Enlightly and Attest are services created by Attest Technologies Limited, a company
registered in England and Wales, with company number 09445883, whose registered office
address and main business address are at Attest Technologies Limited, c/o Attest, 1 Fore
Street, London, EC2Y 9DT, United Kingdom
(“Enlightly”, “Attest”, “we”, “us”, or “our”).
via Enlightly, Attest, and other Attest Survey tools made available to you via the Attest
Service at enlight.ly, askattest.com, and any other website or application from which we
make Attest's survey tools available from time to time (together “the Attest Service”).
Attest is a data controller for the purposes of the Data Protection Act 1998 (“DPA”) in
respect of the data it gathers from you and other users of the Attest Service.
We take the privacy of your personal information and “Personal Data” and “Sensitive
Personal Data” (each as defined by the DPA) very seriously. We are committed to protecting
and respecting your privacy.
This policy (together with our Terms and any other documents referred to on the Attest
Service) sets out the basis on which any Personal Data and Sensitive Personal Data we
gather from you, or that you provide to us, will be processed by us. Please read the
following carefully to understand our practices regarding your Personal Data and how we
will treat it. By using the Attest Service and by registering your details with us, you consent
to us gathering and processing Personal Data and Sensitive Personal Data supplied by you in
If you have any requests concerning your personal information or any queries with regard to
these practices please contact us by e-mail at email@example.com or firstname.lastname@example.org.
Please note the Attest Service is not intended for use by individuals of under 13 years of age.
and, where required, notified to you by e-mail.
Attest is registered under the 1998 Data Protection Act, registration number ZA120737.
Information Gathered from you
The Attest Service is used by “Survey Makers” (people who create and conduct surveys of
one or more questions (“Surveys”)) and “Survey Respondents”
(people who respond to those Surveys).
Each completed Survey submitted by a Survey Respondent is a “Survey Response”.
The information we receive from Survey Makers and Survey Respondents and how we handle it differs,
Survey Respondent Terms and Conditions if you are a Survey Respondent (each, the “Terms”),
as they collectively form our Agreement with you (as defined in the Terms).
We also gather information automatically about your visit to the Attest Service. This
information, which includes demographic data and browsing patterns, is gathered via the
We gather the following information from Survey Makers:
Account information. You need an account with us (a “Survey Maker Account”)
before you can create Surveys on Attest. When you register for an account, we
gather your email address (as your username) and password. With your permission,
Attest will also gather various other Personal Data, Sensitive Personal Data and
other information relating to your background that helps to open new Survey
Opportunities to you, “Boost” your rewards, and which can help Survey
Opportunities to be targeted to people like you. This information will be stored
Billing information. All payments made through the Attest Service are administered
by Stripe, PayPal and other third party payment services selected by us. All such
transactions will be governed by the privacy policies maintained by each third party.
We do not have access to any debit or credit card numbers or information.
However, we will gather the details of the transactions carried out through the
Attest Services, such as value of payments and frequency of payments, but without
viewing your billing information directly.
Account settings. You can set various preferences and personal details on pages like
your Survey Respondent or Survey Maker account settings page. For example, you
can opt in or out of receiving marketing emails from Attest by updating the settings
in your Survey Maker Account.
Survey data. We store your Survey data (questions and responses) for you.
Other data you intentionally share. We may gather your personal information or
Personal Data if you submit it to us in other contexts. For example, if you contact us,
we may keep a record of that correspondence.
We gather the following information from Survey Respondents: We gather and store the
Survey Responses (which will include any Personal Data that you have provided in such
Survey Responses) that you submit via the Attest Service. The Survey Maker is responsible
for this data and manages it. A Survey may ask you to provide Personal Data. The Attest
service also allows Survey Makers to undertake Survey “Targeting” based on Survey
Respondent profile information, such as “send Survey to males, in UK, 25-40”. If you have
any questions about a Survey you are taking, or the use of Personal Data gathered through
the Attest Service, please contact us at email@example.com or firstname.lastname@example.org .
We also gather the following types of data from Survey Respondents and Survey Makers:
Usage data. We gather anonymous usage data whenever you interact with the
Attest Service. This may include which webpages you visit, what you click on, how
long you spend on the Attest Service, when you performed those actions, and so on.
Our web servers also keep log files that record data each time a device accesses
those servers. The log files contain data about the nature of each access, including
originating IP addresses. Note that we do not link this usage data to Survey
Responses or any way that would identify individual users. Details of your visits to
the Attest Service include, but are not limited to, traffic data, location data, weblogs
and other communication data, and the resources that you access.
Device data. We will also gather anonymous data about the device and application
you use to access the Attest service, such as your device model, IP address and
browser type. We may also infer your geographic location based on your IP address.
We gather this data to enhance creation of Surveys by Survey Makers (e.g., allowing
Survey Makers to send Surveys to particular models of mobile devices ? for example:
iPhone 6 users ? to understand those users in particular).
Cookies. We use third party tracking services that employ cookies and page tags
(also known as web beacons) to gather aggregated and anonymised data about
visitors to the Attest Services. This data includes usage and user statistics.
Your email address. For the purposes of creating and maintaining your Attest account,
we will use the email address you provide in your Attest Service account with information about the Attest Service.
Beyond this, your email address will never be shown to other users of the Attest System.
To ensure compliance with legal requirements,
it is not possible to opt out from receiving necessary legal information and updates
about the Attest Service that Attest is required to send from time to time.
We may also send you marketing information to this email address,
Use of personal information
We use Personal Data gathered via the Attest Service:
to provide you with the Attest Service;
to ensure that content from the Attest Service is presented in the most effective
manner for you and for your computer or other device;
to carry out our obligations arising from any contracts entered into between you
to allow you to participate in interactive features of the Attest Service, when you
choose to do so;
to notify you about changes to the Attest Service;
to monitor, maintain, and improve the Attest Service and its features. We internally
perform statistical and other analysis on information we gather (including usage
data, device data, question and response data and information from cookies) to
analyse and measure user behaviour and trends, to understand how people use the
Attest Service, and to monitor and improve the Attest Service, including to help us
evaluate or devise new features. We may use your information for internal purposes
designed to keep the Attest Service secure and operational, such as for testing
purposes, and for service improvement, marketing, research and development
to enforce our Terms with you and to prevent abuses or violations of those Terms
to facilitate account creation and the log-in process;
to contact you for marketing purposes (for example, opportunities to participate in
future market research opportunities) but only if you have consented to our
contacting you for this purpose. For example, during the account registration
process we will ask for your permission to use your information to contact you for
marketing purposes. If you do not want us to use your Personal Data in this way, or
to pass your details on to third parties for marketing purposes, please tick the
relevant box situated on the form or page on which we gather your data. You may
opt out of these communications at any time by clicking on the “unsubscribe” link in
them, or changing the relevant setting in your account;
for re-marketing purposes (as explained in the 'Cookies' section below); and
to contact you via email about service-related announcements, billing-related
matters, changes to the Attest Service or policies, or other service or administrative-
related matters. Please note that you cannot opt-out of such communications.
To whom do we disclose your information?
We may disclose:
Your information as required or permitted by law, or when we believe that
disclosure is necessary to protect our rights, and/or to comply with a judicial
proceeding, court order, subpoena, or other legal process served on us from a court
of competition jurisdiction. This may include exchanging information with other
companies and organisations for the purposes of fraud protection and credit risk
reduction, and may require us to transfer your Personal Data outside of the
European Economic Area (“EEA”).
Your information if there's a change in business ownership or structure. If
ownership of all or substantially all of our business changes, or we undertake a
corporate reorganisation (including a merger or consolidation) or any other action or
transfer between Attest entities, you expressly consent to Attest transferring your
information to the new owner or successor entity so that we can continue providing
the Attest Service. If required, Attest will notify the applicable data protection
agency in each jurisdiction of such a transfer in accordance with the notification
procedures under applicable data protection laws.
Aggregated and non-identifiable information to third parties to improve or promote the Attest Service.
No individuals can reasonably be identified or linked to any part of the information we share with third
parties to improve or promote the Attest Service.
Your information to our service providers. We use service providers who help us to
provide you with the Attest Service. We give relevant persons working for some of
these providers access to limited aspects of your information, but only to the extent
necessary for them to perform their services for us. We also implement reasonable
contractual and technical protections to ensure the confidentiality of your personal
information and data is maintained, used only for the provision of their services to
include payment processors, hosting services, email service providers, and web
traffic analytics tools.
Your email address to your organisation. If the email address under which you've
registered your account belongs to or is controlled by an organisation, we may
disclose that email address to that organisation in order to help it understand who
associated with that organisation uses the Attest Service. (Please do not use a work
email address for the Attest Service unless you are authorised to do so, and are
therefore comfortable with this disclosure.)
If you are a Survey Respondent, we will anonymously disclose the content you provide in
your Survey Responses to Survey Makers. We host Surveys and Survey Responses for Survey
Makers, but Survey Makers determine how to use the content associated with your
anonymous Survey Responses. Anything you choose to disclose in your Survey responses will
be available to them. Again, you never need to provide data you don't want to; simply press
“Skip” if you prefer not to answer any question.
helps us to provide you with a good experience when you browse the Attest Service and also
allows us to improve the Attest service.
We may gather information about your computer or other device, including, where
available, your IP address, operating system and browser type, for system administration
and to report aggregate information to our advertisers. This is statistical data about our
users' browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using
a cookie file which is stored on the hard drive of your computer. Cookies contain information
that is transferred to your computer's hard drive. They help us to improve the Attest Service
and to deliver a better and more personalised service. They enable us:
to estimate our audience size and usage pattern;
to store information about your preferences, and so allow us to customise the Attest
Service according to your individual interests;
to speed up your searches;
to show you reminders, prompts, promotions and adverts for the Attest Service
during your general internet usage (this is called 'remarketing'); and
to recognise you when you return to the Attest Service.
You may refuse to accept cookies by activating the setting on your browser which allows you
to refuse the setting of cookies. However, if you select this setting you may be unable to
access certain parts of the Attest Service. Unless you have adjusted your browser setting so
If you would like more information about cookies, such as what cookies do and how you can
disable them, the ICO has a helpful guide here.
Use of session files
We use session files, along with cookies, to log your browsing patterns and so identify the
areas of the site which have been of interest to you, allowing us to personalise the Attest
Service for you.
We also use information in aggregate form (in other words, no individual user is identified) to:
to allow us to develop the business in ways that help you;
to manage our relationship with advertisers;
to audit usage of the Attest Service.
Your control over the use of your Personal Data
update your registration and other account information on your account page;
access and correct your personal information in your account by visiting your
account page. This right is subject to some exceptions, such as where giving you
access would have an unreasonable impact on the privacy of other individuals;
cancel or delete your account. To cancel and delete your account, please visit your
profile page on the Attest Service. Deleting your account will cause all Personal Data
in the account to be permanently deleted from your profile within a reasonable time
period, as permitted by law, and will disable your access to the Attest Service.
Survey Results will remain available to Attest, but only on an anonymous basis. We
will respond to any such request, and any appropriate request to access, correct,
update or delete your personal information within the time period specified by law
(if applicable) or without excessive delay. We will promptly fulfil requests to fully
delete Personal Data unless the request is not technically feasible or such data is
required to be retained by law (in which case we will block access to such data, if
required by law).
The Attest Service links to other web sites and we are not responsible for the content on
those sites or their data policies and procedures.
Where we store your data
Your data is stored through service agreements with Amazon Web Services EC2. The data
that we gather from you may be transferred to, and stored at, a destination outside the EEA.
It may also be processed by staff operating outside the EEA who work for us or for one of
our suppliers. Such staff may be engaged in, among other things, the processing of your
payment details and the provision of support services. By submitting your Personal Data,
you agree to this transfer, storing or processing. We will take all steps reasonably necessary
All information you provide to us is stored on our (or our third party) secure servers. Any
payment transactions will be encrypted. Where we have given you (or where you have
chosen) a password which enables you to access certain parts of the Attest Service, you are
responsible for keeping this password confidential. We ask you not to share a password
Unfortunately, the transmission of information via the internet is not completely secure.
Although we will do our best to protect your Personal Data, we cannot guarantee the
security of your data transmitted to the Attest Service; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features
to try to prevent unauthorised access.
Access to information
The DPA gives you the right to access information held about you. Your right of access can
be exercised in accordance with the DPA. Any access request may be subject to a fee of £10
to meet our costs in providing you with details of the information we hold about you.