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    * Tools to Make Smarter, Faster Decisions
   
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    * Hype Cycle: Measure Technology Lifecycle
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GARTNER PRIVACY POLICY


EFFECTIVE DATE: SEPTEMBER 2022

Gartner and its affiliates are committed to protecting your information. Please
read this Privacy Policy ("the Policy") carefully as it sets out important
information relating to how we handle your personal information.

Gartner companies issuing the Policy

In this Policy, references to "we," "us," or "Gartner" are references to Gartner
Inc. and all its group companies doing business under the Gartner name listed
here. Certain Gartner products and/or services which may be linked through
www.gartner.com or Gartner group companies with different business models have
their own applicable privacy policies, and this Policy does not apply to
them. Those companies include Evanta, Gartner Digital Performance
Benchmarks, Gartner Consumer and Culture Insights, and the Gartner Digital
Markets Companies of Capterra, GetApp and Software Advice.     

Gartner and all its group companies will have access to information on
individuals covered by this Policy. A list of our entities can be found here.

How to Contact Us

Questions, comments and requests regarding this Privacy Policy should be
addressed to our Data Protection Office by completing the form at
www.gartner.com/personaldatarequest, via email at privacy@gartner.com or regular
mail at:

Global Data Protection Office
Legal Department
56 Top Gallant Road
Stamford, CT 09602
USA

Gartner’s appointed Representatives:

EU Gartner Ireland Limited
Two Park Place
Hatch Street Upper
Dublin 2
Ireland

UK Gartner UK Limited
The Glanty
Egham
Surrey
TW20 9AH


INTRODUCTION

This Policy sets out how we collect and use personal information, and your
choices and rights regarding our use of your personal information.

This Policy describes our practices when using your information when you: 

 1. create, activate and use a Gartner user account and/or license, including a
    Gartner Peer Insights Community profile and account;
 2. express an interest in or have signed up for our conferences or products
    including newsletters, apps, extensions, webinars, and e-books;
 3. register for, and attend a virtual or in-person Gartner conference; or
 4. visit our websites (including our public and/or member-based websites) or
    social media sites or use one of our mobile applications.

This Policy also applies to information we collect from you via our survey or
diagnostic tools as outlined in more detail below. You may be shown an
additional confidentiality notice before participating in a survey or
diagnostic. Please note that in cases where the terms of any such survey- or
diagnostic-specific confidentiality notice conflict with any terms in this
Policy, the terms of that notice will take precedence over the terms in this
Policy. We will not use information we collect via our survey or diagnostic
tools to contact you for marketing purposes.

This Policy will apply whether you have provided the information directly to us
or we have obtained it from a different source, such as a third party.



1. INFORMATION THAT WE COLLECT ABOUT YOU

1.1 DATA COLLECTION AND USE

Information we collect directly from you or from the following sources:

 * Referrals or recommendations, including from within the Gartner group or from
   a third party;
 * Social media sites and other external internet sites, such as LinkedIn; and
 * Resources such as telephone directories, newspapers, internet sites,
   commercially available data resources, public registries or public records.

Categories of information we collect about you include:

 * Personal information such as name and title, contact details, and company
   information;
 * Communications with you;
 * Information you provide when posting content on social media sites.

We use this information for certain activities, including:

 * Facilitating the business through communication with corporate clients and
   other business contacts, for example, to communicate about vendor briefings
   or details of conferences or webinars;
 * For internal analysis and research to help us improve our existing products
   and services, and create new products and services;
 * To send marketing to business contacts regarding our services and products
   which may be of interest and to promote our business and brand;
 * Administering our website, investigating any complaints and providing
   customer service;
 * Monitoring social media content to manage relations with our clients and
   promote our business and brand.    

We use this information because:

 * It is necessary to perform our obligations or exercise our contractual
   rights;
 * It is necessary to comply with applicable laws or regulations;
 * We have a legitimate business interest to:
   * Manage and promote our business and brand;
   * Provide and improve our services;
   * Operate our business; and
 * We have your consent (where required under applicable law) to use your
   information for marketing. Where we rely on your consent, you have the right
   to withdraw consent by contacting us. 

Information we collect when you register for, and attend one of our virtual or
in-person conferences:

Categories of information we collect about you include:

 * Information you provide during registration, such as name, business email
   address, profile photograph, job title, professional interests, requested
   accommodation, and payment card information;
 * Information you provide throughout the conference to receive additional
   Gartner research or materials (e.g. via badge scan or QR scan);
 * Geo-location information at a in-person conference (if you attend a
   conference where we are using RFID-enabled badges and you do not request a
   non-RFID-enabled badge);
 * Information collected when we record one of our conferences.    

We use this information for certain activities, including:

 * Enabling you to attend our conferences;
 * Conducting our conferences;
 *  Sending Gartner research and material related to topics that may be of
   interest to you;
 * Analyzing attendee interests in and interactions with the conference,
   including through geo-location data for in-person conferences, where
   applicable;
 * Marketing our conferences through the use of video;
 * Providing recordings of certain conference sessions to interested business
   contacts, attendees, and online through our website or Gartner social media
   sites.    

We use this information because:

 * It is necessary to perform our obligations or exercise our contractual
   rights;
 * It is necessary to comply with applicable laws or regulations;
 * We have a legitimate business interest to:
   * Manage and promote our business and brand;
   * Operate our conferences business;
   * Provide and improve our services;
   * Collect relevant information for hospitality and health and safety
     purposes.    

Information we collect from users of:

 * Our public and member-based websites;
 * Our apps and Gartner Everywhere browser extension; and
 * Gartner social media sites such as Facebook or Twitter.

Categories of information we collect about you include:


 * Information you provide when you enter information on our website, such as
   when you provide contact details, payment card information, answer online
   questionnaires, or feedback forms;
 * Information you provide when you subscribe to email newsletters such as name,
   email address, job title;
 * Information you provide when registering for an online or member account,
   including name, business or personal email address, job title, organization,
   organization’s physical address, direct telephone number, photograph, and
   biographical details;
 * Where you have an online or member account, log-in credentials and
   information about your use of and preferences for these services;
 * When you link your Gartner account with your LinkedIn profile, we collect
   information from your profile, including your profile photograph;
 * URLs of webpages visited when you use Gartner Everywhere. 

We use this information for certain activities, including:


 * Enabling you to access your Gartner accounts across devices;
 * Personalizing your experience of our website, extension and apps;
 * Administering our website, extension, and apps;
 * For internal analysis and research to help us improve our existing products
   and services, and create new products and services;
 * Enabling peer networking opportunities based on your background and
   experience;
 * Providing more customized client service;
 * Investigating complaints;
 * Monitoring social media content to manage relations with our clients and
   promote our business and brand.    

We use this information because:


 * It is necessary to perform our obligations or exercise our contractual
   rights;
 * It is necessary to comply with applicable laws or regulations;
 * We have a legitimate business interest to:
   * Promote our brand and business through our website and through social media
     tools;
   * Monitor, investigate and report any attempts to breach the security of our
     website;
   * Provide and improve our services including, but not limited to, the Gartner
     Everywhere extension and our apps;
   * Operate our business;
 * We have your consent (where required under applicable law) to use your
   information for marketing. Where we rely on your consent, you have the right
   to withdraw consent by contacting us.    

Information we collect about the use of our website and apps from users.

Categories of information we collect about you include:

 * Information captured in our web logs such as device information (e.g. device
   brand and model, screen dimensions), unique identification numbers (e.g. IP
   address and device ID), and browser information (e.g URL, browser type, pages
   visited, date/time of access), geo-location and other device-specific
   information, Internet connection information;
 * Advertising information (such as size/type of ad, ad impressions,
   location/format of ad, data about interactions with ad);
 * Behavioral information (such as information on the behavior or presumed
   interests of individuals which are linked to those individuals and may be
   used to create a user profile); and
 * Information captured by our cookies (see our Cookie Policy).

We use this information for certain activities, including:

 * Personalizing the experience of our website;
 * Administering our website;
 * Performing statistical and trend analysis to improve the user experience and
   performance of our website;
 * Providing better, more customized client service;
 * Detecting and preventing fraudulent and/or unlawful use of our website(s),
   products and services, including user-provided review content;
 * Investigating any complaints.    

We use this information because:

 * It is necessary to comply with applicable laws or regulations;
 * We have a legitimate business interest to:
   * Monitor, investigate and report any attempts to breach the security of our
     websites;
   * Improve the performance and user experience of our websites;
   * Customize the client experience.    

Information we collect from participants of a survey or diagnostic.

Categories of information we collect about you include:

 * Personal information such as name and title, contact details, and company
   name; and
 * Demographic information provided by your employer and
 * Responses to survey or diagnostic questions.

We use this information for certain activities, including:

 * Validating and analyzing survey and diagnostics;
 * Conducting general research, including creating or updating aggregate
   benchmark data sets and reports;
 * Providing our services; and
 * Developing new products and services.

We use this information because:

 * We have a legitimate business interest to:
   * Provide and update benchmark data and analysis; and
   * Validate and update our products and services.

Information we collect when you create a Gartner Peer Insights Community (“Peer
Community”) profile and participate in the Peer Community via the Website or the
Gartner Peer Insights App:

Categories of information we collect about you include:

 * Information you provide when you create a profile in the Peer Community,
   including: name and title, contact details (including your personal and
   company email addresses), and company information;
 * A photograph, video, or audio file containing your image or voice;
 * Information you choose to add to your Peer Community profile, including links
   to your LinkedIn and/or Twitter profiles;
 * Communications with you;
 * Your responses to various surveys or polls posted in the Peer Community;
 * Information you provide when you subscribe to email newsletters such as name,
   email address, job title;
 * Log-in credentials and information about your use of and preferences for
   participating in the Peer Community;
 * When you link your Gartner.com account and/or your Peer Community profile
   with your LinkedIn profile, we collect information from your profile,
   including your profile photograph;

We use this information for certain activities, including:

 * To provide the service;
 * To send notices about your account;
 * Enabling you to access your account across devices;
 * Personalizing your Peer Community experience;
 * For internal analysis and research to help us improve our existing and create
   new products and services;
 * Administering our website and app, investigating any complaints and providing
   customer service;
 * To administer contests, promotions, and surveys or other Peer Community
   features;
 * To contact you about products and services that may be of interest, including
   third parties’ goods and services;
 * Enabling peer networking opportunities.

We use this information because:

 * It is necessary to provide the service;
 * It is necessary to perform our obligations or exercise our contractual
   rights;
 * It is necessary to comply with applicable laws or regulations;
 * We have a legitimate business interest to:
 * Manage and promote our businesses and brands;
 * Monitor, investigate and report any attempts to breach the security of our
   Website;
 * Provide and improve our services;
 * Operate our business;
 * We have your consent (where required under applicable law) to use your
   information for marketing. Where we rely on your consent, you have the right
   to withdraw consent by contacting us.

1.2 SPECIAL CATEGORIES OF INFORMATION

Certain types of personal information are more sensitive than others. This
includes information about health, disability, race, ethnicity, criminal
offences (or alleged offences), political opinions, biometric information or
religion. It is voluntary for you to disclose this information, but where we
collect and receive these types of information about you, we have identified the
type of special information, how we will use it and why we will use it.

Information we collect when you attend one of our virtual or in-person
conferences

Categories of information we collect about you include:

 * Dietary requirements that may imply specific religious beliefs or medical
   conditions.
 * Any physical or mental disability or impairment you may disclose to us.

We use this information for certain activities, including:

 * Providing hospitality that is suitable for attendees of our conferences.

We use this information because:

 * You have consented by providing us with the information. Where we rely on
   your consent, you have the right to withdraw your consent by contacting us.

Special category information that you choose to provide voluntarily as part of a
survey or diagnostic

Categories of information we collect about you include:

 * Certain surveys or diagnostics may be configured to collection optional
   demographics such as race, ethnicity or disability status.

We use this information for certain activities, including:

 * Validating and analyzing survey and diagnostics;
 * Conducting general research, including creating or updating aggregate
   benchmark data sets and reports;
 * Providing our services; and
 * Developing new products and services.

We use this information because:

 * You have consented by providing us with the information. Where we rely on
   your consent, you have the right to withdraw your consent by contacting us.

1.3 FURTHER INFORMATION

Where we collect and use information for our legitimate interests as mentioned
above, a legitimate interest will only apply when we consider that your
interests or rights requiring protection of your personal information do not
override our legitimate interests. For more information regarding our legitimate
interests as applied to your personal information, please contact us.

Our websites and online services are for individuals who are at least 18 years
old. Our online services are not designed to be used by individuals under the
age of 18.

In certain circumstances, if you do not provide personal information which is
required (for example, in relation to activating your Gartner license), we will
not be able to perform our contractual obligations or provide you with products
and services. When this is the case, we will make it clear. 

Recorded Communications with Gartner

We may ask to record calls for training, quality and research purposes. All
recordings will be treated as confidential. If you do not want us to record your
call, you will be given a chance to opt out. If your call is already in
progress, you may ask us to turn off the recording at the start of the call. 

Communication with Colleagues

You may use the send-to-colleague functionality on some of our sites or apps to
send your colleagues information from Gartner or its subsidiaries. In order to
fulfil this request, we will ask you for your and your colleagues' names and
email addresses. We do not retain this data after the email is sent. Please be
aware that your name and email address may be included in the communication sent
to your colleague.

Payment Card Information

Where you choose to pay for any Gartner products or services using your payment
card, we will collect your personal data connected to your payment card. We use
this personal data in order to process your payment and to prevent fraudulent
transactions. We do this on the basis of your consent to process this
information.

My Favorites

The My Favorites feature of the member websites allows clients to save content
available to the member’s Favorites list, add labels, tags, and notes to saved
content, and share content and notes with and receive content and notes from
other clients. We may review information about your use of My Favorites,
including the content you save, folders you create, any tags, labels, or notes
you add to your saved content or folders you have created, and any content that
you share, and use such information to recommend content, tools, or other
Gartner services we think may be of interest to you. Information about your use
of My Favorites will only be accessible to Gartner and will not be visible to or
otherwise shared with other Gartner clients unless you choose to share it.

Restricted Areas

If you access the Restricted Areas of any of our sites (via browser or a Gartner
app), we may collect information about your access to and use of research
materials, decision-support tools, and other online and offline resources we
offer.

General Benchmarking and Research Purposes

Gartner and its affiliates may use information disclosed through surveys or
diagnostics or otherwise provided to or generated by Gartner or its Affiliates
(collectively “Research Data”) for validation, research and benchmarking
purposes and product development. Unless otherwise specified prior to
collection, Research Data will be disclosed in the aggregate and presented in
anonymous form and will not include (directly or by inference) any information
identifying participating organizations or any identifiable individual as the
source of such data. Access to Research Data will be restricted to those
individuals who need such access to deliver Gartner products and/or services.

Algorithm Recommendation

Basic Principles

We recommend content & topics based on users’ role, industry and activities with
Gartner. Users’ activities include research content users read, topics that were
followed, webinars views, discussions with Gartner. Recommendations depend on
freshness of the content and the popularity of the content amongst similar
users.

Our algorithm will refine overtime based on users’ continuous interactions with
Gartner in order to provide high quality, decision-relevant content.

Computation Mechanism

We take users’ roles, industries, activities data (primarily users’ readership,
topic follow data) to train deep learning recommendation models. Most models
only update daily with some reacting close to real time to users’ actions.

Our models predict the most relevant content and topics that users are
interested in after adjusting for user entitlements and use case specific
suppressions.

Use Cases

Primarily used in:

 1. Recommended contents and topics on Gartner.com home page
 2. Recommended related contents within the context of research content
 3. Recommended contents delivered through in-app notifications & emails

Purposes

Surfacing high quality, decision-relevant contents to enable users make better
and faster decisions and make progress on their priorities.


2. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information to third parties as follows:

 * To Gartner group companies in order to process the data for the above
   mentioned purposes;
 * When we have your consent or authorization to do so;
 * When you engage directly with an exhibitor at an in-person or virtual
   conference e.g., when you allow an exhibitor to scan your badge (at an
   in-person conference) or attend a virtual sponsored session (during a virtual
   conference); 
 * To third parties who work on our behalf to service or maintain business
   contact databases and other IT systems, e.g., suppliers of the IT systems
   which we use to process personal information, or who provide other technical
   services, such as printing;
 * To third parties providing services to us or on our behalf who have a need to
   access your information, e.g., our professional advisors (e.g. auditors and
   lawyers) or venues for our conferences;
 * To comply with applicable laws, protect rights, safety and property, and
   respond to lawful requests from public authorities (e.g., disclosing data in
   appropriate situations for national security or law enforcement purposes);
 * Subject to applicable law, in the event that Gartner is merged, sold, or in
   the event of a transfer of some or all of our assets (including in
   bankruptcy), or in the event of another corporate change, in connection with
   such a transaction, or for pre-transaction review in relation to such
   transactions.

Your personal information may be shared if we anonymize and/or aggregate it, as
in these circumstances the information will cease to be personal information.

Utilization Information

We may share information with our organizational clients about how their
employees use the sites and the resources available to them through the sites
(e.g., how employees used certain features of the sites, utilization trends,
which features were most popular with the client’s employees).


3. DATA SUBJECT RIGHTS

In certain circumstances, you have certain rights regarding your personal
information. A summary of each right and how you can exercise it is set out
below. To opt out of receiving commercial communications, please send an email
to privacy@gartner.com. To exercise any of your other rights (such as the right
to access or deletion of your information), please complete the form at
www.gartner.com/personaldatarequest.  Such requests should include information
to allow us to verify your identity (e.g., your name, address, email address or
other information reasonably required). If you are a California resident, please
refer to Section 11 below for more detailed information on your rights under
California law. 

Where we receive your request to exercise one of these rights, we will respond
without undue delay and within the time required by applicable law. This may be
extended in certain circumstances, e.g., where requests are complex or numerous.

We will provide the information free of charge, except where requests are
manifestly unfounded or excessive, e.g. because of their repetitive character.
In these circumstances we may charge a reasonable fee or may refuse to act on
the request. We will advise you of any fees prior to proceeding with a request.
We may ask for additional information to verify your identity before carrying
out a request.

Right

How you can exercise the right

Right to access and/or correct your personal information


You have the right to access personal information we hold about you and to be
provided with a copy of the information (in most circumstances). You also have
the right to correct any information we may hold about you that is inaccurate.

Right to restrict use of your personal information


You have the right to ask us to restrict processing of your personal information
where one of the following applies:

 * The processing is unlawful but you want us to restrict use of the data
   instead of deleting it;
 * Where you contest the accuracy of your personal information, the restriction
   will apply until we have verified the accuracy or corrected your personal
   information;
 * We no longer require the personal information for the purposes of processing,
   but are required to keep it in connection with a legal claim;
 * You have exercised your right to object to the processing. The restriction
   will apply until we have taken steps to verify whether we have compelling
   legitimate grounds to continue processing. 

Right to request deletion of your personal information


You have the right to ask us to delete your personal information in certain
circumstances. If you want to opt-out from receiving marketing communications,
the best way to do so is to allow us to retain your information with a “do not
contact” tag so we know not to contact you in the future. 

There are also certain exceptions where we may refuse a request for erasure, for
example, where the personal information is required to comply with a legal
obligation or for the establishment, exercise or defense of legal claims.

Right to object to processing of your personal information


You may object to our use of your personal information for marketing purposes.

You may also object to processing of your personal information in cases where we
have used legitimate interests as the basis for processing. In such cases, we
will stop processing your personal information until we verify that we have
compelling legitimate grounds for processing that outweigh your interests,
rights, and freedoms in asking us to stop processing the data, or in limited
cases where we need to continue processing the data for the establishment,
exercise, or defense of legal claims.

Right to data portability 


In most cases, you have the right to receive all personal information you have
provided to us in a structured, commonly used, and machine-readable format and
to transmit this data to another data controller, where technically feasible.

Right to lodge a complaint with a supervisory authority


If you object to our processing of your personal information, you have the right
to complain to the data protection authority (“DPA”) in the country where you
reside, where you work, or where the alleged infringement of data protection
laws has taken place.

We agree that any disputes regarding our privacy policies and related actions
regarding personal information from data subjects in the EU can be heard by a
DPA and we will be subject to the determination of those bodies. Please contact
us to be directed to the relevant DPA.


4. INTERNATIONAL TRANSFERS

Gartner is a global company and we may transfer personal information to other
Gartner group companies or suppliers outside your country. Gartner will take
reasonable steps to ensure that personal information is protected and any such
transfers comply with applicable law.

Gartner may transfer and maintain the personal information of individuals
covered by this Policy on servers or databases outside the European Economic
Area (“EEA”). Some of these countries may not have the equivalent level of
protection under their data protection laws as in the EEA.

The countries to which we transfer data outside of the EEA may include any of
the countries in which Gartner does business. A list of Gartner office locations
can be found here.

All Gartner entities have signed an Intragroup Agreement containing the European
Union (“EU”) Commission Approved Standard Contractual Clauses for the transfer
of data outside the European Economic Area. All Gartner entities have the same
technical, physical, and administrative security controls and are required to
comply with our data protection policies and procedures, applicable laws, and
the terms of our client and member contracts governing the collection and use of
information.


5. RETENTION PERIODS

We will retain your personal information for as long as required to perform the
purposes for which the data was collected, depending on the legal basis for
which that data was obtained and/or whether additional legal/regulatory
obligations require us to retain it.  

In general terms, this will mean that your personal information will be kept for
the duration of our relationship with you and:

 * the period required by tax and company laws and regulations; and
 * as long as it is necessary for you to be able to bring a claim against us and
   for us to be able to defend ourselves against any legal claims. This will
   generally be the length of the relationship plus the length of any applicable
   statutory limitation period under local laws. 


6. CHOICES ABOUT YOUR INFORMATION

We believe it is important to give you choices about the use of your
information. We will use your information as described in this Policy (or any
other conference- or service-specific Privacy Policy). If we want to use your
information for a purpose not described in this Policy, we will first get your
consent to do so.

Marketing Communications

We will respect your wishes not to receive marketing communications. You can
change your marketing preferences by contacting us at the address here. If you
gave us your email address to receive marketing communications, you can opt out
at any time by using the unsubscribe links or instructions included at the
bottom of our emails. Please note that we will continue to send you
service-related communications regardless of any opt-out request. We will not
sell or share your information with third parties (other than our subsidiaries
or affiliates) for their own promotional or marketing purposes unless you give
us consent to do so and where permitted by applicable law.

Gartner Everywhere

Gartner Everywhere is an extension for Google Chrome that allows clients to
customize their Gartner experience by providing them with Gartner research
applicable to the websites they are browsing in real-time via an easy to access
pop-up in their browser. You can easily disable the extension and its collection
of URLs by doing the following:

 1. Click the extension Gartner Everywhere button on the top of the browser
    window.
 2. Click the green toggle button to switch off.
 3. Select the duration that you would like to switch off the extension for.
 4. The extension will be automatically activated after the selected time
    period.

Conferences

When you attend one of our in-person conferences, you may be issued a conference
badge with an RFID chip, which has a unique identifier that can be scanned from
various distances. We may use the RFID information to administer and improve the
conference experience and solicit feedback and/or interest in Gartner products
and services. We will not sell or share RFID information with third parties
(other than our subsidiaries and affiliates) for their own marketing and
promotional purposes.  You may request a non-RFID enabled badge by asking
conferences staff at the registration desk.

We allow Exhibitors to scan attendee badges at our in-person conferences. If you
choose to allow an Exhibitor to scan your badge at the Exhibitor’s booth or when
entering an Exhibitor session or function, you are giving us your consent to
provide your contact details to that Exhibitor. Our Exhibitors’ use of any
information you choose to share with them in this way is governed by each
Exhibitor’s Privacy Policy. Badge scanning is optional and you may refuse to
have your badge scanned by the Exhibitor.


7. SECURITY

We have implemented administrative, technical, and physical security measures to
help prevent unauthorized access. Despite these measures, no data transmission
over the Internet can be entirely secure, and we cannot guarantee or warrant the
security of any information you transmit via our websites or apps. Please note
that you are responsible for maintaining the security of your credentials used
to access any Gartner service or account, and you must report suspected
unauthorized activity to us.

We make reasonable efforts to restrict access to information to only those
employees, contractors, and agents who need such access in order to operate,
develop, improve, or deliver our programs, products, and services.


8. COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small text file which includes a unique identifier that is sent by
a web server to the browser on your computer, mobile phone or any other internet
enabled device when you visit an on-line site. Cookies and similar technologies
are widely used to make websites work efficiently and to collect information
about your online preferences.  For simplicity, we refer to all these
technologies as "cookies".

Some of our website pages may contain electronic images known as web beacons
(also known as clear gifs, tags or pixels) that allow us to count users who have
visited our pages. Web beacons collect only limited information, e.g. a cookie
number, time and date of a page view, and a description of the page on which the
web beacon resides. We may also carry web beacons placed by third party
advertisers. These beacons do not carry any information that could directly
identify you.

We also include web beacons in e-mail messages or newsletters to track whether
you open the messages. We use this information to customize our services and
measure the overall effectiveness of our online content, advertising campaigns,
and products and services we offer through the Site. Flash cookies operate
differently than browser cookies, and cookie management tools available in a web
browser will not remove flash cookies. To learn more about how to manage flash
cookies, you can visit the Adobe website and make changes at the Global Privacy
Settings Panel.

More detailed information on how we use cookies and other web technologies can
be found here.


9. MISCELLANEOUS

9.1 LINKS

We provide links to other websites or resources that are not part of the
products, programs, or services run by Gartner. We do not control these websites
or their privacy practices, and any information you provide to these sites is
subject to the Privacy Policies of those sites and not this Policy.

9.2 CHANGES TO THIS POLICY

From time to time, we may change and/or update this Policy. If this Policy
changes in any way, we will post an updated version on this website. We
recommend you regularly review this website to ensure that you are always aware
of our information practices and any changes to such. Any changes to this Policy
will go into effect on posting to this page.


10. CALIFORNIA PRIVACY RIGHTS & NOTICE OF COLLECTION

California law requires us to provide California residents with additional
information regarding how we collect, use, and share your “personal information”
(as defined in the California Consumer Privacy Act (“CCPA”)).

Categories of personal information we collect. In Section 1 above, and otherwise
throughout this Policy, we discuss in detail the specific pieces of information
we collect from and about users.  Below are the categories of personal
information we collect: 

 * Identifiers (such as name and title, contact details, and company name);
 * Internet or other network or device activity (such as browsing history or app
   usage); 
 * Inference data about you; and
 * Other information that identifies or can be reasonably associated with you.

Use of categories of personal information. We may disclose the categories of
personal information identified above for our operational purposes where the use
is reasonably necessary and proportionate to achieve the operational purpose for
which it was collected or processed, or for another compatible operational
purpose.

Sale of Personal Information. The CCPA sets forth certain obligations for
businesses that “sell” personal information.  Based on the definition of “sell”
under the CCPA and under current regulatory guidance, we do not believe we
engage in such activity and have not engaged in such activity in the past twelve
months (including that we do not “sell” the personal information of minors under
16 years of age).  We do share certain information as set forth in Sections 1
and 2 of this Policy, and allow third parties to collect certain information
about your activity, for example through cookies, as explained in our Cookie
Policy.  

Individual Rights. California law may provide you with certain rights and permit
you to request the following:

 * Provide you the categories of personal information we have collected or
   disclosed about you in the last twelve months; the categories of sources of
   such information; the business or commercial purpose for collecting or
   selling your personal information; and the categories of third parties with
   whom we shared personal information.
 * Provide access to and/or a copy of certain information we hold about you.
 * Delete certain information we have about you.

You may have the right to receive information about the financial incentives
that we offer to you (if any). You also have the right to not be discriminated
against (as provided for in applicable law) for exercising certain of your
rights. Certain information may be exempt from such requests under applicable
law. For example, we need certain types of information so that we can provide
the Services to you and for compliance with applicable law. If you ask us to
delete certain information, you may no longer be able to access or use the
Services.

If would like to exercise any of these rights, please complete the form at
www.gartner.com/personaldatarequest or send your written request to Data
Protection Counsel, Americas, Gartner, 1201 Wilson Blvd., Arlington, VA. You
will be required to verify your identity before we fulfill your request. You can
also designate an authorized agent to make a request on your behalf. To do so,
you must provide us with written authorization or a power of attorney, signed by
you, for the agent to act on your behalf. You will still need to verify your
identity directly with us.

Subject to certain limits under California Civil Code § 1798.83, California
residents may request certain information regarding our disclosure of
information to third parties for their direct marketing purposes. To make such a
request, please contact us as specified at the beginning of this Privacy Policy.

California Online Privacy Protection Act Notice Concerning Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. We do not recognize or respond to browser-related DNT signals, as the
industry is currently working toward a common approach to responding to DNT. To
learn more about Do Not Track, please click here.


11. NEVADA PRIVACY RIGHTS

Nevada law requires us to provide certain Nevada consumers the ability to opt
out of the “sale” of “personally identifiable information” as such terms are
defined under Nevada law.  We do not engage in such activity; however, if you
are a Nevada resident who has purchased goods or services from us, you may
submit a request to opt out of any potential future sales under Nevada law by
emailing privacy@gartner.com. Once verified, we will maintain your request in
the event our practices change.  

HOW TO CONTACT US

Questions, comments and requests regarding this Privacy Policy should be
addressed to our Data Protection Office through the following means:


Global Data Protection Office
Legal Department
56 Top Gallant Road
Stamford, CT 06902
USA
Email Address: privacy@gartner.com

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