CCPA
This privacy statement serves as a supplement to Identify Pulse Inc.'s privacy statement and has been in effect since April 2022. To stay in line with changes in applicable privacy laws and our practices in handling your personal information, we conduct regular reviews and updates to this policy. Any modifications to this policy will be communicated to you by updating the effective date and posting revised versions on our website. Specifically intended for residents of the State of California ("you," "consumer," or "us"), this privacy statement pertains to the personal data collected and utilized by Identify Pulse Inc. ("we," "us," or "our") in accordance with the California Consumer Privacy Act of 2018, as outlined on our websites and through other specified means (CCPA). If you are not a resident of the State of California, please refer to Identify Pulse Inc.'s Privacy Policy. This policy delineates our processes for handling, safeguarding, and managing customer information. Additionally, it addresses the CCPA rights of customers concerning how Identify Pulse Inc. manages their personal data.This policy does not encompass personal data gathered from workers, job applicants, consultants, contractors, or individuals in roles resembling employees residing in the State of California.As the terms governing such instances are governed by the relevant service agreements with our customers, this policy is not applicable to information acquired or managed in our role as a service provider on behalf of our customers.
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When you subscribe to our website or grant consent to our agents for the collection and processing of your personal data, we acquire your personal information. In instances where the information gathered is not detailed in this policy, we will notify consumers appropriately regarding the pertinent data we intend to collect and the manner in which we plan to process it.
In this policy, personal information is defined as data that has the potential to identify, locate, or establish contact with a consumer.
The categories of personal data we collect and utilize to execute the processing activities outlined in this policy include: Identifiers, such as your first and last names, email address, phone number, usernames on websites and social media platforms, or similar identifiers. Your work title, position description, employer, and location; along with any professional or employment-related details (e.g., office address). Internet or analogous network activity, such as information from your LinkedIn profile.
Our website abstains from using cookies or similar optimization technologies to gauge website traffic, monitor usage activity, or gather details such as visit date and time, geographic location, viewed pages, IP address, links to/from any page, browser type and version, operating system, referral source, and duration of website visits.
Additionally, emails, surveys, and alternative communication methods may be employed to collect additional personal information with your explicit permission.
Should you furnish us with personal information about another individual, it is your responsibility to apprise that person of the information contained in this policy and secure their consent to share such information with us.
In what manner do we obtain your personal information?
The aforementioned types of personal data are directly collected from you during your interactions with our website. Moreover, public sources such as social networking websites may be utilized to gather your confidential information. Your decision to provide us with your personal information is entirely voluntary, unless laws or Identify Pulse Inc. policies mandate specific information collection. It's important to note that if you choose not to provide the necessary personal information when requested, we may be unable to offer some or all of our services. How do we ensure the security of your personal information?
Identify Pulse Inc. delivers lead generation, ABM execution campaigns, BANT leads, and data services to businesses engaged in marketing and selling to other businesses. Our commitment to privacy and security protects every prospect who has granted permission for receiving marketing materials from us and our customers, as well as website visitors.
In alignment with relevant laws and privacy policies, we safeguard your personal information through robust technical, security, and administrative controls on systems handling its storage, transmission, and processing. This minimizes the risk of unauthorized access, disclosure, improper processing, accidental or deliberate loss, destruction, alteration, or damage. To secure both your personal information and that of our business, we adhere to protocols, policies, procedures, and guidelines compliant with leading industry standards.
Despite taking reasonable precautions to maintain the confidentiality of your personal information, it's essential to acknowledge that disclosing personal information online always carries some level of risk. If you have any concerns about the safety of your interactions with our website, please promptly contact us using the information provided in the section titled "How to reach us for privacy concerns."
What types of personal data from individuals do we collect?
We do not collect confidential personal information, as detailed below, through our website or any other channels. In the unlikely scenario where we decide to attempt gathering this information, it will be done with your explicit permission and in adherence to any relevant privacy laws.
Sensitive personal data encompasses various categories of personal information that, in accordance with data privacy laws, require special handling, including, in some instances, obtaining your prior consent before collection. These categories include details about an individual's race or ethnicity, political affiliations, religious or philosophical beliefs, as well as participation in trade unions, health information, biometric data, sexual orientation, and records of criminal convictions and offenses.
For what reasons do we utilize your personal information?
We limit access to your confidential information to our employees and contractors who require it solely for work-related purposes. Utilizing your personal details is done only when necessary for tasks such as adhering to applicable rules and regulations, addressing your inquiries, fulfilling your requests, providing customer support, delivering administrative information, and customizing your use of our services. We may also use your information to enhance the content and functionality of our website, market and promote our products and services, operate and manage our business operations, and fulfill our business obligations to you.
When gathering data, we may use it to contact you based on your specified preferences. For instance, your email address may be used to update you on services or information of interest, as well as to send you content and newsletters. Our communication may also involve ensuring proper communication and emergency handling, informing you about future services, opportunities, and general information, conducting market research for insights, and engaging in social listening to protect our image.
In compliance with applicable laws, we process your personal information for these purposes only with your consent. We refrain from using your personal information for any other objectives unless required or permitted by law, as detailed in this privacy statement.
The legal basis for collecting and using personal information is determined by the types of information collected and the specific context in which it is collected. Generally, we collect personal information when processing aligns with our legitimate interests and is not prohibited by your rights, when it is necessary for a transaction with you, or when you have given us permission to do so.
Will we share your private information with external parties?
Your personal information may be disclosed to third parties when you request it or grant us permission to do so, or in alignment with the objectives outlined in this policy. Where applicable, confidentiality agreements will be obtained from anyone or any entity with whom we share your personal information.
Moreover, in compliance with applicable laws and our internal policies, we will take necessary measures to ensure that any recipient of your personal information has the required security safeguards, a legitimate purpose for processing and using it, and may include the transfer of sensitive data to any of our locations. In the event of a corporate transaction, such as the sale of a website, mergers, consolidations, initial public offerings, or the unlikely occurrence of bankruptcy, we may disclose your confidential information to third parties.
Generally, your personal information may be shared with the following categories of third parties for the purposes described in this policy: Service providers assisting with specific services you receive from us, including customer care, email delivery, data processing and management, survey administration, and other fulfillment. Business associates, customers, advertisers, affiliates, and other third parties to customize and send advertisements and content to you about their services or to help you obtain marketing materials. When responding to subpoenas, court orders, legal processes, and other legal issues; law enforcement, regulators, courts, and other governmental agencies. To safeguard legal rights, personal property, personal safety, and the general public interest, your confidential information may also be disclosed to this type of third party. The sale of assets or business transfer in conjunction with a merger, takeover, transfer of control, bankruptcy, or reorganization.
For specific business objectives, the following types of personal data may be disclosed to the aforementioned third parties: Identifiers, Position and information related to your career or job, Internet or other comparable network activity.
We may sell the following types of personal information to our business partners, subsidiaries, advertisers, clients, and other third parties, or as part of a company or asset transfer: Identifiers, Position and information related to your career or job, Internet or other comparable network activity.
Where will the processing of your personal data take place?
Our primary business operations are located in Dubai, UAE. In accordance with relevant privacy legislation and our internal policies, your personal information may be transferred to or accessed from locations outside of the country as part of Identify Pulse Inc.'s global business.
What sources are utilized to acquire your personal data?
If we don't obtain your personal information directly from you, we may acquire it from public sources or through professional websites, such as LinkedIn.
How long will your confidential data be retained?
We retain your confidential information only for the duration necessary to fulfill a specific business or legal purpose. We adhere to records management and information retention procedures to ensure that after a predetermined period, your confidential information is either deleted, anonymized, or isolated, depending on what is deemed appropriate:
- Your personal information will be retained throughout the course of our business relationship.
- We will keep your personal information for as long as necessary to provide you with services.
- Your personal information will be retained for the time required to comply with applicable laws, contractual obligations, and internal policies.
How may you exercise control over the processing of your personal information?
Consumers in California are afforded rights under the CCPA, dictating the handling of their personal information. This segment delineates your CCPA entitlements and outlines the steps for their execution. Its purpose is to apprise you of the specific data we collect and your privilege to data portability.
The CCPA empowers you to request an exhaustive list of the precise personal information we have amassed and processed about you in the preceding twelve (12) months. Upon receipt and verification of your bona fide consumer request, we will furnish the following details:
- The types of personal data we have compiled about you.
- The sources from which we derive your personal information.
- The commercial purpose behind our collection or sharing of your personal data.
- The categories of third parties with whom we have shared the collected personal data.
- The distinct pieces of personal data we hold about you (commonly known as a Data Portability Request).
Should we have sold your personal information for specific business or commercial purposes, you will be duly informed of:
- The types of personal data acquired by each category of third party.
In instances where we shared your personal information for specific business, legal, or commercial purposes, we will disclose:
- The categories of personal information acquired by each category of third party.
Access rights for Business-to-Business (B2B) personal information, gathered for particular business or commercial purposes, are not extended.
Under specific circumstances, there may be no obligation to search for personal information. In such situations, we will elucidate, in response to your request, the categories of data that might encompass personal information but were not probed due to these circumstances.
Request us to delete the personal information we collected about you
Subject to certain limitations, the CCPA provides you with the right to request the deletion of any personal information we have collected and retained about you. Upon receiving and verifying your verifiable consumer request, unless an exception applies, we will erase your personal information from our records and instruct our service providers to do the same. However, based on our legal rights and obligations, we may either deny your deletion request or partially fulfill it for the following reasons:
- To execute a contract with you, complete a transaction for which we received your personal information, or perform the services you requested.
- To identify cybersecurity events, address data breaches, prevent malicious, fraudulent, or unlawful activities, and pursue criminal charges against those involved.
- To exercise our right to free expression, ensuring that other customers also have the same freedom, or for any other legal right.
- To comply with the California Electronic Communications Privacy Act (Cal. Criminal Code 1546 et seq.).
- To use your personal data in a manner compatible with the reason you provided it and based on our relationship with you.
- To adhere to laws and regulations.
Concerning Business-to-Business (B2B) personal information collected for a specific business or commercial purpose, the data deletion rights mentioned above are not applicable. However, you still have the rights to data access, portability, and deletion.
If you wish to exercise the outlined data access, portability, and deletion rights granted by the CCPA, please send a verifiable consumer request via email to Info@identifypulse.com or by mail to: 244 Fifth Ave, Suite Q230, New York, NY 10001.
A verifiable consumer request must be made by you or someone legally authorized to act on your behalf. You can also submit a verifiable consumer request on behalf of a minor (refer to the "Authorized Agent" section for details).
Within a twelve-month period, you are allowed to submit two verifiable consumer requests for data access or portability.
Your verifiable consumer request must contain sufficient details to verify your identity or the authorization of the person making the request. Depending on the sensitivity of the requested personal information, different verification measures will be employed. The request should also include a comprehensive description of your intention for us to comprehend, assess, appropriately respond to, and, if applicable, fulfill your request.
If we are unable to verify your identity or the right to make the request, and that the personal information pertains to you, we will be unable to respond or provide any personal information.
For website-submitted verified consumer inquiries, registration is not mandatory. We will only verify the identity or right to make the request using the personal information provided in the verifiable consumer request. To exercise your right to opt-out of the sale of your personal information, please refer to the "Do not sell my personal information" section in this Notice.
The timing and format of our response
Within a period of forty-five (45) days from the receipt of a verifiable customer request, we will make every effort to provide a response. If we anticipate that processing the request will take longer than expected, we will promptly notify you in writing, detailing the reason for the delay and the extended timeframe.
Our response to your verified consumer request will be communicated in writing, allowing you to choose between electronic or postal mail delivery.
Any disclosures made to you will cover only the twelve (12) months preceding the receipt of your verifiable consumer request. In the event that we are unable to fulfill your request, our response will include an explanation. Requests for data portability will be accommodated with user-friendly formats to facilitate the seamless transfer of information to another entity.
We will handle and respond to your verifiable consumer requests without imposing charges unless they are deemed excessive, repetitive, or baseless. In cases where a fee is applicable, we will notify you in advance and provide a clear rationale for the charge before proceeding with your request.
Authorized Representative
If you are submitting a verifiable consumer request under the CCPA on behalf of the consumer, kindly forward an authorization letter signed by the consumer to Info@identifypulse.com.
Do Not Sell My Personal Information
California residents aged sixteen (16) or older have the right to request that we do not sell their personal information. If we are aware that a California customer is under sixteen (16), we refrain from selling their personal information.
To exercise your opt-out rights, you can submit a request to Info@identifypulse.com. Creating an account is not necessary to exercise your right to object to the sale of your personal information. The information provided in your opt-out request will be utilized to fulfill your request.
Non-Discrimination
We assure you that we will not treat you unfairly for exercising any of your CCPA rights. This includes refraining from denying you services, imposing varying rates or charges for our services, applying sanctions, offering a different quality of service, or suggesting that you may receive different pricing or service quality.
However, we may offer you CCPA-authorized special financial incentives that are reasonably related to the value of your personal information. Such incentives might result in distinct costs, rates, or service levels. Any CCPA-permitted financial incentives will be clearly outlined in written terms that describe the essential features of the program. Additionally, your opt-in consent will be sought before providing these incentives.
California's "Shine the Light" law
California residents are entitled to seek and obtain specific information concerning any personal data disclosed to third parties for direct marketing purposes under the "Shine the Light" law, Civil Code Section 1798.83. To initiate such a request, kindly submit a written inquiry to the contact information provided in the document section labeled "Exercise your data access, portability, and deletion rights."
Changes to our Privacy Policy
To align with updates in pertinent privacy laws and our procedures for handling your personal information, we will regularly assess and revise this policy. Any modifications to this policy will be conveyed to you by updating the effective date and publishing revised versions on our website. Your continued use of our website and services after changes to our Privacy Policy indicates your acceptance of those modifications.
How to contact us if you have privacy issues
Feel free to contact our Data Operations team via email at Info@identifypulse.com or by sending postal mail to the following address if you have any inquiries or concerns regarding our privacy policies related to your personal information: 244 Fifth Ave, Suite Q230, New York, NY 10001.
