Grow Progress Platform Code of Conduct

1. Grow Progress Platform Standards.

Grow Progress, Inc. (“Grow Progress”) operates the Grow Progress Platform (“Platform”). Grow Progress grants access to the Platform for conducting Opinion Measurement.These standards are incorporated by reference into all contracts between Grow Progress and Customers, except where the parties to a contract expressly agree on derogations or other terms. These standards do not create any rights or obligations for Grow Progress or any Customer except when incorporated into a particular contract by reference. When incorporated into a particular contract, these standards create rights and duties only for the contracting parties and no beneficiary rights for any third parties. If there are inconsistencies with this Code of Conduct and stricter provisions within another written agreement, the stricter provisions will control.

Capitalized terms used throughout this Code have the same meanings as the same terms defined in Grow Progress’s Terms and Conditions.

2. Ethical Standards.

Customers engaged with the Platform may not use it to conduct research that directly conflicts with Grow Progress’ mission as a Public Benefit Corporation. Specific restrictions are described below:

1. Consumer Deception. Customers shall not conduct research on the Platform in support of unfair, deceptive, or abusive practices towards consumers.
2. Worker Protection. Customers shall not conduct research on the Platform that directly or indirectly discourages workers from organizing or participating in a union. Customers shall not conduct research on the Platform in support of reducing worker rights, benefits, or wages.
3. Incitement of Violence. Customers shall not conduct research on the Platform in support of the incitement of violence, including the sale of guns or weapons.
4. Incitement of Hate. Customers shall not conduct research on the Platform in support of individuals, organizations, or ideologies identified as extremist by the Southern Poverty Law Center. 
5. Discrimination. Customers shall not conduct research on the Platform in support of stereotyping, discrimination or glorifying abuse against people based on characteristics like race, ethnicity, national origin, religion, disability, disease, age, sexual orientation, gender, or gender identity.
6. Anti-Democracy Rhetoric. Customers shall not conduct research on the Platform in support of authoritarianism or the erosion of democratic or voting rights.
7. Bodily Autonomy. Customers shall not conduct research on the Platform to restrict the human right of bodily autonomy, including access to birth control, safe and legal abortion care, gender-affirming care, and physician-assisted death.
8. Information disorder. Customers shall not conduct research on the platform for the promotion of, or recruitment for, narratives that lack a basis in empirical fact and are widely recognized as misinformation by the scientific, academic, and journalistic communities. This includes, but is not limited to:
   • Denial of Established Historical Events. Narratives that deny or grossly distort documented historical facts (e.g., Holocaust denial or “false flag” claims regarding mass tragedies).
   • Public Health Misinformation. Promoting theories that undermine established medical science, such as anti-vaccination myths or “planned” pandemic narratives.
   • Identity-Based Malice. Theories that attribute malevolent global influence to specific racial, religious, or ethnic groups (e.g., “The Great Replacement” theory).
   • Subversion of Democratic Legitimacy. Narratives that claim election results or institutional processes are systematically fraudulent without evidence.
   • Scientific Denialism. The active promotion of theories that contradict fundamental physical laws or global consensus (e.g., Flat Earth or the denial of human-accelerated climate change)
9. Foreign Governments. Customers shall not conduct research on the Platform in support of advocacy within the United States directed or sponsored by any government outside of the United States. Customers may not act on behalf of any person or entity located or organized in Russia, China, Cuba, Sudan, Iran, North Korea, Syria, the Crimea region of Ukraine, or any other country or region that is subject to comprehensive U.S. economic sanctions. Customers may not act on behalf of any person or entity identified on the Specially Designated Nationals and Consolidated Sanctions List administered by the Office of Foreign Assets Control or with whom U.S. persons are otherwise prohibited from transacting.

At any time, Grow Progress reserves the right to change the Code or to disallow research on certain subjects or to terminate relationships with notice, at no financial penalty.

3. Children and Minors.

Customers must obtain verifiable parental consent for the collection of any data collected from minors and children, as required by Applicable Laws. If Customers exclude minors from Opinion Measurements, they must ask about birth dates in neutral ways (e.g., “when is your birthday?”) and not in ways that could induce minors to overstate their age (e.g., “are you 18 or older?”). If a Customer knows a minor completed a survey, the Customer must confirm and verify parental consent in accordance with the Applicable Laws protecting such minor.

Minors cannot act as Customers on the Grow Progress Platform. Grow Progress contractually obligates Customers to comply with parental consent requirements under Applicable Law, and Grow Progress does not allow minors under the age of 13 to complete Opinion Measurements.

4. Data Privacy Law Compliance.

Customers are responsible for compliance with data privacy laws that apply to their collection and use of data via the Grow Progress Platform or Survey Question Platforms. Customers must determine whether they need to obtain consent under Applicable Laws (often, a conspicuous and easy-to-understand opt-in notice is sufficient and more appropriate where Respondents actively volunteer data).

Grow Progress collects data on behalf of Customers for purposes of performing Grow Progress’s contractual obligations. Customers’ instructions to Grow Progress for the processing of Personal Data shall comply with Data Protection Laws and Regulations.

Personally Identifiable Information (PII), as generally defined under data privacy laws in the United States, is prohibited within the Grow Progress Platform.

5. Data Residency or Localization.

Customers are responsible for compliance with data residency and localization laws that require certain categories of data collected from individuals in such jurisdictions must be processed on primary systems in such countries. This may require additional technical steps in the context of the data collection, but does not typically preclude use of the Grow Progress Platform, because data residency or localization laws do not entirely prohibit a transfer of redacted survey responses, aggregated data (statistics), or a copy of an individual record so long as the original data processing occurs locally within the jurisdiction. Grow Progress operates the Grow Progress Platform on servers in the United States and does not maintain local presences outside the United States to satisfy data residency or localization requirements.

6. Data Security.

Customers are responsible for compliance with applicable data security laws and must meet or exceed the following technical and organizational data protection measures that Grow Progress applies to its operation of the Grow Progress Platform:

• Security Access Control: Implement suitable measures in order to prevent unauthorized persons from gaining access to data processing equipment and premises; limit access to employees and service providers with a legitimate need to know and subject to adequate written confidentiality and data security agreements.
• Transmission Control: Implement SSL for Internet transmissions and other measures to reduce the risk that data is read, copied, altered or deleted by unauthorized parties during the transmission thereof or during the transport of the data media.
• Data Handling: Have adequate security protection, procedures and protocols in place to ensure data is used, stored, maintained, protected, transferred, deleted or archived, as necessary and required by Applicable Laws.
• Data Access, Correction, and Deletion: Disclose, correct, delete, or redact data on request from data subjects, where required by Applicable Laws.

7. Restrictions Applicable to Customers.

Processing of PII is prohibited on the Grow Progress Platform. Customers shall not create custom questions on the Grow Progress Platform intended to derive answers containing PII or other sensitive data.

On the Grow Progress Platform, Customers shall not:

• Share User IDs, passwords, and/or API keys with any unauthorized third party.
• Use survey farms, bots, or scrapers for any purpose.
• Ask questions or test message content that use vulgar, abusive, or inappropriate language or content.
• Leverage tests for purposes outside of research such as to directly fundraise, advertise, or make solicitations to participants.
• Ask or answer leading questions that are intended to coach, guide, or bias specific responses instead of quality research.
• Use copyrights, trademarks, or any other intellectual property without proper ownership or license.
• Download, submit, or otherwise save sensitive content on the Grow Progress Platform. Sensitive content includes survey content of an offensive or especially personal nature.
• Ask or answer questions about sensitive content in ways that do not conform with industry guidelines or Applicable Laws.
• Ask or answer questions about sensitive financial information, including but not limited to, bank account and credit cards, and government-issued identification numbers.
• Ask minors to answer questions without obtaining parental consent, as defined under Applicable Laws.
• Solicit Respondents to take fraudulent or otherwise illegal surveys.

Failure to adhere to these restrictions shall be considered a material breach of the terms and conditions between Grow Progress and its Customers.