Any questions concerning the material presented in this document can be addressed to the contacts listed below. General inquiries may also be submitted through the IRI privacy inbox, which can be found at Privacy@IRIworldwide.com

IRI’s Global Code of Conduct

IRI’s Information Security Policy

IRI’s GDPR Privacy Notice

Various internal policies and procedures

IRI assesses privacy implications while developing its products and services and incorporates appropriate privacy protections and data minimization techniques. IRI takes into account the privacy principles and regulations that may apply in a certain jurisdiction (for instance the GDPR in Europe) or by industry.

In many jurisdictions organizations are required to establish a lawful basis for their use of personal data. IRI has established different lawful bases for different types of processing. In almost all cases, IRI’s basis for processing personal data will be Legitimate Interest, Performance of a Contract, or Consent.

Legitimate Interests. IRI may process personal data based on a legitimate interest in performing market research or other marketing services because the benefits of improving services to existing clients and offering services to new clients would likely outweigh the risk of any harm.

Performance of a contract. Many of IRI’s services are engaged in on the basis of a contract. IRI’s clients engage us contractually in order to perform analytics, offer access to data through our platforms, and to manage CRMs and panels on the client’s behalf.

Consent. IRI typically acts as a data processor, or service provider, to organisations known as data controllers. IRI relies on consent obtained by the data controller because it has a direct relationship with the individual and obtains consent.

IRI is committed to complying with applicable laws regarding the collection of data about children.

IRI has invested in and implemented a series of controls to ensure that personal information is maintained according to our overarching principles of confidentiality, integrity, and availability. Personal Information is housed in physically and electronically secure facilities with protections against intrusion. Protections include extensive physical security, multiple layers of firewalls, and intrusion detection at the network and host level. Additionally, systems, servers and networks are encrypted to prevent loss or unauthorized modification of data.

In this section you can find out more about

• when we collect personal information
• the types of personal information we collect
• how we use personal information
• the legal basis for using personal information

We collect information about you if you:

• use our websites;
• do business with us as a representative of one of our customers or suppliers;
• apply for a position with IRI - in which case, you should refer to our separate privacy notices for applicants
• contact us with any form of query or complaint;
• visit an IRI office or site;
• subscribe to marketing communications from us; or attend an IRI event, collectively ("you").

When we do this, we act as a “Responsible Party” (referred to as a Data Controller in some other jurisdictions). We may also act as an "Operator" (referred to as a Data Processor in some other jurisdictions) under relevant data protection laws when we process personal information on behalf of our customers in providing services to them. In this case, we receive your information from our customer (or potentially a third party) that will be the relevant "Responsible Party".

If you have concerns or questions about our processing of your personal information in the contexts of IRI's services, you should contact our customer. Please note that if you contact us directly, we may need to disclose your request to the relevant customer.

Depending on the context in which we interact with you, the information we collect is likely to include:

• your name;
• your contact details;
• profile / log-in details;
• your marketing preferences;
• CCTV images or identification details (such as in a visitor signing-in book) which may be captured if you visit an IRI office or site;
• any other personal information you provide in correspondence with us, for example where this is relevant to a complaint or query.

Through your use of our websites, we will also collect information - such as IP address and browser generated information (browser type, operating system), as well as information about your browsing session. We do not use this information to identify you as an individual, but in order to tailor or enhance your browsing experience, or in aggregate with data of other users for statistical purposes.

IRI may also conduct online surveys, promotions, or contests for purposes of tracking customer satisfaction, Site usage and/or understanding industry trends and preferences and for other internal marketing purposes. As part of these offerings, IRI may collect personal information. These offerings are completely voluntary, and you may decline to participate; however, in such case, you will not be able to participate in the offering.
We collect information about you when you sign up as an IRI Shopper Panel member (including the In-House Panel), when you complete questionnaires as a IRI Shopper Panel member, and when you use your IRI Shopper Panel Scanner. We may also collect personal information about you through a third party, such as companies who provide lists of consumers, and telephone survey companies. The information we collect about you and your household in this context will only be used for market research purposes and to prepare reports to present to clients. The data will only be analyzed in aggregate. Our clients never see any single individual’s personal information.

We may disclose the information we collect about you and your household to third parties to outsource certain tasks, such as to companies who complete further data analysis, or for on-line surveys, as well as to our printing company, courier, gift supplier, the supplier and repairer of our IRI Shopper Panel Scanner or any other relevant service provider to us.
Where we do provide your information to third parties, we will take reasonable steps to ensure that your privacy is protected and we will regulate these relationships by written contracts.

If you are a Panelist, we use your contact details to mail you or email you our panel documentation including an annual demographic update and gifts. We contact you by email and/or phone if we are having technical issues concerning your IRI Shopper Panel Scanner or if we have not received any data from you. IRI or a nominated 3rd party may contact you by email to invite you to complete online surveys.

Except where required or permitted by law, we will not use your personal information for any purposes other than as set out in this notice, without your express consent.

IRI does not intentionally collect any personal information without a lawful legal basis.
This notice (together with our terms of use) sets out the basis on which any personal data IRI collects from or about you, or that you provide to IRI, will be processed.

IRI uses the personal information you provide for the purposes for which you specifically provided the information, for example to respond to your e-mail comments or requests for information, to process your Site registrations or user profiles and/or to make you eligible to participate in survey, promotion and contest offerings.

IRI may also use this information to better understand the needs and interests of the people and organizations that use the IRI website and to improve the content and functionality of the IRI website or to develop or enhance products or services. IRI may also use this information to contact you in the future regarding information on new or existing products, services, or events that IRI believes will be of interest to you.

IRI may also use the personal information to provide third parties with aggregated information, such as user base and usage patterns; however, IRI will not sell or otherwise disclose the personal information you provide to any third party outside of IRI and its affiliated and partner companies, or IRI respective agents or consultants who act for or on behalf of IRI under obligations of confidentiality.

In addition, IRI may share or transfer personal data to comply with legal requirements and laws, to establish or exercise IRI legal or property rights or defend against legal claims, or in the event of a corporate merger, acquisition, re-organization or similar event.

Your personal information will be used for the purposes listed in the table below. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. We have also described the legal bases which we rely in the table. The legal basis we rely upon will impact which rights you have in relation to your personal information (see section below for more details):

In this section you can find out more about how we share personal information:

• within IRI
• with third parties that help us provide our products and services; and
• our regulators; and other third parties.

We share your information in the manner and for the purposes described below:

• within IRI, where such disclosure is necessary to provide our customers with our services or to manage our business;
• with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These may include for example IT service providers who help manage our IT and back office systems, marketing automation providers and events companies;
• with regulators, such as data protection supervisory authorities, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
• we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers.
• If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

In this section you can find out more about

• how we use personal information to keep you up to date with our products and services.
• how you can manage your marketing preferences
• when and how we undertake profiling and analytics
• when and how we carry out automated decision making

We may use personal information to let you know about IRI products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

To protect privacy rights and to ensure you have control over how we manage marketing with you:

• we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
• you can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing, by following the 'unsubscribe' link you will find on all the email marketing messages we send you.
Alternatively you can contact us at Privacy@IRIworldwide.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (eg email); and
• you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser.
• We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your IRI account.

In this section you can find out more about:

• how we operate as a global business and transfer data internationally.
• the arrangements we have in place to protect your personal information if we transfer it overseas.

IRI operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside of South Africa under relevant data protection laws, including, countries that are subject to different standards of data protection. IRI will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:

• transfers to IRI in the United States are covered by all appropriate safeguards under POPIA including contractual mechanisms and/or supplementary measures surrounding the circumstances of the transfer;
• where we transfer your personal information outside IRI or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized appropriate safeguards or contractual mechanisms; or
• • where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.

You have a right to contact us at Privacy@IRIworldwide.com for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

In limited circumstances, transfers of your personal information may be based on context specific derogations which permit transfers in the absence of safeguards, such as where a transfer is necessary for the establishment, exercise or defence of legal claims.

Any questions concerning the material presented in this document can be addressed to the contacts listed below. General inquiries may also be submitted through the IRI privacy inbox, which can be found at Privacy.Officer@IRIWorldWide.com

IRI’s Global Code of Conduct

IRI’s Information Security Policy

IRI’s Privacy Shield Notice

IRI’s GDPR Privacy Notice

Various internal policies and procedures

IRI assesses privacy implications while developing its products and services and incorporates appropriate privacy protections and data minimization techniques. IRI takes into account the privacy principles and regulations that may apply in a certain jurisdiction (for instance the GDPR in Europe) or by industry.

In many jurisdictions organizations are required to establish a lawful basis for their use of personal data. IRI has established different lawful bases for different types of processing. In almost all cases, IRI’s basis for processing personal data will be Legitimate Interest, Performance of a Contract, or Consent.

Legitimate Interests. IRI may process personal data based on a legitimate interest in performing market research or other marketing services because the benefits of improving services to existing clients and offering services to new clients would likely outweigh the risk of any harm.

Performance of a contract. Many of IRI’s services are engaged in on the basis of a contract. IRI’s clients engage us contractually in order to perform analytics, offer access to data through our platforms, and to manage CRMs and panels on the client’s behalf.

Consent. IRI typically acts as a data processor, or service provider, to organisations known as data controllers. IRI relies on consent obtained by the data controller because it has a direct relationship with the individual and obtains consent.

IRI is committed to complying with applicable laws regarding the collection of data about children.

IRI has invested in and implemented a series of controls to ensure that personal information is maintained according to our overarching principles of confidentiality, integrity, and availability. Personal Information is housed in physically and electronically secure facilities with protections against intrusion. Protections include extensive physical security, multiple layers of firewalls, and intrusion detection at the network and host level. Additionally, systems, servers and networks are encrypted to prevent loss or unauthorized modification of data.

In this section you can find out more about

• the types of personal information we collect
• when we collect personal information
• how we use personal information
• the legal basis for using personal information

We collect information about you if you:

• use our websites;
• do business with us as a representative of one of our customers or suppliers;
• apply for a position with IRI - in which case, you should refer to our separate privacy notices for applicants
• contact us with any form of query or complaint;
• visit an IRI office or site;
• subscribe to marketing communications from us; or attend an IRI event, collectively ("you").

We also process personal information on behalf of our customers when we provide our services to them.

When we do this, we act as a "data processor" under relevant data protection laws, whilst our customer (or potentially a third party) will be the relevant "data controller". If you have concerns or questions about our processing of your personal information in the contexts of IRI's services, you should contact our customer. Please note that if you contact us directly, we may need to disclose your request to the relevant customer.

Depending on the context in which we interact with you, the information we collect is likely to include:

• your name;
• your contact details;
• profile / log-in details;
• your marketing preferences;
• CCTV images or identification details (such as in a visitor signing-in book) which may be captured if you visit an IRI office or site;
• any other personal information you provide in correspondence with us, for example where this is relevant to a complaint or query.

Through your use of our websites, we will also collect information - such as IP address and browser generated information (browser type, operating system), as well as information about your browsing session. We do not use this information to identify you as an individual, but in order to tailor or enhance your browsing experience, or in aggregate with data of other users for statistical purposes.

Your personal information will be used for the purposes listed in the table below. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. We have also described the legal bases which we rely in the table. The legal basis we rely upon will impact which rights you have in relation to your personal information (see section below for more details):

In this section you can find out more about how we share personal information:

• within IRI
• with third parties that help us provide our products and services; and
• our regulators; and other third parties.

We share your information in the manner and for the purposes described below:

• within IRI, where such disclosure is necessary to provide our customers with our services or to manage our business;
• with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include IT service providers who help manage our IT and back office systems, marketing automation providers and events companies;
• with our regulators, such as data protection supervisory authorities, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
• we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers.
• If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

In this section you can find out more about

• how we use personal information to keep you up to date with our products and services.
• how you can manage your marketing preferences
• when and how we undertake profiling and analytics
• when and how we carry out automated decision making

We may use personal information to let you know about IRI products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

To protect privacy rights and to ensure you have control over how we manage marketing with you:

• we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
• you can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing, by following the 'unsubscribe' link you will find on all the email marketing messages we send you.
Alternatively you can contact us at Privacy.Officer@IRIWorldWide.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (eg email); and
• you can change the way your browser manages cookies, which may be used to deliver online advertising, by following the settings on your browser.
• We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your IRI account.

In this section you can find out more about:

• how we operate as a global business and transfer data internationally.
• the arrangements we have in place to protect your personal information if we transfer it overseas.

IRI operates on a global basis. Accordingly, your personal information may be transferred and stored in countries outside of the EU, including in particular in the United States of America, that are subject to different standards of data protection. IRI will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.. To this end,:

• transfers to IRI in the United States are covered by the EU-US Privacy Shield Scheme. More information about our adherence to this scheme and the rights available to you under the Scheme can be found in our Privacy Shield Notice;
• where we transfer your personal information outside IRI or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield or contractual mechanisms such as the Standard Contractual Clauses; or
• where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed

You have a right to contact us at Privacy.Officer@IRIWorldWide.com for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.

In limited circumstances, transfers of your personal information may be based on context specific derogations which permit transfers in the absence of safeguards, such as where a transfer is necessary for the establishment, exercise or defense of legal claims

IRI’s services may involve processing personal data we receive from our client’s shopper loyalty programs, customer relationship management databases, and shopper survey panels. When IRI provides products or services for data analysis for our clients relating to shopper purchasing behaviour, the shopper data IRI receives is typically provided using a loyalty or other program identifier number, not a data subject’s name. That number is assigned a unique identifier. This process is called pseudonymization and is one of the most secure ways to separate sensitive elements from a personal data set.

When IRI provides CRM tools or provides Customer Data for use with CRM tools, we are typically processing data our customer has provided and instructed us to process on their behalf. If IRI manages a CRM directly, we are committed to protecting Data Subject rights.

IRI may also process personal data pursuant to various agreements with our clients. Our services may be deployed on-demand or on-site, and clients may also engage us for professional services and customer support. To fulfil our contractual obligations, IRI may access Customer Data to provide services, to correct and address technical or service problems, to follow instructions of the customer who submitted the data, or in response to contractual requirements.

When providing services to its business customers pursuant to contracts, IRI also collects personal data such as names, business titles, email addresses, and contact information login credentials, IP addresses, and information about how and when they use our services. IRI also has the personal data of its own employees.

IRI also processes employee data and the data of individuals who apply for employment with IRI. IRI must maintain the personal data of its employees in order to evaluate employee performance, process payroll, administer bonuses and process benefits claims. Third party vendors may be involved in these processes. For instance, IRI uses payroll software vendors in many countries, it uses the services of insurance companies to provide health and life benefits to its employees and it may provide retirement benefits through a third party.

IRI may store and process personal data in the United States or any other country in which IRI or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which we or our parent, subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

IRI may provide personal data to third parties and vendors that act as agents, business partners, consultants, and contractors to perform tasks on behalf of and under our instructions such as technical support, client education, billing, analytics, and communication. Such Third Parties must agree to use such personal data only for the purposes for which they have been engaged by IRI.

IRI recognizes potential liability in cases of onward transfer to third parties. IRI will not transfer any personal information to a third-party without first ensuring that the third-party adheres to the Privacy Shield principles.

IRI may be required to disclose Customer or HR Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

IRI employs procedural and technological measures that are reasonably designed to help protect Customer Data from loss, unauthorized access, disclosure, alteration, or destruction. For example, among other measures, we have implemented physical security measures at our premises (e.g., key cards) and we have established technical safeguards such as firewalls and security patches. However, despite our efforts, please be aware that no data security measures can guarantee security.

If you are an individual based in the EU or Switzerland and we process your personal data for our own purposes, you may request access to your personal data. You also have the right to update, correct or delete your personal data. Also, the Frameworks require that participants offer data subjects a choice to opt out of uses and disclosures of their data that are materially different from the purposes for which that data was originally collected or subsequently authorized. Individuals who would like to access their personal information may contact us via our website under the Privacy tab or by emailing IRI’s Data Protection Office at Privacy.Officer@IRIWorldWide.com.

Please note that IRI has limited ability to access data submitted by its customers to the IRI Products and does not have any personal relationship with the individuals whose personal data it processes on behalf of its customers. If you wish to request access to, correct or delete, or to limit the use or disclosure of your personnel data please provide us the name of the IRI customer who has submitted your data into the IRI Product. We will refer your request to that customer and will support our customer as needed in responding to your request.

IRI will cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to HR data transferred from the EU and Switzerland.

If you have any questions or concerns, please write to us at the address listed below. If you are an EEA or Swiss resident, we will investigate and attempt to resolve reasonable complaints and disputes regarding our use and disclosure of Personal Information in accordance with the Principles. If an issue cannot be resolved via our internal dispute resolution mechanism, EEA and Swiss individuals may contact or submit a complaint, at no cost, to JAMS, our US-based third party dispute resolution provider. To find out more, go to https://www.jamsadr.com/eu-usprivacy-shield.

The Federal Trade Commission (FTC) is the investigatory and enforcement authority for your IRI’s Privacy Shield certification. Under certain circumstances detailed in the Privacy Shield, Data Subjects may be able to select binding arbitration for the resolution of complaints. For more information on binding arbitration, see U.S. Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Changes to this Privacy Shield Policy. This Privacy Notice may be amended from time to time consistent with the requirements of the Privacy Shield.

If you have any questions about this Privacy Notice or would like to request access to your EU personal data, please contact us at Privacy.Officer@IRIWorldWide.com or by mail addressed to the following:

Information Resources, Inc.

Attn: Global Data Protection Officer
Legal Dept. 150 N Clinton St.
Chicago, IL 60661