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Privacy Notice for Global DPO Survey

Hello there! 

We’re very happy to see your interest in our Global DPO Survey where we aim to explore, discover (and share the answers with you) questions such as “how do others actually implement this in practice” and “what does industry standard actually mean?”.

If you are in any way similar to us, then we figured you’ll probably be reading this notice before participating (no judgment here!) and make sure all our ducks are in a row, and that we’re not planning anything “weird” with your personal (or other) data. Given that we mostly speak a similar language, we thought it best to keep it short and to the point. You can always contact us at [email protected] should you have any questions or concerns after reading this notice.  

So, without further ado, let’s dive into the details

  1. A brief introduction on who we are
  2. Personal Data we are collecting (and why)
  3. Non-personal data we are collecting (and why)
  4. The legal base we rely on
  5. Who will we be sharing your personal data with
  6. International Transfers
  7. How long will we keep your data?
  8. How do we make sure your data is secure?
  9. Your Rights
  10. What is our role in all this?
  11. Age limit
  12. Anonymity

1. A brief introduction on who we are

We are hoggo and PrivacyTeam (“we”) and we’ve been in the privacy world for many years now. We are conducting this service because throughout our years of experience, we realized that there are a lot of gray areas with a lack of transparency or benchmarks. Which isn’t ideal when navigating such a sensitive sector that is constantly changing. We will be joint controllers with respect to the (very limited) personal data you share when participating in this survey.

2. Personal Data we are collecting (and why)

  • What? Your work email
  • Why? One of our main goals for this survey is to make sure we only collect answers from real professionals. The reason for that is simple – we want to make sure that the outcome reflects the actual standards and practices in the market. 
  • How will we use it? To send you the survey link, notify you about the survey results, and, if you’ve provided consent, occasionally share information with you that we think you could be interested in.

3. Non-personal data we are collecting (and why)

  • What? Survey responses: We took extra measures to make sure your answers in the survey stay anonymous (for obvious reasons) and can’t be connected to you or your organization. Click here to read more about how we’re doing this. 
  • How will we use it? Solely for the purpose of extracting insights from the survey and putting together results and a report.

4. The legal base we rely on

We process this data based on your consent (Article 6(1)(a) of the GDPR) and our legitimate interests (Article 6(1)(f)) in conducting research on data protection practices.

5. Who will we be sharing your personal data with 

Simply put, we don’t share your personal data with anyone other than needed to conduct our survey and, if you consented to receiving updates from us, with trusted third-parties that help us deliver those updates. In extreme cases, we may be legally obligated to share some data with government and law enforcement officials. However, we will only do so if we believe it’s legally required of us to do so or appropriate and even then, only share the minimum required.

Rest assured that when we do share personal data with other companies or individuals, we make sure we have agreements with each of them that clearly specify what they can (and can’t) do with your personal data. Depending on the services they provide, they may have access to your data, but they can only use it for the specific purposes outlined in our agreements. Below is  a list of the third-parties we are currently using and for what purposes.

  • Our survey plugin: quizandsurveymaster (QSM) Privacy Policy
  • Our WordPress hosting service: Hostinger  Privacy Policy
  • Our internal CRM system

6. International Transfers 

hoggo is based in Berlin, Germany and Zurich Switzerland. PrivacyTem is based in Tel-Aviv, Israel (a country that has been granted adequacy by the EU Commission). Some of the selected third-parties we engage with when performing the survey and related activities, are located outside the EEA/IL. In this case, we make sure your personal data will only be transferred to the extent necessary and only to such selected third-parties. 

If your personal data needs to be transferred to countries that are not part of the EEA, UK or Switzerland and that country has lower data protection standards than the EEA, UK, or Switzerland, then we make sure that appropriate transfer mechanisms and safeguards are in place (such as the EU Standard Contractual Clauses) to ensures that your personal data is still protected with adequate standards.

7. How long will we keep your data?

We’ll keep your email for as long as it takes to complete the survey and send you the results, or, if you opted in (consented) to receiving communications from us, until you withdraw consent or exercise your other rights (such as deletion request).

8. How do we make sure your data is secure?

We made sure we’ve implemented sufficient measures to keep your personal data secure and meet all industry standards. Having said that, due to the nature of the online world, we can’t guarantee full immunity against harm, but we can guarantee that we will do our best to get as close as possible.

9. Your Rights 

You have rights regarding your personal data, and we’ll respect those rights should you want to exercise them.

You have the right to:

  • Request to access your personal data.
  • Request to withdraw consent.
  • Request rectification or erasure of your personal data.
  • Request restriction or object to processing of your personal data.
  • Request portability of your personal data.

Just send us an email to [email protected] and let us know if you’d like to exercise your rights and which one. Please be aware that we will need to verify your identity or request and for that we may require additional information and personal data from you so that we can authenticate and process your request.

10. What is our role in all this?

Some privacy laws (such as the GDPR) differentiate between two main roles for parties processing personal data, a “data processor” and a “data controller”. In relation to personal data you provide for the survey (i.e. your work email), hoggo is a data controller. If you opted-in to receive communications from us then hoggo and PrivacyTeam are joint controllers. In each case, as applicable, we assume the responsibilities that come with those respective roles.

11. Age limit

This survey is not meant for individuals under the age of 18, and we do not wish to collect or otherwise process any personal data of anyone under 18. So, if you’re under 18, please don’t provide us with any of your personal data. If you think we may have any personal data of individuals under 18, please let us know.

12. Anonymity

We went the extra mile to assure your anonymity (and confidentiality).

We take your privacy seriously (it’s kind of our thing) but we also understand that you might want to avoid publicly sharing specific information about your organization’s practices. This is a big reason we’re conducting this survey in the first place (because if no one knows what the market is doing then how can there be a standard?). But, this is also why we took the extra mile to make sure to remove that concern. 

How? By removing the option of connecting the answers to the survey to you or your organization.

More details? Once you click the survey link in the email we send you, you are redirected to our survey platform and assigned a random unique ID. The survey platform doesn’t know who you are, and neither do we when we get your results back from the platform. And even if we’d want to, we wouldn’t be able to connect the survey back to you or your organization. All this to make sure you, your organization, and your survey answers, remain anonymous. 

13. Opt in

If you checked the opt-in consent for receiving updates and communications from hoggo and PrivacyTeam, you will receive updates, insights, combined with an occasional meme (we promise they’re funny). Don’t worry, we respect your inbox like we respect our own and we won’t be flooding it with unnecessary stuff. Also, you can always unsubscribe or opt-out (withdraw consent) whenever you want.

14. For anything else

If you have any questions or concerns regarding this privacy policy, please reach out to [email protected], and we’ll do our best to get back to you as quickly as possible. Really, we mean it.