Safe Harbor Privacy Notice

Poll Everywhere, Inc. (“Poll Everywhere”) has certified that the company abides by the Safe Harbor privacy principles as set forth in the U.S.-EU & U.S.-Swiss Safe Harbor Frameworks by the U.S. Department of Commerce regarding the collection, storage, use, transfer and other processing of Personal Data transferred from the European Economic Area (“EEA”) or Switzerland to the United States.

Capitalized terms not defined in this Safe Harbor Privacy Notice shall have the meaning assigned to them in the Poll Everywhere Privacy Policy and Terms of Service.

For purposes of this policy, “Consumer” is an individual Visitor or User -- as the terms are defined in our Privacy Policy -- whose Personal Data Poll Everywhere obtains as the result of the individual’s use of Poll Everywhere polling product or services.

“Personal Data” means any information that (i) is transferred from the EEA or Switzerland to Poll Everywhere in the U.S. and (ii) relates to an identified or identifiable Consumer.

Poll Everywhere’s Safe Harbor certification can be found at safeharbor.export.gov/list.aspx. For more information about the Safe Harbor principles, please visit www.export.gov/safeharbor. For more information about Poll Everywhere’s processing of Personal Data, please visit Poll Everywhere’s Privacy Policy.

How Poll Everywhere Obtains Personal Data

As a provider of polling services, Poll Everywhere obtains Personal Data directly from Consumers who use Poll Everywhere products or services, as well as from business customers (such as conference companies and employers) who purchase Poll Everywhere products and services for use by their employees and other individuals. Poll Everywhere requires its business customers to comply with applicable laws governing the collection, use and other processing of Personal Data.

In all cases, as described below, Poll Everywhere’s practices regarding the collection, storage, use, transfer, and other processing of Personal Data comply with the Safe Harbor principles of notice, choice, onward transfer, access, security, data integrity, and enforcement and oversight.

Notice

Poll Everywhere provides information in its Privacy Policy regarding its Personal Data practices. Poll Everywhere also informs its business customers that they are responsible for providing appropriate notice to their Consumers.

Choice

In circumstances in which Poll Everywhere collects Personal Data directly from Consumers, we offer Consumers the opportunity to choose whether Poll Everywhere may (i) disclose their Personal Data to certain third parties for those parties’ own purposes, or (ii) use their Personal Data for a purpose that is incompatible with the purpose for which the information was originally collected or which was subsequently authorized by the individual.

Our Privacy Policy explains the choices Consumers have to limit our sharing of their Personal Data. Specifically, Users who establish an account with Poll Everywhere may use the account to adjust their preferences on how we use and disclose their information. Visitors who are not registered may contact us at to adjust their preferences.

We may use the information we have about Consumers to offer them products and services that we believe may be of interest to them. We may offer these products and services in conjunction with our business and marketing partners. Consumers may direct us not to use or share their information for these purposes by emailing security@polleveryhwere.com.

Where Poll Everywhere receives Personal Data from its business customers, we have informed the business customers that they are responsible for providing the relevant individuals with a choice regarding the business customer’s use and disclosure of Personal Data.

Poll Everywhere also may disclose Personal Data without offering Consumers an opportunity to opt out (i) if we are required to do so by law or legal process (such as a court order or a subpoena), (ii) in response to a request by law enforcement authorities, or (iii) when we believe disclosure is necessary or appropriate (a) to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (b) to protect or defend the rights or property of Poll Everywhere, Consumers or our business customers. Poll Everywhere also reserves the right to transfer Personal Data in the event we sell, merge or transfer all or a portion of our business or assets. Should such a sale, merger or transfer occur, Poll Everywhere will use reasonable efforts to direct the transferee to use the Personal Data in a manner that is consistent with our Privacy Policy. Following such a sale, merger or transfer, you may contact the entity to which we transferred your Personal Data with any inquiries concerning the processing of that information.

For additional details about the purposes for which Poll Everywhere may disclose Consumer Personal Data, visit the company’s Privacy Policy.

Onward Transfer of Personal Data

Poll Everywhere may share Personal Data with service providers that we have retained to perform services on the Poll Everywhere’s behalf. Poll Everywhere requires service providers to whom it discloses Personal Data and who are not subject to laws based on the European Union Data Protection Directive 95/46/EC to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide the level of protection for Personal Data as is required by the relevant Safe Harbor principles.

Access

Where appropriate, Poll Everywhere provides Consumers with reasonable access to the Personal Data that Poll Everywhere maintains about them. Poll Everywhere also provides a reasonable opportunity for Consumers to correct, amend or delete that information where it is inaccurate. We may limit or deny access to Personal Data where providing such access is unreasonably burdensome or expensive under the circumstances, or as otherwise permitted by the Safe Harbor principles. Users who have established an account with Poll Everywhere may access their Personal Data using their accounts. Visitors may request access to their Personal Data by contacting Poll Everywhere at

In circumstances in which Poll Everywhere receives Personal Data from business customers, we have informed our business customers that they are responsible for providing Consumers with access to the Personal Data and a reasonable opportunity to correct, amend or delete the information where it is inaccurate. Consumers who use Poll Everywhere services through our business customers should direct their access and correction requests to the relevant business customer (e.g., employer or conference company).

Security

Poll Everywhere takes precautions to help protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Data Integrity

Poll Everywhere takes reasonable steps to ensure that the Personal Data the company processes is (i) relevant for the purposes for which it is to be used, (ii) reliable for its intended use, and (iii) accurate, complete and current.

Poll Everywhere depends on Consumers and business customers to update and correct Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the individuals. Users who have established an account with Poll Everywhere may update their Personal Data using the account. Visitors may update their Personal Data by contacting Poll Everywhere at In addition, Poll Everywhere has informed its business customers that they are responsible for taking reasonable steps to ensure that the Personal Data they provide to Poll Everywhere is reliable for its intended use and is accurate, complete and current.

Enforcement and Oversight

Poll Everywhere has established procedures for periodically verifying implementation of and compliance with the Safe Harbor principles. Poll Everywhere conducts an annual self-assessment of its Personal Data practices to verify that the attestations and assertions the company makes about its privacy practices are true and that the company's privacy practices have been implemented as represented.

Consumers may file a complaint concerning Poll Everywhere’s processing of their Personal Data by emailing If the complaint cannot be resolved through Poll Everywhere’s internal processes, we will cooperate with JAMS pursuant to the JAMS International Mediation Rules, which are accessible on the JAMS website at www.jamsadr.com/rules-international-rules. Poll Everywhere will take steps to remedy any issues arising out of a failure to comply with the Safe Harbor principles.

In circumstances in which Poll Everywhere receives Personal Data from a business customer, Consumers may submit complaints concerning the processing of their Personal Data to the relevant business customer, in accordance with that customer’s dispute resolution process.

JAMS mediation may be commenced as provided for in the JAMS International Mediation Rules. The mediator may propose any appropriate remedy, such as publicity for findings of non-compliance, payment of compensation for losses incurred as a result of non-compliance, or cessation of processing of the Personal Data of the Consumer who has brought the complaint. Poll Everywhere will assume the costs of the administrative fees if the mediator makes a written recommendation that finds Poll Everywhere in breach of its duties pursuant to the Safe Harbor. The mediator or the Consumer also may refer the matter to the U.S. Federal Trade Commission, which has Safe Harbor enforcement jurisdiction over Poll Everywhere.

How to Contact Poll Everywhere

To contact Poll Everywhere with questions or concerns about this Safe Harbor Privacy Notice or Poll Everywhere’s practices concerning Consumer Personal Data, please email or write to:

Poll Everywhere, Inc. Attn: Legal Department 1550 Bryant St. Suite 500 San Francisco CA 94103

PLEASE DO NOT SEND ANY SENSITIVE INFORMATION TO US VIA UNENCRYPTED EMAIL. Also, please note that we will need to verify and authenticate any emailed requests for access or changes to your Personal Data or account information.