Privacy Policy

Research Shield™ ("we", "us", "our") respects your privacy. This Privacy Policy explains what data we collect, how we use it, and what rights you have.

1. Who We Are

Research Shield™ is a data quality assurance system for market research. We help research companies verify the authenticity of survey responses.

Data Controller:
TGM Research Pte. Ltd.
6001 Beach Road, #22-01 Golden Mile Tower
Singapore 199589
privacy@researchshield.com

Data Protection Officer:
Marcin Kaleta
privacy@tgmpanel.com
Postal correspondence: use the address above with notation "Data Protection Officer"

EU Representative (Art. 27 GDPR):
TGM Research Europe
[Address in EU Member State]
eu-representative@researchshield.com

UK Representative (UK GDPR Art. 27):
TGM Research UK
[Address in United Kingdom]
uk-representative@researchshield.com

2. What Data We Collect

2.1 Technical Data

• IP address and approximate geographic location
• Browser and device type
• Operating system
• Screen resolution
• Time zone
• Device identifier (fingerprint)

2.2 Behavioral Data

For fraud detection purposes, we collect and analyze:

• Mouse movements, clicks, and scrolling — cursor trajectory across the page, click locations and timing, scroll speed and direction
• Typing rhythm and keystroke dynamics — the speed, rhythm, pauses, and timing between individual keystrokes
• Time spent on each question — how long you spend reading and answering each survey question
• Navigation patterns within the survey — how you move between questions, form fields, and pages
• Browser window focus and tab switching — when you switch away from the survey tab, minimize the window, or lose focus

This data is used to create a fraud risk score through automated analysis (profiling). See Section 7 for details on profiling and automated decision-making, including your rights.

2.3 Survey Data

• Responses provided in the survey
• Session identifier

We do not collect: names, email addresses, or other directly identifying information unless they are part of the survey commissioned by the client.

3. Why We Process Data

Legitimate Interest Assessment

We have conducted a formal Legitimate Interest Assessment (LIA) for behavioral data processing. Our assessment concluded:

• Purpose: Protecting the integrity of market research data by detecting fraudulent, bot-generated, or low-quality responses
• Necessity: Behavioral analysis is necessary because traditional methods (CAPTCHA, IP blocking) are insufficient against sophisticated fraud
• Balancing: We acknowledge that behavioral biometrics processing is privacy-intrusive. We mitigate this through data minimization (90-day raw data retention), pseudonymization, no cross-purpose use, and transparency
• Your right to object: You may object to this processing at any time (see Section 7.5)

A summary of our LIA is available upon request by contacting privacy@researchshield.com.

Processing Operations Chain: Legal Basis per Operation

Our fraud detection involves multiple sequential processing operations. The entire fraud detection chain is based on our legitimate interest in fraud prevention (Art. 6(1)(f), Recital 47). Below is the complete chain as required by EDPB Guidelines 2/2019:

4. Who We Share Data With

4.1 Research Clients

Survey responses and data quality information are shared with the company commissioning the research.

4.2 Sub-Processors and Their Roles

We use the following technical service providers to deliver our fraud detection service. For each, we disclose what data is shared, how they process it, and their legal role under GDPR.

Amazon Web Services (AWS)

FingerprintJS, Inc.

Art. 26 Arrangement Summary: FingerprintJS acts as joint controller for the purpose of improving their device identification technology. We remain responsible for collecting device signals and for decisions about individual fraud assessments. FingerprintJS is responsible for the aggregated model improvement. You may exercise your rights with either party.

IPQualityScore (IPQS)

Art. 26 Arrangement Summary: IPQS acts as joint controller for maintaining their fraud reputation database. We query their database with IP addresses; they use this data (alongside queries from other customers) to improve fraud detection accuracy across their network. We remain responsible for how we use IPQS scores in our fraud assessments. You may exercise your rights with either party.

Sentry (Functional Software, Inc.)

4.3 International Data Transfers

Some personal data is transferred to countries outside the European Economic Area (EEA), particularly the United States. We ensure appropriate safeguards for such transfers:

Transfer Impact Assessments (TIA)

In accordance with the Schrems II ruling (C-311/18), we have conducted Transfer Impact Assessments for each US recipient. These assessments evaluate:

• The legal framework in the recipient country
• The nature of data transferred (pseudonymized technical/behavioral data)
• Likelihood of access by public authorities
• Effectiveness of supplementary measures

TIA Conclusion: Given the technical nature of data (device fingerprints, behavioral patterns), pseudonymization, encryption, and the limited personal identifiability, the risk of harm from potential government access is assessed as low. Supplementary measures provide effective protection.

Supplementary Measures

Standard Contractual Clauses (SCCs) are legal contracts approved by the European Commission (Decision 2021/914) that bind data recipients to protect personal data to EU standards. We implement the following supplementary measures for all US transfers:

• Technical: Encryption of data in transit (TLS 1.3) and at rest (AES-256)
• Technical: Pseudonymization of personal identifiers before transfer
• Organizational: Access controls and audit logging
• Organizational: Data Processing Agreements (DPAs) with all sub-processors
• Contractual: Notification obligations if recipient receives government access requests

Adequacy Decision Contingency

If the EU-US Data Privacy Framework adequacy decision is invalidated (as occurred with Safe Harbor and Privacy Shield), we will rely on Standard Contractual Clauses as the transfer mechanism. SCCs are already in place with all US recipients as a fallback safeguard. We monitor regulatory developments and will implement additional measures as required.

You may request a copy of the relevant SCCs or TIA summaries by contacting privacy@researchshield.com.

4.4 No Advertising or Marketing Use

We do not use your data for advertising, marketing profiling, or any purpose unrelated to fraud detection. Specifically:

• We do not sell your personal data
• We do not share data with advertising networks
• We do not create marketing profiles
• We do not use data for targeted advertising
• We do not share data with social media platforms for advertising

4.5 Other Disclosures

We may disclose data when required by law, court order, or law enforcement authorities.

5. How Long We Keep Data

We apply tiered retention periods based on the data minimization principle. Each category is retained only as long as necessary for its specific purpose:

5.1 Fraud Detection Data (Research Shield™)

After each retention period, data is automatically deleted or irreversibly anonymized. Raw behavioral data is converted to derived fraud indicators before deletion.

5.2 Survey Response Data

Your survey responses are controlled by the research client who commissioned the survey, not by Research Shield™. Retention of survey response data is determined by the research client's data retention policy.

• Typical retention: Research clients typically retain survey response data for 12-36 months depending on the research project
• Who to contact: For questions about survey response data retention, contact the organization that invited you to participate in the survey, or the panel provider if you are a panel member
• Research Shield™ role: We only process survey responses transiently to deliver them to the research client; we do not retain survey response content after delivery

6. Your Rights

Under GDPR, you have the following rights:

• Access - you can obtain information about processed data
• Rectification - you can correct inaccurate data
• Erasure - you can request deletion of data ("right to be forgotten")
• Restriction - you can request limitation of data processing
• Portability - you can receive data in a machine-readable format
• Objection - you can object to processing based on legitimate interest

Granular Objection Rights

You may object to specific aspects of our processing. After survey completion, you can object to:

• Continued retention of your data — we will delete your data upon valid objection
• Cross-session use of device fingerprints — we will remove your device from our duplicate detection database
• ML training use — we will exclude your data from machine learning model improvement

Such objections will be assessed individually and can be honored without affecting your past survey participation. See Section 7.4 for the full objection process.

How to Exercise Your Rights

You can exercise your rights in two ways:

• Online: Visit our Data Rights page for detailed instructions and options
• Email: Send a request to privacy@researchshield.com

We will respond within 30 days.

How We Identify You (Verification Process)

Research Shield™ does not collect names or email addresses unless they are part of the survey itself. This means we cannot directly identify you from your name alone. To exercise your data protection rights, we need information that helps us locate your data in our systems.

What information helps us find your data:

If you participated via a research panel:

The easiest path is to contact your panel provider first. They have your account information and can:

1. Identify which surveys you completed that used Research Shield™
2. Provide you with session IDs for those surveys
3. Forward your data rights request to us on your behalf

If you participated via an open link (social media, advertisement):

Contact us directly at privacy@researchshield.com with as much of the following as you can provide:

• Approximate date and time of participation
• Survey topic or subject matter
• How you found the survey (which platform, ad, link)
• Device and browser you used
• Your approximate location at the time

We will make reasonable efforts to locate your data based on this information. If we cannot identify your data with reasonable certainty, we will explain why and suggest additional information that might help.

GDPR Art. 11 Notice

Under GDPR Art. 11, if we are unable to identify you, we are not required to maintain, acquire, or process additional information solely to identify you. However, if you provide information that enables identification, we will process your request fully.

Complaint to Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, particularly in the EU/EEA Member State of your habitual residence, place of work, or place of the alleged infringement.

Lead Supervisory Authority

As TGM Research Pte. Ltd. is established in Singapore, there is no "lead supervisory authority" under the GDPR one-stop-shop mechanism. However:

• Singapore: Personal Data Protection Commission (PDPC) — pdpc.gov.sg

EU/EEA Supervisory Authorities

EU/EEA residents may contact their local data protection authority:

• Poland: Urząd Ochrony Danych Osobowych (UODO) — uodo.gov.pl
• Germany: Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) — bfdi.bund.de
• France: Commission Nationale de l'Informatique et des Libertés (CNIL) — cnil.fr
• Other EU/EEA: Find your authority at edpb.europa.eu/members

UK Supervisory Authority

• United Kingdom: Information Commissioner's Office (ICO) — ico.org.uk

7. Fraud Detection, Profiling, and Automated Decision-Making

7.1 How Fraud Detection Works

Our fraud detection involves a chain of processing operations (see the Processing Operations Chain in Section 3 for the full mapping). All fraud detection processing is based on our legitimate interest (Art. 6(1)(f)) in preventing fraud. In summary:

1. We collect behavioral signals (typing patterns, mouse movements, device fingerprint) during your survey session
2. We analyze those signals through fraud detection algorithms to generate a fraud risk score
3. We make an automated decision: if your fraud risk score falls below the quality threshold configured by the research client, your response is automatically disqualified — Art. 22 GDPR applies at this step
4. Consequence: disqualification may result in denial of survey compensation and exclusion of your response from the research dataset

The legal basis for all steps above is legitimate interest in fraud prevention (Art. 6(1)(f), Recital 47). We do not rely on contract performance (Art. 6(1)(b)) for fraud detection — see the explanation in Section 3.

7.2 Profiling and Automated Decision-Making (GDPR Art. 4(4) and Art. 22)

Profiling (Art. 4(4))

Our fraud detection processing constitutes profiling within the meaning of GDPR Art. 4(4). We use automated processing of your personal data — specifically, your behavioral patterns (typing rhythm, mouse movements, response timing) and device characteristics — to evaluate aspects relating to you, namely the likelihood that your survey response is fraudulent. This evaluation produces a fraud risk score that is used to make decisions about your response.

Automated Decision-Making (Art. 22(1))

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (Art. 22(1)).

Step 3 of our processing chain constitutes automated decision-making, including profiling, under Art. 22(1). The system automatically evaluates responses based on quality criteria configured by the research client. Responses below the configured threshold are disqualified, which affects your survey compensation. This is a decision based solely on automated processing, including profiling, that "similarly significantly affects" you within the meaning of Art. 22(1).

Exception Applied: Explicit Consent (Art. 22(2)(c))

This automated decision is permitted based on your explicit consent:

• Before you begin the survey, you are informed that automated fraud detection will be used and that responses below the quality threshold will be automatically disqualified
• You are asked to provide explicit consent to this automated decision-making before proceeding
• If you do not consent, you may choose not to participate in the survey

Why explicit consent and not contract performance?

EDPB Guidelines 2/2019 require that Art. 6(1)(b) (and by extension Art. 22(2)(a)) reflect objective necessity from the data subject's perspective. Fraud detection serves TGM and its research clients — it protects data integrity for the benefit of the research industry. While this is a legitimate and important purpose, it is not objectively necessary for the respondent's core contract (answering questions and receiving compensation). We therefore rely on explicit consent (Art. 22(2)(c)) as the more transparent and appropriate basis for the automated decision layer.

Your consent rights

• Withdrawal: You may withdraw your consent to automated decision-making at any time by contacting privacy@researchshield.com. If you withdraw consent after completing a survey, you may request human review of any automated decision made about your response
• No penalty: Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal
• Alternative: If you do not consent to automated decision-making, you may choose not to participate. We acknowledge this limits your choice; however, the nature of real-time survey fraud detection makes a non-automated alternative impractical during the survey session itself

Note: The collection and analysis steps (Steps 1–2) are not themselves automated decisions under Art. 22 — they are preparatory processing under legitimate interest (Art. 6(1)(f)). Your consent under Art. 22(2)(c) is specifically for the automated decision (Step 3) and its consequences (Step 4).

7.3 Your Rights Under Art. 22(3) — Safeguards

Regardless of the legal basis for the automated decision, you have the following safeguards. These rights are enforceable and are implemented through a concrete process described below.

Your rights:

• Obtain reasons for disqualification: If your response was disqualified, you have the right to know the specific fraud signals that triggered the decision, the categories of data involved, and the score assigned to your response
• Request human review: Request that a qualified human reviewer — not the automated system — re-evaluates the decision about your response
• Express your point of view: Provide additional context or explanation that the automated system may not have considered
• Contest the decision: Challenge the disqualification and receive a reasoned response explaining the outcome

How the process works:

1. Contact us directly at privacy@researchshield.com — you do not need to go through the research client or panel provider
2. Within 7 days: We acknowledge your request and provide a reference number
3. Within 21 days: A human reviewer re-evaluates your response, considering the automated signals, any context you provide, and whether alternative legitimate explanations exist
4. Within 30 days: We notify you of the outcome with a reasoned explanation

If the decision is overturned:

If human review determines that your response was incorrectly disqualified, we will reinstate your response (where possible), notify the research client, and use reasonable efforts to ensure any compensation you were entitled to is restored. We will also review the automated system's parameters to prevent similar false positives.

During the review period:

Your data is retained to enable the review. The original disqualification remains in effect until the review is completed. If overturned, compensation is addressed retroactively.

Full details of the human review process and remedy are set out in our Terms of Use, Sections 5.7–5.8.

7.4 Additional Safeguards

• Transparency: We disclose the existence and logic of automated processing in this policy
• No sensitive data: We do not use special category data (Art. 9) in fraud analysis
• Accuracy obligation: Our system is regularly tested and calibrated to minimize false positives
• Human review available: You may request human review of any automated decision at any time, whether or not you consented to automated processing

7.5 Right to Object (Art. 21)

Under GDPR Art. 21, you have the right to object to processing based on legitimate interest. We assess each objection on a case-by-case basis, considering your specific situation and grounds for objection.

Types of Objection We Distinguish:

How to Object

Send your objection to privacy@researchshield.com with:

• A description of which processing you object to
• Your grounds for objection (your particular situation)
• Any identifiers that help us locate your data (session ID, date of participation)

Our Assessment Process

We will:

1. Acknowledge your objection within 7 days
2. Assess your specific grounds against our legitimate interests
3. Provide a reasoned response within 30 days
4. If we reject your objection, explain our compelling grounds
5. Inform you of your right to complain to a supervisory authority

7.6 Relationship Between Participation and Objection

We do not operate on a "take-it-or-leave-it" basis. However, we are transparent about practical consequences:

• Before participation: If you object to all fraud detection processing, participation may not be possible as fraud detection is integral to the service
• During participation: Real-time analysis occurs automatically; objection at this stage is impractical but you retain post-session rights
• After participation: Objection to retention, profiling, and ML training can be fully honored without affecting your past participation

Your right to object is genuine and subject to individual assessment, not a pre-determined outcome.

8. Cookies and Similar Technologies

Research Shield™ uses cookies, local storage, and similar technologies on the survey pages you interact with. These technologies are essential to delivering, securing, and protecting the integrity of the survey experience. We do not use any marketing, advertising, or cross-context behavioral tracking cookies.

8.1 What Are Cookies?

Cookies are small text files placed on your device by the websites you visit. Local storage and session storage serve similar functions but are stored differently in your browser. We use these technologies for three purposes: operating the survey, detecting fraud, and monitoring technical errors.

8.2 Essential Cookies

These cookies are strictly necessary for the survey to function. They do not require your consent under Art. 5(3) of the ePrivacy Directive because the survey cannot operate without them.

8.3 Fraud Detection Cookies and Technologies

Research Shield™ uses device identification technology provided by FingerprintJS, Inc. to detect fraudulent survey responses (bots, duplicate submissions, automated scripts). These technologies are integral to the fraud prevention service described in Section 7 of this Privacy Policy. We classify them as necessary for the provision of the fraud detection service that forms part of the survey experience, as described in our Terms of Use.

8.3.1 Cookies

8.3.2 Local Storage

8.3.3 Session Storage

8.4 Browser APIs for Device Fingerprinting

Our fraud detection system (via FingerprintJS) accesses the following browser APIs to generate device identifiers:

8.5 Third-Party Services

The following external services receive data from the survey page but do not set their own cookies on your device:

Data transfers to US-based providers are protected by Standard Contractual Clauses (SCCs) and/or the EU-US Data Privacy Framework, as described in Section 4 of this Privacy Policy.

8.6 Your Choices

Because our cookies are used exclusively for survey operation and fraud prevention (not for marketing or advertising), we do not display a cookie consent banner. However, you can control cookies through your browser settings.

Please note: Blocking or deleting fraud detection cookies may result in your survey response being flagged or rejected, as the system may be unable to verify the authenticity of your session.

Your right to object: You have the right to object to fraud detection processing under GDPR Art. 21. If you object before participation, we will cease processing, but this means your survey session cannot continue. After participation, you may object to continued data retention, cross-session profiling, and ML training use — these objections can be honored without affecting your past participation. See Section 7.5 for the full objection framework.

8.7 Legal Basis for Cookies

9. Children

Our services are not intended for children. The minimum age for participation varies by jurisdiction:

We do not knowingly collect data from individuals below the applicable age threshold in their jurisdiction. If you believe we have inadvertently collected data from a child, please contact us immediately at privacy@researchshield.com.

10. Information for United States Residents

10.1 Categories of Personal Information Collected

Under US state privacy laws (including CCPA/CPRA), we collect the following categories:

10.2 How We Use and Disclose Information

• Business purpose: Fraud detection, data quality assurance
• Sale of data: We do not sell your personal information
• Sharing for advertising: We do not share your data for cross-context behavioral advertising

10.3 Your Rights (California, Virginia, Colorado, Connecticut, Utah)

Depending on your state, you may have the right to:

• Know what personal information we collect
• Access your personal information
• Delete your personal information
• Correct inaccurate information
• Opt-out of sale/sharing (not applicable - we don't sell data)
• Non-discrimination for exercising your rights

10.4 How to Exercise Your Rights

Submit a request to: privacy@researchshield.com

We will verify your identity and respond within 45 days (or as required by applicable law).

10.5 Authorized Agents

You may designate an authorized agent to submit requests on your behalf with written permission.

10.6 Do Not Track

We do not respond to "Do Not Track" browser signals as there is no industry standard for this feature. However, our tracking is limited to fraud detection purposes only.

11. Policy Changes

We will notify of significant changes by updating the date at the beginning of this document. We encourage periodic review of this Policy.

12. Contact

For privacy-related questions, please contact:

Email: privacy@researchshield.com
Address: TGM Research Pte. Ltd., 6001 Beach Road, #22-01 Golden Mile Tower, Singapore 199589

Last updated: February 6, 2026