Insights Platform Privacy Policy

Last Updated: January 31, 2020

This privacy policy (“Policy”) is posted by Innovate MR, LLC (“we,” “us,” or “Innovate”), and governs uses of Innovate’s Insights Platform (“Platform”) f/k/a Pegasus. We’ve developed this Privacy Policy to describe (1) how we collect, use, transfer, and store information of individuals who provide responses to sample, sample panel, or survey questions (“you” or “Respondents”); (2) your choices regarding your personal information; and (3) how we ensure the privacy of customers who use Platform (“you,” or “Clients or Suppliers”).

This Privacy Policy only applies to the Platform website (the “Site”), and to the data that we collect through the Platform. It does not apply to any data that we collect via sites where this Privacy Policy is not posted.

We make the Site, including this Policy, accessible to individuals with disabilities. If you are having trouble accessing the Site or this Policy, please contact us as provided below.

By using the Platform and/or the Site, you consent to the terms of this Policy, WHICH FORMS A BINDING AGREEMENT BETWEEN YOU AND INNOVATE. If you do not agree with the terms in this Policy, do not use the Platform or the Site. Continued use of the Platform and the Site constitutes your freely given, specific, and informed consent and agreement to the collection and use of your personal information.

Collection of Personal Information

Innovate conforms its privacy and security practices to applicable laws, codes, and regulations, including, without limitation, the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

As used in this Policy, “personal data” and “personal information” mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular data subject, consumer, or household. Personal information includes information such as real names, postal addresses, email addresses, and social security numbers.

Under CCPA’s broad definition, “personal information” may also include unique identifiers, IP addresses, biometric information, internet or other network activity (such as browsing history,search history, etc.), geolocation data, audio/visual data, and even inferences which may be drawn from any of the above to create a profile about a consumer.

We use your information to operate, evaluate, and improve our business, including for such purposes as developing new products and services, managing our communications, and analyzing our products. If you provide us with your name and contact information, we will use this information to answer requests from you, communicate with you regarding any services we are providing to you, and inform you about new products and services (unless and until you opt-out of marketing information). We may also use information derived from cookies, pixels, and other technologies to determine your interests in our products and services.

Any e-mail communications to you regarding new products and services, or any email updates, newsletters, or other communications to which you’ve subscribed, will contain a link with instructions for how to opt out of future communications of that type.

In the previous 12 months, we’ve collected, used, and shared personal information as described below:

Info CollectedSources of InfoBusiness PurposesShared With
Personal information such as name, email addressProvided directly via the Site, or direct communications with InnovateIncentive fulfillment, communicating with you; newsletters; advertising new offeringsThird-party service providers
Log files, including Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, plug-in etc.Collected directly from online usersAnalyzing web traffic and survey usage, optimizing survey platforms for different operating systems and analyzing authenticity of respondentThird-party service providers
Browsing information, such as date and time you visited our website, number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or other research programCollected from internet cookies attached to users while visiting website.Site optimization for different operating systems. User optimization for survey participation and future researchThird-party service providers
Mailing Address, Phone NumberProvided directly via the site or in direct communications with InnovateAuthenticity verification; in home usage testsThird-party service providers

Notice to Survey Respondents

We do not sell your personal information.

Name, email address, phone number
Log files, including Internet Protocol (IP) address, browser type, ISP, browser language, the date and time of your request, operating system, referring/exiting pages, clickstream data, plug-in etc.
Browsing information, such as date and time you visited our website, number of pages you viewed, time in seconds you spend on each page, and details of the any website you visited before and/or after participation in one of our surveys or other research program
Mailing address, phone numbers

If you are a California resident, you also have the following special rights:

Your Right to “Know” and to Request Deletion

You have the right to know the categories and specific pieces of personal information we have collected about you. You have the right to know the categories of sources from which the personal information has been collected, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.

You have the right to request deletion of personal information we’ve collected or maintain.

To exercise these rights contact us at (+1) 888-229-6664 or by filling out the following webform. We may ask you to provide additional information, such as first and last name and email in order to verify who is making the request.

Please note that any requested disclosures will only apply to the 12-month period preceding the request, and you are entitled to request disclosure regarding your personal information twice in any 12-month period.

Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment by Innovate for the exercise of the privacy rights conferred by the CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please understand, however, that certain exercises of your rights may render it impossible for us to render services to you.

Your Right to Use an Authorized Agent

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided below. In order to verify you have authorized an agent we will require a signed, written authorization from you.

Verification Process

If you make a request to access or delete your information, or to opt out of the sale of your personal information, we may ask you for additional information to verify your identity. This information may include: your full name, birth date, phone number, email address, or other basic personal information about you that we already have on file.


We may combine information that your device transmits, information that you actively submit, and information that we obtain from third party sources, including suppliers of market research sample and data marketing platforms that may direct you to our Site, as well as web publishers, advertisers, and online service providers that may have obtained information from you or your devices via cookies, pixels, and other tracking technologies.

Information Tracking Technologies

We may use or allow third parties to use web beacons on our Site to monitor the effectiveness of survey qualification. Web beacons are small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Site or if an email has been read. Web beacons collect the IP address of the device where the web beacon is sent, the URL of the page where the web beacon originates, and the time it was viewed. Web beacons may be linked to your personal information. We may also use third-party devices, services, links, or electronic mail to deliver surveys to you, which may use cookies, web beacons, or other technology to collect information about your visits to our Site (or other sites) in order to present surveys that may be of interest to you.

We may use a pixel or cookie to examine what is happening on third-party websites, including programs and sites with marketing and advertising partners, to improve the understanding of site traffic and market research effectiveness. Respondents or participants in survey or survey panels that are hosted on, accessed by, or routed through the Site should consult the privacy and other policies of third parties through whom they are providing information.

You can opt out of receiving interest-based ads and tracking from third parties who are members of the Network Advertising Initiative (“NAI”) or who follow the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website.

Do Not Track

Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will treat any “do not sell” or similar signals as opt-out requests under CCPA.

Use of Cookies

For more information on our use of cookies, read Innovate’s Cookie Policy, which is incorporated herein by this reference.

Information Retention & Accuracy

We make efforts to ensure that personal information we receive, process, or maintain is accurate, complete, and reliable. We rely on the accuracy of the information provided directly to us but accept responsibility for the management and confidentiality of the personal information collected. In general, we keep personal information only as long as we need it to provide you the services you requested. We may also process data on behalf of third parties who have engaged us. We keep personal information processed on behalf of third parties for as long as needed to provide services to third party in question. However, we reserve the right to retain personal information for any period required by law or to comply with our legal obligations, resolve disputes, and enforce our agreements.

Sharing of Information with Third Parties, Onward Transfer

We may share information associated with your name as follows: (i) with your consent; (ii) with service providers who help deliver our services and run our business, subject to confidentiality agreements; (iii) as required by law including for national security purposes; (iv) to protect you, our business, or third parties from harm, including but not limited to fraud and data security breaches; (v) in a reorganization or sale of our company or assets, subject to the acquirer accepting the commitments made in this Policy and in compliance with applicable law.

Additionally, we share information that is not associated with your name with our clients for purposes of their market research (for example, survey responses plus demographic information about you, but without your name). We also share aggregated usage statistics that cannot be used to identify you individually, as well as randomized, aggregated demographic information about our users. This information is not linked to any personal information and cannot identify any individual person.

If we share your personal data with third party service providers and/or sub-processors, we will: (i) transfer such data only for limited and specified purposes; (ii) require the sub-processor to provide at least the same level of privacy protection as is required by this Policy; (iii) take reasonable and appropriate steps to ensure that the sub-processor effectively processes the personal data transferred in a manner consistent with the organization’s obligations under this Policy; (iv) require the sub-processor to notify us if it determines it can no longer meet its obligation to provide the same level of protection as is required by this Policy; (v) upon notice, take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a copy of the relevant privacy provisions of its contract with that sub-processor to the Department of Commerce upon request.

Innovate complies with the EU-U.S. and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, under the enforcement authority of the Federal Trade Commission, regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Innovate has certified that it adheres to the Privacy Shield Principle of Accountability for Onward Transfer if its sub-processors process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove we are not responsible for the event giving rise to the damage. To learn more about the Privacy Shield program, and to view our certification page, please visit

If you are visiting this website from a country other than the country in which our servers are located, your communications with us will result in the transfer of information across international boundaries. By visiting this website and communicating electronically with us, you consent to such cross-border transfers.

Protection of Personal Information​

Innovate uses reasonable security measures in an effort to prevent loss, misuse, and alteration of information under our control. However, we cannot guarantee the security of information on or transmitted via the Internet. We rely on various security procedures and systems to ensure the secure storage and transmission of data, including encryption and authentication technology licensed from third parties, to effect secure transmission of confidential information. Additionally, we have absolutely no control over the security of other sites you might visit, interact with, or do business with.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps, by posting a notice on the Site if a security and/or sending an email to you at the email address you have previously provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach, or to withdraw your consent from receiving electronic notice, you should notify us.

The Site may contain links to external websites, and areas where you can provide information to third-parties. These are provided for your convenience only, and we do not have control over the content or privacy and security practices and policies of such third parties or third-party sites. Any personal information you provide in such areas, and on such linked pages, is provided directly to that third party and is subject to that third party’s privacy policy. Please learn about the privacy and security practices and policies of external websites and third-parties before providing them with personal information.

Choice Regarding Collection, Use & Distribution of Personal Information

You can choose whether your personal information is (i) disclosed to a third party or (ii) used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. If you choose to opt out, please contact us via email at In such an event, you will be only able to access public areas of the Site and may be limited in the use of the Site. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of Innovate products or services.

Access & Correction

You have the right to access the personal information we hold about you. If you register as a buyer or supplier, you can update, correct, or delete your user information and email subscription preferences by going to the log-in section of our Site.

You may also access your information by contacting us at the address below. You have the right to correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.

We maintain processes or mechanisms to allow you to review, update, correct or delete personal information held by us. You may make changes to your account information, access, correct, or delete personal information held by Innovate by contacting us at:

Innovate MR, LLC
Attn: Platform Privacy Policy Support
23975 Park Sorrento Unit 210
Calabasas CA 91302

To protect your privacy and security, Innovate may also take reasonable steps to verify your identity before making corrections to or deleting your information. We will respond to your request for access to modify or delete your information within a reasonable timeframe.

Contacting Innovate, Dispute Resolution, Class Action Waiver

Innovate will address all questions, complaints or requests concerning this Privacy Policy within 45 days of receipt. Please see the applicable details below:

a. EU & Swiss Citizens. Innovate MR, LLC adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Innovate commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Innovate at:

Innovate MR, LLC
Attn: Platform Privacy Policy Support
23975 Park Sorrento, Unit 210, Calabasas CA 91302

Innovate has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to the INSIGHTS ASSOCIATION PRIVACY SHIELD PROGRAM, a non-profit alternative dispute resolution provider located in the United States and operated by the Insights Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. These dispute resolution services are provided at no cost to you. Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel.

b. Non-EU/Non-Swiss Citizens. Innovate commits to resolve complaints about your privacy and our collection or use of your personal information. Non-EU/Non-Swiss citizens with inquiries or complaints regarding this Policy should contact Innovate at:

Innovate MR, LLC
Attn: Platform Privacy Policy Support
23975 Park Sorrento, Unit 210
Calabasas CA 91302

c. Dispute Resolution. All disputes arising under this Policy shall be governed by and interpreted in accordance with the laws of California, without regard to principles of conflict of laws. The parties to this Policy will submit all disputes arising under this agreement to arbitration in Los Angeles, California, before a single arbitrator of the American Arbitration Association (“AAA”). The arbitrator shall be selected by application of the rules of the AAA, or by mutual agreement of the parties, except that such arbitrator shall be an attorney admitted to practice law California. No party to this Policy will challenge the jurisdiction or venue provisions as provided in this section. No party to this Policy will challenge the jurisdiction or venue provisions as provided in this section. Nothing contained herein shall prevent the party from obtaining an injunction.

d. Class Action Waiver. Any arbitration or court trial, whether before a judge or jury or pursuant to judicial reference, related to any claim under this Policy will take place on an individual basis, without resort to any form of class or representative action (“Class Action Waiver”). THIS CLASS ACTION WAIVER PRECLUDES ANY PARTY FROM PARTICIPATING IN OR BEING REPRESENTED IN ANY CLASS OR REPRESENTATIVE ACTION REGARDING A CLAIM UNDER THIS POLICY. Regardless of anything else herein, the validity and effect of the Class Action Waiver may be determined only by a court and not by an arbitrator.

Changes to Privacy Policy

We reserve the right to modify this Policy at any time. If we decide to change our Policy, we will prominently post those changes here and any other place we deem appropriate, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make any material changes, we will notify you either by way of an email or by a notice on this Site. We will use information in accordance with the Policy as it was in effect at the time information was collected.