PULSE Q&A INC.

PRIVACY POLICY

Last Updated: March 9, 2020



 

  • INTRODUCTION

 

 

Pulse Q&A Inc. (“Pulse Q&A,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Pulse Q&A Platform (the “Platform”) through Pulse Q&A’s website at www.pulse.qa (the “Website”) or Pulse Q&A’s mobile application (the “App”).

 

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.

 

The capitalized terms have the same meaning as ascribed in our Terms of Service, unless otherwise noted here.

 

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU REGISTER FOR OUR SERVICE OR WEBSITE, CREATE AN ACCOUNT FOR OUR SERVICE OR ON OUR WEBSITE, OR USE OUR SERVICE OR WEBSITE, YOU AGREE THAT: (A) YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY; (B) REPRESENT THAT YOU ARE AT LEAST 18 YEARS OLD; (C) YOU CAN FORM A BINDING CONTRACT; AND (D) YOU ACCEPT THIS PRIVACY POLICY AND AGREE THAT YOU ARE LEGALLY BOUND BY ITS TERMS AS WELL AS OUR TERMS & CONDITIONS REFERENCED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS, REGISTER AND USE OUR WEBSITE, APP, AND PLATFORM.

 

WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. 

 

WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUB PROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU. 

 

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT support@pulse.qa.

 

 

  • WHAT INFORMATION DO WE COLLECT?

 

 

When you register or create an account to use our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which will be stored on our servers and which may include the following:

  1. Your name;
  2. Online contact information such as your email address or username;
  3. Professional or employment-related information such as medical associations, bar associations, engineering societies, employer, business title, business address, etc.;
  4. 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;
  5. A photograph, video or audio file containing an image or voice;
  6. Geolocation information that can identify a street name and the name of a city or town; and 
  7.  Other personal information (collectively, the “Personal Information”).

 

Note that Personal Information is commonly referred as personal information or PII in the US and it is commonly referred to as Personal Data in Europe. Throughout this Privacy Policy, we will refer to the information so collected as Personal Information, unless a statutory definition otherwise applies.

 

Users are able to change their personal information via email by contacting us at support@pulse.qa; through their profile or account settings, or via chat or ticket on our Website, App, or Platform.  We collect the following information when you register on our Platform:

 

  1. Account Information. When you register to use our Platform or when you create an account, we will collect your personal information. We may also collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details.

 

  1. Financial Information. We currently do not collect or store any credit cards or bank information. However, we will update this Privacy Policy when we start using and storing such information. We will also inform you via reasonable means if we start collecting such information from you.

 

 

  • HOW DO WE COLLECT INFORMATION?

 

 

We collect personal information from you in the following ways:

 

  1. At registration on our Website, App, or Platform; 
  2. In email, text, and other electronic messages between User and our Website, App, or Platform;
  3. Through mobile and desktop applications User downloads from our Website, App, or Platform, which provides dedicated non-browser-based interaction between User and our Website, App, or Platform; 
  4. When User interacts with our advertising and applications on third-party website and  services, if those applications or advertising include a link to this Privacy Policy; 
  5. When User subscribes to a newsletter; 
  6. From User’s responses to a survey; 
  7. From forms filled out by User; 
  8. From records or copies of correspondences (including email addresses) if User contacts us; 
  9. From search queries on our Website, App, or Platform; and
  10. When User posts information to be published or displayed on our Website, App, or Platform. 

 

We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:

 

  1. Usage details; 
  2. IP addresses; 
  3. Information obtained through browser cookies; 
  4. Information obtained through flash cookies; 
  5. Web beacons on our Website; 
  6. Web beacons on emails sent by us; and
  7. Other tracking technologies. 

 

 

  • HOW DO WE USE YOUR INFORMATION?

 

 

We use the information that you provide to:

 

  1. Personalize User experience in using our Platform; 
  2. Provide Users with information, products, or services requested from us;
  3. Present our Website, App, and Platform and their contents to Users;
  4. Provide Users with notices about account and/or subscription, including expiration and renewal notices;
  5. Notify Users about changes to our Website, App, and Platform and any products or services; 
  6. Allow Users to participate in interactive features on our Website, App, and Platform; 
  7. Improve the Website, App, and Platform; 
  8. Improve our customer service;
  9. Administer contests, promotions, and surveys or other Website, App, and Platform features; 
  10. Anonymize data and aggregate data for statistics to be shared anonymously with our customer;
  11. Contact Users about our products and services that may be of interest; 
  12. Contact Users about third parties’ goods and services; 
  13. Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without User’s consent; and
  14. 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. 

 

 

  • OUR COOKIE POLICY

 

 

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.” 

 

We use Cookies on our Website and App to (a) understand and save User’s preferences for future visits, (b) keep track of advertisements, (c) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future, and (d) allow trusted third-party services that track this information on our behalf.  You can set your browser to refuse all or some browser Cookies, and it will not affect User experience. We do not honor Do Not Track signals.

 

We allow third party behavioral tracking and links to third-party web pages.  Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App, or Platform.  These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback at about these sites. Please contact us at support@pulse.qa.



 

  • HOW DO WE PROTECT INFORMATION WE COLLECT?

 

 

Our Website and App are reasonably scanned to meet or exceed PCI Compliance. Our Website 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 our Website and App.  

 

 

  • DATA SECURITY MEASURES.

 

 

  1. 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. 

 

  1. 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

 

 

  1. Disclosure of Personal Information. 

 

  1. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.  
  2. We will only disclose personal information as described in this Privacy Policy or with the written consent of the User. 

iii. We provide non-Personal Information (disaggregated, de-personalized) to other parties for marketing, advertising, or other uses.



  1. Other Disclosure of Personal Information. 

 

We will disclose personal information (i) to comply with any court order, law, or legal process, i including to respond to any government or regulatory request. In the future, we may disclose your Personal Information (i) if we believe it is necessary or appropriate to protect the rights, property, or safety of Pulse Q&A, our customers or others, and/or (ii) if it is necessary or appropriate to protect the rights, property, or safety of Pulse Q&A, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

  1. Choices Users Have About How Pulse Q&A Uses and Discloses Information. 

 

  1. Disclosure of Users’ Information for Third-Party Advertising.  Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Pulse Q&A for product purchases, warranty registration, or other transactions.    

 

  1. Disclosure of User’s Information for Targeted Advertising.  Users can opt-out by emailing us their opt-out request at support@pulse.qa or write us at Pulse Q&A Inc., 795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA. 

 

 

  • GOOGLE ADSENSE AND GOOGLE ANALYTICS

 

 

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website and App usage data. To learn more about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google-partners

 

We have implemented advertising features on our Website, App, and Platform including: (a) remarketing with Google AdSense; (b) Google Display Network Impression Reporting; and (c) Google Demographics and Interests Reporting.

 

We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App. 

 

 

  • YOUR CALIFORNIA PRIVACY RIGHTS

 

 

Pulse Q&A does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil 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 support@pulse.qa or write us at Pulse Q&A Inc., 795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA .

 

Note that (i) if we delete your Personal 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 a while 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 support@pulse.qa 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 “Personal Information,” 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, and Platform 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 support@pulse.qa.

 

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:

  1. not use false or misleading subjects or email addresses; 
  2. identify the email message as an advertisement in some reasonable way; 
  3. include the physical address of Pulse Q&A, which is 795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA; 
  4. monitor third-party email marketing services for compliance, if one is used;
  5. honor opt-out/unsubscribe requests quickly; and
  6. 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 support@pulse.qa and we will promptly remove you from all future marketing correspondences.

 

 

  • GENERAL DATA PROTECTION REGULATION 

 

 

  1. For European Visitors, Consumers, and Customers

 

    1. 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 Personal Information), as defined in the General Data Protection Regulation (“GDPR”).

 

    1. 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.

 

    1. In such situations, however, we will still respond to let you know of our decision. 

 

    1. As used herein, “Personal Information” means any information that identifies you as an individual, such as:

 

      1. Your name;
      2. Online contact information such as your email address or username;
      3. Professional or employment-related information such as medical associations, bar associations, engineering societies, employer, business title, business address, etc.;
      4. 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;
      5. A photograph, video or audio file containing an image or voice;
      6. Geolocation information that can identify a street name and the name of a city or town; and 
      7.  Other personal information.

 

  1. U.S. Privacy Shield Certification. We have been granted by the U.S. Department of Commerce the EU-US and Swiss-US Privacy Shield Certification (collectively, the "Privacy Shield”). We comply with the Privacy Shield Principles with respect to the transport of Personal Information from the EU and Switzerland to the US for processing. On [certification date], the European Commission deemed the EU-U.S. Privacy Shield Framework adequate to enable data transfers under EU law. On [certification date], the Swiss Government announced the approval of the Swiss-U.S. Privacy Shield Framework as a valid legal mechanism to comply with Swiss requirements when transferring Personal Information from Switzerland to the United States. As such, we comply with the Privacy Shield Framework and Principles, including the Supplemental Principles (collectively the “Principles”) promulgated by the U.S. Department of Commerce and accepted by the EU and Switzerland (15 U.S.C. § 1512).  If there is a conflict between the terms and conditions of this Privacy Policy and the Privacy Shield Framework and Principles, the Privacy Shield Framework and Principles will govern. If we are no longer certified under the Privacy Shield Certification program, the transport of Personal Information from the EU or Switzerland will be governed by the EU Standard Contractual Clauses, described in Subsection c below. 

 

  1. EU Standard Contractual Clauses.  We will comply with the EU Standard Contractual Clauses with respect to the transfer of Personal Information from the EU to countries other than the US for processing. If there is any conflict between the terms and conditions in this Privacy Policy and your rights under the EU Standard Contractual Clauses, the terms and conditions in the EU Standard Contractual Clauses will govern. For the purposes of this Privacy Policy, “EU Standard Contractual Clauses” mean the standard contractual clauses for the transfer of Personal Information to processors established in third countries (Commission Decision 2010/87/EC).

 

  1. 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.

 

    1. Access.  You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.

 

    1. Rectification. If you believe that any Personal Information 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.

 

    1. Objection.  You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.

 

    1. Erasure.  You can request that we erase some or all of your Personal Information from our systems.

 

    1. Restriction of Processing. You can ask us to restrict further processing of your Personal Information.

 

    1. 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.

 

    1. Withdrawal of Consent.  If we are processing your Personal Information 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 Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

 

    1. 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 to https://ec.europa.eu/justice/article-29/structure/data-protection- authorities/index_en.htm to locate your Data Protection Authority.

 

    1. Response. We will respond to your inquiry within thirty (30) days of the receipt. 

 

 

 

  • MODIFICATIONS TO OUR PRIVACY POLICY

 

 

Pulse Q&A reserves the right, at its sole discretion, to change or modify this Privacy Policy at any time. In the event we modify this Privacy Policy, such modifications shall be binding on you only upon your acceptance of the modified Privacy Policy. We will inform you about the modifications on our Privacy Policy page on our Platform by posting a modified version of the Privacy Policy page, or by a comparable means within a reasonable time period. Your continued use of our Website, App, or Platform shall constitute your consent to such changes.

 

 

  • 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 Provider

Contact Information

AWS (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: 800-914-1220

Address: 170 Data Drive, Waltham, MA 02451

Zoominfo

Website: https://help.zoominfo.com/

Phone: (207) 883-7027

Address: 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 support@pulse.qa . 

 

  • 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 Copyright Act 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.

 

Pulse Q&A’s Copyright Agent to receive DMCA Takedown Notices is Mayank Mehta, support@pulse.qa, 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. 

 

 

  • CONTACT US. 

 

 

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

  • Privacy Officer
  • Email: support@pulse.qa
  • Address: Pulse Q&A Inc., 795 Folsom Street, Regus #1028, San Francisco, CA 94107, USA.

 

PLEASE NOTE: WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. IF YOU USE OUR WEBSITE, APP, AND/OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE, APP, AND/OR PLATFORM.