YOUR PERSONAL INFORMATION WE COLLECT

When we refer to “personal information” (referred to as “personal data” under some laws) in this Privacy Statement, we mean any information that identifies you or can be used to identify you. Listed below are the ways we collect personal information about you, the types of information we collect, and how we use it.

Information You Provide

We collect directly from you the personal information you choose to give us. When you visit our Site, you may choose to provide us with personal information, such as:

• Contact information (e.g. name, address, telephone number and email address);
• Identifiers (e.g. online ID, account name, or participant ID;
• Demographic information (e.g. age, gender, marital status, date of birth, race/ethnicity, employment status, name of employer, education level, income level, car ownership, food allergies, menthol allergies, tobacco usage, and product preferences);
• Login credentials (e.g. username and password;
• Inferences about preferences, tobacco usage, and product usage;
• Communication preferences;
• Prior engagement or activities with COC; and
• Other personal information you choose to submit on the Site.

Information We Collect from Your Device

When you visit the Site, we, and certain third parties collect information from your device using automated data collection tools, such as:

“Cookies,” which are small text files that that are placed on the device that you are using when you visit a website and may be used to help recognize your device on future visits and enhance or improve your online experience. Cookies may also be used to remember your preferences or personalize content.

“Web beacons,” also known as pixel tags) are a type of technology placed on a website to track certain activity, such as whether a website page has been viewed or when an email is opened.

The information collected in this manner may include IP addresses, dates and times of visits, duration of visits, specific pages visited, referring site, operating system type, browser type, domain and other system settings.

Information Collected by Online Analytics Services

We may collect your personal information from third-party web analytics services on our Site, such as those of Google Analytics. Google Analytics uses technologies, such as cookies, to help us analyze how visitors use the Site, which links they clicked on to arrive at the Site and to diagnose technical issues. To learn about how Google Analytics collects and processes data and the Google Analytics Opt-out Browser Add-on, you can visit https://policies.google.com/technologies/partner-sites and https://support.google.com/analytics/answer/181881?hl=en.

HOW WE USE THE INFORMATION WE OBTAIN

We may use the information you provide to:

• Create and manage your online profile and participant account
• Send you notifications or other communications, and administer your participation in research, special events, programs, surveys, contests, sweepstakes, and other offers or promotions
• Verify your identity, age and eligibility for studies
• Issue participation incentive payments
• Manage our participant information databases
• Operate, evaluate and improve our business
• Comply with applicable legal requirements, industry standards and our own policies and terms

We may use information collected through automated means for purposes such as (i) customizing our users’ visits to the Site, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Site and (iii) managing our Site and other aspects of our business.

HOW WE DISCLOSE INFORMATION ABOUT YOU

We may disclose your personal information we collect about you.

We generally disclose your information with companies who need it in order to provide us a service—such as verifying your age, analyzing survey results, communicating with you, or handling any research stipends. We also may disclose your information with others (i) as legally required by law or legal process; (ii) if we believe there has been a violation of our website policies; (iii) when we believe disclosure is necessary or appropriate to prevent injury, harm or financial loss; or (iv) in connection with an investigation of suspected or actual illegal activity. Sometimes we may disclose your information for other purposes we find in our business interests—such as defending ourselves against legal claims.

YOUR CHOICES FOR HOW WE USE YOUR PERSONAL INFORMATION

You can make choices about how we use your personal information.

Your Browser Settings

Your browser may give you the ability to control cookies or other tracking tools. The Help portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to delete existing cookies. Choices you make are browser and device specific. For more information on deleting or controlling cookies, visit www.aboutcookies.org.

To opt-out of Google Analytics, see section above titled “Information Collected by Online Analytics Services.”

Communications

We offer you certain choices about how we communicate with you and what information we obtain from you. To update your information, ask us to remove you from our mailing lists, or submit a request, please contact us as indicated in the “How to Contact Us” section of this Privacy Statement.

HOW WE PROTECT PERSONAL INFORMATION

We value keeping your information secure. We maintain technical, administrative, and physical safeguards for this Site designed to protect against unauthorized disclosure, use, alteration, and destruction of the information you provide on our Site. We cannot guarantee that your information will be free from unauthorized access by third parties.

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in this Privacy Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

LINKS

Our Site may contain links to other websites, some of which are operated by us and others of which are operated by third parties. We provide these links solely for your convenience and information. These websites, including those operated by COC, may have their own privacy notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these websites, any product or services that may be offered through these websites or any other use of these websites.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Statement, please contact us by email at cocinfo@consumeropinioncenter.com or by phone at 1-800-9267-COC (1-800-926-7262).

You also may write to us at:

Consumer Opinion Center
601 E. Jackson Street
Richmond, VA 23219