EU-U.S. Swiss-U.S. Privacy Shield Framework
Pulse Secure 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 is committed to subjecting all personal data received from countries in the European Economic Area and Switzerland, respectively, in reliance on the Privacy Shield Frameworks and to their applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.[https://www.privacyshield.gov/list]
Pulse Secure is responsible for the processing of personal data it receives, under the Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. Pulse Secure complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Pulse Secure 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.
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, email address, phone number, photo, postal or physical address, occupation, industry, 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.
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 firstname.lastname@example.org.
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 email@example.com, 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. 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 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);
- as part of a joint sales promotion or to pass sales leads to one of our distribution/reseller partners; and
- 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).
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 generally accepted standards for physical, electronic and managerial procedures. 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 firstname.lastname@example.org.
We will retain your information for as long as your account is active or as needed to provide you services. 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.
We and our marketing partners, affiliates, or analytics or service providers, use technologies such as cookies or other similar technologies to analyze trends, administer the website, tracking users’ movements around the website, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
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 partner 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.
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 email@example.com.
Pulse Secure encourages all individuals who provide personal information to Pulse Secure to keep their personal information accurate and up to date. Individuals may also request access to, correction, or deletion of their personal information by sending an email to firstname.lastname@example.org. We will respond to your request within 30 days.
Co-Branding Relationship: BambooHR
- 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
Our websites do not target and are not intended to attract children under the age of 16. Pulse Secure does not knowingly solicit personal information from children under the age of 16 or send them requests for personal information.
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: email@example.com.
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 firstname.lastname@example.org 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 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.
Pulse Secure, LLC
2700 Zanker Road
San Jose California 95134
Tel: (408) 372-9600
© 2019 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 8, 2019.