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PULSE Q&A PRIVACY POLICY


Effective Date: December 2021



Pulse Q&A, (“Pulse Q&A,” “we,” “us,” or “our”) a wholly owned subsidiary of
Gartner Inc., is 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.This Policy only applies to
data collected by Pulse Q&A and does not apply to Gartner Inc. and its other
associated group companies, products, and/or services, www.gartner.com, or
Gartner entities which have their own applicable privacy notices: Evanta,
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 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 
privacy@gartner.com


UK:


Gartner UK Limited
The Glanty
Egham
Surrey
TW20 9AH 
privacy@gartner.com



Introduction
‍Effective Date: December 2021
‍
This Policy sets out how we collect and use personal information when you use
the Pulse Q&A Platform (the “Platform”) through our website at www.pulse.qa (the
“Website”) or our mobile application (the “App”), and your choices and rights
regarding our use of your personal information.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 when you register for an account and use the Website or
the App:



Categories of information we collect about you include:


 * Information you provide when you register for an account on the Platform,
   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 profile, including links to your
   LinkedIn and/or Twitter profiles;
 * Communications with you;
 * Your responses to various surveys on the Platform;
 * 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
   using the Platform;
 * When you link your Pulse Q&A account 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 Pulse Q&A account;
 * Enabling you to access your Pulse Q&A account across devices;
 * Personalizing your Pulse Q&A experience;
 * For internal analysis and research to help us improve our services;
 * Administering our website and app, investigating any complaints and providing
   customer service;
 * To administer contests, promotions, and surveys or other Platform features;
 * To contact you about products and services that may be of interest, including
   third parties’ goods and services;
 * To enable ads to be displayed to our advertisers’ target audiences (though
   personal information is not shared with advertisers without your consent);
 * 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; a legitimate business interest to:
 * 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 app 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.

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 service;
 * Detecting and preventing fraudulent and/or unlawful use of our website;
 * 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.    

1.2 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, 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.

‍Payment Card Information

‍Where you choose to pay for any Pulse Q&A 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.
‍


2. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION



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


 * To other Gartner group companies in order to process the data for the above
   mentioned purposes;
 * When we have your consent to do so; 
 * 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 Pulse Q&A or Gartner Inc. 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.
‍


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 exercise any of these rights, please contact us. 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.


4. INTERNATIONAL TRANSFERS



Pulse Q&A is a wholly owned subsidiary of Gartner, a global company, and we may
transfer personal information to other Gartner group companies or suppliers
outside your country. We will take reasonable steps to ensure that personal
information is protected and any such transfers comply with applicable law.

We 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 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. 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.
‍


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.



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 Pulse Q&A. 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 you would like to exercise any of these rights, please email us at
privacy@gartner.com 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.  



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