Privacy Policy

v. 20200117

Last updated: January 17, 2020

This Privacy Policy explains how Pulse Insights LLC (“Pulse Insights”, or “we”, “us” or “our”) handles personal information that we collect

  • through our website at pulseinsights.com (the “Site”);
  • about users of the Pulse Insights service (the “Service”);
  • in connection with our marketing activities;
  • in other settings where we post this Privacy Policy.

Pulse Insights respects your privacy rights and is committed to transparency in how we collect, use and share your personal information. If you have any questions or concerns about your personal information or this Privacy Policy, email us at privacy@pulseinsights.com.

 

1. Service and Customer Data

Registered users of the Service (“Customers”) are businesses that use it to collect and manage information about their own users (“Customer Data”), including information about their opinions, feedback, and preferences. Pulse Insights also collects information about how they interact with the Customer’s websites, applications, email, and services   and designated third-party partners (“Customer Services”) . Customers also use the Service to more efficiently route Customer Data to the other services that they use or to third parties that they work with, and to control how Customer Data is exchanged between these services and third parties.

Customer Data may include, without limitation, information about the identity of Customer users (such as name, postal address, email address, IP address and phone number), as well as information that the user explicitly provides such as feedback, opinions, data, or preferences. It also includes information about the pages users visit, the features they use, and the actions they take while using Customer Services. This Privacy Policy does not apply to Customer Data   or to Customer Services , and we are not responsible for our Customers’ handling of Customer Data. Our Customers have their own policies regarding the collection, use and disclosure of your personal information. To learn about how a particular Customer handles your personal information, we encourage you to read the Customer’s privacy policy. Our use of Customer Data provided by our Customers in connection with our Service is subject to the written agreement between Pulse Insights and Customer.

 

2. Personal Information We Collect.

 

a. Information you give us.

Personal information that you may provide to us through the service or otherwise, including:

• Contact information, such as your first name, last name, professional title, organizational affiliation, postal address, office location, email address and telephone number;

• Profile information, such as your username, password and preferences;

• Communications, such as information you provide when you respond to surveys, participate in market research activities, participate in telephone conferences with our representatives (which may be recorded with your permission where permitted by law); report a problem with Service, receive customer support or otherwise communicate with us;

• Transaction information, which may include such as the credit card or other payment card details that you use to pay for the Service, and your Service-related billing information and transaction history;

• Marketing information, such your preferences for receiving marketing communications and details about how you engage with them; and

• Other information that you choose to provide but is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

b. Information from third-party sources.

We may combine personal information we receive from you with personal information we obtain from other sources, such as our Customers; data providers; affiliates within our corporate group of companies; business partners, such as joint marketing partners and event co-sponsors; and publicly accessible sources, such as social media platforms.

c. Data collected automatically.

We, our service providers, and our business partners may automatically log the following information about you, your computer or mobile device, and your activity over time on the Site and other online services:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city or town.

• Usage data, such as the website you visited before browsing to the Site, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Some of our automatic collection is facilitated by:

Cookies and local storage, which are text files stored on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently and remembering your preferences, enabling functionality, helping us understand user activity and patterns, facilitating online advertising and measuring the effectiveness of our ads.

Javascript libraries, which are snippets of code within web pages that execute when certain actions take place.

Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content within it was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

For more information about the use of these technologies on the Site, see our Website Data Collection Policy.

Sensitive personal information

We ask that you not share with us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Service or otherwise. If you do anyway, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy.

Changes to your personal information

Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at privacy@pulseinsights.com.

 

3.     How We Use Your Personal Information

We use your personal information for the following purposes or as otherwise described to you at the time of collection:

a.     Service delivery

We use your personal information to:

• provide, operate, maintain, and improve the Service;

• communicate with you regarding the Service if you are a Customer, including by sending you Service announcements, technical notices, updates, security alerts, and support and administrative messages;

• understand your needs and interests, and personalize your experience with the Service; and

• provide support for the Service and respond to your requests, questions and feedback.

          

b.     Site operation

We use your personal information to:

• provide, operate, maintain and improve the Site;

• understand your needs and interests, and personalize your experience with the Site; and

• provide support for the Site and respond to your requests, questions and feedback.

c.     Research and development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and develop other products and services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

d.     Marketing.

We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. If you request information from us, use the Service or participate in our surveys, promotions or events, we may send you Pulse Insights-related marketing communications as permitted by law but will provide you with the ability to opt out.

• Interest-based advertising. We may contract with third-party advertising and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising, in the Advertising choices section below.

e. Compliance and protection.

We may use your personal information to:

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements and internal policies;

• enforce our Terms of Service;

• protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and

• comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

f.  Other purposes with your consent

In some cases we will ask for your consent to collect, use or share your personal information for other purposes. For example, we may ask for your consent to send you marketing emails where required by law or to post your testimonial or endorsement.

 

4.     How We Share your Personal Information

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

• Service Providers. We may employ companies and individuals to help provide the Site or Service on our behalf or help us operate our business (such as IT, customer support, hosting, website analytics, email delivery, marketing and advertising, research, event management). They are permitted to use your personal information only as authorized to perform these tasks in a manner consistent with this Privacy Policy.

• Payment processors.  Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, Quickbooks, and we never physically receive or store your full payment card information.

• Advertising partners. We work with third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services (including, through interest-based advertising), and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

• Customers. When you have an organization-administered account your organization can access your information as described in the Organization-Administered Accounts section below.

• Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates for use consistent with this Privacy Policy.

• 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 they render to us.

• Compliance and protection. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties (a) for the compliance and protection purposes described above; (b) as required by law, lawful requests or legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with any legal investigation; and (d) to prosecute or defend legal claims.

• Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy.

 

5. Your Choices

Access, Update, Correct or Delete Your Information.

Customers may review, update, correct or delete the personal information in their registration profile by logging into their account or emailing us at privacy@pulseinsights.com.

Access to Data Controlled by our Customers.

Pulse Insights has no direct relationship with the individuals whose personal information is contained within the Customer Data processed by the Service. An individual who seeks to access, correct or delete this information should direct their request to the Customer.

Marketing communications

You may opt out of marketing-related emails by logging in and changing your account settings or by following the opt-out prompt in the email. You may continue to receive Service-related and other non-marketing emails.

Testimonials

If you gave us consent to post a testimonial to our site, but wish to update or delete it, please contact us.

Cookies

You may opt-out of certain cookie-based tracking activities on our Site. Additionally, most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Advertising choices

You can opt-out of data collection through our Site for interest-based advertising purposes in our Privacy Center center. You can limit use of your information for interest-based advertising by:

• Browser settings. Blocking third party cookies in your browser settings using or ad-blocking browser plug-ins/extensions.

• Mobile device settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Platform settings. Using Google’s and Facebook’s interest-based advertising opt-out features:

Google: https://adssettings.google.com/

Facebook: https://www.facebook.com/about/ads

• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:

Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp

European Interactive Digital Advertising Alliance (for European users): http://www.youronlinechoices.eu/

Digital Advertising Alliance:

optout.aboutads.info, which lets you opt-out of interest-based ads on websites.

AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which lets you opt-out of interest-based ads in mobile apps.

The opt-out preferences described above must be set on each device for which you want them to apply. Not all companies that serve interest-based ads participate in the ad industry opt-out programs described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide your personal information

If you do not provide information indicated as required or mandatory within the Service, or that is otherwise necessary to provide a requested service or feature within the Service, that portion or all of the Service may be unavailable to you.

6.     Security

The security of your personal information is 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.

7.     International Data Use

Pulse Insights is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country.

Individuals in the European Economic Area should read the important information provided below about transfer of personal information outside of the European Economic Area.

8.     Third Party Sites and Services

The Service may contain links to other websites and services operated by third parties, such as social media platforms, advertising services and other websites and applications. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and disclosure of your personal information. We encourage you to read their privacy policies to learn more.

9.     Children

No part of Pulse Insights’ Service is directed at children, and Pulse Insights does not knowingly acquire or receive personal information from, children under the age of 16. If we learn that any user of the Service is under the age of 16, we will take appropriate steps to delete that individual’s personal information and restrict that individual from future access to the Service.

10.  Organization-Administered Accounts

Where the Service is provided to you through your employer or another organization, please note that your organization’s administrator may be able to:

• require you to reset your account password;

• restrict, suspend or terminate your access to the Service;

• access and retain information in and about your account;

• access or retain information stored as part of your account;

• change the email address associated with your account;

• change your information, including profile information; and

• restrict your ability to edit, restrict, modify or delete information.

Please contact your organization or refer to your administrator’s organizational policies for more information.

11.  Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy we will notify you by email (if you have an account linked to a valid email address) or another manner through the Service that we believe is reasonably likely to reach you.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes in the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any updated Privacy Policy indicates your acceptance of the update.

12.  Contact Us

If you have any questions or concerns about our Privacy Policy, please contact us.

Pulse Insights LLC
175 Varick St. 4th Fl
New York, NY 10014
Attention: Data Protection Officer
Email:privacy@pulseinsights.com

 

Important Information for California Residents

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

 

Your California privacy rights

You have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

The categories of Personal Information that we have collected.

The categories of sources from which we collected Personal Information.

The business or commercial purpose for collecting and/or selling Personal Information.

The categories of third parties with whom we share Personal Information.

Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.

Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

Deletion. You can ask us to delete the Personal Information that we have collected from you.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

How to exercise your information, access and deletion rights.

You may submit a request to exercise your information, access or deletion rights by visiting emailing privacy@pulseinsights.com or emailing us toll-free at (888) 718 – 6860. We will need to verify your identity to process your information, access and deletion requests and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.

We do not sell your personal information.

Based on our current understanding of the CCPA, we do not “sell” your personal information as defined in the CCPA. However, like many companies online, Pulse Insights uses services provided by Google, Facebook and other advertising companies that track website visitor activity to help deliver interest-based ads to those visitors. We describe this in more detail in the section above entitled Interest-based advertising.

Personal information we collect, use and disclose.

The chart below describes the categories of Personal Information we collect by reference to the categories specified by the CCPA (California Civil Code § 1798.140(o)).

Statutory category of personal information (PI)

PI we collect

Sources of the PI

Business/commercial purpose for PI collection

Parties to whom we disclose PI for a business  purpose

Identifiers (general)

- Contact information
- Profile information

- You
- Third party sources

- Service delivery
- Research & development
- Marketing
- Compliance & Protection

- Advertising  partners
- Service  providers

Commercial Information

- Communications
- Marketing Information

- You
- Third party sources

- Service delivery
- Research & development
- Marketing
- Compliance & Protection

- Service providers

Financial Information

- Transaction information

- Our Customers

- Service delivery- Compliance & Protection

- Payment processors
- Service providers

Identifiers  (online)

- Device data

- You
- Automatic collection

- Service delivery
- Site operation
- Research & development
- Marketing
- Compliance & Protection

- Advertising partners
- Service providers

Internet or Network Information

- Online activity data

- Automatic collection

- Service delivery
- Site operation
- Research & development
- Marketing
- Compliance & Protection

- Advertising partners
- Service providers

Professional or Employment Information

- Contact information
- Profile information

- You
- Third party sources

- Service delivery
- Research & development
- Marketing
- Compliance & Protection

- Service providers

Sensory Information

-Communications

- You

- Marketing
- Compliance & Protection

- Service providers

Inferences

User preferences derived from any of the information listed above that we collect from Customers

- Us

- Service delivery
- Site Operation
- Research & development
- Marketing
- Compliance & Protection

- Service providers

We may further disclose each category of Personal Information to our affiliates, to our professional advisors, in connection with our compliance and protection activities and in connection with business transfers as described in the section above entitled How We Share Your Personal Information.

This chart describes our practices as of, and during the 12 months preceding, the effective date of this Privacy Policy.

 

Additional Information for European Union Users

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller, Data Protection Officer and EU Representative. Pulse Insights LLC is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation and you can contact us and our Data Protection Officer using the contact details listed in the Contact Us section above.

 

Our EU representative is:

Osano International Compliance Services Limited
ATTN: KQWI
25/28 North Wall Quay
Dublin 1, D01 H104
IRELAND Email: privacy@pulseinsights.com

 

Legal bases for processing.

The legal bases on which we process your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). 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

Service delivery & Site Operation

Processing is necessary to perform the contract governing our operation of the Site or the provision of the Services, or to take steps that you request prior to engaging our Services. Where we cannot process your personal data as required to operate the Site or Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the Services you access and request.

Marketing

Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business.

Research & Development

Processing is based on our legitimate interests in performing research and development to improve our services and develop new services.

Compliance & Protection

Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety or property.

Other purposes 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 when you consent or in the Service.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

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.

Your rights

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 communications.

• 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 or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

If we transfer your personal information out of the European Economic Area or Switzerland and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Such safeguards may include applying the European Commission Model contracts for the transfer of personal data to third countries described here, or for transfers to third parties in the United States, ensuring they participate in the EU-U.S. Privacy Shield Framework or Swiss-U.S. Privacy Shield Framework. Please contact us for further information about any such transfers or the specific safeguards applied.

Pulse Insights itself has self-certified to the EU-U.S. and Swiss-U.S. Privacy Shield. For more information, see our Privacy Shield Notice.

Privacy Shield Notice

Effective as of January 17, 2020.

Pulse Insights LLC (“Pulse Insights” or “we”, “us” or “our”) complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred to it in the United States from the European Economic Area (“EEA”) or Switzerland, respectively. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield program, the Privacy Shield Principles and to view our certification, please visit www.privacyshield.gov.

Scope. Our certification of adherence to the Privacy Shield Principles applies to the personal data that (a) we collect from our customers and other visitors to our website for account management, billing or marketing purposes (“Pulse Insights User Data”) and (b) that we process on behalf of our customers in providing online services to them under a service agreement (“Services Data”).

Data processed. The Pulse Insights User Data that we collect, use and share is described in our Privacy Policy. While our customers decide what Services Data to submit, it typically includes information about their own users and how they use the customer’s sites, applications and services and third party applications. We process Services Data as instructed by our customers and do not own or control Services Data.

Purposes of data processing. We collect, use and share Pulse Insights User Data for the purposes described in our Privacy Policy. We process Services Data for the purpose of providing our online services to our customers, which may include accessing and processing the data to provide the services, to correct and address technical or service problems, to follow instructions of the customer who submitted the data, or in response to contractual requirements.

Inquiries and complaints

If you believe Pulse Insights maintains your personal data within the scope of our Privacy Shield certification, you may direct any inquiries or complaints concerning our Privacy Shield compliance to privacy@pulseinsights.com. If you are located in the EEA or Switzerland and have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/.

Arbitration

If you are located in the EEA or Switzerland and neither Pulse Insights nor our dispute resolution provider resolves your complaint, you may be entitled to invoke binding arbitration under certain conditions more fully described on the Privacy Shield website.

Third parties who may receive personal data

We share Pulse Insights User Data with third parties as described in our Privacy Policy. We may share Services Data with third parties under the following circumstances and only in accordance with the applicable customer agreements:

• Affiliates. We may disclose Services Data to our subsidiaries and corporate affiliates for use consistent with this Privacy Policy.

 • Service Providers. We may employ third party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, website analytics, email delivery, database management services). Pulse Insights maintains contracts with these service providers restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations, including the onward transfer provisions, and we may be liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

• Legal requirements. We may disclose Services Data if required to do so by law in order to (for example) respond to a subpoena or request from law enforcement, a court or a government agency, or in the good faith belief that such action is necessary (a) to comply with a legal obligation, (b) to protect or defend our rights, interests or property or that of third parties, (c) to prevent or investigate possible wrongdoing in connection with the services, (d) to act in urgent circumstances to protect the personal safety of customers, their users or the public; or (e) to protect against legal liability.

• Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Services Data may be part of the transferred assets.

In addition, we may be required to disclose any personal data that we process in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Your rights to access, to limit use, and to limit disclosure.

Individuals in the EEA and Switzerland have rights to access personal data about them, and to limit use and disclosure of their personal data. With our Privacy Shield self-certification, we have committed to respect those rights. We process Services Data only on behalf of our customers in accordance with their instructions. This means that if you wish to access Services Data and request that we correct, amend or delete it if it is inaccurate or processed in violation of Privacy Shield, you should contact that customer with your request. We will then help them to fulfill that request in accordance with their instructions.

If your personal data includes Pulse Insights Personal Data, you can request access to that data and request that we correct amend, or delete it if it is inaccurate or processed in violation of Privacy Shield by emailing your request to privacy@pulseinsights.com. 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.

U.S. Federal Trade Commission Enforcement.

Pulse Insights’s commitments under the Privacy Shield are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.   If there is any conflict between the terms in this Privacy Shield Notice and the Privacy Shield Principles, the Privacy Shield Principles shall take precedence.