Effective Date: December 2018

The L2 website located at www.l2inc.com and the associated L2 products (collectively, “the Services”) are provided by L2 Inc., a wholly owned subsidiary of Gartner Inc. Please read this Privacy Policy (“the Policy”) carefully as it sets out important information relating to how we handle your personal information. 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 Officer through the following means:

Global Data Protection Officer
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, 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 analysing use of the Services

We use this information because:

  • It is necessary for performing our obligations, or exercising our rights, under our contracts with Clients
  • It is necessary for compliance with any legal or regulatory obligations
  • We have a legitimate business interest to:

    • Promote our brand, Services, events, and business
    • Monitor, investigate, and report any attempts to breach the security of the Services
    • Provide and improve the Services
    • Operate our business
  • 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
  • Behavioural information, such as information on the behaviour or presumed interests of clients
  • 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 analysing use of the Services

We use this information because:

  • It is necessary for compliance with any legal or regulatory obligations
  • 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
    • Provide and improve the Services
    • Operate our business
    • 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, email address, company name, job title, and country
  • Information to facilitate your attendance at an event, such as dietary requirements or physical or mental disability or impairment you may disclose to us

We use this information for certain activities, including:

  • Registering you for an event
  • Facilitating your attendance at an event, including providing hospitality that is suitable for attendees of our events
  • Providing better, more customized client service and responding to your inquiries
  • Facilitating networking with fellow event attendees
  • Investigating any complaints
  • Researching and analysing attendance at our events

We use this information because:

  • It is necessary for performing our obligations, or exercising our rights, under our contracts with Clients
  • It is necessary for compliance with any legal or regulatory obligations
  • We have a legitimate business interest to:

    • Promote our brand, Services, events, and business
    • Provide and improve the Services
    • Operate our business
  • We have your consent (where required under applicable law) to collect your sensitive information or use your information for marketing. Where we rely on your consent, you have the right to withdraw consent by contacting us.

1.2 Further information

Where legitimate interests are mentioned above, a legitimate interest will only apply where we consider that your interests or rights which require protection of your personal information do not override our legitimate interests. If you require further information regarding our legitimate interests as applied to your personal information, you may contact our Data Protection Officer.

The Services are for individuals who are at least 18 years of age. The 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 (such as log-in information to create an account), we will not be able to perform our obligations under the contract with you or may not be able to provide you with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be.

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 enrol 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. INTERNATIONAL TRANSFERS

We may transfer personal information to other Gartner group companies or suppliers outside your home jurisdiction. We will take all reasonable steps to ensure that personal information is protected and any such transfers comply with applicable law.

L2 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 L2 and Gartner do 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.

4. 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 mandate that we retain your personal information. We may also retain personal information for the period during which a claim may be made in relation to our dealings with you.

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.

5. 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.

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.

6. DATA SUBJECT RIGHTS

You have certain rights, in certain circumstances, in relation to your personal information. A summary of each right and how an individual can take steps to exercise it is set out below. If you wish to exercise any of these rights, please contact us using the contact details specified above for the Data Protection Officer. Such requests should include appropriate identity verification information (such as your name, address, email address or other information reasonably required).

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 and in any event within one month of receipt of the request. This may be extended by a further two months 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 L2 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 defence 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 defence 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.

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 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.

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 California Privacy Rights

Subject to certain limits under California Civil Code § 1798.83, California residents may request certain information regarding our disclosure of their personal information (as defined by California law) to third parties or their direct marketing purposes. To make such a request, please contact us as specified at the beginning of this Policy.

9.3 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.