Privacy Policy

Effective/updated as of January 18, 2022

Introduction

Emergn (“the Company”) is committed to protecting the privacy of personal information we collect when you access emergn.com (“the Site”). This Privacy Policy (“the Policy”) describes our policies and practices regarding how we collect, use and disclose information that you submit or that we obtain in connection with your use of the Site. 

BY ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. Please read the Policy carefully before using the Site or submitting personal information to us. The Policy is incorporated into and subject to the Terms of Use. 

Changes to the policy

We reserve the right to make changes to this Policy at any time. In the event we make material changes to the Policy, we will provide notice through the Site. Changes will be effective immediately upon posting to the Site and will apply to your use of the Site after the “effective date” listed above.

You understand and agree that your continued use of the Site after the effective date means that the collection, use, and sharing of your personal information is subject to the updated Policy.

Except to the extent we receive your authorization or as permitted or required by applicable law, we will handle your data in accordance with the terms of the Policy in effect at the time of the collection.

Information we collect

We may collect personal information that you provide directly to us, such as information you submit when you visit the Site. We may also collect information that is passively or automatically collected from you, such as information collected from your browser or device. We use this information to operate the Site, carry out our business, comply with laws and for other purposes described herein.

Information you provide and how we use it

When you contact us, purchase something through the Site, interact with us through an online “chat conversation”, register an account, subscribe to our newsletter, request a thought paper, sign up for a webinar or event, or agree to receive our marketing materials you may provide some or all of the following:

• Your name and email address
• demographic information such as name, company, job title, industry and phone number
• username and password
• credit card number and related payment and shipping information (We use a third-party service to process your online payment, but we do not store the credit card information you provide.)

If you apply for a job with us, we collect the information contained in your resume and related materials.

When you take any diagnostic assessments on our Site, you may provide information such as your team’s name and details of your working practices for the purpose of us making recommendations for improvements you can make to your ways of working and learning content you may find relevant.

Occasionally, we may display surveys on the Site to gather your feedback and guide our product development. These surveys are optional, and it is up to you whether you choose to provide a response.

You do not have to provide the above information to access or use the other sections of the Site.

Information from third parties

We may collect information about you from third parties, such as through your social media services consistent with your settings on such services, and from other third-party sources that are lawfully entitled to share your data with us. We may use and share this information and add it to the other information we have on file for you for the purposes described in the Policy.

Statistical data

To monitor use of the Site and continuously improve its quality, we may compile statistical information concerning the usage of the Site with the help of third-party analytics vendors. Examples of this information would include: the number of visitors to the Site, or to sections or pages within the Site, patterns of traffic flowing through the Site, length of time spent on the Site, or in sections or pages of the Site, the other sites that refer visitors to the Site, the pages of the Site that visitors frequently use as entry and exit points, utilization of the browser and operating systems and versions used by visitors to the Site, methods used to browse away from the page, any phone number used to call our customer service number, and location information. The analytics services may transfer this information to third parties in case of a legal obligation or if a third-party processes data on behalf of that service.

To compile this information, we may collect and store:

• Your IP address
• Your operating system and platform
• Your browser type and version
• Time zone setting
• Location
• Browser plug-in types and versions
• The pages you visit within the Site
• Your interactions with elements on those pages, such as buttons clicked
• Data provider
• The length of time you spend on pages within the Site
• The site from which you linked to the Site
• Search terms you used in search engines that resulted in you linking to the Site, etc.

In general, while all of this information can be associated with the IP address your computer had while you visited the Site, it will not be associated with you as an individual or associated with any other information you may submit through the Site, or that we may store about you for any other purposes.

If you submit your email address in one of our online forms or register an account, you will be created as a “contact”. We will link your activity on the Site to that contact. If you register an account using your company email address, we may add publicly available information about the company in that contact.

We may also use this information to generate aggregate statistics about visitors to our Site. Please check your web browser if you want to learn what information your browser sends or how to change your settings.

Akismet

The Site uses Automattic’s Akismet to detect abusive traffic on the Site. Aksimet checks form submissions against its global database of spam – training, identifying and filtering out malicious entries. Only the personal data needed to carry out Akismet’s core function of protecting the Site against form submission spam is collected from commenters on the Site.

They do not sell the data sent to the Akismet service, and they do not keep it for long. They have short retention periods of between two weeks and ninety days for the vast majority of their spam-related data, at which point it is automatically deleted from their databases. Anyone can opt-out of all long-term tracking for the very small subset of data they do keep longer by using their contact form. For more information, please visit their Privacy Notice

Cookies

We use cookies on the Site. A cookie is a small file consisting of letters and numbers that automatically collects certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform functions such as remembering the contents of a shopping cart or your user preferences, improving the quality of your visit, recording the website pages you view, remembering the name or address you entered during a visit, or delivering ads that are targeted to your interests and browsing activity.  

For visitors to emergn.com, please see our Cookie Policy for more information on how the Site uses cookies and to manage your cookie preferences.

By using the Site, you consent to the processing of any personal information for the analytics purposes and functions described above.

Embedded content

The Site contains embedded content (e.g. videos). Embedded content may place third-party cookies on your device that track your online activity to enhance your experience or assess the success of their application. We have no direct control over the information these cookies collect, and you should refer to their website privacy policy for additional information.

Do not track

“Do Not Track” is a privacy preference that you can set in your internet browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because the Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests. We track the Site users over time and across third-party websites.

How we use your personal information

In general, we will use the personal information we collect only for the purpose it was collected, for compatible purposes, as permitted or required by law, as necessary to carry out our contractual duties and obligations, and as otherwise provided in the Policy. In addition to the examples provided above, we may use your personal information in the following ways:

• To enable your use of the Site.
• To provide you with information, products or services that you request from us.
• To manage your account.
• To process your payments and fulfill orders.
• To communicate with you, including sending messages about the availability of the Site, security, or other service-related issues. (You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.)
• For other everyday business purposes such as product development, contract management, IT and website administration and security, fraud prevention, corporate governance, reporting and legal compliance.
• To engage in marketing and advertising activities, including lead generation, data matching, enrichment, or profiling to identify customer needs and interests.
• To communicate with you in social media concerning our products and services.
• To carry out our obligations and enforce our rights, including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
• To review, improve, and monitor our website, applications, online services, and overall customer experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of customer.
• To provide customer service and engage in quality control activities concerning our products and services.
• For testing, research, analytics and product and service development.
• To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes; for public safety purposes.
• To process applications for employment, as well as to evaluate and improve our recruiting efforts.
• As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• To provide you with relevant recommendations of actions and learning content to help you improve your ways of working.
• To provide you or your employer with a view of your learning progress.

Disclosure of information

In general, we will not disclose your personal information except with your consent and as described in the Policy. We may disclose your data for the same reasons that we may use it as described in this Policy, which includes disclosing it to our affiliates and non-affiliated third parties, as we deem necessary to carry out those purposes.

Third parties, vendors or service providers

We may need to use or disclose this information with a member of our group partners or third-party vendors as follows:

• With your consent or as you direct
• To manage the Site
• For event or activity hosting and management.
• To improve and optimize our Site
• For cloud storage
• For the performance of obligations arising from any contract we enter into with you;
• To process payments and requests for products and services
• To provide you with our products, services, offers, promotions, news, etc.
• For marketing activities, including delivering advertisements with our marketing automation vendor, social media partners, and AdTech vendors
• For data cleansing to ensure we have accurate and up to date information
• To enhance our services by, among other methods, obtaining assistance with providing more personalized services to you through analytics and other technologies (including, but not limited to, data storage, maintenance services, database management, web analytics and payment processing)
• To protect our interests and legal rights, such as through responding to subpoenas and defending litigation
• To protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications) and claims and other liabilities.

We endeavor to choose affiliates and non-affiliates with similar standards to ours regarding the protection of data.  

Legal process, security, defense, protection

It is possible that we may need to disclose information about you if required by law, subpoena, or other legal process.

Additional disclosures

We may disclose information about you if we have a good faith belief that disclosure is reasonably necessary to:

• demonstrate our relationship with you
• investigate, prevent, or take action regarding suspected or actual illegal activities or to assist law enforcement agencies
• protect the security or integrity of the Site
• protect against or investigate fraud
• investigate and defend ourselves against any third-party allegations or claims
• protect the rights and safety of others.

Registered users

We may disclose information about a registered user’s activity on the Site and learning progress to their employer if their access was purchased by their employer, e.g. an enterprise license or they are a client of Emergn for consulting services.

Change in control or sale

We can share, sell, assign, or license your personal data in connection with certain business transactions, such as a sale, acquisitions, merger, or change in control, or in preparation for any of these events. In such cases, we will take appropriate steps under the circumstances and to the extent possible to ensure that the recipient agrees to provide privacy protections substantially similar to those established by this Policy. Any entity that acquires all or substantially all the Company’s assets will have the right to continue using your data consistent with this Policy or as otherwise agreed to by you.

In no case will we sell or license your data to third parties, except as set forth above or as required or permitted by law.

Safeguarding information

We employ reasonable and appropriate administrative, physical and technical measures designed to protect the security of personal information we collect from you. However, no system for safeguarding personal or other information is 100% secure and although we have taken steps to protect your personal information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information. 

Your choices regarding your personal information

You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access some of the services, offers, and content on the Site.

Links to third parties’ sites and third-party integrations

For your convenience, we may provide links to sites operated by organizations other than the companies in the Emergn Group that we believe may be of interest to you. We do not disclose your personal information to these sites without obtaining your consent and we do not endorse, and are not responsible for, the privacy practices of these sites. If you choose to click on a link to one of these sites, you should review the privacy policy posted on the other site to understand how they collect and use your personal information.

We may also provide links to third party integrations. Third party integrations are websites or platforms that synchronize with our Site to provide you with additional functionality, tools, or services such as collecting resumes, providing maps, sending requested information, etc.

You acknowledge and agree we are not responsible for the availability of third-party sites, resources, or integrations and do not endorse and are not responsible or liable for any content, advertising, goods, services or other materials on, available through, or provided by such sites, resources, or integrations. We are not responsible for the privacy or other practices of such sites or integrations and cannot guarantee the security of personal information that you provide, or is collected by, such sites. We encourage you to review the privacy policies and terms and conditions on those linked sites and integrations.

Information on children

The Site is not directed to children as the products and services on the Site are intended for persons 13 years of age and older. We do not knowingly collect, use, or disclose any personal information from children. If we are alerted that personal information of persons less than 13 years-of-age has been collected through our Site, we will take the appropriate steps to delete this information.

Applicable law

The Policy is governed by the internal substantive laws of the Republic of Ireland without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Privacy Policy shall lie exclusively with the state and federal courts within the Republic of Ireland. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.

California residents

“Shine the Light Law”

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by certain members of the Company to third parties for the third parties’ direct marketing purposes. Requests may be made one time per calendar year. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 sharing activities). You may submit your request using the contact information at the end of this Policy.

California Consumer Privacy Act (“CCPA’”) Addendum

The following California Privacy Policy Addendum (“CA Addendum”) applies solely to individuals who are residents of the State of California (“consumers” or “you”). This CA Addendum describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Site, or through other channels including, but not limited to visiting one of our locations, phone and email conversations, online chat conversations, social media interactions on our websites and other third party websites such as social media sites, viewing our emails, or through our authorized services providers.

This CA Addendum supplements and amends the information contained in the Site Policy with respect to California residents. Any terms defined within the CCPA have the same meaning when utilized within this CA Addendum. The other provisions of the Policy continue to apply except as modified in this CA Addendum.

This CA Addendum does not apply to personal information we collect about you as a job applicant to, an employee of, owner of, director of, officer of, or contractor of the Company. This CA Addendum also does not apply to personal information we collect about you as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency when your communications or transactions with the Company occur solely within the context of the Company conducting due diligence regarding, or providing or receiving a product or service to or from, such company, partnership, sole proprietorship, non-profit, or government agency.

Please read this CA Addendum carefully before using the Site or submitting information to us.  By accessing or visiting the Site, you indicate your understanding that the collection, use, and sharing of your information is subject to the terms of this CA Addendum and our Terms of Use Except as otherwise noted, any capitalized terms not defined in the CA Addendum have the meaning set forth in the Policy and Terms of Use.

IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS CA ADDENDUM, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.

a. Personal information we collect

As described below, we may collect or have collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of PI we collect and the purpose we use PI. In that case, we will inform you by posting an updated version of this CA Addendum on the Site.

1. Identifiers. Examples include real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
2. Other elements. Examples include name, signature, characteristics or description, address, telephone number, education, employment, employment history, bank account number, credit card number.
3. Characteristics of protected classifications under California or federal law. Examples include race, religion, and age.
4. Commercial information. This includesservices purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
5. Education information. This includes information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
6. Internet or other electronic network activity. Examples include browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
7. Geolocation data. This might include location information while using the Site.
8. Audio, electronic, visual, thermal, olfactory, or similar information. Examples of this category including identifiable information obtained about you while speaking with our customer service representatives on the telephone.
9. Professional or employment-related information.
10. Consumer profile. This includes inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and behaviors.

PI does not include:

1. Publicly available information from government records.
2. Deidentified or aggregated consumer information.
3. Information excluded from the CCPA’s scope, such as certain health or medical information and other categories of information protected by different laws.

b. Purposes for which we collect your personal information

We have collected your PI for the following business or commercial purposes. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.

1. To provide you with information, products or services that you request from us.
2. To fulfill or meet the reason for which the information is provided. For example, if you place an order with us, we will collect your address for delivery/shipping purposes or to fulfill our tax collection and reporting obligations.
3. To contact you and/or provide you with email alerts and other notices concerning our products or services, or events or news, that may be of interest to you.
4. To engage in marketing activities, including to help design products and services appropriate for our customers.
5. To communicate with you on social media concerning our products and services.
6. To carry out our obligations and enforce our rights including those arising from any contracts entered into between you and us, including for billing, payment, and collections.
7. To review, improve, and monitor our website, applications, online services, and overall customer experience, including to provide customization to meet the specific needs, ensure a consistent experience, and to assess trends, interests, and the demands of customers.
8. To provide customer service and engage in quality control activities concerning our products and services.
9. For testing, research, analysis and product and service development.
10. To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
11. As described to you when collecting your personal information or as otherwise set forth in the CCPA.
12. To process applications for employment, as well as to evaluate and improve our recruiting efforts.
13. As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
14. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
15. To provide you with relevant recommendations of actions and learning content to help you improve your ways of working.
16. To provide you or your employer with a view of your learning progress.

c. Sources of personal information

• You. We may collect personal information from you when you contact us, place an order, schedule an event, register, participate in a contest, promotion, or survey, or apply or inquire about employment; or through web technologies such as browser cookies, and web beacons set when you visit the Site.
• Social media and related services.
• Third Parties. We may collect information about you from third parties such as from your employer, through your social media services consistent with your settings on such services, or from other third-party sources that are lawfully entitled to share your data with us.

d. Sharing or disclosing personal information

Of the categories of PI noted above, during the past 12 months, we shared the following:

Categories of Personal Information disclosed

Categories of third parties to whom disclosed

Identifiers. Other elements. Characteristics of protected classifications under California or federal law. Commercial information. Education information. Internet or other electronic network activity. Geolocation data. Audio, electronic, visual or similar information. Professional or employment-related information. Consumer profile.

Third parties as directed by you. We will share your PI with those third parties to whom you direct. Our business partners. For example, we might share your PI with one of our business partners for purposes of collaborating on providing services to you, or to invite you to an event we are organizing. These business partners should also have their own privacy statements that set out the manner in which they will collect, use, and disclose PI. Where applicable, we encourage you to review each such business partner’s privacy statement before signing on with them. Third parties who perform services on our behalf. For example, we share information with certain service providers, including marketing companies, AdTech vendors, professional service providers, debt collectors, information technology providers, and data storage companies. We might also authorize our service providers to collect PI on our behalf. Governmental entities, legal service providers. We may share your PI in order to comply with the law and in the course of providing our products and services. We may also disclose information if a government agency or investigatory body submits a request. Successors to all or portions of our business. If all or part of our business is sold, we may disclose PI in preparation for or as part of that transaction.

We do not sell your PI as that term is defined in the CCPA. We do not have actual knowledge that we have sold personal information of minors under age 16.

e. Consumer rights

The CCPA provides California consumers with the following rights, subject to certain exceptions:

   1. Right to request deletion

You have the right to request that we delete your PI from our records, subject to certain exceptions.

Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will delete and direct any service providers to delete your PI from its records.

The Company is not required to comply with your request to delete your PI if it is necessary for the Company (or its service provider) to maintain your PI in order to:

1. Complete the transaction for which the PI was collected, provide a good or service requested by you, or reasonably anticipated within the context of the Company’s ongoing business relationship with you, or otherwise perform a contract between the Company and you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
3. Debug to identify and repair errors that impair existing intended functionality.
4. Exercise free speech ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
6. To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company.
7. Comply with a legal obligation.
8. Otherwise use your PI, internally, in a lawful manner that is compatible with the context in which you provided the information.

   2. Right to know

You have the right to request that we disclose the following to you as it relates to the 12-month period preceding the Company’s receipt of your verifiable consumer request (see below):

1. The categories of PI we have collected about you.
2. The categories of sources from which the PI was collected.
3. The business or commercial purpose for collecting or selling PI.
4. The categories of PI we disclosed or sold for a business purpose.
5. The categories of third parties we disclosed or sold PI to, by the category of PI.
6. The specific pieces of PI we collected about you.

   3. Nondiscrimination

We will not discriminate against you for exercising any of your CCPA rights. For example, we generally will not provide you a different level or quality of goods or services if you exercise your rights under the CCPA.

f. Submitting consumer rights requests

To submit a California Consumer Rights request as outlined in this CA Addendum, please contact us at (833) 776-8245 or [email protected].

g. Verifiable requests

We reserve the right to only respond to verifiable consumer requests. A verifiable consumer request is one made by any individual who is:

1. the consumer who is the subject of the request
2. a consumer on behalf of the consumer’s minor child, or  
3. by a natural person or person registered with the Secretary of State authorized to act on behalf of a consumer.

If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a Consumer. In general, we may ask you to provide identifying information that we already maintain about you or we may use a third-party verification service. In either event, we will try to avoid asking you for sensitive PI to verify your identity. We may not be able to respond to your request or provide you with PI if we cannot verify your identity or authority to make the request and confirm the PI relates to you. However, making a verifiable consumer request does not require you to create an account with us.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the PI we collect from an individual to determine a verifiable request for any other purpose, except as required by law.

We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will attempt to respond to a verifiable consumer request within forty-five (45) days of receipt, but we may require up to ninety (90) days to respond, under which circumstances we will notify you of the need for an extension.

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 receipt of your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. To the extent permitted by the CCPA, we will respond to no more than two requests during any 12-month period.

h. Authorized agents

You may authorize a natural person, or a business registered with the California Secretary of State to act on your behalf with respect to the right under this CA Addendum. When you submit a Request to Know or a Request to Delete, unless you have provided the authorized agent with a qualifying power of attorney, you must provide your authorized agent written permission (signed by you) to act on your behalf and verify the authorized agent’s identity with us. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.

European Economic Area

If you are located in the European Economic Area (“EEA”), please read the following:

This section incorporates the general provisions of the Policy, where applicable. If any provision in the Policy is inconsistent with this EEA section (“EEA Policy”), the terms of this EEA Policy shall apply to the processing of Personal Data subject to this EEA Policy. Terms used in this EEA Policy shall have the meaning ascribed to them by the applicable data protection law, including the definition of Personal Data.

For purposes of applicable data protection laws, we are the data controller of the personal data we collect through this Site. As data controller, we process your personal data in accordance with this EEA Policy. If you have any questions, you may contact us at [email protected]. 

We make every attempt to process your personal data in accordance with applicable law. In addition to the information provided above, individuals located in the European Economic Area should be aware of the following:

Rights

You may have certain additional rights, subject to limitations, regarding the processing of your personal information. These may include the right to:

• Access or request a copy of your personal data
• Correct any inaccuracies relating to your personal data
• Restrict the processing of your personal data
• Object to the processing of your personal data, including where the data is used for marketing purposes
• Request the erasure of your personal data
• Receive your personal data in a commonly used machine-readable format and have that data transmitted to a data controller of your choosing
• Withdraw your consent to the processing of your personal data where processing is based on consent
• Right not to be subject to automated decisions where the decision produces a legal effect or similarly significant effect
• Lodge a complaint with the appropriate authority in your jurisdiction.

To exercise any of these rights, please contact us [email protected].

Legal basis for processing

The following chart identifies the legal basis for processing personal data we collect from you. We may process your Personal Data for a variety of purposes as outlined in the Policy and this EEA Policy. In general, we will process your personal data based on your consent, our legitimate interests, for performance of a contract with you or to meet legal obligations.

You may obtain information regarding how we assess our legitimate interests or opt out of our processing your personal data where our legitimate interest is not outweighed by your privacy rights by contacting us at [email protected].

Data elements	Purpose for processing	Legal basis for processing
Identity data Contact data Financial data Professional data Education data Usage and technical data	To provide information, products, and services that you request or that we think would interest you; to register you for events or webinars. To perform research and development. To measure the effectiveness of our education. To provide you or your employer with a view of your learning progress. To develop and administer the Site including how the Site is used. For marketing activities, lead generation, business development, data matching or enrichment, or to develop customer profiles for analyzing customer behaviors, needs, and interests. To communicate with you.	Performance of a contract. Legal or regulatory requirements. Legitimate interests. Consent.
Financial data	To provide information, products, and services that you request.	Performance of a contract.
Professional data Education data Special categories of data	To process applications for employment, as well as to evaluate and improve our recruiting efforts.	Performance of a contract. Legal or regulatory requirements. Legitimate interests. Consent.

You are not required to provide any of this personal data; however, if you choose not to provide certain requested information, you may be unable to access some of the services, offers, and content on the Site.

We will process your personal data for the purpose for which we collected it and for further purposes only if we deem them compatible with that original purpose.

Retention

We retain your personal data only for the period of time needed to fulfill the purposes stated in this Policy, comply with applicable laws, and for our legitimate business needs.

International transfers

When we share your personal data within the Emergn Group, or with our subsidiaries, we may transfer your data out of the EEA. We will make such transfers in reliance on an adequate transfer mechanism. To obtain additional information on how we transfer your personal data, please contact us at [email protected].

Contact us

[email protected]

190 High Street, Floor 4
Boston, MA 02110
USA

Clerks Court
18-20 Farringdon Lane
London
EC1R 3AU
UK