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Personal Data Policy for Research surveys
This Policy is addressed to those who have been shown a survey questionnaire or who have received a questionnaire collecting data for a media research. The name of the Research is indicated on the survey. In this policy, we describe the survey with the word "Research" capitalized.
What happens after completing the questionnaire?
To properly carry out the purpose of the Research, we need socio-demographic data collected through the questionnaire. This data is linked with your cookie identifier.
After completing the questionnaire, we may invite you to install additional research software, such as a mobile application or a browser plugin. We will never install it automatically - you always have full control over what is installed on your device.
The privacy policies for these research tools are available on our website. They may also be accessible in app stores and during the software installation process.
What is the purpose of the Research?
The Research aims to define the profile of internet users who use internet resources, i.e., those who visit websites and use applications, including a statistical profile of media audiences and the profile of recipients of advertising campaigns carried out on the Internet. The collected data allow us to present collective statistical information on the media users.
Who processes data about me?
- Gemius Araştırma ve Danışmanlık Hizmetleri Ltd. Şti., Maslak Mah. Taşyoncası Sok. T4 Apt. No:1U/B 186 Sarıyer, İstanbul, Turkey (“Gemius TR”), and
- Gemius S.A., ul. Domaniewska 48, 02-672 Warsaw, Poland (“Gemius SA”).
Gemius TR is the primary data controller in Turkey. It collects your survey data and is responsible for handling your rights under the Turkish Personal Data Protection Law (KVKK).
Gemius SA is a joint controller, ensuring compliance with the EU GDPR and providing technical and organisational measures for secure processing.
Any transfer of your personal data from Gemius TR to Gemius SA takes place in accordance with the KVKK, using appropriate legal mechanisms and safeguards.
You can exercise your rights under both KVKK and GDPR by contacting either Gemius TR or Gemius SA. For convenience, please use the common contact address paneltr@gemius.com Gemius TR will handle your request in cooperation with Gemius SA.
For what purpose and for how long is the data processed?
We process data for the following purposes:
| Purpose of processing | Legal basis | Retention period |
|---|---|---|
| Conducting the Research in accordance with this Policy | The legal basis for processing is our legitimate interest (Article 5(2)(f) KVKK) – carrying out reliable statistical research of the media and advertising market. In some cases, the implementation of this interest is linked to consent required under specific legal provisions (e.g. regarding cookies). | Data are stored for the duration of the Research in a given country. In some cases, the data may be stored longer, if used solely for statistical purposes. In such cases, we apply appropriate safeguards to ensure that the data cannot be attributed to an identifiable person. |
| Provision of technical support | The legal basis is our legitimate interest (Article 5(2)(f) KVKK) – providing you with technical assistance. | Data are processed until the expiry of claims resulting from the provided technical support, unless you object earlier and such objection is positively considered. |
| Contacting you, e.g. when we encourage you to take an active or broader part in the Research. We may also invite you to participate in loyalty programmes. Such contact does not concern marketing. | The legal basis is our legitimate interest (Article 5(2)(f) KVKK) – maintaining active participation in the Research and ensuring the quality of Research data. Our legitimate interest may be combined with consent, if required by specific provisions of law. In such cases, we will obtain such consent in the questionnaire. | Data are processed for the duration of the Research in a given country, unless you object to the processing or withdraw consent required under specific provisions (if such consent was obtained). |
What information do we collect about you?
Below we explain what data we collect directly from you in the questionnaire, and what data is automatically obtained, for example, through cookies.
We collect this data through a survey questionnaire
The data we collect directly from you in the questionnaire includes:
- Socio-demographic data, such as age, sex, education, etc. These might also involve data on shopping preferences or information on the way of using the internet
- For some markets, we may ask you to provide contact information such as email address or phone number
- Online IDs of a device, browser ID, and technical data of the device used by you (screen resolution, operating system
- User agent (a string of characters that contains information on, for example, the type of mobile device, operating system, version of the application, and your identifiers).
What data do we collect when you use the Internet?
We collect data when you visit websites or applications participating in the Research. The publishers of these websites and applications inform you about such processing in their policies and ask for your consent.
Once you have completed the survey questionnaire (even partially), we automatically begin collecting the following categories of data:
- online device and browser identifiers (including anonymized IP address) and device technical data (screen resolution, operating system)
- information about the websites participating in the Research that you visit and the content that is displayed to you
- data about your clicks on the above-mentioned websites, including interactions with the advertisements you see.
How can you help us keep your data up to date?
Occasionally, we may ask you to update your data through additional questionnaires.
Sharing information with data recipients
We may share your data with the following entities:
- Gemius Group: other companies within the Gemius Group, including Gemius S.A. and its subsidiaries.
- Providers of technical and panel management services, e.g., hosting, IT, communication, technical support, recruitment, and panel management (including the organisation of competitions and loyalty programmes).
- the company commissioning the Research/auditor, for the purpose of verifying and confirming the reliability of the data; the scope of data shared is minimised to the greatest possible extent.
- research and business partners, e.g., academic institutions, research companies, and commercial partners, solely for research and statistical purposes consistent with the Research, the data is shared in a secured form (pseudonymisation, encryption, data minimisation etc.) to prevent direct identification.
Is your data passed outside the European Economic Area (“EEA”)?
As a rule, your data are not transferred outside the EEA. An exception applies if you are a Panelist from outside the EEA - in that case, your data may be transferred to your country of origin. In such a situation, we apply appropriate agreements and legal mechanisms to ensure security and compliance with the law. If, for any other reason, it becomes necessary to transfer your data outside the EEA, we will do so only in accordance with the law. In particular:
- we will ask for your explicit consent to such transfer, and
- we will inform you about the risks connected with it.
What are your rights?
Respecting your rights, we support data protection in accordance with both the EU GDPR and the Turkish Personal Data Protection Law (KVKK).
You have, among others, the right to:
- know whether your personal data are processed and to request information about such processing;
- learn the purpose of processing and whether your data are used in line with that purpose;
- know the third parties to whom your data are transferred, in Turkey or abroad;
- request access to your data;
- request rectification of inaccurate or incomplete data and to have this communicated to third parties;
- request erasure or destruction of your data and to have this communicated to third parties;
- withdraw your consent at any time (e.g. by uninstalling the app/plug-in or by contacting us);
- object to processing, including objections to profiling or automated decisions;
- request data portability (where applicable under GDPR);
- claim compensation if you suffer damage due to unlawful processing.
To exercise these rights, please contact us at paneltr@gemius.com, by post to the Data Controller’s address, or through the Gemius Privacy Tool website.
You have the right to complain
If you think we act against this Policy or have any questions, please get in touch with us at the e-mail address indicated in the "What are your rights" section above or at the postal address of the Data Controller. You can also apply with a formal complaint to your country’s data protection authority.
Obligation to provide data
Participation in the Research is voluntary, so you do not have to provide your data.
Are your interests or other information predicted based on the collected data?
No, we do not use the data for the purposes of profiling.
Contacting us about the data processing
Any questions and doubts about the scope of data processing might be sent to the e-mail address indicated in the "What are your rights" section above or to the postal address of the Data Controller. We have also appointed a Data Protection Officer, who can be contacted at the e-mail address paneltr@gemius.com.
Updates to this Policy
Any change to this Policy will be made publicly available. In the case of material changes, we will make all reasonable efforts to inform you at least 14 days before they take effect.