Last updated: May 24, 2018
Use of the Subscription Service
Our online Subscription Service enables our business Clients to collect user feedback to improve business decision-making, collect user’s information & preferences to better personalize user experience, or to highlight relevant content on-site.
Use by Our Clients
Clients use our technology on their own sites, apps, and email campaigns to collect and analyze information such as users’ thoughts on product value and opportunities, brand affinity, shopping process, and page user experience. The service also collects information such as website and app engagement for content/survey/offer targeting and analysis.
Pulse Insights processes information as they direct and in accordance with our agreements with our Clients, and we store it on our service providers’ servers, but we do not have control over its collection or management. We have no direct relationship with end-user individuals who interact with our subscription service.
Pulse Insights acknowledges that you have the right to access your Personal Information. Our Clients control and are responsible for correcting, deleting or updating information they have collected from you using the Subscription Service. If requested to remove data we will respond within a reasonable timeframe to help our Clients do so.
Use of our Website
Our website enables prospective Clients to learn about our products or contact us for sales or other purposes.
Information We Collect
We collect information about you in the following ways:
Information you give us
Personal information that you may provide through the Service or otherwise communicate with us includes:
- Identity information, such as your first name and last name
- Contact information, such as your postal address, email address and telephone number;
- Profile information, such as your username and password, preferences
- Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive Client support or otherwise correspond with us;
- Financial information, such as your billing details;
- Marketing information, such your preferences for receiving marketing communications and details about how you engage with them;
Information we get from others
We may periodically obtain additional information about you from third party sources to enrich your experience on the Website and provide you with more relevant information related to our service offerings.
Information automatically collected
Our servers may automatically record certain information about how you use our Website and Subscription Service (we refer to this information as “Log Data“), including both Clients and casual visitors. Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our site to which a user browsed and the time spent on those pages or features, and other similar statistics. We use this information to administer the Website & Subscription Service and we analyze (and may engage third parties to analyze) this information to improve and enhance them to meet our users’ needs and preferences.
Sensitive Personal Information
Subject to the following paragraph, we ask that you not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, criminal background or union membership) on or through the Subscription Service or Website.
How We Use Information We Collect
To provide the Subscription Service
If you have a Pulse Insights account, we use your information:
- to operate, maintain, administer and improve the Subscription Service;
- to manage and communicate with you regarding your Service account, if you have one, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;
- to process payments
- to better understand your needs and interests, and personalize your experience with the Service; and
- to respond to your Service-related requests, questions and feedback.
To communicate with you
If you request information from us, register for the Subscription Service or participate in our surveys, promotions or events, we may send you Pulse Insights-related marketing communications if permitted by law, but will provide you with the ability to opt out.
To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
With your consent
We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Site, you instruct us to take a specific action with respect to your personal information or you opt into third party marketing communications.
To create anonymous data for analytics
We may create anonymous data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous data by aggregating data and excluding information that makes the data personally identifiable to you, and use that anonymous data for our lawful business purposes.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
How We Share your Personal Information
We disclose personal information to third parties under the following circumstances:
- Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
- Compliance with Laws and Law Enforcement; Protection and Safety. Pulse Insights may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Access, Update, Correct or Delete Your Information
All Pulse Insights Subscription Service account holders may review, update, or delete the personal information in their registration profile by logging into their account. Pulse Insights account holders may also contact us at Privacy@PulseInsights.com to accomplish the foregoing or if you have additional requests or questions.
Access to Data Controlled by our Clients
Pulse Insights has no direct relationship with the individuals whose personal information is contained within the Client User Data processed by our Service. An individual who seeks access, or who seeks to correct, amend, or delete personal information provided by our Client should direct their request to our Client. You may also contact us at Privacy@PulseInsights.com if you have additional questions or concerns.
You may opt out of marketing-related emails by clicking on a link at the bottom of each email. You may continue to receive Service-related and other non-marketing emails.
If you gave us consent to post a testimonial to our site, but wish to update or delete it, please contact us.
Tracking and Targeted Advertising
Choosing not to share your personal information
Where we need to collect your personal information by law, or to be able to provide the Service to you and you do not provide that information when requested (or you later ask to delete it), we may not be able to provide you with the Service and may need to close your account. We will tell you what information you must provide to receive the Service by designating it as required in the Service or through other appropriate means.
The security of your personal information important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.
Pulse Insights is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.
Other Sites and Services
The Service may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Social Media Widgets
User Generated Content
We may make available on our Site, or link to, features that allow you to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.
Pulse Insights does not knowingly acquire or receive personal information from children under 16. If we later learn that any user of our Service is under the age of 16, we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.
Legal Basis For Processing
We only use your personal information as permitted by law. We are required to inform you of the legal basis of our processing of your personal information, which are described in the table below. If you have questions about the legal basis of how we process your personal information, contact us at Privacy@PulseInsights.com.
|Processing purpose||Legal Basis|
|To provide the Service||Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service|
To communicate with you
To create anonymous data for analytics
For compliance, fraud prevention and safety
|These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||Processing is necessary to comply with our legal obligations|
|With your consent||Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at Privacy@PulseInsights.com.|
Use for new purposes
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our Clients (including Contact, Identity, Financial and Transaction Information) for six years after they cease being Clients for tax purposes.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to Privacy@PulseInsights.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at Privacy@PulseInsights.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the following safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation:
- Contracts approved by the European Commission which impose data protection obligations on the parties to the transfer. For further details, see European Commission Model contracts for the transfer of personal information to third countries.
- For transfers to third parties in the United States, ensuring they participate in the E.U.-U.S. Privacy Shield Framework
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
Pulse Insights, LLC
175 Varick St. 4th Fl
New York, NY 10014