Last Updated February 15, 2023
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 Privacy Statement describes the types of information, including Personal Information, collected and processed through Gallup websites and mobile applications (collectively, “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.
This Privacy Statement covers the following topics:
I. INFORMATION COLLECTED BY GALLUP WEBSITES
- Information Collected Indirectly
- Information Collected Directly
II. DATA COLLECTION
- Access to Your Survey or Assessment Results From Another User Account
- Sharing Your Survey Results With Other People
III. GENERAL INFORMATION ON COLLECTION AND PROCESSING OF INFORMATION
- Correcting and Changing User Information and Preferences; Deletion of User Accounts
- Information Security
- Third-Party Information Storage
- Children and Privacy
- Links to Other Sites
- Location of Data Collection and Processing and Storage
- Your Rights
- Sensitive Information
- Dispute Resolution
- “Do Not Track” Signals
- U.S. State-Specific Privacy Disclosure
- Gallup Privacy Notice for California Residents
- Policy Updates
- Additional Questions or Comments
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).
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.
Cookies and Other Tracking Technologies
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 use the information only 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.
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, email 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.
For European data subjects, the processing is necessary to perform the contract with you according to Article 6 (1) 1 lit. b) of the European Union’s General Data Protection Regulation (“GDPR”) or UK General Data Protection Regulation for United Kingdom data subjects. 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 be stored only 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 be stored only 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 to 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 email communications from Gallup but wish to withdraw your consent and discontinue this service, you may do so at any time by clicking the unsubscribe link included in the footer of our emails or by contacting us (see also below clause III.7. "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
We provide Personal Information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Statement and any other appropriate confidentiality and security measures. For example, we use vendors such as Amazon cloud for data storage. Any vendor or agent that we retain is not allowed to use Personal Information they receive from us for any other purpose than to perform the contracted services we have contracted them to perform.
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 websites 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 for doing so. Please also see clauses I.2.1 and I.2.2 above for additional information on how we retain your Personal Information.
7. 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. 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 GDPR, object to the use or processing of your Personal Information or withdraw consent to use your Personal Information at any time.
Under GDPR, regarding the processing of your Personal Information, you have the following rights:
- the right to require free of charge (i) information on 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 that produce legal effects on you or similarly significantly affect 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 are 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 email: 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.
8. 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 consent or, where legally required, your explicit consent.
Gallup is among others not required to obtain explicit consent under GDPR 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 insofar 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.
9. Dispute Resolution
If you have any complaints regarding our compliance with this Privacy Statement, 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.
With respect to human resources data, Gallup will cooperate and comply with the EU Data Protection Authorities (DPAs) 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 DPAs for more information or to file a complaint. The services of the EU DPAs are provided at no cost to you.
Gallup is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
10. “Do Not Track” Signals
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Gallup websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
11. U.S. State-Specific Privacy Disclosure
Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. Please see our U.S. State-Specific Privacy Disclosure to learn more.
12. Gallup Privacy Notice for California Residents
If you are a California resident, please see our Gallup Privacy Notice for California Residents.
13. Policy Updates
Additional information that is particular to specific Gallup websites 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 website. Gallup reserves the right to change the policy on use of information collected at any time by posting an updated version on each website. If required by law, we will provide you with notice of any update.
We are committed to ensuring this Privacy Statement is accessible to individuals with disabilities. If you wish to access this Privacy Statement in an alternative format, please contact us as described below.
15. Additional Questions or Comments
If you have any inquiries, complaints, access requests and any other questions or comments regarding Gallup's Privacy Statement, please contact us.