Code of Conduct

Effective Date: September 3, 2020

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 Grow Progress Platform must respect the customs, rules, and practices that apply to our industry, some of which are described in this Code of Conduct.
Protection of Human Rights. Customers shall protect the human rights of its employees and comply with all Applicable Laws, as well as all ethical standards applicable in the countries in which they operate.Corruption and Bribery. Our Customers shall not engage in corruption, extortion, embezzlement, money laundering, or bribery.Child Labor and Forced Labor. Customers shall prohibit and refrain from child labor within their organizations.

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 or answer questions using vulgar, abusive, or inappropriate language or content.Fundraise, advertise, or make solicitations.Ask or answer leading questions that are intended to coach, guide, or bias specific responses.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.