Privacy Policy


Updated: April 2020


Who are we?

We are Toluna Group Limited, part of the ITWP Acquisitions Limited worldwide group (“we” “our” “us” or “Toluna”). You can see who our group members are by clicking on the link below:

Toluna is an online data collection group focused on providing high-quality market research data to its clients who are in various business sectors, including other market research agencies and other global and corporate clients of all sizes. We also build and maintain large online consumer panels, providing real-time digital consumer insights to our clients via our market research client surveys and analytics platforms. We host and administer the online platform and help our Client to recruit online community members, like you and we build and manage this site.


What is our Privacy Commitment to you?

We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we collect, use, share and protect personal data that you provide on Captured Moments Community (the “site”) when you become a community member and participate in our Client’s surveys and/or research studies (“surveys”). Our Client (“Client”) operates in the e-commerce industry. Our Client wishes to remain anonymous so that the responses to the surveys you provide, and your use of the Community are not biased in any way.

This privacy notice explains your privacy rights and how laws that may be applicable to you may protect you and tells you:

  • Who are we?
  • What is our Privacy Commitment to you?
  • What personal data do we collect about you and how do we use your personal data?
  • Who do we share your personal data with?
  • Do we transfer your personal data to other countries?
  • What cookies do we use on the site?
  • What other tracking technologies do we use?
  • What is our winner’s policy?
  • What security measures do we undertake to protect your personal data?
  • What are our data retention and destruction policies?
  • Links
  • Children’s privacy
  • Your rights
    • Your legal rights if you are in California
    • How do you access your information; use the member services area and/or update, correct or delete your information?
    • How do you opt out from your community membership?
  • Changes to the privacy notice and your duty to inform us of changes
  • Privacy contact details


What personal data do we collect about you and how do we use your personal data?

Community Members

When you agree to become one of our Client’s community members and complete the registration form on the site, you become eligible to participate in our surveys. As part of your registration, you will provide us with your Identity data and Contact data and we will through your participation in the Surveys obtain, use and share certain other data about you, such as; Demographic/Profile data, Technical data and Pseudonymised data.

We use your Identity data and Contact data for:

  • Contacting you for any reason connected with your panel community membership;
  • Incentive fulfilment - when you earn sweepstake entries, the entries are linked with your account. We use your email address to contact you, if needed, to notify you of your rewards.
  • Sending you invitations for your participation in surveys - to ask you if you are interested in participating in our upcoming surveys. We may also make you aware via your online panel community membership account of surveys you may be suitable to participate in, based on our knowledge of your personal data.

We may from time to time ask you to provide us with Special Categories of personal data about yourself for specific surveys and if required by applicable law, we will ask you for your consent before processing such Special Categories of personal data.

We use your Demographic/Profile data for matching you with appropriate surveys to see if you qualify for particular surveys and your birth date is automatically updated so that we may ensure we select individuals, based on their age as may be required for the relevant survey.

Public forums and blogs

Our site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We display personal testimonials of satisfied customers on the site in addition to other endorsements. With your consent, we may post such testimonials along with your first name and first letter of your surname. If you wish to update or delete your testimonial, you can contact us at

You should be aware that any personal data you choose to make public on the site, in the Community area (under a message on your wall, as an opinion, topic, battle, thumb it) can be read, collected, stored and/or used by other users and could be used to send you unsolicited messages. We strongly discourage you from disclosing any of your personal data in the community area that you may find on the site and in particular, we would never ask you to provide your Contact data or Identity data on a public community area as part of a survey. We cannot guarantee that third parties with whom you share your personal data via those community areas will keep them secure and confidential. Please be aware that we are not responsible for the personal data you choose to submit or make public. In addition, we are not responsible for the content you publicly post on the site that can be found via web-based search engines.

Categories of personal data we may process about you

  1. Identity data – name (includes first, last, maiden and married names), date of birth, marital status, gender, panellist id and username.
  2. Contact data – address state, address zip code, email address and telephone number.
  3. Special categories of personal data – ethnic/racial origin, health, genetics, political opinion, religion, sexual orientation and sex life and biometrics data. In this context “biometrics data” are data resulting from specific technical processing relating to the physical, physiological, or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or fingerprint data and used for ID purposes.
  4. Demographic/Profile data - interests, preferences, feedback and survey responses and including, but not limited to; age, marital status, gender, birthday, household size, income, education and employment status.
  5. Technical data includes internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  6. “Pseudonymised data” is identifiable data as unique identifiers such as panellist ID’s are used, however, direct identifiers, such as name and contact data are removed.


Who do we share your personal data with?

Except for the results of surveys, which may be pseudonymised data, we do not allow our Client to process any personal data about you. If on occasions we do provide your personal data to our Client, such use shall be for specific surveys, for the purposes of research, and we would never provide such data to our Client unless we have first received your consent and confirmed with them that their use is in accordance with applicable law.

We have engaged Amazon Web Services (AWS) (located in Ireland) to host the Community platform and to provide back-up services.

From time to time, Toluna may use third-party software for fraud, quality checking and validation purposes, including, but not limited to speeding.

Though we make every effort to preserve your privacy, we may be required to disclose your personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, to protect your safety or the safety of others, to investigate fraud or breaches of the site terms, or to respond to a government request.


Do we transfer your personal data to other countries?

From time to time your personal data is transferred and/or accessed from a Toluna company that is located in a different country. Toluna has put in place transfer agreements using the standard contractual clauses for the transfer of personal data to third countries as decreed by the European Commission.


What Cookies do we use on the site?

Cookies are used on the site to distinguish you from other users of the site, helping us to provide you with a good experience when you browse our site and allowing us to improve the site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.


What other Tracking Technologies do we use?

Automated technologies or interactions. As you interact with the site, we will automatically collect Technical data about your equipment, browsing actions and patterns. We collect this Technical data by using cookies, server logs, digital finger printing technologies and other similar technologies. We may also receive Technical data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

Server log files: We may collect Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. This Technical data may be combined with other information collected about you for the purposes of improving our services, site functionality and collecting analytical data.

Fingerprint technologies: In general, digital Fingerprinting technologies assign a unique identifier or "Machine-ID" to a user's computer to identify and track your device (“Technology”). The Technology will analyse publicly available information and data obtained from your computer's web browser and from other publicly available data points, including the technical settings of your computer, the characteristics of your computer, and its IP Address, to create a unique identifier, which will be assigned to your device. We use the Technology for quality control, validation, and fraud detection and prevention purposes, including assisting us in ensuring the integrity of survey results. Appropriate technical and operational processes and procedures will be put in place to ensure that the Technology is safe, secure and does not cause undue privacy or data security risks and the Technology will be used and distributed in a professional and ethical manner and in accordance with (a) this privacy notice, (b) any other statements and/or disclosures made to you as a member of the community and (c) applicable laws and market research codes of practice. In the event any unethical conduct is discovered in connection with the use of the Technology, or that the Technology is being used in a manner that is inconsistent with privacy notice, immediate action will be taken to prohibit such unethical conduct and to ensure the proper administration of the Technology.


What is our winner’s policy?

Community members receive sweepstakes entries for their participation in surveys, polls and discussion forums. Participating members become eligible to win the monthly drawing through random selection of sweepstake entries. All winners are notified by email of their winnings. For more information, please visit our Sweepstake Policy page. Toluna shall post the first name and first initial of last name of winners on the community portal Rewards Page and may communicate them via newsletter to all panellists.


What security measures do we undertake to protect your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data in accordance with our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator or supervisory authority of a breach where we are legally required to do so.


What are our data retention and destruction policies?

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

As the results of the surveys and other aggregated or Pseudonymised data are used for research and/or statistical purposes, we, our Client and other third parties may use this information in accordance with the terms indefinitely without further notice to you.



From time to time we may offer visitors the ability to voluntarily link to other sites. We do not review and are not responsible for, the content or effect of the privacy policies of these sites.


Children’s privacy

We will not knowingly collect any information online from any child under the age 16 without permission from his/her parents, legal guardian or an adult responsible for the care of the child. Eligible ‘young people’ (individuals aged between 16 and 17) may be invited to participate in our Teens panel from time to time. We comply with COPPA, the EU “Safer Internet programme”, the General Data Protection Regulation and the ESOMAR guidelines in relation to online surveys concerning children and young people.


Your rights

You have the following rights:

  • Request access to your personal data. We may conduct ID checks before we can respond to your request. See below on how to do this.
  • Have your personal data erased, corrected or restricted if it is inaccurate or requires updating. You may also have the right under certain circumstances to request deletion of your personal data; however, this is not always possible due to legal requirements and other obligations and factors. You can update your account information via your Account or by contacting us at the address given below. See below on how to do this.
  • Make a complaint. You can direct any questions or complaints about the use or disclosure of your personal data to our Privacy Contact. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal data within 30 days of receiving your complaint.
  • Opt out of your membership of the panel. Click below on how to do this.


Your legal rights if you are in California

You have certain rights under the California Consumer Privacy Act 2018 (CCPA) if you are a citizen of California. You can exercise the above rights by:

Once you make an opt-out request, we will remove you from our panel and we will not contact you again unless you decide to re-register with us.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not exclude you from participating in any activities you may be eligible for on the basis of you exercising your CCPA rights.


How do you access your information; use the member services area and/or update, correct or delete your information?

Upon request, we will provide you with information about what personal data we may hold about you. You may access, correct, or request deletion of your personal data, or terminate your membership by logging into your Community Account. By following the appropriate directions, your information should be automatically updated in our database. For these purposes, and if you are unable to correct your personal data yourself via your Community Account you may write to us at the postal address found at the end of this Privacy notice or contact us by email at We will respond to all requests within a reasonable timeframe.


How do you opt out from your panel community membership?

If you choose to end your membership with the Community or require us to cease processing your personal data, you may discontinue your membership by logging into the community portal and selecting “Unsubscribe” at the footer of the page. By following the appropriate directions, your record will be marked as "do not contact", and you will no longer receive invites to participate in future Surveys from Captured Moments Community. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. In most cases it will take 2 to 3 days to process this change, but please allow up to two full weeks for your status to be finalized. Please note that you may continue to receive communications during this short period after changing your preferences while our systems are fully updated.

You may also send an email directly to requesting to be removed. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.

If you decide to terminate your membership, we will no longer use your Identity data or Contact data, except for archival purposes and we will process your personal data in accordance with our backup procedures. Your personal data will eventually be destroyed in accordance with our Data Retention and Destruction Policies and we will continue to employ the security procedures and technologies to keep your personal data safe.


Changes to the privacy notice and your duty to inform us of changes

This version was last updated on the date at the top of this privacy policy.

If we decide to change our privacy notice, we will post those changes to this privacy statement on the homepage, or other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.

It is important that the personal data we hold about you is accurate and current. Please keep your Account details updated if your personal data changes during your relationship with us.


Privacy contact details

You may contact us by writing to:

Captured Moments Community
Toluna USA Inc.,
Suite 2000
21 River Road
Wilton, Connecticut
06897 USA