about each of these rights can be found below.
If you wish to exercise any of these rights, please contact Secret Shopper by doing one of the following:
Secret Shopper will respond to your request without undue delay, but in any case, within one month of receipt of the request. That period may be extended by two further months where necessary, considering the complexity and number of the requests. Secret Shopper shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
If you choose to contact directly by [email/phone/in writing], you will need to provide us with:
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. In order to ensure that the information you request is yours, we may ask you to send a valid proof of identity. If Secret Shopper cannot (fully) determine to which personal data your request relates, Secret Shopper can ask you to (further) specify your request.
If Secret Shopper does not take action on your request, for example because your request is unfounded or excessive or because Secret Shopper (legally) cannot or does not have to comply with your request, Secret Shopper shall inform you within one month of receipt of the request of the reasons for not taking action. In that case, you also have the right to file a complaint with the supervisory authority.
If you have any questions or complaints about the processing of your personal data, please send an e-mail to privacy@secretshopper.com. In case you suspect a breach of data protection legislation and the matter is not solved amicably between us in negotiations, you also have the right to lodge a complaint with a supervisory authority.
Secret Shopper Data Protection Officer
620 Mendelssohn Ave
Golden Valley, MN 55427
We will update this privacy statement when necessary to reflect feedback, changes in our Services, or legal changes. When we post changes to this privacy statement, we will revise the “Updated Date”.
If there are material changes to the privacy statement, such as relating to the sharing or selling of your personal data 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. We encourage you to periodically review this privacy policy to learn how Secret Shopper is using your information.
Effective Date: February 2, 2023
Last Updated: January 24, 2023