EU-U.S. Swiss-U.S. Privacy Shield Framework
Pulse Secure, LLC, (and its subsidiary companies Cellsec Inc. and SMobile Systems Inc.) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Pulse Secure, LLC is committed to subjecting all personal data received from countries in the European Economic Area, United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.[https://www.privacyshield.gov/list]
Pulse Secure, LLC. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Pulse Secure, LLC. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, United Kingdom and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Pulse Secure, LLC. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Pulse Secure may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Personal information means any information or combination of information that may be used to identify, contact, or locate an individual, including, but not limited to, a first and last name, initials, email address, phone number, photo, postal or physical address, occupation, industry, login credentials that is needed to answer a request, to better provide information and services or to comply with various national, state, provincial or local governmental reporting requirements.
We and third-party service providers on our behalf collect information about your location when you use or access our websites and services. The degree of precision of the location data varies depending on the source of such information. This source is the IP address. We collect and use this location-related data in order to ensure that you are not located in a restricted country under the applicable US export laws.
When you apply for a job to job position on our career portal, we might also collect the following information to process your application: Profession, Initials, Job title, ,Job level and employment details if you send us a Cover Letter, resumé or other details of your employment history in connection with a job vacancy or an enquiry regarding employment opportunities with us.
Pulse Secure may collect personal information as described below. In each case, we only collect personal information that we believe to be relevant and required to provide an individual with requested information and services and/or to conduct our business.
By way of example, we may collect personal information for the purposes set forth below:
- Viewing of product demonstrations
- Accessing of white papers (Note: once you have registered for a white paper or tool, you may visit at any time using your password and user ID.)
- Participation in marketing promotions
- Participation in seminars, training courses or events
- Career opportunities
- User surveys
- Secured Partner sites
- Registration of products
- Direct marketing by Pulse Secure or its telemarketing service providers
- Responding to an inquiry
- Providing technical support or consulting services
During marketing events such as fairs, expos, or exhibitions, we may also collect personal information from you, such as your name and contact details in order to refer our products and services to you. When you provide us with such personal information we will only use it for the reason for which it is provided. If you would like the information to be removed from our database, please contact us at email@example.com.
Pulse Secure may collect, compile and publish statistical information related to the use of and the performance of its appliances and software for marketing purposes, provided that such information is pseudonymized. Pulse Secure may collect information about the connection, connected appliances, firmware, software and use of its products in order to improve or to help resolve any issues with its products and service and/or to increase end user security.
We may transfer personal information to companies that help us provide our services. Transfers to subsequent third parties are covered by the service agreements with our customers.
In addition, when accessing certain documents or services on our website or during other marketing activities, visitors may be asked to provide certain information, such as how they can be contacted, where they work, and what they do. We may also track information about the web pages and content accessed by visitors to our website and the number of times such content is accessed by a visitor. We collect this information in an effort to better meet the needs of visitors to our website, to answer questions, and to improve delivery of information and services to visitors of the website.
Also, in the course of performing services for our enterprise customers, Pulse Secure may be provided access to a customer's networks or systems, and in rare cases, may be able to view or receive portions of personal information of our customer's end users. Pulse Secure does not and will not use this information, and if indirectly collected as part of the performance of services, all such information is safeguarded in accordance with this Notice.
From time to time, Pulse Secure may offer products and services that involve additional privacy-related issues. Please check the product page of our website for information on such additional privacy-related issues. If there are contradictions between this Notice and the more specific information on a product page, then the latter shall prevail.
Access to Information
In some instances Pulse Secure may have access to personal information, but does not collect it. For instance, with respect to Pulse Workspace customers using the Pulse Secure Android application, Pulse secure uses the Android BIND-DEVICE-ADMIN permission to allow a company administrator to create a Managed Work Profile which is separate and independent from a user’s Personal Profile on the user’s Android device or smart phone. This allows the administrator to provision and control enterprise applications to that device and to enforce various application policies defined by the company, such as configuring passcodes, erasing data, configuring WiFi or other profile specific settings. The Pulse Secure Android application does not collect information found in the user’s Personal Profile.
Notice and Ability to Opt-Out
When personal information is collected, we typically inform the individual at the point of collection or upon our first communication to the individual the purpose for the collection and where appropriate, allow the individual to elect whether to provide the information to Pulse Secure and/or specify how we can use such personal information.
Pulse Secure provides individuals who elect to receive electronic or other communications the ability to “opt-out” of those communications by sending us a notice to unsubscribe by using the “Unsubscribe” link found in emails we send to you, by contacting us at firstname.lastname@example.org, or by writing to us at Pulse Secure, LLC, 2700 Zanker Road, Suite 200, San Jose, CA 95134, Attn: Legal Department. Pulse Secure respects your wishes and will discontinue communicating with individuals who have requested not to receive email or other communications from Pulse Secure.
Pulse Secure does not alter its data collection based on the presence of a “do not track” request configured in your browser; however, you may opt-out of data collection performed by Google Analytics. The data collected may be used to improve web site performance and to improve the user experience, in order to provide relevant products and services. You may opt-out from Google Analytics by following the instructions here: https://tools.google.com/dlpage/gaoptout/.
Sharing, Disclosure and Security of Personal Information
We will share your personal information with third parties only in the ways that are described in this Notice.
If an individual chooses to provide Pulse Secure with personal information, the personal information will be used solely by and transferred only to Pulse Secure, its offices and subsidiaries around the world, its resellers and distributors and service providers (e.g., human resources, marketing and sales, customer support), which are those companies contracted by Pulse Secure to deliver requested information and services such as recruiting, marketing, lead generation and customer support, pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use PI they receive from us for any other purpose.
We may also transfer personal information across borders and from the individual’s country or jurisdictions to Pulse Secure’ offices and subsidiaries, its resellers and distributors and service providers around the world. All such entities are governed by this Notice or are bound by appropriate confidentiality agreements.
An individual’s personal information is typically not shared outside Pulse Secure without permission, except under conditions explained below. Pulse Secure may send personal information to other service provider companies under any of the following circumstances:
- when we have an individual’s consent to share the information;
- if sharing an individual’s information is necessary to provide a product or service that is requested (If personal information is shared with third parties service providers we will only provide the information they need to deliver the service. Also, such companies are prohibited from using such personal information for any other purpose);
- to keep an individual up to date on the latest product announcements, product updates, special offers or other information we think he/she would like to hear about either from us or from our service providers (unless the individual has opted out of these types of communications).
Within Our Corporate Family: We disclose PI to affiliated companies related by common ownership or control within the Pulse Secure group of entities to carry out regular business activities and to accomplish our legitimate business purposes, pursuant to contractual safeguards.
In certain situations, Pulse Secure may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
If Pulse Secure is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.
The security of your personal information is important to us. Pulse Secure safeguards the security of the personal information and other data provided to us with commercially reasonable technical and organizational safeguards for physical, electronic and managerial procedures to appropriately protect your personal information against accidental, unauthorized, or unlawful access, use, loss, destruction or damage. Inside Pulse Secure, data is stored in secure and controlled servers with limited access. Your information may be stored and processed in the United States or any other country where Pulse Secure, its subsidiaries or service providers are located. While we strive to protect personal information, we cannot ensure absolute security of the personal information provided to us. We urge individuals to protect their personal information when using the internet by, for example, changing passwords often, using a combination of letters and numbers and making sure to use a secure browser. If you have any questions about the security of your personal information, you can contact us at email@example.com.
International Transfer of Personal Information
To facilitate our operations, we may transfer, store and process your personal information in jurisdictions other than where you live including in the United States. Laws in these countries may differ from the laws applicable to your country of residence. For instance, if you are a European Economic Area (EEA) data subject and your personal information is shared with our affiliates, partners, or third-party service providers acting on our behalf outside of the EEA, then it is done so pursuant to necessary means to ensure an adequate level of protection.
We will retain your information for as long as your account is active, as needed to provide you services or to fulfill the purposes outlined in this Privacy Notice. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will retain personal data we process on behalf of our customers for as long as needed to provide services to our customer. Pulse Secure will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.
When you visit our website, we send you a cookie. Cookies may be used in the following ways:
- To help us recognize you as a unique visitor (just a number) when you return to our website, to allow us to tailor content or advertisements to match your preferred interests, or to avoid showing you the same advertisements repeatedly.
- To develop leads for our internal sales group and our business partners and provide direct marketing communications to you if you have explicitly consented to receive such communications.
- To compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve the structure of our website. We cannot identify you personally in this way.
- To protect the security of our website.
Two types of cookies may be used on this website: session cookies (which are temporary cookies that remain in the cookie file of your browser until you leave the site) and persistent cookies (which remain in the cookie file of your browser for much longer, though how long will depend on the lifetime of the specific cookie).
You have the ability to accept or decline cookies by modifying the settings in your browser, as well as delete any cookies that have been installed in the cookie folder of your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled/deleted. If you do not know how to disable or delete cookies for the browser you are using, you should select ‘cookies’ in the Help function of your browser to get more information.
As is true of most websites, we gather certain information automatically. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
We partner with a third party to display advertising on our website and to manage our advertising on other sites. Our third party service providers may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Please note that these settings must be performed on each device (including each web browser on each device) for which you wish to opt-out, and if you clear your cookies or if you use a different browser or device, you will need to renew your opt-out preferences.
In the mobile environment, most mobile operating systems offer device-based opt-out choices that are transmitted to companies providing interest-based advertising. To set an opt-out preference for a mobile device identifier (such as Apple's IDFA or Android's GAID), visit the device manufacturer's current choice instructions pages, or read more about sending signals to limit ad tracking for your operating system here: http://www.networkadvertising.org/mobile-choices.
Accessing and Updating Personal Information
Upon request, Pulse Secure will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at firstname.lastname@example.org.
Pulse Secure encourages all individuals who provide personal information to Pulse Secure to keep their personal information accurate and up to date. Individuals have the right to request access to, correction, or deletion of their personal information and they can do so by sending an email to email@example.com. Individuals have the right to request restrictions, temporarily or permanently, on our processing of some or all personal information about them. We will respond to your request within 30 days.
Please note that for personal information about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity--which determined the means and purposes of processing, all such requests should be made to that entity directly. We will honor and support any instructions they provide us with respect to your personal information.
- Pulse Secure utilizes the services of BambooHR to collect and host information from job applicants and employees.
- BambooHR will forward information to Pulse Secure submitted by job applicants and host employee personal information.
- Personal information of EU residents is stored exclusively on the BambooHR EU data server and is never stored or hosted on US servers. However, such data may be accessed by Pulse Secure in the U.S.
Children and Privacy
We do not knowingly collect personal information from minors without proper consent from a parent or legal guardian. If you believe that we may have collected personal information from a minor without the requisite consent, please contact us as described in this PN and we will investigate and promptly address the issue. Pulse Secure does not knowingly permit children under age 16 to register for any website, application, product or service
Third Party Sites
Pulse Secure’ website may provide links to other third party websites which are outside our control and not covered by this Notice. We encourage you to review the privacy policies posted on these third party websites.
Social Media Widgets
Our website includes social media features, such as the Facebook “Like” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our website. These features may collect your internet protocol address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy statement of the company providing it.
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at: firstname.lastname@example.org.
Changes to Our Privacy Notice
Pulse Secure may amend this Notice from time to time to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email addressed specified in your account) or by posting a revised statement on this site prior to the change becoming effective. We encourage you to periodically review this Notice for the latest information on our privacy practices.
Questions and Dispute Resolution
Pulse Secure commits to resolve complaints about your privacy and our collection or use of your personal information.
For European Union Residents
If you are in the EU, you should contact us at email@example.com to resolve your complaint, regardless of which of our companies the complaint is about. If you are not satisfied with our resolution of your complaint, you may complain to the Information Commissioner’s Office of your local Data Protection Authority. We commit to cooperating with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by the panel or the FDPIC with regard to personal information transferred from the EU, United Kingdom or Switzerland. For the purposes of the Privacy Shield Frameworks, we are subject to the investigatory and enforcement powers of the Federal Trade Commission. In some conditions, you may be able to invoke binding arbitration to resolve your complaint where your personal information has been transferred to and processed in the United States.
If you 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://feedback-form.truste.com/watchdog/request.
For United States residents
If you are not satisfied with our resolution of your complaint, you can make a privacy complaint to the Federal Trade Commission or you can make a consumer reporting complaint to the Consumer Financial Protection Bureau.
Privacy Notice for California Residents
Effective Date: February 10, 2020
Last Reviewed on: February 10, 2020
Information We Collect
Our website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or device (“Personal Information”). In particular our website has collected the following categories of Personal Information from its Consumers within the last twelve (12) months:
Category A: Identifiers
Examples: A real name, Internet Protocol address, email address, or other similar identifiers.
Category B: Some of the Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
Category C: Protected classification characteristics under California or federal law.
Examples: Age, national origin, citizenship and veteran or military status.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated Consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or Medical Information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from You. For example, from forms You complete on our website.
Use of Personal Information
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason You provided the information. For example, if You share Your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to Your inquiry. We may also save Your information to facilitate new product orders or process returns.
- To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our responses.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As may be described to You when collecting Your Personal Information or as otherwise set forth in the CCPA.
- We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing You notice.
Sharing Personal Information
We may disclose Your Personal Information to a third party for a business purpose [or may sell Your personal information, subject to Your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights)]. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. [The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless You have received explicit notice and an opportunity to opt-out of further sales.]
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the below categories of Personal Information to service providers for a business purpose.
- Identifiers such as a full name, job title, name of employer, postal address, unique personal identifier, Internet Protocol address, email address and telephone number.
- Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, including, but not limited to, information regarding a Consumer’s interaction with our website, application or advertisement.
- Geolocation data.
Your Rights and Choices
The CCPA provides Consumers (California residents) with specific rights regarding their Personal Information. This section describes Your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to You about our collection and use of Your Personal Information over the past 12 months. Once we receive and confirm Your verifiable Consumer request, we will disclose to You:
- The categories of Personal Information we collected about You.
- The categories of sources for the Personal Information we collected about You.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about You (also called a data portability request).
- If we sold or disclosed Your Personal Information for a business purpose, consisting of two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of Your Personal Information that we collected from You and retained, subject to certain exceptions. Once we receive and confirm Your verifiable Consumer request, we will delete (and direct our service providers to delete) Your Personal Information from our and their records, unless an exception applies.
We may deny Your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with Consumer expectations based on Your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
Exercising Access, Data Portability, and Deletion Rights
You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable Consumer request must:
- Provide sufficient information that allows us to reasonably verify You are the person about whom we collected Personal Information or an authorized representative.
- Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to Your request or provide You with Personal Information if we cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to further 45 days), we will inform You of the reason and extension period in writing. We will deliver our written response by mail or electronically, at Your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to Your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell You why we made that decision and provide You with a cost estimate before completing Your request.
Personal Information Sales Opt-Out and Opt-In Rights
Once You make an opt-out request, we will wait at least twelve (12) months before asking You to reauthorize personal information sales. However, You may change Your mind and opt back in to Personal Information sales at any time by visiting our website and sending us a message. We will only use Personal Information provided in an opt-out request to review and comply with the request.
We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny You goods or services.
- Charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide You a different level or quality of goods or services.
- Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. If we make any material changes, we will notify you by email (sent to the email addressed specified in your account) or by posting a revised statement on this site prior to the change becoming effective. Your continued use of our website following the posting of changes constitutes Your acceptance of such changes.
If You have any questions or comments about this notice, the ways in which we collect and use Your information, Your choices and rights regarding such use, or wish to exercise Your rights under California law, please do not hesitate to contact us as follows:
- You can also write to us at our address listed below:
Pulse Secure, LLC
2700 Zanker Road
San Jose California 95134
Tel: (408) 372-9600
© 2020 Pulse Secure, LLC. Use of this website assumes acceptance of our Legal Notices and Privacy Notice. Pulse Secure has updated its Privacy Notice effective August 19, 2020.