Last Updated: January 30, 2020
The Pulse of GovCon, LLC (“The Pulse”) values and respects the privacy of those who visit www.thepulsegovcon.com and its dependent pages (the “Website”) or use The Pulse’s software, products, and web-based services (the “Offerings”). This Privacy Policy (the “Policy”) is designed to explain how The Pulse collects, uses, shares, and protects the personal information you provide to The Pulse when you access the Offerings including the Website. This Policy applies to and serves as notification regarding information collected automatically via the Offerings, as well as that which is affirmatively provided by Users.
You acknowledge that this Policy is part of The Pulse’s Terms of Use, and by accessing or using the Offerings, including the Website, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use the Offerings. Any terms not defined in this Policy shall be given the meaning set forth in the Terms of Use.
The Pulse reserves the right to change this Policy at any time. Such changes, modifications, additions, or deletions shall be effective immediately upon notice of the change. Notice of change shall be effective when The Pulse publishes the revised Policy on this page and changes the “last updated” date at the top of this Policy. In the event that such changes are material, The Pulse may also provide an email notification to the email address provided by each registered user (who have not opted out of such notifications). Any changes are effective immediately upon publication on the Website, and you waive specific notice of any changes to the Policy by continuing to use and access the Offerings. The Pulse encourages you to review this Policy periodically, when you use the Offerings for any purpose. You are deemed to have accepted any changes to any revised Policy by your continued use of the Offerings after the revised Policy is posted.
1. INFORMATION THAT THE PULSE COLLECTS
The Pulse collects a variety of information from you when you access or use the Offerings, including visiting the Website. By accepting this Policy, you are specifically consenting to the Pulse’s collection, use, processing, and sharing of the data described below. The information The Pulse collects may include:
1.1 Personal Data.
“Personal Data” means any information that, by itself or in combination with other information, identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person, including, based on applicable privacy laws, a consumer or household. While this Policy uses the term Personal Data, it shall be read to encompass similar terms of art, such as Personal Information and Personally Identifiable Information, depending on jurisdiction. This does not include anonymized, aggregated, statistical, or non-personally identifiable data resulting from the use of the Offerings.
1.2 Usage Information.
The Pulse may collect usage information about the Offerings you use, including the time, date, and duration of your use of the Website, your interaction with content offered through the Website, search terms used, any referring website, and software crash reports. The Pulse also collects information stored using cookies, mobile ad identifiers, and similar technologies set on your device. The Pulse’s servers may automatically keep an activity log of your use of the Offerings. The Pulse may collect such usage information at the individual or aggregate level.
1.3 Derivative Data.
“Derivative Data” is information that the Pulse’s servers automatically collect about you when you access the Website, such as your IP address, browser type, the dates and times that you access the Website, and the specific pages you view. If you are using a mobile application, the Pulse’s servers may collect information about your device name and type, your phone number, the country your data originated from, and other interactions with the Offerings.
1.4 Financial Data.
“Financial Data” is data that is related to your payment method, such as credit card or bank transfer details. The Pulse collects Financial Data in order to allow you to purchase, order, return, or exchange products or services from the Website and any related mobile apps. The Pulse stores limited Financial Data. Most Financial Data are transferred to the Pulse’s payment processor, Stripe, and you should review this processors’ privacy policy to determine how they use, disclose, and protect your data. As a courtesy, Stripe’s privacy policy can be found here: https://stripe.com/us/privacy.
1.5 Social Networking Data.
The Pulse may access personal information from social networking sites and apps, including Facebook, Instagram, LinkedIn, Twitter, Snapchat, and other social networking sites or apps not named specifically here, which may include your name, your social network username, location, email address, age, gender, profile picture and any other public information. If you do not want The Pulse to access this information, please go to the specific social networking site and change your privacy settings.
1.6 Mobile Device Data.
If you use the Offerings, including the Website, via a mobile device or app, The Pulse may collect information about your mobile device, including device ID, model and manufacturer, and location information.
2. HOW THE PULSE COLLECTS AND USES YOUR INFORMATION
2.1 Collection.
You consent to giving The Pulse Personal Data by providing it voluntarily to The Pulse. You provide certain Personal Data when you use the Offerings; register for The Pulse’s services; sign up for special offers from select third-parties; send email messages, submit forms or transmit other information by telephone or letter; submit your credit card or other payment information when ordering or purchasing products and services on the Website. Your decision to disclose Personal Data and Financial Data are entirely voluntary. The Pulse may also collect other types of data including: Usage Information, Derivative Data, Social Networking, and Mobile Device Data. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain Offerings including certain benefits on the Website.
2.2 Use of Information.
Your information allows The Pulse to offer you certain Offerings, including the use of the Website, to fulfill The Pulse’s obligations to you, to customize your interaction with The Pulse and the Website, and to allow The Pulse to suggest other products and services The Pulse may think might interest you, The Pulse generally stores your data and transmits it to a third-party for processing. However, to the extent The Pulse processes your data, The Pulse does so to serve its legitimate business interests (such as providing you with the opportunity to purchase and interact with the Offerings, including the Website).
Specifically, The Pulse may use and process the information and data described above to:
(A) Create and administer your account, including your name, address, email address, and payment information;
(B) Deliver any products or services purchased by you to you;
(C) Correspond with you;
(D) Process payments or refunds;
(E) Contact you about new offerings that The Pulse thinks you will be interested in;
(F) Interact with you via social media;
(G) Send you any newsletters, emails, or other updates about The Pulse or the Offerings;
(H) Deliver targeted advertising;
(I) Request feedback from you;
(J) Notify you of updates to The Pulse’s product and service offerings;
(K) Resolve disputes and troubleshoot any problems;
(L) Administer contests or giveaways;
(M) Generate a profile that is personalized to you, so that future interactions with the Website will be more personal;
(N) Compile anonymous statistical data for The Pulse’s use or for a third-party’s use;
(O) Learning about the Users and Offerings;
(P) Assist law enforcement as necessary;
(Q) Prevent fraudulent activity on the Offerings, including the Website; and
(R) Analyze trends to improve the Offerings, including the Website.
3. RELEASE OF INFORMATION
3.1 General.
The Pulse may share your information with third-parties in certain situations. In particular, The Pulse may share your data with third-party processors as needed to serve its legitimate business interests, which include administration of the Website, administration of your account, entering into contracts with you, communicating with you, taking orders for goods or services, delivering The Pulse’s goods and services, identifying trends, protecting the security of The Pulse and Website, and marketing additional goods and services to you. The legal basis for The Pulse’s disclosure of your data is both your consent to this Policy and The Pulse’s right to protect and promote The Pulse’s legitimate business interests.
Subsection 3.2 – 3.11 of this Policy illustrate some, but not all specific instances why The Pulse may share your information.
3.2 Third-Party Processing.
The Pulse does not sell, trade, or rent your data to others. The Pulse does provide some of its services through contractual arrangements with affiliates, service providers, partners, and other third-parties. The Pulse and its service partners use your data to operate the Website and to deliver services. For example, The Pulse must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this site; release your email information to the email management service to deliver updates that are included in the Pulse’s Offerings; and provide order information to third-parties that help The Pulse provide customer service.
The Pulse will encourage its service partners to adopt and post privacy policies. However, the use of your data, including your Personal Data and Financial Data, by The Pulse’s service partners is governed by the privacy policies of those service partners, and is not subject to The Pulse’s control.
The Pulse may also provide information about The Pulse’s customers’ sales, traffic patterns, and related site information to third-party advertisers, but these statistics do not include any personally identifiable information.
3.3 Required by Law.
The Pulse may share your data as required by law or to respond to legal process, including a subpoena, or as necessary to protect the rights, property, and safety of others. This includes sharing information with other parties to prevent or address fraud and to avoid credit risks. The Pulse fully cooperates with law enforcement agencies in identifying those who use The Pulse services for illegal activities. The Pulse reserves the right to report to law enforcement agencies any activities that The Pulse in good faith believes to be unlawful.
3.4 To Protect The Pulse.
The Pulse may use your information to protect The Pulse, including to investigate and remedy any violations of The Pulse’s rights or policies. The Pulse may also disclose your information as reasonably necessary to acquire and maintain insurance coverage, manage risks, obtain financial or legal advice, or to exercise or defend against legal claims.
3.5 Sale, Merger, or Bankruptcy:
In the event that The Pulse experiences a change in control due to a sale, merger, goes out of business, or bankruptcy, your information may be transferred or assigned to a third-party successor. Such a successor may not be bound by this Policy and may have its own privacy policy. The Pulse may notify registered users via email in the event The Pulse is sold, merges, goes out of business, or enters bankruptcy such that it will change this Policy.
3.6 Interaction with Others.
If you interact with others via the Offerings, such as participating in a group chat or a group online course, other users may have access to some of your data, including your name, profile picture, and your history of interaction with the Website, such as prior comments or posts.
3.7 Online Postings.
When you post on the Website, your posts may be viewed by others, and The Pulse may distribute your comments outside the Website.
4. ONLINE TRACKING
4.1 Tracking.
When you use the Offerings, The Pulse and The Pulse’s third-party partners (which provide content, advertising, functionality, measurements, or analytics for the Offerings) may use cookies, web beacons, and other similar technologies to track your use of the Offerings.
4.2 Cookies.
The Pulse and third-parties use cookies for a variety of purposes, including remembering your sign-in credentials and preferences so that you do not have to input them each time you use the Offerings; allowing The Pulse and third-parties to customize your experience using the Website, including by determining the most relevant content and advertisements to show you on the websites and elsewhere online; and allowing The Pulse and third-parties to monitor site traffic and performance, so that The Pulse may improve the Offerings and your experience. Please find The Pulse’s Cookie Policy here.
4.3 Beacons.
Web beacons (also called “web tags” or “pixels”) are tiny graphics or scripts that communicate information from your device to a server. Beacons can be embedded in online or mobile content, videos, advertisements, or emails. They allow a server to read certain types of information from your device, such as when you viewed the beacon (and thus the content in which it is embedded) and the IP address of the device on which you viewed the beacon. The Pulse and third-parties use beacons for a variety of purposes, including to analyze the use of the Offerings and (in conjunction with cookies) to provide content and ads that are more relevant to you.
5. WEBSITE ANALYTICS
The Pulse may partner with third-party analytic companies, including, HubSpot and Google Analytics. These third-party analytic companies may also use cookies or other tracking technologies to analyze visitors’ use of the Offerings, including the Website to determine the popularity of the content, and better understand online activity. The Pulse does not transfer Personal Data to these third-party vendors. However, in order to access the Website, you must consent to the collection and use of your information by these third-party analytic companies. You should review their privacy policies and contact them directly if you have questions. If you do not want any information to be collected and used by tracking technologies, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.
6. PRIVACY POLICIES OF THIRD-PARTY SITES
Except as otherwise discussed in this Policy, this document only addresses the use and disclosure of information The Pulse collects from you. Other sites, accessible through the Offerings have their own privacy policies, data collection, use, and disclosure practices. The Pulse is not bound by or responsible for the privacy policies or practices of any third-parties regardless of whether or not you access those third-parties via a hyperlink in the Offerings.
The Pulse suggests you exercise caution when clicking on any hyperlinks as The Pulse is not responsible for any damage or consequences you suffer by using or accessing third-party sites, content, or offerings. The Pulse also encourages you to read the policies of those third-party websites before interacting with them or making purchases.
7. INTERNATIONAL TRANSFER; E.U.-U.S. PRIVACY SHIELD
7.1 International Transfer
The Pulse operates its technology from servers located in the United States and the information it collects through clients is processed solely in the United States. Laws governing the collection and use of data in the European Union (“E.U.”), Switzerland or United States may not be equivalent to those in the country where you reside, but The Pulse will at all times protect your data in accordance with this Policy.
The Pulse may share your information with its affiliates and other third-parties described above who are based in countries outside of your country of residence. While some countries may not have data protection laws that are equivalent to those of the country in which you reside, The Pulse will take reasonable measures to protect your information in accordance with this Policy and all applicable legal requirements.
If any recipient is located in a country without the adequate legal protection or safeguards for personal data, The Pulse will make reasonable efforts so the recipient adopts the principles described in this Policy.
7.2 Impact of E.U. – U.S. Privacy Shield
This Policy is intended to comply with the General Data Protection Regulation (“GDPR”) and the E.U.-U.S. framework of privacy principles agreed on February 2, 2016, and formally adopted by the European Commission implementing decision C(2016) 4176 final of July 12, 2016, or any other framework for transferring personal data from the European Economic Area or Switzerland to the United States that is approved by the European Commission as providing an adequate level of protection pursuant to the GDPR (the “Privacy Shield”). Therefore, if you reside in the E.U. or Switzerland, some of your data will be transferred internationally to servers located in the United States, however, transfers will be protected by the Privacy Shield. More information on the Privacy Shield can be found at: https://www.privacyshield.gov/welcome.
8. SENSITIVE PERSONAL DATA
The Pulse does not knowingly collect or obtain from third-parties, any personal data, including any Sensitive Personal Data. “Sensitive Personal Data” are data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data.
9. DATA RETENTION
The Pulse may retain personal data as long as it is needed to conduct its legitimate business purposes or to comply with its legal obligations, or until you ask The Pulse to delete your data. For example, The Pulse will retain certain personal information indefinitely for the purposes of maintaining your account, unless and until you delete your account. Data The Pulse gathers for a specific and particular purpose, such as assisting law enforcement or analyzing trends, will not be kept for longer than is necessary for that particular purpose. Data that is no longer needed by The Pulse for any of the purposes listed above will be permanently deleted.
You may request that The Pulse delete your data at any time. However, note that The Pulse cannot control the retention policies of third-parties. If you wish to have any third-parties, including those to whom The Pulse has transmitted your data, delete that data, you will need to contact those third-parties directly. You may request from The Pulse a list of all third-parties to whom The Pulse has transmitted your data.
10. SECURITY OF YOUR INFORMATION
The Pulse takes all commercially reasonable steps to protect your Personal Data and keep your information secure using current industry standards. Your Personal Data are protected in several ways. Access by you to your Personal Data is available through a password and unique customer ID selected by you. The password is encrypted. The Pulse recommends you do not divulge your password to anyone. In addition, your Personal Data resides on a secure server that only The Pulse personnel and contractors have access to via password. The Pulse encrypts your Personal Data and thereby prevent any unauthorized parties from viewing such information when it is transmitted to The Pulse.
Information that you provide that is not Personal Data also resides on a secure server that is only accessible via password. Since this information is not accessible from the Pulse’s Offerings you will not be asked to select a password in order to view or modify such information.
In order to most efficiently serve you, credit card transactions are handled by established third-party banking, processing agents, and institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process your order.
In light of the fact that no security measure is foolproof, and no method of data transmission can be guaranteed against interception or misuse. The Pulse cannot guarantee complete security of any information you transmit to The Pulse .
By consenting to this Policy, you acknowledge that your Personal Data may be available, via the internet, around the world. The Pulse cannot prevent the use or misuse of your data by other parties.
The Pulse will notify registered users promptly of any known breach of The Pulse’s security systems or your Personal Data or Financial Data which might expose you to serious risk.
11. NO MINORS
The Pulse’s Website is not designed for use by minors under age 18, and The Pulse does not knowingly solicit personal data from anyone under age 18. If you are under age 18, do not access or use the Website. If you become aware that The Pulse has collected data of anyone under the age of 18, please contact The Pulse so that The Pulse may delete that data.
12. YOUR RIGHTS
12.1 Your Rights to Your Data.
You have certain rights with respect to your personal data, as outlined below. Note that The Pulse may charge you a reasonable fee for actions that you ask The Pulse to take with respect to your data. In addition, The Pulse reserves the right to request that you provide it with evidence of your identity before any action is taken with respect to the exercise of your data rights. Further, your rights may be restricted or nullified to the extent they conflict with The Pulse’s compelling business interests, the public interest, or the law.
12.2 Update Account Information.
You have the right to update or change any information you have provided to The Pulse. To update or delete your Personal Data in your account you may access and edit the Personal Data you have provided to us in your account online at any time by linking to your account accordance with instructions posted elsewhere on the Website. You may also access and correct your personal information by writing The Pulse.
The Pulse encourages you to promptly update your Personal Data if it changes. You may ask to have the information on your account deleted or removed; however, because The Pulse keeps track of past transactions, you cannot delete information associated with past transactions on this site. In addition, it may be impossible to completely delete your information without some residual information because of backups.
12.3 Confirm Personal Data and Its Use.
You have the right to request The Pulse confirm what data The Pulse holds about you, and for what purposes. You also have the right to confirmation of whether The Pulse processes your data or deliver your data to third-party processors, and for what purposes. The Pulse will supply you with copies of your personal data unless doing so would affect the rights and freedoms of others.
12.4 Change Consent.
You have the right to change your consent to The Pulse’s use of your information. In such cases, The Pulse may require you to delete your account, as described above, and you may not have full access to the Offerings, including the Website.
12.5 Request a Copy of Data.
You have the right to request a digital copy of the data that The Pulse holds about you. Your first request for a copy of your Personal Data will be provided free of charge; subsequent requests will incur a reasonable fee.
12.6 Transfer Your Data.
You have the right to request that The Pulse gather and transfer your data to another controller, in a commonly used and machine-readable format, unless doing so would cause an undue burden to The Pulse.
12.7 Delete All Data.
You have the right to request that The Pulse delete all data that it holds about you, and to delete such data without undue delay. There are exceptions to this right, such as when keeping your data is (a) required by law, (b) necessary to exercise the right of freedom of expression and information, (c) required for compliance with a legal obligation, or (d) necessary for the exercise or defense of legal claims. Such a request may result in a termination of your account with The Pulse and you may have limited or no use of the Offerings, including the Website.
12.8 Email Communications; Marketing Communications.
You may opt out of receiving future email correspondence from The Pulse by checking the appropriate box when you register for the account or make a purchase. You may change your email communication preferences in your account or by contacting The Pulse. You may also opt out of receiving any third-party marketing communications on The Pulse’s behalf or having your personal information used for marketing purposes by The Pulse by changing your communication preferences in your account or contacting the Pulse.
12.9 Processing.
You may, in some circumstances restrict the processing of your data, such as when you contest the accuracy of your data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, The Pulse will continue to store your data but will not pass it on to third-party processors without your consent, unless such transmission is necessary to comply with legal obligations or protect your rights, the rights of others, or The Pulse’s rights. In addition, you may opt out of any processing of your data altogether. Note however that doing so may result in the termination of your account and loss of access to the Website.
12.10 State Specific Privacy Rights.
Some U.S. states, including California, have established their own unique privacy regulations that apply to certain residents. If you reside in California, you may have the right to obtain information regarding what information The Pulse discloses to third-party marketers and the names and addresses of each third-party to whom The Pulse disclosed your data. If you are a California resident and would like to make such a request, please use the contact information listed in Section 12.12.
12.11 Complaints:
You have the right to complain to a supervising authority if you believe The Pulse is misusing your data or have violated any of your rights under this Policy or applicable law.
12.12 Requests and Notices.
Requests, notices, and complaints under this Section 12 may be made by writing The Pulse at:
The Pulse of GovCon LLC
P.O. Box 710746
Oak Hill, VA 20171
United States
or by email at : pundits@pulsegovcon.com.
Please include your name, address, and email when you contact us.
13. NEWSLETTER
The Pulse offers the opportunity for you to volunteer certain information to The Pulse that is used for email and marketing purposes. This information includes, but is not limited to, your name and email. You will have an opportunity to unsubscribe from any future communications via email, but The Pulse reserves the right to maintain a database of past email subscribers. The Pulse reserves the right to use this information as reasonably necessary in The Pulse’s business and as provided by law. Your information will be shared with reasonably necessary parties for the ordinary course of conducting The Pulse’s business, such as through Facebook ads or Google Pay Per Click marketing campaigns.
14. CONTACT INFORMATION
If you have any questions about this Policy, the practices of The Pulse, or your dealings with the Website, please contact us by sending a letter to:
The Pulse of GovCon LLC
Attn: Privacy Compliance Officer
P.O. Box 710746
Oak Hill, VA 20171
United States
You may also contact us by email at pundits@pulsegovcon.com
