Last updated January 2024

Brado Cuneo Nollau, LLC (“we” or “Brado” or “us”) is fully committed to safeguarding the privacy of market research participants (“you” or “Participant”) through our compliance with this Privacy Policy (“Privacy Policy”) and Applicable Law (as defined herein). We have implemented certain technologies and best practices to ensure that confidential information is protected. We do not sell your personally identifiable information (referred to herein as “PII” and further defined herein). We will never share PII or use it for any purpose other than market research, except as required by law or when anonymized and used for training purposes. An explanation of a market research study (“Study”) is found here. 

This Privacy Policy provides an overview of the data that Brado collects, and what we do with it:  collection, usage, storage, transfer, processing and sharing. Additionally, it covers your choices regarding the use and processing of your information, any special or unique circumstances, and how you can contact us for any questions or requests related to your data or our Privacy Policy. 

How Information Is Collected 

Brado obtains confidential information directly from Participants, including consumers, patients, and healthcare professionals, as well as from third parties (such as recruiting firms and clients) you have authorized to share your PII.  

The legal basis for processing PII is for the performance of our contracts with our clients and performance of obligations under a Study Agreement (defined herein) with you. We also process PII with your consent when we have asked for it and you have provided it. You can withdraw your consent at any time. 

Types of Personally Identifiable Information (PII) 

We use the term “PII” herein to include definitions from various jurisdictions. Depending upon the objective of a Study, Brado may collect the following categories of PII about you:  

• Contact Information:  First name, last name, work, cell and/or personal phone numbers, USPS mailing address, email address, online identifiers, account data, and ID numbers. 
• Demographic information:  birthdate, birthplace, gender, race, ethnicity, insurance, household income, employment, education, marital status, living situation, religion, geographic location. 
• Opinions, experiences, preferences, profession, and memberships. 
• Health Information:  history, diagnoses, medication use and treatments, biometrics, vaccinations. 
• Personal likenesses:  recorded on photographs, video, audio, or other digital media. 

Study Agreement  

The exact categories of PII collected will vary by Study and will be defined in one or more separate agreements (“Study Agreement”) you will be asked to sign indicating consent. The Study Agreement will also address your obligations regarding confidentiality and confirm you are at least 18 years old. Your participation is voluntary, but if you choose not to sign the Study Agreement, you may not participate in a Study.  

Your Choices and Rights 

Brado recognizes and respects that Participants may have the following rights regarding their PII based upon applicable jurisdictional law: 

• To be informed about use and management 
• To access, rectify or correct 
• To delete, erase or restrict processing 
• To lodge a complaint with the supervisory authority in your jurisdiction 
• Rights in relation to automated decision making and profiling.  

If you want us to modify or delete your PII, you can contact us at InfoSec@brado.net with your request. We will take steps to delete your information as soon as is reasonably practicable, but some information may remain in archived/backup copies for our records or as otherwise required by Applicable Law. For purposes hereof, “Applicable Law” shall mean applicable State privacy law and the European Union General Data Protection Regulation (GDPR), as and when applicable with respect to certain Participants. 

If the GDPR applies to our processing of your PII (which will be the case if you reside in a country or are a citizen of a country that is a part of the European Union or European Economic Area), you also have the right to request limited processing, to object to processing, or to request data portability. 

How Information Is Shared 

We may disclose the PII we collect as described below or otherwise disclosed to you at the time the data is collected. 

• PII shall be treated confidentially and shall not be disclosed outside of Brado (and Brado’s clients and subcontractors/subprocessors), except with your consent or as required by law or by court order. 
• Brado may share PII with subcontracted third-party service providers that may process information for Studies, such as recruiting firms, moderators, translators, and platforms that host market research surveys or interviews. These third parties are authorized to use your PII only as necessary to provide market research services. This may entail the transfer of data to countries outside of your country of residence, which have different data protection rules. Participants are encouraged to review the privacy policies of the third parties involved in a Study.  
• Brado will not transfer PII to a location outside the U.S. or the European Economic Area unless that territory or country ensures an adequate level of protection for the rights and freedoms of data subjects.  

How Brado Addresses Your Rights 

This section informs Participants about Brado’s priorities, processes and policies regarding PII and Studies. 

• Participation in a Study is voluntary, and Participants may opt-out of (withdraw from) any Study at any time.  
• Selection of Participants may be based on automated decision-making regarding demographics, attitudes, and behavioral information you provide.  
• Brado will collect only as much PII as we need for a Study and will obtain your written consent to do so. We analyze the data to give our clients a summary that includes a synthesis of findings, recommendations, and presentations. Final reports include only anonymized, aggregated, and de-identified data.  
• Brado endeavors to collect, store, process, and utilize data from Participants in accordance with Applicable Law. Brado adheres to the laws, regulations, and industry codes of conduct of the locations in which we manage research.  
• Brado will only use PII for the purpose consented to and it will be deleted when that purpose is concluded pursuant to our data retention policy described herein. Brado will not sell or use PII for advertising or any other commercial purpose.  
• We take appropriate physical, technical, and organizational measures to protect your PII from loss, misuse, unauthorized access or disclosure, alteration, and destruction. However, no system is guaranteed to be secure from intrusion or hacking, and there is always risk assumed by sharing PII online. If you have reason to believe there has been a security breach, please notify us immediately at  InfoSec@brado.net. 
• We will address disagreements or concerns regarding potential misuse of data and resolve disputes in a timely manner.   

Exceptions or Special Circumstances 

Video recording of Studies, which include Participants’ personal likenesses and voice, may be shared with our clients, and may be retained after the Study is concluded, but shall not include other PII.  

Study Agreements with your signature shall be retained as required by Applicable Law, client agreements or industry standards. 

Healthcare Market Research 

Brado manages Studies in the healthcare and medical fields and, therefore, we often request information related to health, symptoms, medications, and treatments. If you mention an adverse event (for example, a negative reaction to a medication) or a product quality complaint, understand that Brado is obligated by FDA regulations to report it. We may ask additional details for evaluation. It is your right to provide additional details or to decline to do so. 

Research Involving Children 

If a Study involves children, we first require parent/guardian consent for the research and may require parent/guardian participation in the actual Study, as applicable to the laws of the jurisdiction. Otherwise, Brado does not knowingly solicit or collect PII from persons under 18 years of age. The Study Agreement requires a Participant to acknowledge they are at least 18 years old. 

Data Retention 

Your PII is stored only for as long as there is a need to fulfil the purposes for which the PII was collected. Mandatory legislation, such as bookkeeping, account keeping, or tax legislation, may require us to store some of your PII for longer periods.  

PII processed based on your consent will be deleted in the event of your withdrawal of your consent. 

How to Contact Us 

To contact us about any matter relating to privacy or your rights, please email InfoSec@brado.net or write to Brado Cuneo Nollau, LLC, 900 Spruce St., St. Louis, MO, USA; Attention: Privacy Officer. We will respond to your request within 30 days of receipt. 

In the communication, you must reference the name and date of the Study, your full name, email address and the recruiter’s company name. We may require additional information and documents, including PII, to authenticate and validate your identity and to process your request. We will retain such additional data for legal purposes. 

We may only process requests with respect to the PII associated with the email address that sent the request.  

If you believe that our processing of your PII does not correspond to what we have described in this Privacy Policy, or otherwise breaches applicable personal data legislation, you are welcome to contact us. If you reside in a country or are a citizen of a country that is a part of the European Union or European Economic Area, you may, as an alternative, complain to the Data Protection Authority in your country. 

Compelled Disclosure 

We reserve the right to disclose your PII if required by law or if we believe use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or comply with a law, court order, or legal process. 

Changes to this Policy 

We may update this Privacy Policy from time to time to reflect changes to our business practices. We encourage you to periodically review this page for the latest information on our privacy practices to ensure they still meet your approval. 

This Privacy Policy is not a contract and does not create any legal rights or obligations.