• Emerge EQ is not a professional entity licensed in any jurisdiction to perform diagnostic, therapeutic or clinical services.  Services do not include and Company team members do not perform, diagnostic, therapeutic or clinical services or any other services that may require licensure in any jurisdiction, notwithstanding that team members may be licensed professionals.

  • Global Privacy Notice

    Last updated November  27, 2024

    Emerge EQ, Inc. (together with any future affiliates, “Emerge EQ”), as a “data controller” or a “business”, collects and processes your personal information. Emerge EQ is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations in accordance with applicable data protection laws.

    It is important that you read and understand this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the applicable data protection laws.  Processing means any operation which is performed on personal information which is such as collection, recording, organization, structuring, storage, adaptation, or alteration, retrieval, consultation, use, disclosure, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

    Your Rights

    The General Data Protection Regulation (GDPR) and the UK GDPR afford residents in those jurisdictions with certain rights.  Emerge EQ takes privacy seriously, so we grant these rights across the globe.  Here are your rights, regardless of where you live:

    1.         The right to be forgotten (or the right of erasure)

    2.         The right to know how we are processing your personal information

    3.         The right to access your personal information

    4.         The right to rectification

    5.         The right to withdraw consent

    6.         The right to object to processing your personal information

    7.         The right to object to certain types of data processing, e.g., direct marketing; the processing of personal information for statistical purposes related to historical or scientific research; the processing of data in the public interest; the exercising of official authority invested in you; processing of you or a third party’s legitimate interest; data processing based on your own beliefs and situations

    To exercise any of these rights, contact Margaret Smith at msmith@emerge-eq.com.

    What information does Emerge EQ collect?

    Emerge EQ may collect, process, and store personal information about you, including, without limitation:

    •        your address and contact details, including email address and telephone number, and gender;

    •        training records including competencies, qualifications, certificates and accreditations;

    •        details of your qualifications, skills, experience and employment history;

    •        information about your entitlement to benefits, as appropriate;

    •        information about your next of kin, dependants and emergency contacts including their personal information such as home address, employer’s address, contact details, etc.;

    •        information about your nationality;

    •        employment records (including job titles, work history, working hours, holidays, training records and professional memberships), where appropriate;

    •        information about your use of our information and communications systems;

    •        details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;

    •        assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence;

    •        information about medical or health conditions, including whether or not you have a disability; and

    •        information about your ethnic origin, religion, or belief and any other personal information referring to protected characteristics.

    Particularly Sensitive Personal information 

    Emerge EQ processes some special categories of personal information, such as information about physical or mental health or disability, to facilitate your health and safety in the workplace and to assess your fitness to work.

    Where Emerge EQ processes other special categories of personal information, such as information about ethnic origin, sexual orientation, religion, or belief, this is done for the purposes of providing services to you. This is to carry out Emerge EQ’s obligations. 

    How is your personal information collected?

    Emerge EQ may collect the categories of information listed above in a variety of ways. For example, data might be collected through application forms, CVs or resumes; from correspondence with you; or through interviews, meetings, or other engagements.

    Data will be stored in a range of different places, including in Emerge EQ’s HR management systems and in other IT systems (including Emerge EQ’s email system).

    Why does Emerge EQ process personal information?

    Emerge EQ needs to process all the categories of data in the list above primarily to provide services to you. In some cases, Emerge EQ needs to process data to comply with its legal obligations.

    In other cases, Emerge EQ has a legitimate interest in processing personal information before, during and after the end of our relationship.

    We will not use your personal information for purposes other than that for which it was collected, unless required by law or we reasonably consider that this is required, and the reason is compatible with the original purpose.  If we need to use it for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please be aware that we may process your personal information without your knowledge or consent, in compliance with the above, where it is required or permitted by law.  

    The legal basis on which we will process your personal information is to carry out our obligations under our services agreement, and to protect your vital interests. 

    Who has access to data?

    Your information may be shared internally, including with employees of Emerge EQ. We limit sharing your personal information to only those of our employees on a need-to-know basis.

    Emerge EQ may share personal information in the context of business reorganization or group restructuring exercise, for system maintenance support and hosting of data. This may involve transferring your data to another country.  Where required by applicable law, we will not share your personal information outside of its country of location with third parties unless there is an appropriate data transfer mechanism in place.

     Emerge EQ may also share your personal information with third parties in the context of a sale of some or all of its business. In those circumstances the personal information will be subject to confidentiality arrangements.

    Emerge EQ may also share your personal information with third parties that process information on its behalf, such as Zoom and Calendly.  All third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies.  We will not allow our third-party service providers to use your personal information for their own purposes.  We only permit them to process your personal information for specified purposes and in accordance with our instructions.

    How does Emerge EQ protect your personal information?

    Emerge EQ takes the security of your personal information seriously. Emerge EQ has internal policies and controls in place so that your personal information is not lost, accidentally destroyed, misused, or disclosed, and is not accessed except by its employees in the performance of their duties.

    In addition, we will limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Where Emerge EQ engages third parties to process personal information on its behalf, these third parties do so on the basis of written instructions, are under a duty of confidentiality, and are obliged to implement appropriate technical and organisational measures to facilitate the security of data.

    For how long does Emerge EQ keep data?

    We will only retain your personal information for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Emerge EQ will hold your personal information at least for the duration of your employment, however, to determine the specific appropriate retention period for personal information, we will consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purpose for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements of your jurisdiction.

    Legal Basis

    Our legal basis for processing your personal information will depend on the personal information concerned and the specific context in which it is collected.  However, we will normally collect or process personal information from you only where:

    ·       we have a legal obligation to do so;

    ·       the personal information is required for performance of our obligations;

    ·       the personal information is needed for legitimate interests;

    ·       the personal information is needed to protect your vital interests.

    Some of the personal information we collect may be considered sensitive information, or special categories of data under applicable data protection laws.  Where we collect sensitive data, we will ensure that we have a legitimate reason for processing sensitive data.

    Transfers

    Where sharing personal information with a third-party service provider may mean your data is transferred to the US.  We endeavour to maintain a similar degree of protection as that provided in the EU by implementing at least one of the following safeguards:

    ·       We will transfer your personal information to countries for which there is an adequacy decision.  This means that they have been deemed by the UK to provide an adequate level of protection for personal information.

    ·       Where we use certain service providers, we may use specific contracts which give personal information the same protection it has under applicable data protection laws.

    Automated decision-making

    Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention, and this type of processing is only permissible in specified circumstances. 

    Within Emerge EQ, decisions are not based solely on automated decision-making. 

    If you believe that Emerge EQ has not complied with your data protection rights, you can complain to the Information Commissioner.  You can do this by contacting the Information Commissioner’s Office directly. Full contact details including a helpline number can be found on the Information Commissioner’s Office website (www.ico.org.uk).  In the EU, you can complain to the Data Protection Authority in your country.

    Changes to this privacy notice 

    We reserve the right to update our privacy policies at any time, and we will revise this written policy when we make updates applicable to you.  We may also notify you from time to time in other ways about the processing of your personal information. 

    If you have any questions at all about this privacy notice, please contact Margaret Smith, CEO, Emerge EQ, Inc.

    I acknowledge that I have read and understood this Global Privacy Notice.