- What is Sommer Consulting?
- Collecting and Using Information
- Cookies and Other Tracking Technologies
- Third Party Processors
- International Data Transfers
- “Do Not Track” Signals
- Advertising and Marketing Choices
- Third Party Links
- Children’s Privacy
- Your Choices and Rights
- Your Personal Data and Your Rights –United States Only
- Your Personal Data and Your Rights –Europe and the United Kingdom Only
- How to Contact Us
What is Sommer Consulting?
Sommer Consulting is a market research and consulting firm that leverages their proprietary 8-Components Linguis-Techs questioning model to provide actionable insight to clients across diverse industries—biotech, finance, pharmaceuticals, luxury goods & healthcare. The Insighters platform enables marketers to connect with respondents to engage in marketing research and studies. Sommer Consulting is a registered Minority & Woman-Owned Small Business & Federal vendor.
Sommer Consulting’s offices are located at 408 Executive Drive, Langhorne, Pennsylvania 19047, USA. Sommer Consulting is the data controller of all personal data collected from residents of the European Economic Area or the United Kingdom.
Collecting and Using Information
Personal Data We Collect
Information You Provide
When you use the Services, you may voluntarily provide us with the following types of Personal Data:
- Contact Us. When you send us a message, you explicitly consent to providing your full legal name, email address, and phone number in the web form.
Third Party Information
How We Use Your Personal Data
We use the Personal Data we collect to provide the Services to you, to improve our Services, and to protect our legal rights. In addition, we may use the Personal Data we collect to:
- Contact you regarding your interest in a Project;
- Contact you regarding our products and services that we feel may be of interest to you;
- Communicate with you about our Services or to inform you of any changes to our Services;
- Maintain and improve our Services;
- Defend our legal rights and the rights of others;
- Efficiently maintain our business; and
- Comply with applicable law.
How We Share Your Personal Data
We may share the information that we collect about you in the following ways:
- With service providers who perform data services on our behalf (e.g., email, survey generator, appointment scheduling, hosting, maintenance, backup, analysis, etc.). Any such service providers will be under an obligation to us to maintain the confidentiality of your Personal Data;
- To service providers to prepare, deploy and analyze advertising content;
- To the extent that we are required to do so by law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our legal rights, including providing information to others for the purposes of fraud prevention;
- To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personal Data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Data;
- To any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition or in preparation for any of these events; and
- To any other person or entity where you consent to the disclosure.
Cookies and Other Tracking Technologies
Third Party Processors
To ensure that your Personal Data receives an adequate level of protection, we have put in place appropriate procedures with the service providers we share your Personal Data with to ensure that your Personal Data is treated by those service providers in a way that is consistent with and which respects the applicable laws on data security and privacy. For example, we use email service providers.
International Data Transfers
We operate internationally and transfer information to the United States for the purposes described in this policy. The United States may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. Your Personal Data can be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.
By using our Services, you explicitly consent to this risk and to the transfer, processing and storage of your information in the United States, irrespective of which country you live in. To the extent that you agree to our terms of service and enter into a contract with us, you acknowledge that the transfer is necessary for performance of that contract.
“Do Not Track” Signals
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the website does not currently interpret, respond to or alter its practices when it receives “Do Not Track” signals.
Advertising and Marketing Choices
Depending on your location (and reflecting applicable law), you may have been asked to indicate your preferences, provide us with your consent regarding the receipt of such information from us, and indicate how you would like to receive it.
Wherever you are located, we will send you marketing communications based on any preferences you may have expressed.
We only want to send you information in which you are interested. If you do not want to receive these communications or would like to understand more about other unsubscribe options, please contact us as set out in the “How to Contact Us” section below.
For email communications, you can opt-out by clicking on the unsubscribe link provided at the bottom of any email you receive from us. You also may submit a request to us at [email protected]. Note, however, that you will continue to receive communications regarding your use of the Services (e.g., when you have decided to participate in a Project). If we call or text you with information you do not want to receive, you can advise us of this during the telephone call [or by replying “STOP” to the text message].
Third Party Links
We maintain commercially reasonable security measures to protect the Personal Data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee absolute security.
Our Services are not intended for individuals under 18 years of age. We do not knowingly collect, use, or disclose personal information from individuals under 18.
Your Choices and Rights
Depending on the jurisdiction in which you are located, you may have additional rights with respect to your Personal Data. We discuss some of those jurisdictions and rights below. For example, you may have the rights to access, delete, update, or correct your information. You also may have the right to object to or opt out of direct marketing from us. If you would like to exercise your legal rights, please contact us at [email protected]. We will process your request in accordance with any applicable legal requirements.
Your Personal Data and Your Rights –United States Only
California Shine the Light Law
We do not disclose personal information obtained through our Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.
Notice to Nevada Residents
Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to a number of exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to [email protected].
Your Personal Data and Your Rights –Europe and the United Kingdom Only
If you are in a country in the European Economic Area (EEA) or in the United Kingdom, you are entitled to the following explanation of the legal bases we rely on to process your Personal Data and a description of your privacy rights.
Legal Bases for Processing Your Personal Data
The legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it.
We may process your Personal Data based on your consent such as when you create an account or when you ask us to send certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
Our Legitimate Interests
We may process your Personal Data if doing so is necessary for our legitimate interests and your rights as an individual do not override those legitimate interests. For example, when we process your Personal Data to carry out fraud prevention activities and activities to increase network and information security, to market directly to you, to expand our business activities and to improve our services.
To Perform a Contract
We may process your Personal Data to administer and fulfill contractual obligations to you.
To Enable Us to Comply with a Legal Obligation
We may process your Personal Data to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts and to comply with legal process.
Necessary for the Exercise or Defense of Legal Claims
If you bring a claim against us or we bring a claim against you, we may process your Personal Data in relation to that claim.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Data for any specific processing activity, please contact us using the “How to Contact Us” section below.
To exercise any of these rights, please contact us as described in the “How to Contact Us” section below.
Access Your Personal Data
Rectify Your Personal Data
You have the right to ask us to rectify any inaccurate Personal Data about you and to have incomplete Personal Data completed.
Restrict Our Use of Your Personal Data
You have the right to ask us to place a restriction on our use of your Personal Data if one of the following applies to you:
- You contest the accuracy of the information that we hold about you, while we verify its accuracy;
- We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
- We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
- You have objected to us using your information, while we check whether our legitimate grounds override your right to object.
Object to Our Use of Your Personal Data
You have the right to object to our use of your Personal Data where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).
Delete Your Personal Data
You can ask us to delete your Personal Data if:
- We no longer need it for the purposes for which we collected it;
- We have been using it with no valid legal basis;
- We are obligated to erase it to comply with a legal obligation to which we are subject;
- We need your consent to use the information and you withdraw consent;
- You object to us processing your Personal Data where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.
However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the “How Long Is Your Personal Data Kept” section below.
If you do exercise a valid right to have your Personal Data deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).
Transfer Your Personal Data to Another Service Provider
You may request that we transfer some of the Personal Data you have provided to you or another service provider in electronic copy. This applies to Personal Data we are processing to service a contract with you and to Personal Data we are processing based on your consent.
Make a Complaint
If you have any concerns or complaints regarding our processing of your Personal Data, please contact us as described in the “How to Contact Us” section below and we will do our best to answer any question and resolve any complaint to your satisfaction.
If, for whatever reason, you feel we do not meet the standards you expect of us, you are also entitled to make a complaint to your local supervisory authority:
EU Data Protection Authorities (DPAs)
Swiss Federal Data Protection and Information Commissioner (FDPIC)
Information Commissioner’s Office (United Kingdom)
How Long Is Your Personal Data Kept?
How to Contact Us
For questions or concerns about our privacy policies or practices, please contact us by email at [email protected].