Last Updated: March, 2021
Pulse Q&A is committed to protecting the privacy of its Users whose information is collected and stored while using Pulse Q&A’s Platform through our Website or App.
WHAT INFORMATION DO WE COLLECT?
HOW DO WE COLLECT INFORMATION?
We collect personal information from you in the following ways:
a. At registration on our Website, App, or Platform;
b. In email, text, and other electronic messages between User and our Website, App, or Platform;
c. Through mobile and desktop applications User downloads from our Website, App, orPlatform, which provides dedicated non-browser-based interaction between User and our Website, App, or Platform;
e. WhenUser subscribes to a newsletter;
f. FromUser’s responses to a survey;
g. From forms filled out by User;
h. From records or copies of correspondences (including email addresses) if User contacts us;
i. From search queries on our Website, App, or Platform; and
j. WhenUser posts information to be published or displayed on our Website, App, orPlatform. We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways: Usage details; IP addresses; Information obtained through browser cookies; Information obtained through flash cookies; Web beacons on our Website; Web beacons on emails sent by us; and Other tracking technologies.
HOW DO WE USE YOUR INFORMATION?
We use the information that you provide to:
a. Personalize User experience in using our Platform;
b. ProvideUsers with information, products, or services requested from us;
c. Present our Website, App, and Platform and their contents to Users;
d. Provide Users with notices about account and/or subscription, including expiration and renewal notices;
e. Notify Users about changes to our Website, App, and Platform and any products or services;
f. AllowUsers to participate in interactive features on our Website, App, and Platform;
g. Improve the Website, App, and Platform;
h. Improve our customer service;
i. Administer contests, promotions, and surveys or other Website, App, and Platform features;
j. Anonymize data and aggregate data for statistics to be shared anonymously with our customer;
k. Contact Users about our products and services that may be of interest;
l. Contact Users about third parties’ goods and services;
m. Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without User’s consent; and
n. Send User periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 13, via the email address provided by User to (i) send information, respond to inquiries, and/or other requests or questions; (ii)send additional information related to User’s product and/or service; and (iii)market to our mailing list or continue to send email to User after the original transaction has occurred.
HOW DO WE PROTECT INFORMATION WE COLLECT?
Our Website and App are reasonably scanned to meet or exceed PCI Compliance. OurWebsite and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access the personal information of Users that we store and/or process on our Platform and servers.In addition, we actively prevent third parties from getting access to the personal information of Users that we store and/or process on our Platform and servers. We accept payment by credit-card through a third-party credit card processor on our behalf. We will implement reasonable security measures every time you (a) enter, submit, or access your information, (b) register, or (c) access our Platform, on ourWebsite and App.
DATA SECURITY MEASURES.
Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, Platform, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform. Fair Information Practice Principles. In the event of a personal data breach, we will notify the User within 72 hours via (i) email, and/or (ii) our Platform notification system on our Website and/or App. We will also notify the FTC, FCC and/or any other relevant state regulatory agency. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
DISCLOSURE OF PERSONAL INFORMATION
GOOGLE ADSENSE AND GOOGLE ANALYTICS
YOUR CALIFORNIA PRIVACY RIGHTS
PulseQ&A does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the CaliforniaCivil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to email@example.com or write us at Pulse Q&A Inc., 795 Folsom Street, Regus #1028, San Francisco,CA 94107, USA . Note that (i) if we delete yourPersonal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for awhile during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at firstname.lastname@example.org or write us at Pulse Q&A Inc.,795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA.
COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)
The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “PersonalInformation,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, App, andPlatform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of persons identified as under 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at email@example.com.
IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM.
FOR OUR NEW YORK CUSTOMERS We will fully comply with the letter and the spirit of the New York Shield Act(the “Act’), which became effective on January 1, 2020, to the fullest extent that it is applicable to us. We have adopted reasonable safeguards to protect the security, confidentiality, and integrity of your private information, as defined in the Act ("Private Information").We will securely protect any personal information, as defined in the Act("Personal Information"), and/or Private Information in accordance with the requirements set forth in the Act. We will notify you of any unauthorized access to or disclosure of your Personal Information or your Private Information in accordance with the requirements of the Act.
CAN-SPAM ACT OF 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
a. not use false or misleading subjects or email addresses;
b. identify the email message as an advertisement in some reasonable way;
c. include the physical address of Pulse Q&A, which is795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA;
d. monitor third-party email marketing services for compliance, if one is used;
e. honor opt-out/unsubscribe requests quickly; and
f. give an “opt-out” or “unsubscribe” option. If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at firstname.lastname@example.org and we will promptly remove you from all future marketing correspondences.
GENERAL DATA PROTECTION REGULATION
For European Visitors, Consumers, and Customers.
(i) If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing of your Personal Data (referred here as PersonalInformation), as defined in the General Data Protection Regulation (“GDPR”).
(ii) Please note that in some circumstances, we may ask you to provide us with additional information in connection with your request, which may be Personal Information, for example, if we need to verify your identity or the nature of your request. (iii) In such situations, however, we will still respond to let you know of our decision.
(iv) You have the right to access the personal data that we store on you. We are subject to the investigation and enforcement powers of the Federal TradeCommission (FTC). You may require us to arbitrate your complaints under certain circumstances. We will be liable to you for any unauthorized transfers of your personal data to third parties.
(v) You may also be able to invoke binding arbitration for unresolved complaints but prior to initiating such arbitration, a resident of a European country participating in the Privacy Shield must first: (1) contact us and afford us the opportunity to resolve the issue; (2) seek assistance from BBB PRIVACYSHIELD; and (3) contact the U.S. Department of Commerce (either directly or through a European Data Protection Authority) and afford the Department ofCommerce time to attempt to resolve the issue. If such a resident invokes binding arbitration, each party shall be responsible for its own attorney’s fees. Please be advised that, pursuant to the Privacy Shield, the arbitrator(s)may only impose individual-specific, non-monetary, equitable relief necessary to remedy any violation of the Privacy Shield Principles with respect to the resident.
(vi) As used herein, “Personal Information” means any information that identifies you as an individual, such as:
i. Your name;
ii. Online contact information such as your email address or username;
iii. Professional or employment-related information such as medical associations, bar associations, engineering societies, employer, business title, business address, etc.;
iv. Persistent identifier that can be used to identify a user over time across different websites or other online services, such as a customer number stored in a cookie, IP address, of device or processor identifier;
v. A photograph, video or audio file containing an image or voice;
vi. Geolocation information that can identify a street name and the name of a city or town; and
(i) Obligations of the data importer(processors)The data importer agrees and warrants:
● to process the personal data only on behalf of the data exporter and in compliance with its instructions and the Clauses; if it cannot provide such compliance for whatever reasons, it agrees to inform promptly the data exporter of its inability to comply, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
● that it has no reason to believe that the legislation applicable to it prevents it from fulfilling the instructions received from the data exporter and its obligations under the contract and that in the event of a change in this legislation which is likely to have a substantial adverse effect on the warranties and obligations provided by the Clauses, it will promptly notify the change to the data exporter as soon as it is aware, in which case the data exporter is entitled to suspend the transfer of data and/or terminate the contract;
● that it has implemented the technical and organizational security measures before processing the personal data transferred;
● that it will promptly notify the data exporter about:● any legally binding request for disclosure of the personal data by a law enforcement authority unless otherwise prohibited, such as a prohibition under criminal law to preserve the confidentiality of a law enforcement investigation,● any accidental or unauthorized access, and
● any request received directly from the data subjects without responding to that request, unless it has been otherwise authorized to do so;
● to deal promptly and properly with all inquiries from the data exporter relating to its processing of the personal data subject to the transfer and to abide by the advice of the supervisory authority with regard to the processing of the data transferred;
● at the request of the data exporter to submit its data processing facilities for audit of the processing activities covered by the Clauses which shall be carried out by the data exporter or an inspection body composed of independent members and in possession of the required professional qualifications bound by a duty of confidentiality, selected by the data exporter, where applicable, in agreement with the supervisory authority;
● to make available to the data subject upon request a copy of the Clauses, or any existing contract for sub-processing, unless the Clauses or contract contain commercial information, in which case it may remove such commercial information, with the exception of Appendix 2 which shall be replaced by a summary description of the security measures in those cases where the data subject is unable to obtain a copy from the data exporter;
● that, in the event of sub-processing, it has previously informed the data exporter and obtained its prior written consent;(ii) Obligations of the data exporter.
The data exporter agrees and warrants:
● that the processing, including the transfer itself, of the personal data has been and will continue to be carried out in accordance with the relevant provisions of the applicable data protection law (and, where applicable, has been notified to the relevant authorities of the Member State where the data exporter is established) and does not violate the relevant provisions of that State;● that it has instructed and throughout the duration of the personal data processing services will instruct the data importer to process the personal data transferred only on the data exporter's behalf and in accordance with the applicable data protection law and the Clauses;
● that the data importer will provide sufficient guarantees in respect of the technical and organizational security measures;
● that after assessment of the requirements of the applicable data protection law, the security measures are appropriate to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing, and that these measures ensure a level of security appropriate to the risks presented by the processing and the nature of the data to be protected having regard to the state of the art and the cost of their implementation;
● that it will ensure compliance with the security measures;
● that, if the transfer involves special categories of data, the data subject has been informed or will be informed before, or as soon as possible after, the transfer that its data could be transmitted to a third country not providing adequate protection within the meaning of Directive 95/46/EC;
● to make available to the data subjects upon request a copy of the Clauses, with a summary description of the security measures, as well as a copy of any contract for sub-processing services which has to be made in accordance with theClauses, unless the Clauses or the contract contain commercial information, in which case it may remove such commercial information; and
● that, in the event of sub-processing, the processing activity is carried out in at least the same level of protection for the personal data and the rights of the data subject as the data importer under the Clauses.
● The parties agree that any data subject, who has suffered damage as a result of any breach of the obligations referred above by any party or sub-processor is entitled to receive compensation from the data exporter for the damage suffered.
● If a data subject is not able to bring a claim for compensation in accordance with paragraph a against the data exporter, arising out of a breach by the data importer or his sub-processor of any of their obligations referred to above, because the data exporter has factually disappeared or ceased to exist in law or has become insolvent, the data importer agrees that the data subject may issue a claim against the data importer as if it were the data exporter, unless any successor entity has assumed the entire legal obligations of the data exporter by contract of by operation of law, in which case the data subject can enforce its rights against such entity. c. Rights of the Data Subject. To make any of the following requests, please contact us (i) via email at [email address], (ii) by phone at our toll-free number 1-8[__-____],or (iii) by writing to us at Privacy Officer, 795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA.
(i) Access. You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
(ii) Rectification. If you believe that any PersonalInformation we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
(iii) Objection. You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
(iv) Erasure. You can request that we erase some or all of your Personal Information from our systems.
(v) Restriction of Processing.You can ask us to restrict further processing of your Personal Information.
(vi) Portability. You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
(vii) Withdrawal of Consent. If we are processing your PersonalInformation based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your PersonalInformation, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
(viii) Right to File Complaint. You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. Please go tohttps://ec.europa.eu/justice/article-29/structure/data-protection- authorities/index_en.htm to locate your Data Protection Authority.
(ix) Response. We will respond to your inquiry within thirty (30) days of the receipt.
LIST OF THIRD-PARTY SERVICE PROVIDERS
Pulse Q&A uses the following third-party service providers for the provision of services as detailed under the Terms of Service.Name of Third-Party Service ProviderContact InformationAWS (US) Website: https://aws.amazon.com/premiumsupport/knowledge-center/aws-phone-support/Address: 410 Terry Avenue North, Seattle, WA 98109-5210 DiscoverDB Website: https://discoverorg.com/Phone: 800-914-1220Address: 170 Data Drive, Waltham, MA 02451 ZoomInfo Website: https://help.zoominfo.com/Phone: (207) 883-7027Address: P.O. Box 335, Scarborough, Maine, 04070, United States Additionally, if you have any questions or concerns about our third-party service providers, please email us at email@example.com.
COPYRIGHT INFRINGEMENT/DMCA NOTICE
If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium CopyrightAct of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.
● Your physical or electronic signature;
● Identification of the copyrighted work(s) that you claim to have been infringed;
● Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove;
● Sufficient information to permit us to locate such material;
● Your address, telephone number, and email address;
● A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
● A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner. PulseQ&A’s Copyright Agent to receive DMCA Takedown Notices is Mayank Mehta, firstname.lastname@example.org, at Pulse Q&A, Attn: DMCA Notice, 795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. §512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Pulse Q&A in connection with the written notification and allegation of copyright infringement.