Effective Date: January 2020
The Gartner Digital Performance Benchmarks member/client portal, formerly L2, Inc., and the associated products (collectively, “the Services”) are provided by, Gartner Inc. Please read this Privacy Policy (“the Policy”) carefully as it sets out important information relating to how we handle your personal information for the Services. For detail on other Gartner product and services, please reference the Gartner Privacy Policy. Gartner and all its group companies will have access to information on individuals covered by this Policy.
How to Contact Us
Questions, comments and requests regarding this Privacy Policy should be addressed to our Data Protection Office through the following means:
Global Data Protection Office
Legal Department
56 Top Gallant Road
Stamford, CT 09602
USA
Email Address: privacy@gartner.com
Introduction
This Policy sets out how we will collect and use personal information, and the choices and rights available to you in connection with our use of your personal information.
This Policy will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party.
1. INFORMATION THAT WE COLLECT ABOUT YOU
1.1 Data collection and usage
Information we collect directly from you or from the following sources:
- Your employer
- Our website (client-based and public)
Categories of information we collect about you include:
- Information you provide when you register to become a client, including your name, business or personal email address, company name, job title, country, industry, and company size
- Information you provide when you subscribe to email newsletters, such as email address, country, and industry interests
- Account login information, including email address, password, and similar credentials
- Any other information you provide through the Services, such as when you contact us, RSVP to an event, answer online questionnaires, participate in surveys, submit feedback forms, post job openings, or engage in other transactions
- Information your employer provides to us about you, including your name, email address, job title, telephone number, and area of focus
We use this information for certain activities, including:
- Administering and improving the Services
- Enabling you to access your account across devices
- Personalizing and enhancing the experience of our Services
- Attributing content that you make available through the Services
- Providing better, more customized client service and responding to your inquiries
- Investigating any complaints
- Researching and analyzing use of the Services
We use this information because:
- It is necessary to perform our obligations or exercise our contractual rights
- It is necessary to comply with applicable laws or regulations;
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We have a legitimate business interest to:
- Manage and promote our business and brand;
- Provide and improve our services;
- Operate our business; and
- We have your consent (where required under applicable law) to use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us.
Information we collect about the use of the Services
Categories of information we collect about you include:
- Information captured in our web logs, such as device information (e.g. device brand and model, screen dimensions); unique identification numbers (e.g. IP address and device ID); browser information (e.g. URL, browser type, pages visited, date/time of access); general location information (e.g. based on IP address); and Internet connection information
- Behavioral information, (such as information on the behavior or presumed interests of individuals which are linked to those individuals and may be used to create a user profile)
- Information captured by our cookies (see our Cookie Policy).
We use this information for certain activities, including:
- Administering and improving the Services
- Enabling you to access your account across devices
- Personalizing and enhancing the experience of our Services
- Providing better, more customized client service and responding to your inquiries
- Investigating any complaints
- Researching and analyzing use of the Services
We use this information because:
- It is necessary to comply with applicable laws or regulations
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We have a legitimate business interest to:
- Monitor, investigate, and report any attempts to breach the security of the Services
- Improve the performance and user experience of the Services
- Customize the client experience
Information we collect when you RSVP to or attend one of our events
Categories of information we collect about you include:
- Information you provide when you RSVP to an event, including your name, business or personal email address, company name, job title, and country
We use this information for certain activities, including:
- Registering you for an event
- Facilitating your attendance at an event
- Providing better, more customized client service and responding to your inquiries
- Facilitating networking with fellow event attendees
- Researching and analyzing attendance at our events
We use this information because:
- It is necessary to perform our obligations or exercise our contractual rights
- It is necessary to comply with applicable laws or regulations
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We have a legitimate business interest to:
- Promote our brand, Services, events, and business
- Provide and improve the Services
- Operate our business
- Collect relevant information for hospitality and health and safety purposes
1.2 Special categories of information
Certain types of personal information are more sensitive than others. This includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometric information or religion. It is voluntary for you to disclose this information, but where we collect and receive these types of information about you, we have identified the type of special information, how we will use it and why we will use it.
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Information when you RSVP to or attend one of our events |
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1.3 Further Information
Where we collect and use information for our legitimate interests as mentioned above, a legitimate interest will only apply when we consider that your interests or rights requiring protection of your personal information do not override our legitimate interests. For more information regarding our legitimate interests as applied to your personal information, please contact us.
Our websites and online services are for individuals who are at least 18 years old. Our online services are not designed to be used by individuals under the age of 18.
In certain circumstances, if you do not provide personal information which is required (for example, in relation to activating your Gartner license), we will not be able to perform our contractual obligations or provide you with products and services. When this is the case, we will make it clear.
Restricted Areas
If you access the Restricted Areas of any of our Services, we may collect information about your access to and use of research materials, decision-support tools, and other online and offline resources we offer.
Information from Other Sources
We may also periodically obtain information about you from other sources. The collection of such information will be in accordance with applicable privacy laws. Examples of information we receive include updated contact information and additional demographic information. Please note that we sometimes collect information relating to you at the time you or your company enroll in a program run by Gartner or any of its subsidiaries, as well as in the course of allocating and issuing to you a unique ID and password to access any Restricted Areas of the services.
2. WHEN WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose your personal information to third parties as follows:
- To Gartner group companies in order to process the data for the above mentioned purposes;
- When we have your consent or authorization to do so;
- To third parties who work on our behalf to service or maintain business contact databases and other IT systems, such as suppliers of the IT systems which we use to process personal information, or who provide other technical services, such as printing;
- To third parties providing services to us who have a need to access your information, such as our professional advisors (e.g. auditors and lawyers);
- To comply with applicable laws, protect rights, safety and property, and respond to lawful requests from public authorities (such as disclosing data in appropriate situations for national security or law enforcement purposes);
- Subject to applicable law, in the event that Gartner is merged or sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such a transaction, or for pre-transaction review in relation to such transactions.
Your personal information may be shared if we anonymize and/or aggregate it, as in these circumstances the information will cease to be personal information.
Utilization Information
We may share information with our organizational clients about how their employees use the resources available to them through the Services (e.g. reports downloaded, events attended, newsletters subscribed too, projects requested/provided, and quotes).
3. DATA SUBJECT ACCESS RIGHTS
In certain circumstances, you have certain rights regarding your personal information. A summary of each right and how you can exercise it is set out below. To exercise any of these rights, please contact us. Such requests should include information to allow us to verify your identity(e.g., your name, address, email address or other information reasonably required). If you are a California resident, please refer to Section 11 below for more detailed information on your rights under California law.
Where we receive a request to exercise one of these rights, we shall provide information on the action we take on the request without undue delay within the time required by applicable law. This may be extended in certain circumstances, for example where requests are complex or numerous.
The information will be provided free of charge, except where requests are manifestly unfounded or excessive, in particular because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request.
We may ask for additional information to verify your identity before carrying out a request.
Where we do not carry out a request, we shall inform you without delay and within one month of receipt of the request, providing our reasons for not taking the action requested.
Right to access and/or correct your personal information
You have the right to access personal information we hold about you, as well as to be provided with a copy of the information (in most circumstances). You also have the right to correct any information we may hold about you that is inaccurate. In some cases, you may directly access your online profile and other personal details, and amend, update, or add to the information in your client profile at any time by logging into your account on the website.
Right to restrict use of your personal information
You have the right to ask us to restrict processing of your personal information where one of the following applies:
- The processing is unlawful but you want us to restrict use of the data instead of deleting it;
- Where you contest the accuracy of your personal information, the restriction will apply until we have verified the accuracy or corrected your personal information;
- We no longer require the personal information for the purposes of processing, but you still require us to keep it in connection with a legal claim; or
- You have exercised your right to object to the processing.
Any restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.
Right to request deletion of your personal information
You have the right to ask us to delete your personal information in certain circumstances. Please note that if you want us to refrain from sending you marketing communications, you may do so by following the instructions in Section 5 (Choices About Your Information) above. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defense of legal claims.
Right to object to processing of your personal information
You may object to our use of your personal information for marketing purposes.
You may also object to processing of your personal information in cases where we have used legitimate interests as the basis for processing. In such cases, we will stop processing your personal information until we verify that we have compelling legitimate grounds for processing that outweigh your interests, rights, and freedoms in asking us to stop processing the data, or in limited cases where we need to continue processing the data for the establishment, exercise, or defense of legal claims.
Right to data portability
In most cases, you have the right to receive all personal information you have provided to us in a structured, commonly used, and machine-readable format and to transmit this data to another data controller, where technically feasible.
Right to lodge a complaint with a supervisory authority
If you object to our processing of your personal information, you have the right to complain to the data protection authority (“DPA”) in the country where you reside, where you work, or where an alleged infringement of data protection laws has taken place.
4. INTERNATIONAL TRANSFERS
Gartner is a global company and we may transfer personal information to other Gartner group companies or suppliers outside your country. Gartner will take reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.
Gartner may transfer and maintain the personal information of individuals covered by this Policy on servers or databases outside the European Economic Area (“EEA”). Some of these countries may not have the equivalent level of protection under their data protection laws as in the EEA.
The countries to which we transfer data outside of the EEA may include any of the countries in which Gartner does business. A list of Gartner office locations can be found here.
All Gartner entities have signed an Intragroup Agreement containing the European Union (“EU”) Commission Approved Standard Contractual Clauses for the transfer of data outside the European Economic Area. All Gartner entities have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, and the terms of our client and member contracts governing the collection and use of information.
5. RETENTION PERIODS
We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations require us to retain it.
In general terms, this will mean that your personal information will be kept for the duration of our relationship with you and:
- the period required by tax and company laws and regulations; and
- as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.
6. CHOICES ABOUT YOUR INFORMATION
We believe it is important to give you choices about the use of your information. We will use your information as described in this Policy (or any other event- or service-specific privacy policy). If we want to use your information for a purpose not described in this Policy, we will first get your consent to do so.
Marketing Communications
We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us at the address here. If you gave us your email address to receive marketing communications, you can opt out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information or information with third parties (other than our subsidiaries or affiliates) for their own promotional or marketing purposes unless you give us consent to do so and where permitted by applicable law.
7. SECURITY
We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot and do not guarantee or warrant the security of any information you transmit via the Services. Please note that you are responsible for maintaining the security of your credentials used to access the Services, and you must report suspected unauthorized activity to us.
We make reasonable efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.
8. COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”.
Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.
We also include web beacons in e-mail messages or newsletters to track whether you open the messages. We use this information to customize our services and measure the overall effectiveness of our online content, advertising campaigns, and products and services we offer through the Site. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
More detailed information on how we use cookies and other web technologies can be found here.
9. MISCELLANEOUS
9.1 Links
To provide increased value to you, we provide links to other websites or resources that are not part of the Services run by Gartner. We do not control these websites or their privacy practices, and any information you provide to these sites is subject to the privacy policies of those sites and not this Policy.
9.2 Changes to this Policy
From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on this website. We recommend you regularly review this website to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.
10. California Privacy Rights
California law requires us to provide California residents with additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
Categories of personal information we collect. Throughout this Policy, we discuss in detail the specific pieces of information we collect from and about users. Below are the categories of personal information we collect:
- Identifiers (such as name and title, contact details, and company name);
- Internet or other network or device activity (such as browsing history or app usage);
- Inference data about you; and
- Other information that identifies or can be reasonably associated with you.
Use of categories of personal information. We may disclose the categories of personal information identified above for our operational purposes where the use is reasonably necessary and proportionate to achieve the operational purpose for which it was collected or processed, or for another compatible operational purpose.
Sale of Personal Information. The CCPA sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months (including that we do not “sell” the personal information of minors under 16 years of age). We do share certain information as set forth in Sections 1 and 2 of this Policy, and allow third parties to collect certain information about your activity, for example through cookies, as explained in our Cookie Policy.
Individual Rights. California law may provide you with certain rights and permit you to request the following:
- Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.
- Provide access to and/or a copy of certain information we hold about you.
- Delete certain information we have about you.
You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.
If would like to exercise any of these rights, please email us at privacy@gartner.com or send your written request to Data Protection Counsel, Americas, Gartner, 1201 Wilson Blvd., Arlington, VA. You will be required to verify your identify before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.
Subject to certain limits under California Civil Code § 1798.83, California residents may request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please contact us as specified at the beginning of this Privacy Policy.
California Online Privacy Protection Act Notice Concerning Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT. To learn more about Do Not Track, please click here.
11. Nevada Privacy Rights
Nevada law requires us to provide certain Nevada consumers the ability to opt out of the “sale” of “personally identifiable information” as such terms are defined under Nevada law. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing privacy@gartner.com. Once verified, we will maintain your request in the event our practices change.