Privacy Policy


Lucid Holdings, LLC

Lucid Holdings, LLC Privacy Policy

Effective Date: November 1, 2017

Your privacy is important to us. As a result, we’ve developed this Privacy Policy that provides a description of how we collect, use, disclose, transfer, and store your information, as well as your choices regarding use, access and of your personal information. This Privacy Policy does not apply to data that we collect through other means, including data that we collect offline via web or mobile sites on which we do not post this Privacy Policy. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

I. Introduction & Notice

a. Introduction
Lucid Holdings, LLC, Lucid Holdings International Limited, Lucid Holdings UK Limited, and Lucid Holdings India Private Limited (“Lucid”) is committed to ensuring the privacy of those customers who use the Lucid website (“Clients or Suppliers” or “you”) and to individuals who provide responses to sample, sample panel or survey questions (“Respondents” or “you”)  brokered, accessed by, hosted on or otherwise provided to Clients or Suppliers on or through the websites owned, maintained or licensed by Lucid, including but not limited to: including at http://luc.id, http://labs.lucidhq.com/, https://partners.lucidhq.com, and http://www.samplicio.us. (collectively the “Sites”). This Privacy Policy (“Policy”) describes what information is collected from Clients or Suppliers and Respondents and how that information is used and disclosed. By using the Sites, you consent to the terms of this Policy. This Privacy Policy was created to demonstrate our commitment to fair information practices. Our policies and procedures address applicable U.S. and international privacy requirements concerning the collection, use, and cross-border transfer of personal data.

As described more fully below, Lucid participates in and has certified its compliance with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland, respectively. Lucid has certified that it 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.

To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

IF YOU DO NOT AGREE WITH THE TERMS IN THIS PRIVACY POLICY, DO NOT USE THE SERVICES AND SITES. CONTINUED USE OF THE SERVICES AND SITES CONSTITUES YOUR FREELY GIVEN SPECIFIC AND INFORMED CONSENT AND AGREEMENT TO YOUR PERSONAL DATA BEING PROCESSED PURSUANT TO THIS POLICY

b. Definitions

  • The terms “we”, “our”, and “us” in this Privacy Policy refer to Lucid delivering the services and products herein.
  • “You” means the individual to whom any given Personal Data covered by this Privacy Policy refers.
  • “Personal Data” and “Personal Information” means any information relating to an individual that can be used to identify that individual either on its own or in combination with other readily available data.

c. Regulatory Oversight
For this Privacy Policy and its content, Lucid is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If Lucid becomes subject to an FTC or court order based on non-compliance with this policy or EU-U.S. and Swiss-U.S. Privacy Shield frameworks, Lucid shall make public any relevant Privacy Shield related sections of any compliance or assessment report submitted to the FTC, to the extent consistent with confidentiality requirements.

II. Collection of Personal Information

a. Usage and Browsing Information Your Devices Transmits
You can visit most of our Sites without registering or actively submitting personal data to us. If you do not register, general technical user data, such as your device’s Internet Protocol (IP) address, operating system and browser type, and the date and time of your visit, may be automatically collected through the use of “cookies” (small files that are stored on your computer by a website to give you a unique identification) or other technologies. Cookies also keep track of services you have used, record registration information regarding your login name and password, ensure you do not repeatedly see survey questions, record your preferences and keep you logged into the Lucid Site.

b. Information You Actively Submit
If you register on our Sites on behalf of a corporate customer (e.g., a client or supplier of market research sample) or if you sign up for our newsletter, you will provide contact information such as your name, email address, mailing address and company affiliation. If you use our Sites to provide responses to sample, sample panel or survey questions, you will provide demographic information about yourself and answer questions at your choice. In each such case, you know what information you provide and we collect, because you will actively submit the information.

c. Combination
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 to answer demographic questions about yourself in preparation for your completion of surveys, and web publishers, advertisers and online service providers that may have obtained information from you or your devices via cookies, pixles,  and other tracking technologies).

d. Business Information
We do collect employee contact names, addresses, phone numbers and email addresses of our business partners, including buyers, suppliers and vendors, for the administration our business relationships. If you feel that your personal data or personally identifiable information is being collected inappropriately, please notify us at privacy@luc.id.

e. Cookie Opt-Out
If you do not wish to participate in any of Lucid’s online measurement and research services, please click here to receive an opt-out cookie. Lucid’s platforms and systems are cookie based, so for the opt-out to work for you, your browser must allow third party cookies.

f. Information Tracking Technologies
We may use, and 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 Sites or if an email has been read. Web beacons collect the IP address of the device that the web beacon is sent to, the URL of the page the web beacon comes from and the time it was viewed. Web beacons may be linked to your personal information. We may also use third-party devices, links or electronic mail, to deliver surveys to you. These third-party surveys or devices may use cookies, web beacons or other technology to collect information about your visits to our Sites (or other sites) in order to present surveys that may be of interest to you. We may collect traffic information and data on and from the use of third parties sites. Lucid 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 at a granular level and market research effectiveness. Respondents or participants in survey or survey panels that are hosted on, accessed by or routed through the Sites 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 Self- Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. (http://www.networkadvertising.org/choices/) and (http://www.aboutads.info/choices/).

g. Do Not Track
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our website is not currently set up to respond to those signals for tracking on our website.

III. Purpose & Use of Collected Personal Information

We use your information to operate, evaluate and improve our business (including developing new products and services; enhancing and improving our 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 as well as inform you about new products and services (unless and until you opt-out of marketing information).

If you come to our Sites as a “Respondent” to qualify for or take surveys, we use the demographic information you provide to make your survey answers more meaningful to us and our clients. We may also use information derived from cookies, pixels and other technologies to determine your interests in particular surveys, advertisements and other communications.

IV. Information Retention & Accuracy

We take reasonable steps to ensure that personal information we receive, process, or maintain is accurate, complete, and reliable for its intended use. 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.

V. Sharing of Personal Information and Accountability for Onward Transfer

Information associated with your name we share only as follows:

With your consent.

  • We use affiliated and unaffiliated service providers all over the world that help us deliver our service and run our business subject to confidentiality agreements.
  • We will disclose data as required by law including to meet national security requirements or to protect you, other users, us or third parties from harm, including fraud, data security breaches or where someone’s physical safety seems at risk.
  • In a reorganization or sale of our company or assets, your data may be transferred, subject to the acquirer accepting the commitments made in this Privacy 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).

Also, we freely share aggregated usage statistics that cannot be used to identify you individually.

We share randomized, aggregated demographic information about our users with third parties. This information is not linked to any personal information and cannot identify any individual person.

Lucid may also disclose your Personal Information to any other third party with your prior consent. Additionally, Lucid may share your Personal Information, without your prior consent, for the limited purposes noted below:

When Lucid does share your Personal Information with third party service providers and/or subprocessors, Lucid will:

  1. transfer such data only for limited and specified purposes;
  2. ascertain that the subprocessor is obligated to provide at least the same level of privacy protection as is required by these Principles;
  3. take reasonable and appropriate steps to ensure that the subprocessor effectively processes the Personal Information transferred in a manner consistent with the organization’s obligations under these Principles;
  4. require the subprocessor to notify Lucid if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by these Principles;
  5. upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and
  6. provide a summary or a representative copy of the relevant privacy provisions of its contract with that subprocessor to the Department of Commerce upon request.

Lucid shall remain liable under the EU-US Privacy Shield Principle of Accountability for Onward Transfer if its subprocessors process your Personal Information in a manner inconsistent with the Privacy Shield Principles, unless Lucid proves that it is not responsible for the event giving rise to the damage.

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.  In the case of data transfers from the EEA and Switzerland, the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks apply.

VI. Protection of Personal Information

Lucid 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, then we may attempt to notify you electronically so that you can take appropriate protective steps. Lucid may post a notice on the Lucid Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. 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.

VII. Limits to Your Privacy

Our Sites 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.

VIII. Choice Regarding Collection, Use & Distribution of Personal Information

You can choose to opt-out whether your Personal Information is (i) to be disclosed to a third party or (ii) to be 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 privacy@luc.id. In such an event, you will be only able to access public areas of the Sites and may be limited in the use of Lucid’s Sites. In certain cases, limiting the use and disclosure of your personal data may impact functionality or prevent the use of Lucid products or services.

IX. Access & Correction

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 have the right to access the Personal Information we hold about you.

You may also access your information that Lucid holds by contacting us at the address below. You have the right to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles, 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 Lucid by contacting us at:

Lucid Holdings, LLC
Attn: Chris Wheaton, Privacy & Compliance Counsel
365 Canal Street
Suite 700
New Orleans, LA 70130
United States of America
Email: privacy@luc.id

To protect your privacy and security, Lucid 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.

X. Contacting Lucid, Dispute Resolution, Arbitration & Cost

Lucid 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

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, Lucid 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 Lucid at:

Lucid Holdings, LLC
Attn: Chris Wheaton, Privacy & Compliance Counsel
365 Canal Street
Suite 700
New Orleans, LA 70130
United States of America
Email: privacy@luc.id

Lucid has further committed to refer unresolved privacy complaints under the EU-US 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 http://www.insightsassociation.org/get-support/privacy-shield-program/privacy-shield-eu-swiss-citizens-file-complaint for more information and to file a complaint. These dispute resolution services are provided at no cost to you.

If your complaint is not resolved after following the recourse mechanisms described above, you may have the ability to invoke binding arbitration. Additional information is available here.

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

Lucid Holdings, LLC
Attn: Chris Wheaton, Privacy & Compliance Counsel
365 Canal Street
Suite 700
New Orleans, LA 70130
United States of America
Email: privacy@luc.id

c. Mandatory Arbitration Agreement, Class-Action Waiver, and Jury Waiver
Any dispute with our business partners arising out of or in connection with this Privacy Policy and not satisfactory addressed by Lucid or Insights Association will be governed as to all matters, including, but not limited to the validity, construction and performance of this Agreement, by and under the laws of the State of New York, United States of America, without giving effect to conflicts of law principles thereof and excluding the U.N. Convention on the International Sale of Goods. (i) The Parties agree to maintain the confidential nature of all disputes and disagreements between them, including, but not limited to, informal negotiations, mediation or arbitration, except as may be necessary to prepare for or conduct these dispute resolution procedures or unless otherwise required by law or judicial decision. Except as provided in Section X.c (ii), each Party agrees that before it seeks mediation, arbitration, or any other form of legal relief, it shall provide written notice to the other of the specific issues in dispute (and referencing the specific portion of any contract between the Parties and which are allegedly being breached). Within thirty (30) days after such notice, knowledgeable executives of the Parties shall hold at least one meeting (in person or by video- or tele- conference) for the purpose of attempting in good faith to resolve the dispute. Except as provided in Section X.c (ii), any and all disputes, claims or controversies arising out of or relating to this Agreement shall be submitted to JAMS for mediation before arbitration or any other form of legal relief may be instituted. Mediation may be commenced by a Party providing JAMS a written request for mediation setting forth the subject of the dispute and the relief requested. The Parties will cooperate with JAMS in selecting a single mediator and scheduling a mediation, which should take place within forty-five (45) days following a request for mediation. The mediator shall be a retired judge who has had experience with technology disputes, but the mediator shall not have the authority to award punitive or exemplary damages. The Parties agree that they will participate in good faith and share equally in its costs. The mediation shall take place in New Orleans, Louisiana. (ii) The dispute resolution procedures in this Agreement shall not apply prior to a Party seeking a provisional remedy related to claims of misappropriation or ownership of intellectual property, trade secrets, or Confidential Information.

XI. Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy 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 by way of an email (sent to the email address associated with your account) or by means of a notice on this site prior to the change becoming effective. We will use information in accordance with the privacy policy under which the information was collected.

We use a self-assessment approach to address compliance with this Privacy Policy, verifying periodically that the policy is accurate, comprehensive, and addresses the privacy requirements applicable to the markets we serve. Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the confidentiality of information. These reviews are conducted by internal staff who report directly to our General Counsel.