Privacy Policy – Divergent Insights

Privacy Policy

This Privacy Policy is posted by Divergent Insights Pte Ltd (hereinafter called as “Divergent”) encourages our customers, visitors, business associates, and other interested parties to read this Privacy Notice, which applies to all users. By using our Service or submitting personal/business information to Divergent Insights Pte by any other means, you acknowledge that you understand and agree to be bound by this Privacy Notice, and agree that Divergent Insights Pte may collect, process, transfer, use, and disclose your personal/business information as described in this Notice. Further, by accessing any part of the Service, you are agreeing to the terms and conditions of our terms of service (the “terms of service”). if you do not agree with any part of this privacy notice or our terms of service, please do not use any of the services.

We’ve developed this Policy to describe (1) how we collect, use, transfer, and store information of individuals; (2) your choices regarding your personal information; and (3) how we ensure your privacy.


We, Divergent Insights Pte. Ltd (“Company”) on behalf of itself and its affiliates worldwide under “Divergent Insights”, having its principal office at 10 Anson Road, #22-02 International Plaza, Singapore 079903 as data controller.


Divergent Insights Pte Ltd (referred to as “our”, “us” and “we” in this notice) is part of Divergent Insights Group, a global market research group. We help our clients to improve how they advertise and market, whether by print, post, email or on websites. We believe that the responsible use of data supports business growth and builds strong relationships between brand and consumer. As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact. We are committed to being always transparent in our handling of personal information and processing personal information in accordance with applicable privacy and data protection laws.


As part of its social responsibility, Divergent Insights Pte Ltd is committed to international compliance with data protection laws, regulations, and rules. This privacy & data protection policy (“Policy” or “Data Protection Policy”) applies worldwide to Divergent Insights and is based on globally accepted basic principles on data protection. This Policy adopts the fundamental principles of the EU’s General Data Protection Regulation (“GDPR”) as the minimum standard to which Divergent Insights, its employees and suppliers must adhere. Although this should go without saying, it does not make GDPR itself applicable to us globally.


Divergent Insights Pte Ltd depends on the collection and analysis of information about identifiable living individuals (“Data Subjects”) to carry out its market research and associated business. Maintaining respondents’ and the public’s confidence requires that respondents do not suffer direct risk, or harm because of providing us with their information or their Personal Data being processed for our business purposes.


To conduct its business, Divergent Insights needs to collect and process certain types of information, including Personal Data, about people with whom Divergent Insights deals. In addition, Divergent Insights may occasionally be required by law to process certain types of Personal Data to comply with certain legal requirements.


The Policy is applicable globally to Divergent Insights, regardless of where they are based. Within Divergent Insights, this Policy will form the minimum standard to which all employees and suppliers must adhere, regardless of whether GDPR directly applies to any specific activity or territory.


Everyone who works for Divergent Insights Pte Ltd has some responsibility for ensuring Personal Data is collected, stored, and handled appropriately. It is everyone’s responsibility that Personal Data is handled and processed in line with this Policy and its data protection principles. Divergent Insights also expects that its suppliers/vendors comply with the principles as set out herein.


This Privacy Notice explains what personal information we collect from you, how we use it and what your rights are. This privacy notice does not apply to Divergent Insights’ processing of employee personal data.


This Privacy Notice explains the following:

  • What personal information we collect;
  • How we use this information;
  • How long we keep your personal information;
  • How we secure your personal information;
  • Information Sharing and Disclosure;
  • International and group company transfers of personal information;
  • Your rights regarding the personal information you provide to us;
  • Our responsibility for website links;
  • Updates;
  • How to contact us.


What personal information we collect

We may collect personal information in a number of different contexts.

What personal information we collect during the course of our market research studies

The Company conducts market research surveys on behalf of our clients / survey sponsors. These studies collect data for research purposes only and the information gathered is not used for marketing or sales. Unless you are specifically informed otherwise (for example by specifically consenting for your personal information to be shared with our client) , the details you provide are used for aggregated analysis – that is, responses are pooled with those of other survey participants and are reported to our clients / survey sponsors anonymously.


We may collect information such as name, job title, company name, e-mail address and job title from certain public and non-public sources, such as our corporate website and third-party business contact data suppliers. We may also receive the information such as name, job title, company name, e-mail address and job title from our clients, who are usually suppliers of services looking for feedback on their products, services or industry from their customers.

In online surveys, we may collect your IP address. This is only used for quality checking purposes and to prevent fraud. We never use an IP address to identify individuals.


What personal information we collect on our website

We collect information such as name, job title, company name, postal address, e-mail address and telephone number. This information may be shared through forms, e-mail or via telephone. Where personal information is collected through our website or our online services in this way, this will be clearly indicated.


We collect information about how you use our website and the device(s) you use to access our site. This includes collecting unique mobile device ID or the internet protocol (IP) address online identifiers, which are numbers that can uniquely identify a specific computer or other network device on the internet. This information is linked to a cookie ID, which we receive and process.


We also collect information about you if you make use of any of the interactive features within our website that rely on a personalised response, or where you ask us to respond to a query you have or add your details to one of our alert or subscription services. The information we collect is limited to the details we need to provide the specific service you have asked for. We do not collect sensitive information, such as your political or religious beliefs, ethnic background, sexual preference, health or any other sensitive information.


We do not actively seek to collect information about children aged 16 or under. If you have any concerns about your child’s privacy in relation to our services, or if you believe that your child may have entered personal information onto our website, please contact us at [email protected]. We will delete such information from our records within a reasonable time.


Storage Limitation

Personal Data must not be retained in a form which permits identification of Data Subjects for longer than is necessary for the purpose for which the Personal Data are processed. Divergent Insights will not keep Personal Data longer than is necessary for the purpose or purposes for which they were collected Divergent Insights will take all reasonable steps to destroy, or erase from its systems, all Personal Data which are no longer required. This does not apply to anonymised data.


General Measures and Considerations

Additionally, in respect of its market research business Divergent Insights  complies with the ESOMAR International Code on Market, Opinion, and Social Research and Data Analytics and ESOMAR’s Data Protection Checklist.


How we use this information

Except where required by law, we use the personal data you provide for the following purposes:

  • to provide market research services to our clients;
  • to deliver the specific information or services you have requested;
  • to enable the download of our content;
  • send you newsletters and information relating to our brands and services;
  • respond to your requests and feedback; and
  • analyse and/or improve our services.


Under data protection law we are required to advise you on the legal basis for processing your personal data. For the most part, the processing of your personal information is based either on a) our legitimate interests related to us providing you services you have requested or otherwise your customer relationship with us, or b) your consent, where requested.


In the table below we set out further information about the purposes for which we use your personal data and the legal basis we rely on for its use. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.


Purpose/Activity Types of personal data that may be processed Lawful basis for processing including basis of legitimate interest
Collection of personal information from public sources (a) Name (b) Email address (c) Company (d) Telephone number (e) job title Necessary for our legitimate interests of sourcing potential participants to a market research study, in a business-to-business context and largely using corporate office switchboard numbers.
To contact you to conduct a market research study (a) Name (b) Email address (c) Company (d) Telephone number (e) job title To the extent that we collect information that has not been passed to us by our clients (in which case our client will provide an approach lawful basis for contacting you, with our client acting as data controller), we rely on your consent to contact you to continue a market research study.
To conduct the market research study including recording responses and developing a report for our client/survey sponsor; verifying or validating answers you provide, including for internal quality control purposes; and to obtain extended (open-ended) information that helps to provide context for your survey responses – for example, the nature of a complaint that has arisen while using our clients’ products or services (a) Name (b) Email address (c) Company (d) Telephone number (e) job title (f) IP address (for online surveys) (g) other personal information which may be shared during the course of a market research interview We rely on your consent to process personal information relating to your continued participation in a market research study.

To the extent that we make audio or visual recordings of a market research study, our lawful basis is our legitimate interest in creating a record of the discussion to support our creation of an accurate report for our client/survey sponsor. You will always be notified before any recording takes place. You should not participate in a study which involves recording, if you are not happy to be recorded.

To share your personal information with our client or survey sponsor (a) Name (b) Audio or visual recording (c) Attributed quotations (d) Job title In some cases, we may ask for your consent to share your personal data and responses with a third party in digital (data file), audio or some other format. You are under no obligation to agree to this and you will always be informed who these third parties are (usually the survey sponsor). We would share this personal information on the basis of your consent.
To manage incentives (a) Name (b) E-mail address (c) Job title Some projects may include an incentive for taking part. These incentives will be processed by our staff. Incentives will usually be in the form of a gift voucher or charitable donation. Incentives will only be awarded if a survey or research activity is fully completed. We process this personal information on the basis of your consent.
To send you information about our services: · To send you information which you have requested e.g. newsletters or publications in accordance with your specified preferences (a) Name (b) Email address (c) Company (d) Location Where you have requested information from us, such as newsletters, publications or event invitations, we send such communications based on your consent. You can ask us to stop such communications at any time by clicking on the unsubscribe link at the bottom of the message.
To improve and develop our website: · We conduct statistical analysis on your usage of the website e.g. to enable us to improve our website, offer new features and material etc. (a) Technical (b) Usage Necessary for our legitimate interest (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To deliver relevant content to you and measure or understand the effectiveness of the content we serve to you. (a) Name (b) Email address (c) Company (d) Location (e) Usage (f) Marketing and communications (g) Technical Necessary for our legitimate interests (to study how clients use our service and engage with our content. To develop our service, to grow our business and to inform our marketing strategy).
To respond to any enquiries or feedback that you send us· To update you with any changes to our terms and conditions/other policies (a) Name (b) Email address (c) Company (d) Location It is in our legitimate interest to respond to communications that you send to us, inform you of relevant information in relation to the services that we provide and utilise your information to improve our business.
To reach out with information on our products and services relevant to your needs (a) Name (b) Email address (c) Location (d) Usage It is our legitimate interests to work out which of our products or services may interest you and tell you about them. Our offices outside of the UK may reach out to you with such information based on your consent.
To share information with our service providers. (a) Name (b) Email address (c) Usage (d) Marketing and communications (e) Technical It is our legitimate business interest to share your data with trusted third parties who provide us with services relevant to the provision of our website.
To share information within the Divergent Insights group. (a) Name (b) Email address (c) Location (d) Usage As Divergent Insights operates as a global operating market research company, it is our legitimate business interest to share your data within the group in order to manage our business effectively and provide our products and services.
To share information with other third parties, such as regulator and law enforcement agencies (a) Name (b) Email address(c) Location (d) Usage (e) Technical We share your data as necessary for compliance with any legal obligation to which we are subject or in order to satisfy our legitimate business interests.


How long we keep your personal information


We store your personal information in accordance with legal, regulatory, financial and best-practice business requirements. Once your personal information is no longer necessary, we will securely delete/destroy your data in line with our data retention policies.


Our standard retention period for personal data relating to market research studies is 3 years.


How we secure your personal information

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers do the same.


Information Sharing and Disclosure

We may send personal data collected from research surveys to third party organizations, but only when:

  • We have your express consent to share the information with a research sponsor for a specified and limited purpose (e.g. to resolve a customer service problem);
  • We need to share this information to provide you with information you have specifically requested;
  • We need to respond to court orders or the requests of law enforcement agencies;
  • We retain a third party to provide us with services, subject to that third party being able to comply with relevant legal requirements and obligations regarding the use of personal data;


In addition, we have offices and operations in a number of international locations and we share information between our group companies for business and administrative purposes.

Your personal information may also be stored in one or more databases hosted by third parties. These third parties do not have use or access to your personal information for any purpose other than cloud storage or retrieval.


Where required or permitted by law, personal information may be provided to others, such as regulators and law enforcement agencies, for example in response to a court order or a subpoena, or in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law.


From time to time, we may consider corporate transactions such as a merger, acquisition, reorganisation, asset sale, or similar. In these instances, we may transfer or allow access to information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, personal information may be transferred to third parties involved in the transaction.


International and group company transfers of personal information


We are part of an international group of companies and, as such, from time to time we may transfer personal information concerning you to countries outside the European Union (“EU”).


Where we transfer personal information outside of EU, we either transfer personal information to countries that provide an adequate level of protection (as determined by the European Commission) or we have appropriate safeguards in place.


If you would like more information on the any of the data transfer mechanisms on which we rely please contact us at using the details provided below.


International Data Transfer

If you are in Switzerland, the United Kingdom, or the European Economic Area (“EEA”), please note that we and our servers are located outside of the EEA. Any information that you provide to us may be transferred to and processed in Indian and other countries around the world where we do business. Although this may include recipients of information located in countries where there may be a lower level of legal protection for your personal/business information than in your country, we will protect your information in accordance with requirements applicable to the law in your jurisdiction and take steps to only share with third parties that offer similar protection. By using our Service, you unambiguously consent to your information being collected, processed, used, and transferred as disclosed herein.


Your rights regarding the personal information you provide to us


General rights

  • If you wish to stop receiving marketing communications from us then please click on the “unsubscribe” link at the bottom of the relevant mailing. If you wish to opt-out completely then please contact us at using the details provided below.
  • If you would like us to delete your information from our records, please contact us using the contact details below and we will respond within a reasonable time. Please note that we may be required to retain certain information by law and/or for our own legitimate business purpose.
  • the right to be informed about the processing of your Personal Data
  • the right to have access to your Personal Data
  • the right to update and/or correct your Personal Data
  • the right to portability of your Personal Data
  • the right to oppose or limit the processing of your Personal Data
  • the right to request that we stop processing and delete your Personal Data
  • the right to block any Personal Data processing in violation of any applicable law


Data Privacy Rights (European Union, South Africa, and other similar jurisdictions)

If you are from the European Union or similar jurisdictions, you have rights (with some exceptions and restrictions) to:

  • object to our processing of your personal information. You can object at any time, and we shall stop processing the information you have objected to, unless we can show compelling legitimate grounds to continue that processing.
  • access your personal information. If you make this kind of request and we hold personal information about you, we are required to provide you with information on it, including a description and copy of the personal information and why we are processing it;
  • request erasure of your personal information in certain circumstances.
  • request correction or updating of the personal information that we hold about you and that is inaccurate.
  • request the restriction of our processing of your personal information in some situations. If you request this, we can continue to store your personal information but are restricted from processing it while the restriction is in place.
  • withdraw your consent to our use of your personal information at any time. When you use our website you may have been asked to consent to the use of cookies. You may withdraw your consent to our processing of your personal information that has been derived from cookies. If you do withdraw consent, that will not affect the lawfulness of what we have done with your personal information before you withdrew consent.
  • object to our use of your personal information for direct marketing.
  • request portability of your personal information that we hold, in certain circumstances.


If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.


If you are from the EU and would like to exercise any of these rights in relation to any information, we hold about you via this website please contact us using the contact details provided below. We will consider and respond to your request in accordance with the relevant law.


California Privacy Rights

As a California resident, the California Consumer Privacy Act (“CCPA”) provides you the ability to make inquiries regarding to your personal/business information. Specifically, the degree to which the information is not already provided in this Privacy Notice, you have the right to request disclosure about the collection and use of your personal/business information over the past 12 months, including:

  • The categories of personal/business information collected about you.
  • The categories of sources for the personal/business information collected about you.
  • The business or commercial purpose for collecting your personal/business information.
  • The categories of third parties with whom your personal/business information was shared.
  • The specific pieces of personal/business information collected about you.
  • If your personal/business information was disclosed for a business purpose, the personal/business information categories disclosed and the categories of third parties to which the information was disclosed.
  • If your personal/business information was sold in the past 12 months, the personal/business information categories sold and the categories of third parties to which the information was sold. (NOTE: DIVERGENT INSIGHTS PTE DOES NOT SELL PERSONAL/BUSINESS INFORMATION).

Please note that you may only make the above requests twice in a 12-month period. You also have the right to request that any of your personal/business information collected and retained be deleted, subject to certain exceptions.

If at any time you require us to cease processing your personal/business data, you may submit a request to delete your personal/business data by clicking on the “Unsubscribe” option OR by contacting us at [email protected].

By following the appropriate directions, your record will be marked as \”do not contact\”, and you will no longer receive communications from Company. We will retain your information for as long as your account is active or as needed to provide you services or in accordance with the applicable laws. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and other related purposes.


Our responsibility for website links


This Privacy Notice is limited to the personal data collected by Divergent Insights Pte Ltd. We may provide links within our website to other websites, including social media sites such as Facebook, Twitter and LinkedIn. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices as their data practices fall outside the scope of this Privacy Notice. Further, we can have no responsibility for or control over the information collected by any third-party website and we cannot be responsible for the protection and privacy of any information which you may provide on such websites.


Data Protection Audit


Compliance with this Data Protection Policy and the applicable data protection laws is checked regularly with data protection audits and other controls. The performance of these controls is the responsibility of the DPO, Internal Audit and/or externally hired auditors. On request, the results of data protection audits will be made available to the responsible data protection authorities



This Privacy Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal data. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please do not continue to use our services and please refrain from sharing your personal data with us. You should check this notice frequently for updates.


How to contact us

If you have any questions about this Privacy Notice, our approach to privacy or you would like to exercise any of the rights mentioned in this Privacy Notice you can contact us in on our email:

Email: [email protected]



In this Supplementary Information section, we explain some of terminology used in this Privacy Notice.

“data controller” – the person or company that controls the purposes and means of processing personal data.

“personal data” – any information that relates to you (or from which you can be identified).

“processing”– means doing anything with data. For example, it includes collecting it, holding it, disclosing it and deleting it.

“transfer” – sending personal information outside the European Economic Area (e.g. by storing it on equipment located outside the European Economic Area), or allowing someone from outside the European Economic Area to access the personal information.