Data Privacy Policy
Updated July 6, 2022
Jack Horne Consulting and its affiliates (collectively, "Jack Horne") are committed to protecting the privacy of our clients and any data that comes into our possession. This privacy policy applies to all client data, personally identifiable information (PII), and any other data that may or may not constitute PII that we collect or use in the course of conducting our business, as well as all client information and related data housed at any Jack Horne facility or stored on the Jack Horne network and/or computers. Anyone who has access to such information or data must follow this privacy policy.
All inquiries, including (a) requests to amend incorrect personal information, change consent status, or delete personal information; (b) requests to file a complaint regarding potential misuse of personal information; and (c) any other concerns related to this policy, should be directed to privacy@jackhorne.net, unless stated otherwise below.
Client Information
We treat all information we receive from clients as confidential and do not use the information for any purpose other than to fulfill our obligations to them that are related to a legitimate research purpose. We keep client information secure and strive to prevent the misuse and/or unauthorized disclosure of it by our employees or any third parties.
Personally Identifiable Information
In order to provide our services to clients, we may at times employ the use of client-provided participant contact lists which contain personal information such as names, email addresses, phone numbers, and/or mailing addresses. On engagements involving participants in the European Union, contact lists will only be used in cases where active consent to be contacted for research purposes has been explicitly granted by the participant. Any entity providing such lists to Jack Horne must warrant that such consent has been granted.
All responses to our research are confidential. We only collect and/or use data for the legitimate research purposes of our clients, and our use of that information is limited to that purpose.
We may at times request from research participants their personal information such as names, email addresses, phone numbers, and/or mailing addresses. In cases of video recorded research, the ability to record facial images may be requested. This collection of personal information from research participants is done solely through the legal basis of informed consent.
We do not knowingly collect and/or use personal information under any circumstances from anyone under the age of thirteen (13) without express permission from the legal parent or guardian of such. If we become aware that we have inadvertently collected and/or used personal information from anyone under this age threshold without the required permission, we will promptly delete such information and inform entities providing such information to us of the deletion(s).
Research participation is voluntary. Participants may decline involvement or "opt out" of the research at any time without penalty or hesitation, including after having previously agreed to participate. If a research participant chooses to "opt out," any information we may have collected about that participant will be deleted upon the participant’s request.
We do not rent, sell or otherwise provide in any way personal information to any third party for the purposes of direct or indirect marketing of any products and/or services. In some cases, we may share personal information with third parties that provide research services in support of the research engagement. Any third party that receives personal information is obligated to observe at least the same level of privacy and protection regulations delineated by this policy.
Upon request, we provide research participants access to the personal information we have collected about them as individuals. In response to such requests, we may correct any information that is inaccurate or incomplete, change their consent status, or delete their personal information.
Sharing of Information
We may share information in the following ways: (a) with our service providers, as necessary to enable them to provide services to us (in which cases such service providers are prohibited from using the information except as necessary to provide such services); (b) with our clients or other sponsors of the research as part of a legitimate research purpose; (c) as reasonably necessary to comply with law or a legal process (including a court or government order or subpoena), to detect, prevent, or otherwise address fraud, security or technical issues, to enforce this privacy policy, and to protect the rights, property or safety of Jack Horne, our users, and/or the public; (d) if we sell, transfer or otherwise share some or all of our business or assets, including personal information, in connection with a corporate transaction such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this privacy policy; or (e) with the express written consent of a research participant.
Information Security
Jack Horne maintains necessary physical, electronic and procedural security measures to safeguard client data and personal information. Third parties that provide us with support or other services may at times receive client data or personal information, and we require them to maintain at least the same level of security measures with respect to such information.
Jack Horne does not warrant or ensure the security of any information provided to us. In the unlikely event of a data breach, loss, and/or unauthorized access, use or disclosure of information under our control, we will take reasonable steps to investigate, and notify those individuals whose personal information may have been compromised. We will further take any other steps deemed necessary in accordance with any applicable laws and regulations.
Data Integrity
Jack Horne will take reasonable steps to ensure that personal information provided to us is accurate, complete, current and relevant to a legitimate research purpose, and is used only as described in the "Data Retention" section below. While we accept responsibility for the management and confidentiality of the personal information collected, please note that we cannot always verify the accuracy of the information provided to us and bear no responsibility for the accuracy of information in such cases.
Data Retention
In general, to determine the appropriate retention period for personal information, we consider (a) the amount, nature, and sensitivity of such information; (b) the potential risk of harm from unauthorized use or disclosure of the information; (c) the legitimate research purposes for which we process the information, and whether we can achieve those same purposes through other means; and (d) the applicable legal requirements concerning retention.
We may further process data on behalf of third parties who have engaged us and provided us such data. We retain personal information processed on behalf of third parties for as long as is needed to provide services related to the legitimate research purposes concerning those data to the third party in question. Notwithstanding anything above to the contrary, we reserve the right to retain personal information for any period required by law or to comply with any legal obligations, resolve disputes, and/or enforce our agreements.
Third Party Websites
Our website (https://jackhorne.net) may contain links to external websites, and areas where you can provide information to third parties. These are provided for your convenience only, and we do not warrant or control the content, privacy and security practices, and/or policies of such third parties or third-party sites. Any personal information you provide in such areas, and on such linked pages, is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third parties before providing them with personal information.
Information Collected Automatically
Jack Horne respects the voluntary nature of research participation and protects our research participants’ identities when collecting market research or related information online.
We may at times process IP addresses for the legitimate business purpose of identifying and preventing duplicate participants in our surveys or related online instruments. Whenever we process data for these purposes, we take reasonable and customary steps to keep your personal data safe and secure.
You have the right to object to this processing. If you wish to do so please send a request to privacy@jackhorne.net.
All other personal information is only collected when the research participant deliberately and voluntarily provides it, with informed consent. We may at times collect (a) web browsing activity to ensure a stable, error-free online experience, and/or for legitimate research purposes when an engagement calls for such types of data; (b) telemetry data; and/or (c) application usage data.
The only information we collect from visitors to our website (https://jackhorne.net) is that which is voluntarily provided by requests for more information about our services, or viewing papers, articles and videos from our content library. Otherwise, the only use of visitors’ web browsing activity is to generate aggregate traffic reporting statistics for the website.
Do Not Track Signals
Whether or not we receive Do Not Track request signals from a web browser, we will never use browsing activity information from our research participants, clients, or other website visitors to provide or offer third-party advertising content.
Compliance, Data Protection Officer
As a company based in the United States, Jack Horne is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If you are concerned about our use of personal or client information, please contact us by email at privacy@jackhorne.net.
Individuals in the European Union who have concerns about our compliance with the General Data Protection Regulation (GDPR) or any other data privacy/compliance issues should contact us by email at privacy@jackhorne.net.
Changes in the Privacy Policy
We reserve the right to modify this privacy policy at any time. If we decide to change our policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you either by way of an email or by a notice on our website. We will use information in accordance with the policy as it was in effect at the time information was collected.
Class Action Waiver
Any arbitration or court trial, whether before a judge or jury or pursuant to judicial reference, related to any claim under this privacy policy will take place on an individual basis, without resort to any form of class or representative action ("Class Action Waiver"). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS PRIVACY POLICY. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator.
Legal Obligations
Under certain circumstances permitted or required by law (for example, in connection with law enforcement investigations), we may be required to disclose client data or personal information without giving notice.