System1 is dedicated to safeguarding your privacy in accordance with relevant data protection legislation applicable to your region (such as the General Data Protection Regulation (GDPR), the California Consumer Protection Act (CCPA) and Lei Geral de Proteção de Dados (LGPD)).
This policy is designed to give you useful information about the way we collect and use personal information and how we use cookies.
If you are an employee (or former employee) or applying for a job at System1, there is a separate policy applicable to the processing of your data. Please contact HR@system1group.com for further details.
Personal information – collection and use
Personal information means any information that could identify you e.g. your name, title, phone number, IP address (or other transaction data used when responding to a market research questionnaire), e-mail and mailing address. Further details are described below.
Please note System1 does not collect Personal information in an ordinary course of its business, however may act as a controller or a processor depending on the activities or services performed as further described in this policy.
Controller
System1 Group plc and affiliated companies are the controllers making decisions on how personal data is used in the context of our Services (collectively referred to as “System1”, “we”, “us” or “our” in this privacy policy).
We have designated a Data Protection Officer (DPO) who is responsible for addressing inquiries related to this privacy policy. If you have any questions or wish to exercise your legal rights, please contact our data privacy team using the provided contact information.
Processor
Please note that in some cases System1 may carry out the activities referred to in this policy in our capacity as a data processor acting on behalf of our clients.
Contact Details
Our full details are:
Full name of legal entity: System1 Group plc
Email address: legal@system1group.com
Postal address:
You are entitled to file a complaint with the Information Commissioner’s Office (ICO), the UK authority responsible for data protection matters, at any time. However, we kindly request that you first contact us to address your concerns before approaching the ICO.
Updates to the Privacy Policy and Consent
By accessing system1group.com, testyourad.system1group.com or any other site, including Test Your Ad/Brand/Idea portal which can be accessed via the following link: https://app-s1g-prd-up-ui-01.azurewebsites.net/, operated by System1 where you can use our services (“Services”), act as a visitor of our sites, participate in market research studies or accept to receive our marketing materials you acknowledge and agree to the practices outlined in this policy and confirm that you consent to the collection and use of the information as outlined in this policy. Please read this policy carefully.
This version was last updated in July 2023 and historic versions can be obtained by contacting us. Any changes we make to this policy in the future will be posted on this page and informed to you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your dealings with us.
We collect and process the following data on our site, through online market research studies and our Test Your Ad/Brand/Idea portal via:
1. Direct interactions:
2. Automated technologies:
3. Third parties:
We also gather, utilise, and share aggregated data, which includes statistical information solely for backoffice purposes and improvement of our Services,. Such aggregated data may be derived from your personal data but is not classified as personal data under the law, as it does not directly or indirectly disclose your identity. For instance, data on how you and others utilise a particular feature may be collected and combined, with personal information excluded from the resulting data. However, if we merge or link aggregated data with your personal data in a manner that directly or indirectly identifies you, we handle the merged data as personal data, subject to the terms of this privacy policy.
System1 might use data collected about you for the purposes of detecting and preventing breaches of the System1’s network security, the law or any applicable T&Cs, support, capacity planning and the operation or improvement of System1’s Services. By leveraging this data, we aim to maintain a secure and efficient environment while continuously improving the quality and functionality of our Services. Please see below for more details.
We process personal information about you on the basis that it is:
This shows our use of your personal data collected through this site and Test Your Ad/Brand/Idea portal, and the legal basis under which we process it.
| Purpose | Categories of data collected | Source | Legal basis | |
| Fulfilment of Contract or Service Request incl.
registration as client, user account management, authentication, access and receipt of Services. Provision of Services to our clients.
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Name and contact data, such as, first and last name, email address, postal address, phone number, password or other security information and other similar contact data (“Account Credentials”) and Profile Data.
|
We obtain this data from you directly or through cookies or similar technologies implemented in our Services, incl. through market research studies where applicable. | Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you and or our clients
|
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| Management of Relationship and Service-related Communication
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Account Credentials, Profile Data, Usage and Technical Data | We obtain this data from you directly or through cookies or similar technologies implemented in our Services. | Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) | |
| Administration, Protection, and Compliance (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | Account Credentials, Usage and Technical Data | We obtain this data from you directly or through cookies or similar technologies implemented in our Services. | Lawful basis for processing including basis of legitimate interest: a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to detect and prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
|
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| Data Analytics for Improvement of our sites, products/services, marketing, customer relationships and experiences, including delivering relevant content.
|
Account Credentials, Profile Data, Usage and Technical Data | We obtain this data from you directly or through cookies or similar technologies implemented in our Services. | Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to define types of customers for our products and services, to keep our Services updated and relevant, to grow our business and to inform our marketing strategy). You can withdraw your consent or opt out of communications from System1 at any time. | |
| Information Provision and Personalised Recommendations either in response to a request or where we have determined the Services may be of interest. | Account Credentials, Profile Data, Usage and Technical Data | We obtain this data from you directly or through cookies or similar technologies implemented in our Services.
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We will have your consent or determine that we have a legitimate interest in using your details to provide you with relevant information: necessary for our legitimate interests (to develop our products/services and grow our business). You can withdraw your consent or opt out of communications from System1 at any time. | |
We share personal information within the System1 group companies, with our business partners and third party service providers but will do so only when necessary to enable us to deliver our Services, to control the quality of our studies, keep an internal record of communication we have sent to you, register you as a new customer, manage payments, enable you to partake in a competition or prize draw, administer and improve our sites or respond to any questions. These providers help us build and run the Services as well as our Test Your Ad/Brand/Idea portal functionalities e.g. provision of login service, tracking tools, etc. as available to you from time to time (such as e.g. HubSpot Inc., MAP, Toluna, Google Analytics, ,Recurly, etc,) and as directed by you through the use of our Services. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us. For full details please contact legal@system1group.com.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or the UK. It may also be processed by staff operating outside the EEA or the UK who work for us or for one of our suppliers or group companies. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
When we transfer personal information internationally, we put in place safeguards in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation). If you would like to know more about our data transfer practices and obtain copies of any relevant safeguarding measures, please contact our Privacy Team using the contact form on our site.
When you are participating in a market research healthcare study, we are required to pass details of adverse events or product complaints mentioned in your responses on to our client’s drug safety department.
Data Security
Please protect your data at all times. Make sure that nobody can see over your shoulder when typing in personal information and close your browser when you have finished. System1, as an ISO27001:2013 certified organisation, and its third party suppliers, have used their reasonable endeavors to ensure that access to information provided is secure. We work to protect the security of your information during transmission. The site, hosted on Microsoft Azure, is secured using a SSL Web Server Certificate to offer you secure communications by automatically encrypting all data when it is entered.
You should be aware that the computer that you use must also be secure, and include the latest operating system, software and anti-virus updates. The use of a shared computer to connect to the online-payments system could increase the risk that others will see your sensitive information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We retain your information in accordance with the purposes for which we are using it. The period for which we keep your personal information will be determined by a number of criteria, including the purposes for which we are using the information as explained above, the amount and sensitivity of the information, the potential risk from any unauthorized use or disclosure of the information, and our legal and regulatory obligations.
Marketing
We deliver marketing and event communications to you via the System1 Test Your Ad/Brand/Idea portal or the general System1 newsletter and will ask you to explicitly opt in to receive direct marketing from us via these channels.
If we send you a marketing communication, it will include instructions on how to opt out of receiving these communications in the future.
Even if you opt out of receiving marketing communications by email, we may still send you Service communications or important transactional information related to your accounts and Subscriptions (for purposes such as providing customer support).
Links To Other Websites
Our site and Test Your Ad/Brand/Idea portal may contain links to and from the websites of our partner networks and affiliates or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Your legal rights
You have the following rights in relation to your personal information. Please note that certain rights may apply only under specific circumstances and can vary based on the legal basis of data processing or your location:
If you would like to exercise any of these rights, such as opting out of marketing communications, you can use the unsubscribe button included in our email correspondence. Alternatively, you can contact us at info@system1group.com or refer to the phone numbers provided in the “contact us” section of our website. Please note that in certain situations, we may need to verify your identity and ask you to provide more information to help us understand your request better. Excessive requests may be subject to an administrative fee.
Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They cannot harm your computer.
We use cookies on our site to enhance your experience, improve site functionality, remember your preferences, and for analytical and marketing purposes. These cookies can be broadly categorised as follows:
For a more detailed explanation of the specific cookies we use, as well as to manage your cookie preferences, please refer to the cookie declaration, accessible through the cookie banner on our website. The cookie declaration is maintained dynamically and updated regularly via CookieHub. CookieHub complies with privacy laws and provides an easy, user-friendly interface for you to manage your cookie preferences at any time.
Please remember, your experience on our website may be influenced by your cookie settings. If you choose to decline certain types of cookies, it may impact your experience and the services we are able to offer.
We encourage you to check the cookie declaration regularly to stay informed about the cookies we use and how we use them.
To amend your cookie consent please click here.