Introduction
Your privacy matters to us. This Privacy Policy explains how TGM Research Pte. Ltd. ("TGM", "we", "us", or "our") collects, uses, and shares personal information when you use our services, including:
- The TGM Panels website at tgmpanel.us and related panel websites ("Website")
- The TGM Panels mobile application ("App")
- Participation in surveys and market research programs ("Services")
This Privacy Policy applies to all users worldwide. We are committed to protecting your privacy and complying with applicable data protection laws, including:
- GDPR (EU/UK General Data Protection Regulation)
- CCPA/CPRA (California Consumer Privacy Act / California Privacy Rights Act)
- PDPA (Singapore Personal Data Protection Act)
The following entities act as joint data controllers for processing your personal data (GDPR Art. 26):
TGM Research Pte. Ltd. (Primary Controller)
6001 Beach Road, #22-01 Golden Mile Tower
Singapore 199589
TGM Research FZE (Joint Controller)
Business Center, Al Shmookh Building
UAQ Free Trade Zone, Umm Al Quwain, UAE
TGM Research Pte. Ltd. is the parent company and primary controller responsible for determining the purposes and means of processing. TGM Research FZE participates in data processing activities for operational purposes. Both entities are jointly responsible for compliance with applicable data protection laws.
Contact for all privacy matters: privacy@tgmpanel.com
1. Information We Collect
We collect different types of information depending on how you use our Services.
A. Data You Provide Directly
| Data Type | Examples | When Collected |
|---|---|---|
| Account data | Email address, password, country | Registration |
| Profile data | Name, date of birth, gender, postcode | Profile completion |
| Demographic data | Education, employment, household, income | Profile surveys |
| Contact data | Phone number (optional) | For phone-based rewards only |
| Survey responses | Answers, completion status, timestamps | Survey participation |
| Support messages | Communications via email or chat | When you contact us |
B. Special Category (Sensitive) Data
Some surveys may include questions about:
- Health-related information
- Ethnicity or racial origin
- Political opinions
- Religious or philosophical beliefs
C. Data We Collect Automatically
| Data Type | Examples | Purpose |
|---|---|---|
| Device data | Device model, operating system, app version | Compatibility, troubleshooting |
| Network data | IP address, approximate location from IP | Fraud prevention, survey eligibility |
| Usage data | Pages visited, features used, timestamps | Service improvement |
| Login data | Login times, IP at login, derived country | Security, fraud detection |
2. Platform-Specific Data Collection
Some data collection differs between our Website and App:
| Data Type | Website | App |
|---|---|---|
| Cookies | ✓ | ✗ |
| Session recording | ✓ | ✗ |
| Browser data | ✓ | ✗ |
| Push notification tokens | ✓ | ✓ |
| App crash reports | ✗ | ✓ |
- Collect precise GPS location without explicit consent
- Use device identifiers for advertising or remarketing
- Share identifiers with advertising networks
3. How We Use Your Information
| Purpose | Legal Basis (GDPR) |
|---|---|
| Create and manage your account | Contract |
| Match you with relevant surveys | Contract, Legitimate Interest |
| Process rewards and payments | Contract |
| Send survey invitations | Contract, Legitimate Interest |
| Prevent fraud and ensure security | Legitimate Interest |
| Improve our Services | Legitimate Interest |
| Comply with legal obligations | Legal Obligation |
- Advertising or marketing to third parties
- Cross-context behavioral advertising
- Selling to data brokers
4. Data Sharing
We Do Not Sell Your Data
We do not sell, license, or share your personal data with advertising networks, data brokers, or for advertising measurement purposes.
Service Providers We Use
| Provider | Purpose | Platform | Location |
|---|---|---|---|
| Amazon Web Services | Cloud hosting, storage | Both | EU/US |
| Firebase Analytics | App usage analytics | App only | USA |
| Firebase Crashlytics | App crash reporting | App only | USA |
| Google Analytics | Website analytics | Website only | USA |
| Inspectlet | Session recording | Website only | USA |
| Sentry | Error monitoring | Website only | USA |
| UserPilot | Feature tracking | Website only | USA |
| HelpScout | Customer support | Website only | USA |
| Postmark | Transactional emails | Both | USA |
5. Session Recording (tgm.mobi Only)
We use Inspectlet for session recording on tgm.mobi only. Session recording is not active on portal.tgmpanel.com.
Legal Basis: Consent
Session recording is processed under Consent (GDPR Art. 6(1)(a)). You provide consent during registration when you agree to cookies for market research purposes. This consent also satisfies the ePrivacy Directive Art. 5(3) requirement.
What is recorded:
- Mouse movements, clicks, and scrolling
- Page navigation and form interactions
- Time spent on pages
What is NOT recorded:
- Password fields (automatically masked)
- Payment card details (automatically masked)
- Sensitive form inputs
You may withdraw your consent for session recording at any time by contacting privacy@tgmpanel.com. Withdrawing consent will not affect your ability to use the Services or the lawfulness of processing before withdrawal.
6. Profiling and Automated Decision-Making
We use profiling to match you with relevant surveys based on your profile and participation history.
- Profiling does NOT produce legal effects or similarly significant effects
- Profiling does NOT affect access to essential services or pricing
- You may object to profiling (this may result in fewer survey invitations)
7. International Transfers
Your data may be transferred to countries outside your residence. We apply appropriate safeguards:
- EU Standard Contractual Clauses (SCCs)
- Adequacy decisions where applicable
- Data processing agreements with all providers
8. Data Retention
| Data Category | Retention Period |
|---|---|
| Account and profile data | Duration of account + 12 months after deletion |
| IP addresses and login history | Duration of account + 12 months |
| Survey responses | Typically anonymised within 24 months |
| Points and rewards | Points expire after 6 months of inactivity |
| Session recordings | 90 days |
| Error logs | 90 days |
10. Your Privacy Rights
Depending on your location, you may have the following rights:
| Right | Description | GDPR | CCPA |
|---|---|---|---|
| Access | Request a copy of your data | ✓ | ✓ |
| Correction | Correct inaccurate data | ✓ | ✓ |
| Deletion | Request deletion of your data | ✓ | ✓ |
| Portability | Receive data in portable format | ✓ | ✓ |
| Objection | Object to certain processing | ✓ | - |
How to Exercise Your Rights
- Email: privacy@tgmpanel.com
- In-app: Settings > Privacy
- Website: Profile settings > Privacy
We respond within 30 days (GDPR) or 45 days (CCPA).
11. Account Deletion
You can delete your account:
- In-app: Settings > Account > Delete Account
- Website: Profile > Account Settings > Delete Account
- Email: privacy@tgmpanel.com
- Permanent loss of all accumulated points
- Loss of unredeemed rewards
- Removal from all panels
- Data deleted within 30 days
12. Children's Privacy
Our Services are intended only for users aged 18 or older.
We do not knowingly collect data from children. If we discover we have collected data from someone under 18, we will delete it promptly.
13. Data Security
We implement appropriate security measures:
- Encryption in transit (HTTPS/TLS) and at rest
- Access controls limiting who can access data
- Security monitoring and logging
- Regular security assessments
- Employee training on data protection
14. Region-Specific Disclosures
California Residents (CCPA/CPRA)
Your California rights include:
- Right to know what data we collect
- Right to delete your data
- Right to correct inaccurate data
- Right to opt-out (we don't sell data)
- Right to non-discrimination
To exercise rights: Email privacy@tgmpanel.com with subject "California Privacy Request"
EU/UK Residents (GDPR)
To lodge a complaint, contact your local supervisory authority:
- UK: Information Commissioner's Office (ico.org.uk)
- EU: Your local data protection authority
Contact Us
TGM Research Pte. Ltd.
6001 Beach Road, #22-01 Golden Mile Tower
Singapore 199589
Privacy inquiries: privacy@tgmpanel.com
Response time: Within 30 days