Last Updated December 19, 2019
The protection of personal privacy has always been a hallmark of Gallup. Since its inception in 1935, Gallup has maintained the confidentiality of each survey respondent unless an individual user consents to the release of the user's Personal Information or individual results. In a similar manner, Gallup protects the identity of individuals who access Gallup Websites. For the purposes of this Privacy Statement, the terms "Gallup, we, us, and our" refer to Gallup, Inc., 901 F Street, NW, Washington, D.C., 20004, U.S.A. and its subsidiaries and affiliates.
Gallup's data protection officer can be contacted at Privacy_Administrator@Gallup.com.
This statement describes the types of information, including Personal Information, collected and processed through Gallup websites and through the services delivered via Gallup websites, and how Gallup treats such information. For questions about this Privacy Statement or your Personal Information, please contact Privacy_Administrator@Gallup.com.
By using the term "Personal Information" in our Privacy Statement, we refer to information that you individually provide to Gallup either directly or indirectly that on its own or in combination with other information, can be used to identify you or make you identifiable. Personal Information includes, for example, your name, your mailing address, your telephone number, your email address or other information that identifies you or makes you identifiable.
Information that by itself cannot be used to identify you or make you identifiable does not qualify as Personal Information.
I. INFORMATION COLLECTED BY GALLUP WEBSITES
Gallup websites gather information in two ways: (1) indirectly (for example, through our site's technology), and (2) directly (for example, when you, the site visitor, voluntarily provide information on various pages).
The information will be transferred to Gallup Inc.'s servers located in the United States of America ("USA"). Gallup has certified to the U.S. Department of Commerce that it adheres to the U.S. Privacy Shield Principles. In accordance with Article 45 of the European General Data Protection Regulation ("GDPR") the European Commission recognizes that the certification under the EU-U.S.-Privacy Shield ensures an adequate level of data protection, so that the data transfer to the USA does not require any specific authorization (see also below clause III. 7 "Compliance and Cooperation with Regulatory Authorities").
1. Information Collected Indirectly
Gallup indirectly collects a variety of information through your interaction with and use of Gallup websites. This information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, content information based on your individual interests, demographic information, geographic or geo-location information, statistical and aggregated information ("Other Information").
Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of users in a particular zip code.
If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.
1.1 Gallup Cookies
Some types of indirectly collected information are stored in "cookies." Cookies are small files of electronic information that a website can transfer to a visitor's hard drive to help that visitor while on the site. There are different types of cookies:
- Strictly necessary cookies are required for the operation of our website.
- Functionality cookies are used to recognize you when you return to our website. These cookies simply store a user code so that the user does not have to re-enter their information when re-joining the site.
- Targeting cookies record your visit on our platform and the pages you have visited. We will use this information to make our website more relevant to your interest.
1.1. a. Tracking Data and Third Party Analytics Providers
Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis is typically referred to as Tracking Data. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers, the computers that "serve up" Web pages, automatically identify your computer by its IP address. When you visit any Gallup Websites, our servers log your computer's IP address.
For the abovementioned purpose Gallup uses the following Third Party Analytics Providers: Google Analytics, Selligent, Oracle, Dynatrace and Zendesk. The list includes information about the use of each cookie, how to prevent the collection and use of information collected by the cookie.
One of our Third Party Analytic Providers is Google Analytics:
Google Analytics is a service from Google, Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA; hereinafter "Google") using cookies which are saved on your computer. The information generated by the cookie is transferred to and stored on a Google server (generally) located in the USA. Google uses this information on our behalf in order to analyze the use of our websites. The IP address transferred from your browser through Google Analytics is not merged with other data by Google for profiling purposes.
You can prevent Google Analytics' collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available here. Gallup uses IP anonymization, which truncates/anonymizes the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to and shortened by Google servers in the USA.
Further information can be found in the Google Analytics Terms of Service.
Only designated administrators of Gallup can access the information gathered by Google Analytics, and the information is used only for administrative and planning purposes to meet the needs of our users, such as to improve the content of the site and to customize the content and/or layout of the site for individuals or groups of users.
b. Cookies for Advertising
2. Information Collected Directly
Gallup also collects Personal Information and other information that users voluntarily provide. It is entirely your decision to provide the requested information.
Gallup keeps all information directly collected confidential, and will only use the information for the particular purpose stated at the point of collection. Gallup will seek your specific permission for any additional use. You may choose to have this information removed at any time. Gallup will never barter, trade, or sell access to your information without your specific consent.
2.1. User Account Data
When setting up an account on one of the Gallup Websites ("User Account"), you may be asked to provide Personal Information including, but not limited to, your name, e-mail address, and your phone number. If you choose to purchase any products, services, access codes or other items for sale by Gallup, you will be asked to provide payment details and your full address for billing purposes.
As a customer/user of Gallup, we may obtain Personal Information about you when you register to use one of our websites or services/products or when you provide feedback about our products or services. The processing is necessary to perform the contract with you according to Article 6 (1) 1 lit. b) GDPR. As a customer/user, we will use your Personal Information, unless otherwise prohibited by law, for the following purposes:
- To provide you with the products and services you request.
- To communicate with you about your account or transactions with us and send you changes to our policies.
- To provide support including, but not limited to, product updates, product patches and fixes and other similar communications.
Furthermore, we will use your Personal Information for our legitimate interests according to Article 6 (1) 1 lit. f) GDPR to notify you about information about features on our site, new product releases and service developments and to advertise Gallup's products and services in accordance with this Privacy Statement.
Any User Account data will only be stored until you decide to terminate your User Account (see clause III.1. below). In case we are obliged to further store your Personal Information due to statutory retention requirements, your Personal Information will be barred for further use by Gallup and only be stored until such retention periods expire.
2.2. Other Personal Information Provided Directly
Personal Information provided by you on Gallup Websites, e.g. via contact forms, or via telephone will be stored in our service database and retained for the period necessary to fulfill our contractual obligations to you in accordance with Art. 6 (1) 1 lit. b) GDPR unless a longer retention period is required by law.
II. DATA COLLECTION
Many Gallup websites offer users the opportunity to participate in surveys or assessments via the internet. Gallup will provide information about the purpose and process for each survey or assessment as part of the applicable survey or assessment.
1. Access to Your Survey or Assessment Results From Another User Account
Another online user may purchase an access code to a Gallup survey or assessment for you. Please note that when participating in a survey or assessment, your results will also be accessible to the online user who purchased the Gallup access code. The data accessible to that account holder may include your name and your results, but will not include your specific answers to individual questions within the survey or assessment. In addition, the account holder cannot modify, alter, or delete any of your results or User Account data.
After completion of the survey or assessment, you will at all times have the opportunity to change the settings for sharing your results with other account holders and opt-out from sharing your results.
2. Sharing Your Survey Results With Other People
III. GENERAL INFORMATION ON COLLECTION AND PROCESSING OF INFORMATION
1. Correcting and Changing User Information and Preferences; Deletion of User Accounts
If you have given your consent in accordance with Article 6 (1) 1 lit. a) GDPR to receiving e-mail communications from Gallup but wish to withdraw your consent and discontinue this service, you may do so at any time by contacting us (see also below clause III.8. "Your rights"). In addition, as a registered user, you can change your settings within your User Account under "MY ACCOUNT" by updating your "Contact Me" settings.
You also have the option at all times to have your User Account deleted for any of the Gallup websites or to request a revision of your user information at any time. To do so, please contact us.
2. Information Security
3. Third-Party Information Storage
4. Children and Privacy
Gallup encourages parents and guardians to spend time with their children online and to be fully familiar with the sites visited by their children. Gallup sites do not contain content that is generally considered unsuitable for children.
5. Links to Other Sites
Gallup websites may contain links to sites owned and/or operated by other organizations, and the privacy policies of those sites may differ from that of Gallup. These sites may collect data and make use of it in ways that Gallup does not. We encourage you to review the privacy policies posted on all third-party sites.
6. Location of Data Collection and Processing and Storage
In personally accessing Gallup websites, you may be submitting Personal Information and survey or assessment results that Gallup will use for business purposes that are consistent with this Privacy Statement. As a worldwide organization, Gallup collects information that may be processed internationally throughout Gallup offices worldwide. Your information may be processed in the United States or any other country in which Gallup maintains facilities including any Gallup subsidiary (a complete list of Gallup companies can be found on Gallup.com).
Gallup keeps Personal Information gathered and processed for the purposes described in this Privacy Statement for as long as there is a business purpose.
7. Compliance and Cooperation With Regulatory Authorities
Gallup complies with the EU-U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information transferred from the European Union and Switzerland to the United States respectively. Gallup has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification please visit https://www.privacyshield.gov.
8. Your Rights
You have the right to access the Personal Information that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Information where it is inaccurate, or has been processed in violation of the EU-US Privacy Shield Principles. When updating your Personal Information, we may ask you to verify your identity before we can act upon your request.
You may also, if governed by the General Data Protection Regulations, object to the use or processing of your Personal Information or withdraw consent to use your Personal Information at any time.
Under the General Data Protection Regulations, regarding the processing of your Personal Information, you have the following rights:
- the right to require free of charge (i) information whether your Personal Information is retained and (ii) access to and/or (iii) duplicates of the Personal Information retained. However, if the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request;
- the right to request proper rectification, removal or restriction of your Personal Information;
- where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability);
- where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question; the right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you and
- the right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.
To exercise the rights referred to above, please contact us at Privacy_Administrator@Gallup.com.
As far as we process your Personal Information on the basis of our legitimate interests pursuant to Art. 6 1) lit. f) GDPR, you may object to processing at any time. You may find the detailed description of our processing activities and the legal basis in the sections before. If you object we will no longer process your Personal Information unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defense of legal claims. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.
Please note that the processing of your Personal Information may involve advertising activities as described above. If you do not want that we process your Personal Information for direct marketing activities, you can object free of charge at any time via e-mail Privacy_Administrator@Gallup.com.
Gallup will obtain your consent before sharing your Personal Information with any third party that is not acting as an agent or vendor to perform tasks on our behalf or to use the information for a purpose materially different from the purpose for which it was initially collected or subsequently authorized by you. An exception to this will be (among others) where Gallup's processing of Personal Information is necessary for compliance with a legal obligation under the applicable law.
9. Sensitive Information
For processing of your sensitive information (e.g. medical information, Personal Information revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural's person sex life or sexual orientation), we will obtain your explicit consent.
Gallup is among others not required to obtain explicit consent with respect to sensitive information where the processing is (a) necessary to protect the vital interests of the data subject or another natural person where the data subject is physically or legally incapable of giving consent; (b) necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity; (c) necessary to carry out Gallup's obligations in the field of employment law in so far as it is authorized by European Union or Member State Law or a collective agreement pursuant to Member State Law providing for appropriate safeguards for the fundamental rights and the interests of the data subject; or (d) related to information that is manifestly made public by the individual.
10. Dispute Resolution
If you have any complaints regarding our compliance with this Policy or a Privacy Shield related or general privacy related complaint, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with this Policy.
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://www.jamsadr.com/eu-us-privacy-shield.
With respect to human resources data, Gallup will cooperate and comply with the EU DPA's and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with the advice given by such authorities with respect to human resources data transferred from the EU and Switzerland in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from Gallup, or if we have not addressed your complaint to your satisfaction, you may contact the EU DPA's for more information or to file a complaint. The services of the EU DPA's are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, you have the possibility to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Gallup is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
11. Gallup Privacy Notice for California Residents
INFORMATION WE COLLECT
The Gallup website (the "Site") 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, the Site has collected the following categories of personal information from its consumers within the last 12 months:
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
- Protected classification characteristics under California or federal law
- Commercial information
- Internet or other similar network activity
- Geolocation data
- Professional or employment-related information
- Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))
- Inferences drawn from other personal information
Personal information does not include:
- Publicly available information from government records
- Deidentified or aggregated consumer information
- Information excluded from the CCPA's scope such as:
- 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 (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Gallup obtains the categories of personal information listed above from the following categories of sources:
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Site.
- Indirectly from your employer. For example, information required for you to complete a Gallup survey or assessment.
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. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize and develop our Site, products and services.
- To create, maintain, customize and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- 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 personalize your Site experience.
- For testing, research, analysis and product development, including to develop and improve our Site, products and services.
- To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
Gallup 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
Gallup may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter 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.
We share your personal information with the following categories of third parties:
- Subsidiaries and affiliates
- Contractors and service providers
- Data aggregators
- Third parties with whom we partner to offer products and services to you
DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE
In the preceding 12 months, Gallup has disclosed the following categories of personal information for a business purpose to one or more of the parties identified above:
Category A: Identifiers
Category B: California Customer Records personal information categories
Category C: Protected classification characteristics under California or federal law
Category D: Commercial information
Category E: Internet or other similar network activity
Category F: Geolocation data
SALES OF PERSONAL INFORMATION
In the preceding 12 months, Gallup has not sold personal information.
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 Gallup 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 (see Exercising Access, Data Portability and Deletion Rights), 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, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased
- 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 Gallup 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 (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our 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 consumer 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
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by contacting us at:
Only you, or a person registered with the California Secretary of State who you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice in 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.
Making a verifiable consumer request does not require you to create an account with us. 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 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account.
If you do not have an account with us, 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 usable and should allow you to transmit the information from one entity to another entity without hindrance.
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
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer who is between 13 and 16 years of age.
Consumers who opt in to personal information sales may opt out of future sales at any time.
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.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
OTHER CALIFORNIA PRIVACY RIGHTS
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write or email to us at:
12. Policy Updates
This Privacy Statement is Gallup's promise to its websites users and Users with a registered User Account. Additional information that is particular to specific Gallup sites may exist, and updates to this policy may be posted. For these reasons, we suggest that users who may have specific concerns about the information being gathered and use of that information regularly view the Privacy Statement on each site. Gallup reserves the right to change the policy on use of information collected at any time.
13. Additional Questions or Comments