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BIG VILLAGE INSIGHTS - PRIVACY NOTICE FOR VESTIS PROJECTS

This Privacy Notice for Vestis Projects is provided by Big Village Insights, Inc. (“Big Village”) and is applicable to the research work that Big Village does for its client Vestis. This privacy notice applies only for the research we do for Vestis.

Big Village provides market opinion and social research. You have the right to know what data we collect and the business purposes for which we use that information. We provide a summary of key points in the immediately following section. For more information about what we collect, and your privacy choices, please find our full privacy policy below this summary.

SUMMARY

What data does Big Village collect?

Big Village collects data pursuant to market research surveys which we conduct on behalf of our clients. The categories of data we collect may include: (a) certain information about you (“PII”) such as email address, telephone number and postal address, and (b) Pseudonymous Information collected from your browser or device such as IP address, cookie ID, information about the website you were on prior to taking our survey, the city and state you are located in, browser type, computer, device operating system type and other weblog information. Some of this information is inferred, and some is available via publicly available sources. We may obtain additional insights about your browser or device from third party ad networks and data brokers that pass us Pseudonymous Information. We collect and aggregate survey responses and give a summary of that information to our clients.

What does Big Village do with this data?

Big Village uses this data to help drive market research programs on behalf of Big Village's clients who are seeking to obtain a better understanding of consumer perceptions. These consumer perceptions are often valuable in helping our clients improve their products and services. We process this data in order to inform which questions to ask, and to help our clients make sense of the survey responses. For example, it may be helpful to understand that men and women in general have a different opinion on given topic or with respect to a particular product or service. We send the survey responses to each client. The survey responses will contain a name, email address, postal address, telephone number and pseudonymous ID. The pseudonymous ID does not allow Big Village or Big Village's clients to directly identify a respondent. But the pseudonymous ID is considered personal information in some jurisdictions. We don't consider the transfer of the results to be a sale of personal information under California law, but we nonetheless want you to understand our process and want you to be able to opt-out in the instances where a sale may be deemed to have taken place.

Third Party Collection and Receipt of Information

Big Village partners with third parties such as ad networks and data brokers who provide us with data as we conduct some surveys. Some of these third parties may also provide us with Pseudonymous Information and PII in order to give a more complete understanding to our clients of the Internet usage of the survey participants. It is possible that some of these data transfers may be considered a sale of data under California or other applicable privacy laws. In connection with your survey, Big Village may also send data about your device to a third-party fraud detection vendor named Imperium. Imperium may drop its cookie on your device. For information about how Imperium uses information to prevent fraud, please see their privacy policy located at https://www.imperium.com/privacy/.

Big Village adheres to applicable privacy laws and conducts its business in accordance with best practices as set forth by the Insights Association (IA) and members of the European Society for Opinion and Marketing Research (ESOMAR). For more information about what we collect, and your privacy choices, please find the full privacy policy below.

WHAT DATA DOES Big Village COLLECT?

Big Village collects data pursuant to market research surveys which we conduct on behalf of our clients. The categories of data we collect may include: (a) PII such as email address, telephone number and postal address, and (b) Pseudonymous Information collected from your browser or device such as IP address, HTTP cookie ID, information about the website you were on prior to taking our survey, the city and state you are located in, browser type, computer, device operating system type and other weblog information. We may obtain additional insights about your browser or device from third party ad networks and data brokers that pass us Pseudonymous Information. We collect survey responses and give a summary of that information to our clients.

WHAT DOES Big Village DO WITH THIS DATA?

Big Village uses this data to help drive market research programs on behalf of Big Village's clients who are seeking to obtain a better understanding of consumer perceptions. These consumer perceptions are often valuable in helping our clients improve their products and services. We process this data in order to inform which questions to ask, and to help our clients make sense of the survey responses. For example, it may be helpful to understand that men and women in general have a different opinion on given topic or with respect to a particular product or service. We send the survey responses to each client. The survey responses will contain a name, email address, postal address, telephone number and/or pseudonymous ID. The pseudonymous ID does not allow Big Village or Big Village's clients to directly identify a respondent. But the pseudonymous ID is considered personal information in some jurisdictions. We don't consider the transfer of the results to be a sale of personal information under California law, but we nonetheless want you to understand our process and want you to be able to opt-out in the instances where a sale may be deemed to have taken place.

THIRD PARTY COLLECTION AND RECEIPT OF INFORMATION

Big Village partners with third parties such as ad networks and data brokers who provide us with data as we conduct these surveys. Some of these third parties may also provide us with Pseudonymous Information and PII in order to give a more complete understanding to our clients of the Internet usage of the survey participants. It is possible that some of these data transfers may be considered a sale of data under California or other applicable privacy laws. In connection with your survey, Big Village may also send data about your device to a third-party fraud detection vendor named Imperium. Imperium may drop its cookie on your device. For information about how Imperium uses information to prevent fraud, please see their privacy policy located at https://www.imperium.com/privacy/.

SCOPE OF PRIVACY POLICY

This Privacy Policy applies to Big Village and not to any of our third-party partners. It also does not apply to the privacy practices of any of our research clients.

PRIVACY BY DESIGN

Our foundation of building a strong privacy framework at Big Village follows an internal framework of privacy by design. We integrate privacy in strategy, research, surveys, and more. Our internal procedures align our data use practices in a manner that maximizes the innovative benefits of our services while keeping consumer privacy at the forefront of our business practices and building infrastructure that is effective to guard the data we handle. We protect consumer privacy and provide relevant services in the research sector. Ensuring the protection of privacy throughout the entire lifecycle of the data is of the utmost importance and Big Village is careful to protect privacy as data is collected, used, and destroyed responsibly.

Big Village has developed a strong privacy foundation and has a company culture aimed at data minimization, pseudonymization and adequate data encryption and security.

HOW DOES Big Village PROVIDE RESEARCH SERVICES?

We work with businesses whose privacy policies allow them to share information about their customers or prospective customers, or share information about those customers' interests as inferred from their web browser. This information may include the date and time of a visit to their store, website or mobile application. The information allows us to conduct research and provide our clients with more information about the things consumers are interested in.

DISCLOSURE OF INFORMATION

We may disclose pseudonymous information to our clients for reporting purposes, and we may share aggregated information as well as certain PII such as name, address, email address and transactions with other third parties for analytical and research purposes. We also work with third party agents who are contractually required to use data only to provide services to us. These third-party service providers used by Big Village include: (a) cloud computer, data storage and file storage providers, (b) email marketing providers, (c) website and b2b sales analytics providers, (d) customer relationship management, contact database vendors, data hygiene vendors, survey vendors and project management software providers, (e) customer billing systems partners, (f) login authentication providers to ensure that the logins to our systems are working efficiently, (g) social media platforms for advertising and marketing purposes, (h) outsourced computer programmers helping ensure our systems are operating properly, (i) auditing, debugging and security vendors, (j) data collection vendors, and (k) data visualization platforms.

Big Village may also need to disclose information if (1) we believe that there has been a violation of the law, of your rights, or of our rights, (2) to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, and (3) if our company or substantially all of its assets are acquired.

BIG VILLAGE MAY PROVIDE SERVICES ON THE WEB

When a consumer engages with an online survey from us, we will obtain consent to utilize a "cookie" or "pixel tag" to be placed on the consumer's machine by a third-party partner that may collect device identifiers like iOS and Android Unique Identification Number (UID). Information collected from a cookie, UID, or pixel tag are not linked to PII. No PII is transferred in the cookie, UID or pixel tag to a third party. A third party only knows that consumer by a pseudonymous ID.

WHAT IS A "COOKIE" OR "PIXEL TAG"?

A cookie is an industry-standard small data file placed on a consumer's computer. Cookies allow websites to "remember you" when you return to their website. No PII is transferred in the Big Village cookie to a third party. This website and associated surveys may contain, in addition to Big Village cookies, other third-party cookies that assist us in supplying information that will make it easier for you to navigate on our site. A pixel tag (also commonly known as a web beacon or clear gif) is an industry-standard, often transparent graphic image usually no larger than a 1X1 pixel that is placed in a website or e-mail.

Pixel tags are used by Big Village to transfer relevant pseudonymous information from a website or a client's website to third parties associated with us for the purpose of providing additional research and relevant information for clients. Pixel tags and cookies may be used to link additional pseudonymous information provided by a third party.

DATA RETENTION

Big Village retains data it uses for research purposes for periods determined by our clients, after which the information is removed and discarded. If you have contacted us or provided PII to Big Village to be contacted or joined our mailing list, we will retain your information for as long as you're active or as reasonably needed to provide you with information.

YOUR CHOICES

For some of our surveys, we may request your permission to collect data from your browser. We will not collect that data without your consent. If you do not want data to be collected, please indicate this preference when prompted in the survey.

Upon request, Big Village will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at dpo_US@big-village.com. We will respond to your request within a reasonable timeframe. In order to help us to respond promptly to your inquiry or request, please include as much information as you can in your communication with us-such as the reason you believe we hold any of your data, and any other supporting information such as a particular survey or focus group you took part in, or the title of any email you may have received, or the phone number you may have received a call from.

CALIFORNIA DATA SUBJECTS

The California Consumer Privacy Act of 2018, as amended by the as amended by the California Privacy Rights Act (collectively, “California Law”), provides additional privacy protections for California data subjects and users, including: (a) the right to see what data we have about you, your computer or device (i.e., the right to know), (b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) (c) the right to request the correction of inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process it (i.e. the right to correction), (d) the right to opt-out of the sale or sharing of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales or sharing of your information) and (e) the right not to be discriminated against for exercising these rights.

In addition, and as set forth below, California Law requires us to identify, for the 12-month period prior to the date of this privacy policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this privacy policy, we don't consider the services we provide to have constituted a sale of any personal information about you. For the 12-month period prior to the date of this privacy policy, we have only shared personal information about customers as described above.

You may access those rights with respect to Big Village by sending us an email to dpo_US@big-village.com or calling us via our toll-free California data subject hotline at 833-457-0281. We will take steps to confirm your request within 10 business days and make a good faith attempt to fulfill your request within 45 days. Big Village does not discriminate against you if you exercise any of the above rights. Please note that we may not be able to honor one or more of these rights if doing so would violate applicable law.

The CCPA defines personal information broadly and as such, it includes pseudonymous identifiers such as cookie ID's and mobile advertising ID's. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold, disclosed or shared for a business purpose about you; (5) categories of third parties to whom the personal information was disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting, selling or sharing personal information within the preceding 12 months.

We may take reasonable steps to verify your request and confirm your identity. We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.

You may make an access or deletion request via an authorized agent. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. We may require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.

We do not collect, use or disclose Sensitive Personal Information, as defined in applicable laws.

SAFEGUARDING INFORMATION WE COLLECT AND USE

The security of your information is important to us. We have implemented appropriate security measures to protect the information in our care, both during transmission and once we receive it. We take reasonable physical and technical security measures to protect our data from unauthorized access, as well as unauthorized disclosure.

PRIVACY OF CHILDREN

We do not target our client's surveys to children and do not knowingly collect personal information from children under thirteen (13) years of age. If we learn that a child under the age of thirteen (13) has submitted personal information on our website without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information, we have collected from children under thirteen (13), please contact us at dpo_US@big-village.com.

Minors under eighteen (18) years of age may email us at dpo_US@big-village.comto have the personal information they have provided to us deleted, subject to applicable law. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

We do not have actual knowledge about selling or sharing personal information of consumers under the age of 16.

NOTICE OF FINANCIAL INCENTIVE

We may offer you limited-time promotions and opportunities to participate in surveys. In exchange for participating in our promotions or surveys, and providing us with your personal information, we may offer you financial incentives. We may collect personal information such as your name, email address, preferences, experiences, and engagement with our clients (“Customer Data”). You can terminate participation at any time as explained in the applicable promotion or survey terms. We estimate that the value of the Customer Data is the value of the benefit we offer to you in connection with the promotion or survey, which is reasonably related to the costs associated with offering such benefit.

CHANGES TO THIS PRIVACY POLICY AND HOW TO CONTACT US

We may change this Privacy Policy from time to time. When we do, we will post the change(s) on our website. We encourage you to periodically review this page for the latest information on our privacy practices.

TERMS & CONDITIONS DURING YOUR VISIT TO Big Village's WEBSITES

The place of performance for Big Village's websites is New York. Big Village makes no representation that materials at these sites are appropriate or available for use outside of the United States and access to them from territories where their contents are illegal is prohibited. You are responsible for compliance with local laws in relation to the use of our sites outside the United States. The use of our sites does not establish any joint venture, partnership, employment, or agency relationship between you and Big Village. The Choice of Law is New York. You hereby consent to the jurisdiction and venue in the state and federal courts in New York, NY. Please be aware that Big Village may provide links to other websites, which if you click on them may collect personal information about you. The information practices of those third-party websites linked to Big Village are not covered by this Privacy Statement.

Headings are for reference purposes only and in no way define, limit, construe or describe the scope or extent of such section. As a visitor to our websites, YOU UNDERSTAND AND CONSENT THAT ANY DISPUTE CONCERNING PRIVACY IS SUBJECT TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND APPLICABLE SITE TERMS AND CONDITIONS. You also agree that you have provided notice to, and obtained consent from, any third-party individuals whose information you supply to us with regard to: (a) the purposes for which such third party's information has been collected; (b) the intended recipients or categories of recipients of the third party's information; (c) which of the third party's data are obligatory and which data, if any, are voluntary; and (d) how the third party can access and, if necessary, rectify the data held about them. You agree that the English-language version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy.

Your use of our websites constitutes your agreement to indemnify Big Village and its affiliated entities and to hold them harmless from any and all claims and expenses, including attorney's fees, arising from your use of these websites.

YOU AGREE THAT OUR LIABILITY FOR ANY BREACH OF THIS PRIVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR SERVICES PROVIDED TO YOU BY US TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE BARRED BY OUR TERMS AND CONDITIONS.