Privacy Policy


Focus Project Research - Privacy Policy

What is the Focus Project? The Focus Project is an online behavioural and market research project involving the use of eye tracking technology to explore how individuals view and interact with online media (the “Research”). It is managed by Nectar Loyalty Limited (“Nectar”) in collaboration with Lumen Research Limited (“Lumen”) (collectively “the Focus Project Team”).
Individuals participating in the Research will be provided by Lumen with an eye tracking device and with software required for the collection of eye tracking and web browsing data. This data shall be collected by Lumen on an anonymous basis and will be treated in accordance with data protection laws and market research ethical guidelines. Your personal details will not be shared with any third parties without your consent.
This Privacy Policy describes the types of information collected, as well as how we use and disclose such information.

What consent am I giving to the use of data collected during the Research?
By installing the software and the eye tracking device, you consent to our collection, use and disclosure of your information as described in this Privacy Policy. However, while participating in the project, you can choose to turn the collection of data on or off at any time through the control panel in the Chrome web browser extension that will be installed when you get started. You can also withdraw your consent to our future collection of your information by contacting us using the information provided in the Contacting Us section of this Privacy Policy or by uninstalling the software and the eye tracking device. Withdrawal of your consent will not apply retroactively to information that was previously collected with your consent.

What information will be collected?
By participating in this research, we will collect and use information about you. This information includes:
• your registration details;
• information on your web-browsing undertaken within the Chrome browser (“Web-Browsing Data”). This data is only collected when the eye tracking software is turned on – as controlled by you;
• information on the content of your web-browsing (“Web-Browsing Content Data”). This data is only collected from a sub-set of ‘white-listed’ sites – see below;
• information on where your eyes are focusing on your screen when the eye tracking hardware and software is enabled (“Gaze Data”);
• information about your computer that can optimise the performance of our software including information about your browser, such as its name and version, as well as your operating system's name and version;
• your responses to specific surveys and activities administered as part of the project; and
• any other information that you give to use in participating in the research; (together "your information").

How will the data be collected?
Participation in the Research will require use, during your web-browsing, of a supplied eye tracking device. This device uses infra-red reflections to capture information about where your eyes are focusing on your computer screen over time. The device will need to be returned when you terminate your participation.
Participation will also require installation of Lumen’s software onto your desktop personal computer or laptop, (each, a “PC”). This software will enable Lumen to collect information related to internet browsing activity undertaken within the Chrome web browser on your PC by you or any other person, on an ongoing basis, for as long as the software remains installed and is turned on. You will be able to turn the data collection off at any time. The software also enables Lumen to associate the Gaze Data with your Web-Browsing Data (i.e., to see what you were looking at while you were browsing – see next question below).
Information on your internet browsing can only be collected when browsing is taking place within the Chrome web browser; information on browsing undertaken in any other web browser (e.g. Internet Explorer, Mozilla Firefox, Safari) will not be collected.

What information do you collect about web browsing?
Information is only collected about your web browsing when you are browsing in Chrome and when our software indicates that an eye tracking session is turned on. You have full control over the installed software and will be able to turn off any eyetracking session at any time.
The information collected about your web browsing depends on whether the website you are visiting is on a controlled ‘white list’ of predetermined sites. This list is available on request. Web-Browsing Data that may be collected during browsing on white-listed sites includes data about: o The URLs of the websites you visit, the time of your visit, the amount of time you spend on each page and the Gaze Data on displayed elements;
o Cookies that your browser receives, sends or stores;
o Undisplayed data associated with some specific elements on the screen (e.g., the source of a served advertisement);
o Your mouse movement and clicks on the web pages you visit; and
o Some of the content of your web-browsing (see next question below)
If the site you are visiting is not on the white list, no Web-Browsing Data is captured except information about the number of different pages visited and time spent on them. Online banking sites are not white-listed to prevent the collection of personal financial information.

What information do you collect about the content of my web browsing?
Information about the content of your Web-Browsing Content Data will only be collected from a controlled ‘white-list’ of predetermined sites.
On most white-listed sites, only the type of content that is on the page will be recorded and the eyetracking data associated with that content element (e.g. whether you were looking at a picture or a text box), but not the actual content (the specific image, or the actual text). This applies to social media and webmail sites so that your privacy is protected and data is not collected about the content of your emails or social media posts.
On a small sub-set of white-listed sites data will also be collected about the actual content of your web browsing. This is restricted to sites that are not deemed to contain any personal or sensitive data (e.g., news / information sites). Furthermore, content will never be collected from these sites whenever a “personal data identifier” is displayed (such as password entry fields or information that could indicate the presence of banking data). Content will also never be collected whenever any text is typed into any input field on the web page (e.g., a login box, a search bar, or any other data entry field).

What controls and protections do I have over the data collected?
To summarise the key points above, the following controls are in place to protect your privacy during your participation in the Research:
• You are able to turn off the collection of data in the Focus Project control panel at any time
• Data is only collected when you are browsing in Chrome, no data will be collected relating to any browsing carried out in any other web browser
• Information about the content of your web-browsing is only collected if you are visiting a site listed on a specified list of white-listed sites.
• On most white-listed sites information is only collected about the type of content viewed (eg, whether it is text), not the actual content (eg, not the actual text)
• On some sites actual content may be collected. This list of sites is also available on request. On these sites, Web-Browsing Content Data will not take place if “personally identifiable information” is displayed or if any information is typed into a text input field
• For visits to any sites that are not on the white list, only information about the number of different pages visited and time spent on them will be collected
• When visiting white-listed sites the ‘fp’ icon will be green and the lights on the eye-tracking device will be on. When visiting a non-white-listed site the ‘fp’ icon will be red and the lights on the eye-tracking device will be off
• Gaze Data and Web-Browsing Data collected will be stored anonymously (i.e. it will not be stored alongside any personal details – name, address, phone number etc).
• You are able to terminate your participation in the Focus Project at any time by emailing thefocusproject@loyalty.co.uk

How will your information be used?
Your information will be used to explore how individuals view and interact with online media. We may share the research data with our affiliated companies and with our business partners and clients. While the research data might be shared with our affiliates, partners and clients, it is only used anonymously and such affiliates, partners and clients use this data to create summary descriptions of a wide range of consumer behaviours and consumer segments to develop products or to provide marketing solutions to their customers or consumers.
We combine the information that we collect from your use of the software and the eye-tracker, and inferences that we draw from that information, with information we have collected from or about you or other members of your household in connection with you or your household’s participation in our online and offline research studies. We analyse and use your information for our research purposes at an aggregated level. We also use it to create reports for our clients. These reports do not identify you or any other person by name, address, telephone number, or other information that identifies you individually but may include information about your device usage and the operational information described above.

Why do you use cookies and what are these used for?
From time to time cookies may be used to carry out the Focus Project research and to make your experience better. A cookie is a piece of information which is transferred to the cookie file of the browser on your computer. The browser saves the information and sends it back to a website server whenever the browser returns to the website. Cookies may be deposited through your visits to particular websites or may be deposited directly by the Focus Project extension software. The purpose of any cookies deposited will be (i) to identify the state of your browsing device e.g., whether or not the eyetracking device is connected and currently in operation and (ii) to enable specific test content to be served to you during your Focus Project browsing session.

What is a cookie?
A cookie is a piece of information which a website transfers to the cookie file of the browser on your computer. The browser saves the information and sends it back to the website server whenever the browser returns to the website. A cookie will typically contain the name of the domain (internet location) from which the cookie has come, the "lifetime" of the cookie (i.e. when does it expire), and a value, usually a randomly generated unique number. Cookies may be deposited through your visits to particular websites or may be deposited directly by the Focus Project extension software. We use the following four types of cookies:
• Session cookies which are temporary cookies that remain in the cookie file of your browser until you leave the site. We use session cookies to:
o Enable you to securely login and connect to our services
• Persistent cookies which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). We use persistent cookies to:
o Enable you to securely login and connect to our services - using the "Remember me" option
• First & Third party Advertising cookies which are used to help us and other sites serve adverts to you on this and other sites that are likely to be of interest to you or relevant to a specific task requested of you in that Focus Project browsing session
• First & Third party Analytics cookies which are used to analyse your usage of browsing the internet
You can opt out of third party advertising cookies by visiting: http://www.youronlinechoices.com/uk/opt-out-help

How do I know my personal information is safe?
The information will be analysed in aggregate, and will not be attributed to you individually. Personal information won’t be collected via the software or the eye tracking device. Your contact details will be shared with Lumen, no other personally identifiable information that you give to us via the research will be shared with third parties.
The data collected by Lumen is encrypted using Secure Sockets Layer SSL technology. This is a commonly used high standard of encryption technology.

How we use and disclose information we collect?
We may disclose the information we collect from and about you to our third party service providers, to enable them to provide services to us. We may also disclose such information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). We may also use or disclose the information we collect from and about you as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our end user license agreement; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Security
We take reasonable steps to protect your information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Only our authorized employees and agents who require access to your personal information in order to fulfill their job requirements will have access to your personal information.

Retention period
Any of your personal information that we collect will be retained for the period necessary to fulfill the purposes outlined.

Will this Privacy Policy change over time?
We may change this Privacy Policy from time to time. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. We will notify you of any changes to the privacy policy before they become effective and will post the revised Privacy Policy on the Focus Project website www.focusproject.co.uk/.
Your acceptance and continued use of software following these changes constitutes an acknowledgement by you of such revisions and an agreement by you to abide by and be bound by the revised Privacy Policy. Any material change to this Privacy Policy shall not apply retroactively to any claim or dispute between you and us in connection with this Privacy Policy where such claim arose prior to the date on which the Privacy Policy was revised to include such material change.

Contacting us
If you have any questions regarding the Privacy Policy please contact us at thefocusproject@loyalty.co.uk
We are Nectar Loyalty Ltd, a company registered in England under number 4224736. Our registered office is at 6th Floor, 80 Strand, London, WC2R 0NN. Our data protection notification number is Z6913653.
Lumen Research Ltd is a company registered in England, company number 8682432. Its registered office is at Unit 320, 22 Highbury Grove, London N5 2EF. Its data protection registration reference is ZA130772.
We protect your information, our business depends on it.