Privacy Policy

Effective: 14-OCTOBER-2024

At Walker Information, Inc. (“Walker”), we believe that survey respondents and online visitors are key stakeholders in our company. For this reason, Walker prides itself not only on its customer focus, but also on its efforts to protect and be sound advocates for our respondents and online visitors. Walker helps its clients conduct market research, customer experience and employee experience surveys using scientific methods. Walker promises that in obtaining your cooperation, Walker will not mislead you about the nature of the survey or the use that will be made of the findings. At a minimum, Walker will comply with all laws and regulations including all global data privacy regulations. Walker promises that when collecting personal information in response to marketing or product requests, we will use your information solely for this purpose.

The remainder of this statement will provide insight on what information we may collect about you, how either Walker or our clients may use your opinions and personal information as it relates to our services and your rights, and our commitment to your rights. It also describes your choices regarding use, access, and correction of your personal information.

Our Mission

Walker’s mission is to provide our clients with information-based measurement solutions to help improve their performance by enhancing business loyalty and critical relationships with their customers, employees, and other key stakeholders. As a part of our process, we use scientific methods that reveal to clients where they have leverageable strengths and critical weaknesses in their relationships with their stakeholder groups. In assessing these strengths and weaknesses, we encourage our clients to act on the feedback provided by their stakeholders by creating process improvement initiatives. The outcome from these efforts is improved quality of products or services and/or increased value delivered to customers of our clients.

Information we may collect about you

Walker collects online registration information such as Name, Email Address, Company Name, and Phone Number. Walker surveys collect only your provided responses.

Surveys

For surveys, Walker processes, on behalf of our clients, personal data that has been collected by or on behalf of those clients. Personal Information (“PI”) means information relating to an identified or identifiable person. Walker acts as a Data Processor and each Walker client acts as a Data Controller. A “Data Processor” is an entity that processes PI on behalf of a Data Controller; a “Data Controller” is an entity that determines the purposes for which PI are processed. To “process” PI means to carry out an operation or set of operations on such PI, such as collecting, transmitting, recording, storing, disclosing, or organizing it. The “Data Subject” means the person to whom a certain set of PI relate; for example, the person who responds to a survey.

Sharing of PI

Walker does not share PI with third parties. In certain situations, Walker may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Walker may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when Walker believes in good faith that disclosure is necessary to protect your rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Walker shares your personal information according to this Privacy Policy, with your consent or as necessary to provide you services that you request, as well as to operate our business. The ways in which Walker shares your personal information are set forth below.

Third Party Service Providers/Vendors: Walker shares your information with third parties who provide services on Walker’s behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to Walker, pursuant to written instructions. In such cases, these companies must abide by Walker’s data privacy and security requirements and are not allowed to use PI they receive from Walker for any other purpose. Representative business processes that our service providers/vendors assist us with include:

1. AWS (Amazon Web Services)
2. Egnyte

AWS and Egnyte will not access or use, or disclose to any third party, any Customer Data, except, in each case, as necessary to maintain or provide the Services, or as necessary to comply with the law or a valid and binding order of a governmental body (such as a subpoena or court order).
Legal Compliance: In certain situations, Walker may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Walker may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when Walker believes in good faith that disclosure is necessary to protect Walker’s rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

Walker will not disclose personal information to a third party not acting as an agent, nor to be used for a purpose that is materially different than that for which it was collected.

Data Subjects Access Rights

Walker acknowledges that you have the right to access your personal information. For client activities as a Data Processor, Walker will only process PI pursuant to the instructions of the applicable client (the Data Controller). Walker has no direct relationship with the individuals whose PI it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the Walker client (the Data Controller). If the client requests Walker to remove the data, Walker will respond within a reasonable timeframe.

Walker collects information under the direction of its clients and has no direct relationship with the individuals whose data it processes. If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly.

For Walker’s marketing activities, Walker acts as the Data Controller. In these instances, an individual who seeks to exercise their data protection rights (data subject access request, data portability, data deletion, data correction, etc.) or withdraw your consent, please direct your query via email to privacy@walkerinfo.com. You can expect a response to your requests within 30 days.

Data retention

If Walker processes your personal information, Walker will retain your personal information and the data Walker processes on behalf of Walker’s clients for as long as stipulated in client agreements. Walker will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Marketing requests

Walker collects PI when you register for subscriptions to online newsletters and seminars, information downloads and requests for marketing materials or product information, or when you ask to be included in an e-mail or other mailing list. During registration, we require your name, title, company, and email address. You also have the option of providing other information such as a salutation and business contact information. We maintain PI to control access to specific registration sites. We do log your IP address (the Internet address of your computer) to tell us which part of our website you visit and how long you spend there.

Some of our outgoing emails contain a unique image. When the email is accessed and the image is requested from our server, we will identify when that request occurred and record information from the http request, such as the IP address, user agent, etc. This allows us to gauge the effectiveness of our communications and also lets us know which emails and links have been opened by recipients.

Walker uses such information, if it has been collected, in accordance with acceptable privacy practices consistent with this policy and applicable laws. Access to certain Walker web pages requires a login and a password.

Walker uses information for several general purposes: to fulfill your requests for certain products and services, to personalize your experience on our website, to keep you up to date on the latest product announcements or other information we think you’d like to hear about, and to better understand your needs and provide you with better services.

Walker subscribes to an “opt-in” policy. This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted. We will always give you the opportunity to “opt out” of receiving direct marketing information by clicking on the unsubscribe link at the bottom of the email or reply to the corresponding received e-mail message with the word “remove” or “unsubscribe” in the subject.

Tracking technologies

Walker uses cookies (first-party, session, persistent, performance, functional and social media cookies) or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. Neither Walker or Walker’s third parties are not allowed to use cookies or tracking technologies for Interest-Based Advertising or online behavioral advertising.

For marketing requests, we automatically capture information about your browser type in order to deliver richer context, tailored for a better experience, and suited to your software and preferred language setting. We do no other invisible processing of data from your computer. Additionally, we may use cookies tied to PI (“cookies” are small text files stored on your PC’s hard disk and used for keeping track of settings or data for a particular web site) and other similar devices sparingly and only for quality control and security validation purposes.

Security

If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of Walker’s website if you do so.

Our web site has security measures in place to protect the loss, misuse, and alteration of the information under our control. Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. Only certain Walker employees have access to the information you provide Walker. They have access only for data analysis, quality control purposes, and opt-in marketing. If you have any questions about the security of your personal information, you can contact Walker at privacy@walkerinfo.com.

How your information may be used: surveys

Respondents are adequately informed about the nature of the survey (who is conducting it, how the information will be used, etc.) and understand that their cooperation is entirely voluntary and agree to participate on this basis. Depending upon the nature of the program, it may be necessary for clients to look at information from individual respondents in an effort to better understand specific issues or to develop process improvement initiatives.

Those wishing to not receive invitations to take surveys from Walker clients may opt-out in the survey invitation or refer to the specific client’s privacy policy.

Upon request, Walker will provide you with information about whether we hold any of your PI. Individuals who need to change or delete PI submitted to Walker may send an e-mail to privacy@walkerinfo.com. We will respond to your request to access within 30 days. For more information on the Data Subject Access Request procedure, please click here.

Your information may be stored and processed in the United States or any other country in which Walker or its affiliates, subsidiaries, or agents maintain facilities. By participating in a Walker sponsored survey, you consent to any such transfer of information outside of your country under certain circumstances.

Walker Extensions

Qualtrics LLC is a provider of an experience management and survey software platform, and Walker is a member of the Qualtrics Partner Network. As a partner, Walker may create extensions (“Walker Extensions”) to the Qualtrics platform to add new functionality to the software. Any Walker Extensions created for the Qualtrics platform will not transmit, process, or store any PI as part of its functionality.

Blog

Our Web site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at support@walkerinfo.com.

Links to 3rd party sites

The www.walkerinfo.com (brochure site) includes links to other Web sites whose privacy practices may differ from those of Walker. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Social media widgets

Our Web site includes Social Media Features, such as the Facebook Like button [and Widgets, such as the Share this button or interactive mini programs that run on our site]. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Data Privacy Framework Participation

Walker complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Walker has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. Walker has certified to the U.S. Department of Commerce that it adheres to the UK Extension to the EU-U.S. DPF with regard to the processing of personal data received from the UK in reliance on the EU-U.S. DPF. Walker has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov.

Walker is responsible for the processing of personal data it receives, under the EU-U.S. DPF, UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF, and subsequently transfers to a third party acting as an agent on its behalf. Walker complies with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF and Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over Walker’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF. In certain situations, Walker may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Walker commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Walker commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Walker commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Walker at: DPO@Walkerinfo.com

For complaints regarding EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Changes to the Privacy Policy

Walker will, and reserves the right to, modify and update this policy or its related business practices at any time. Walker will not apply changes to this policy that retroactively affects personally identifiable information without your express consent. For material changes affecting personally identifiable information that is not owned by the data controller, Walker will post a prominent notice on the site for 30 days prior to changes taking effect.

Our policy for children under 13

Walker does not knowingly collect PI from users under the age of 13. If for some reason, Walker finds that a US user is under the age of 13 Walker will delete that personal information accordingly.

How you can reach us

You can contact us at support@walkerinfo.com to discuss any problems related to our privacy policy. If you are concerned about our use of your PI, or would like to file a complaint, please contact us at privacy@walkerinfo.com. You can expect a response to your requests within 30 days.

We can also be reached via postal mail at the following address:

Walker Information, Inc.
Attn: Data Privacy Officer
8940 River Crossing Blvd.
Indianapolis, IN 46240