Contact us at (763) 525-1460

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

Table of Contents
  1. About Secret Shopper
  2. How We Use Your Information
  3. How We Use Your Information
  4. Sale of Personal Information
  5. How We Collect Your Information
  6. How We Share Your Information
  7. Hyperlinks (Third-party links)
  8. How We Use Cookies
  9. How does Secret Shopper protect your data?
  10. Can this privacy statement be changed?
  11. How long does Secret Shopper keep your personal data?
  12. Your Legal Rights
  13. How to Exercise Your Rights
  14. Data Controller
  15. Changes to this Policy
  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, 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. Please contact us if you need further details regarding the specific legal ground.

    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 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. 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 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, ability to obtain, own and purchase medicinal marijuana and CBD, 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 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.

    3. Customer Service Contacts

      Personal data: If you contact Secret Shopper through the Website, Secret Shopper will process the following data:

      • Identifiers

      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.

    4. Quote request

      Personal data: If you submit a quote request through the Website, Secret Shopper processes your contact details:

      • Identifiers
      • Other company and contact information

      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.

    5. 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 consist of the following:

      • Internet or other electronic network activity information, such as:
        • Your IP address (the number of your computer that makes it possible to recognize your computer)
        • The type of browser (the computer program you use to view internet pages)
        • 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 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.

  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;
    • To identify you as a user of the account;
    • To make use of the shopper portal, to apply for your shopper services;
    • To create a shopper profile;
    • To manage our relationship with you;
    • Provide customer service;
    • To 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, 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.

  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 and
    • 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.

    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.

  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 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.

  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 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.

  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 of personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
    • The right to request deletion of personal information – You have the right to request that we delete your personal information, however, state and federal law may prohibit us from deleting personal information, which Secret Shopper will disclose to you. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), 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 of your personal data – Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to object to processing of such data. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
    • The right to request restriction of processing of your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
    • The right to request the transfer of your personal data to you or to a third party - We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only 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 at any time 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.
    • Rights related to automated decision making and profiling - 'Automated Decision Making' refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention. We may use automated decision making to match you to and provide you with relevant shops in our system. You can ask not to be subject to a decision which is based solely on automated processing but only where that decision produces legal effects concerning you or otherwise significantly affects you. Your right to obtain human intervention or to contest a decision does not apply where the decision which is made following automated decision making is necessary for entering into or performing a contract with you; is authorized by law; and there are suitable safeguards for your rights and freedoms; or is based on your explicit consent. However, in these situations you can still obtain human intervention in the decision making, and we will ensure measures are in place to allow you to express your point of view, and/or contest the automated decision.
    • The right to non-discrimination - We will not discriminate against you if you exercise any of these rights.
    • The right to an authorized agent – You can designate an authorized agent to make any of these requests by providing your express written authorization. We must be able to verify your identity and the authorization must include the authorized agent’s name, address, telephone number, and email address (for providing the personal information collected or to respond to a request for deletion).
  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:

    1. You may send your request to privacy@secretshopper.com.
    2. By calling us at (763) 525-1460 or toll free at 1 (800) 582-4079.
    3. By submitting 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, 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:

    • Enough information to identify you [e.g., your full name, address and customer or matter reference number];
    • Proof of your identity and address (e.g., a copy of your driving license and a recent utility or credit card bill); and
    • Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

    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. To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete with respect to your personal information, we follow procedures to verify your, or your agent’s, identity. These procedures seek to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification procedures involve matching data points that you provide with your request against information about you we already have in our records and that we have determined to be reliable for purposes of verifying your identity. We will use information you provide in your completed request form to verify your identity, and 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 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 may refuse to comply with your request in these circumstances.

    If you would like to appeal of our decision with respect to your exercise of the above rights, an appeal may be sent to the data controller using the same process for submitting initial requests. A response to an appeal may take up to 60 days, at which time Secret Shopper shall respond to your request.

  14. Data Controller

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

    Secret Shopper Data Protection Officer
    620 Mendelssohn Ave
    Golden Valley, MN 55427

  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 to this privacy statement, we will revise the “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. 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

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