WHAT PERSONAL INFORMATION DO WE COLLECT AND WHEN, AND WHY WE USE IT ABOUT YOU
The information we collect from you allows you use our Services, (“Services”).
We collect or receive personal information from you via our Site, Applications and/or Services. For example, we receive personal information from you directly when you subscribe or purchase one of our Services. We also collect personal information about you, for example, by using cookies to understand how you use our Site.
We will only collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. The chart below summarizes when we collect personal information, the types of personal information we collect, how we use the personal information, and the legal basis for our use of such personal information.
|When We Collect
|The Types of Personal
Information We Collect
|How We Use Personal Information||The Legal Basis for
Using Personal Information
Information we collect by cookies or similar technologies (“cookies”) when you visit our Site.
|We may collect data related to your use of our Site including where you came from, login details, pages you looked at, duration of your visit, geographic location, and/or the links you click. Technical information collected includes your browser type and operating system, device information, your Internet Protocol (“IP”) address, and your unique ID which is given to each visitor and expiration of date of the ID.||We use this information to tailor our Services to you, that is to show you recommendations, marketing, or content based on your profile and interests and to display Services in a tailored way, for example to show you advertising we think you might like. This data allows our Site and Applications to function properly, that is to ensure the proper display of content, create and remember your shopping chart, improve our Site, to ensure our Site is secure and safe and to protect against fraud. This data is used to run statistics to avoid visitors being recorded twice, know users’ reaction to our advertising campaigns, For opting out of targeted advertising on social media platforms, please visit the relevant social media platform to explore the options they may provide.||Our legal basis to use this information includes (1) your consent (to store cookies on your device) and (2) our legitimate interests, including to improve our Site and Services, to better engage with you, and to secure our Site.|
|Personal Information we collect and use for personal account creation and management.||Where your personal information is collected during the creation or management of an account on our Site, including employme.com, we may ask you to provide first and last name, email address, subscription preferences, other profile data such as mailing address, phone number and payment information.||We use this information to manage your registration of Services, offer personalized offers, run analytics or collect statistics. We may use the information to secure our Site and protect you and us against fraud, to respond to your questions and otherwise communicate with you about your use of our Services.||Our legal basis for using this information includes (1) performance of a contract so you submit and alert about any change of personal details, (2) our legitimate interests including to improve our Site and Services, better engage with you, to prevent fraud, and secure our Site, and (3) consent so you can receive marketing communications from us.|
|Personal Information we collect and use if you register for our Services.||We collect first and last name, email address, physical address, phone number, transaction information including payment information.||We use this information to contact you to finalize your order where you have saved your shopping card or placed Services in your cart without completing the process, inform you when Service updates or new Services are available, process your order, manage payment (note: your payment information are not collected directly by us but by payment service providers), manage any contact you have with us about your purchase, secure your transactions against fraud (we may use a third party provider solution to detect fraud), manage any dispute relating to a purchase, run analytics or collect statistics, and to communicate with you about your use of our Services.||Our legal basis for using this information includes (1) performance of a contract so we can create your account, (2) our legitimate interests which include to improve our Site and Services, better engage with you, prevent fraud, and secure our Site, and (3) to comply with a legal obligation (to keep information we are required to keep).|
|Personal information we collect and use when you purchase Services from EmployMe.||We collect first and last name, date of birth, email address, physical address, phone number, transaction information including payment information, and purchase history.||We use this information to contact you about your orders of our Services, inform you when Service updates or new Services are available, process your order, manage payment (note: your payment information is not collected directly by us but by payment service providers), manage any contact you have with us about our Services, secure your transactions against fraud (we may use a third party provider solution to detect fraud), manage any dispute relating to a purchase, run analytics or collect statistics. Communicate with you about your use of our Services.||Our legal basis for using this type of information includes (1) performance of a contract so we can create your account, (2) our legitimate interests including to improve our Site and Services, better engage with you, prevent fraud, and secure our Site, and (3) to comply with a legal obligation (to keep information we are required to keep).|
|Personal Information we collect and use when you ask questions relating to our Services, your orders, account
or rights, and customer support.
|We collect first and last name, email address, phone number, information about your activities and interests, and other information you have shared with us about yourself in relation to your enquiry (which may include activities and interests).||We use this information to communicate with you about your use of our Services.||Our lawful basis to use this information includes (1) consent to provide you with the service you have requested or (2) our legitimate interests which include to improve our Services, to better engage with you and to secure our Site.|
|Personal Information we collect and use during a competition, game, contest, promotional offer, sample request, survey, etc.||We collect first and last name, email address and desired password, displayed name, date of birth, subscription preferences, information about your activities and interests, other profile data such as contact information, occupation, and gender,||We use this information to complete tasks that you have asked us to, for example to manage your participation in the promotion, including to take into account your feedback and suggestions, to run analytics and statistics, add your participation to your profile||Our legal basis to use this information is (1) performance of a contract so we can create and manage your account and (2) our legitimate interests including to improve our Services and to better engage with you.|
|physical activities or similar health related information, social media profile (where you use your social media login or share this personal data with us), user generated content, other information you have shared with us, by contacting us, or by participating in a survey, etc.).||so we can understand your interests and preferences.|
|Personal Information we collect and use if you apply for employment with EmployMe.||We collect your education, employment history, qualifications, and the contact information of a former colleague.||This information is used for job reference purposes only and is not used for any other purpose. This information is collected from the individual directly.||Our legal basis to use this information is your consent.|
HOW WE SHARE PERSONAL INFORMATION WITHIN EMPLOYME AND WITH OUR SERVICE PROVIDERS, REGULATORS AND OTHER THIRD PARTIES
We share your personal information in the manner and for the purposes described below:
- With other EmployMe entities where such disclosure is necessary to provide you with our Services or to manage our business. We may also share your personal information with other EmployMe entities to improve the services.
- With third parties who help manage our business and deliver services, for example, IT service providers who help manage our IT and back office systems or administer our Site and Applications. These third parties have agreed to confidentiality restrictions and have agreed to use any personal information we share with them, or which they collect on our behalf, solely for the purpose of providing the contracted service to us.
- If you are using our site to register for, or purchase a product or service, EmployMe shares the personal information that you provide with the applicable EmployMe in order to fulfill your request. You may also receive communications, correspondence, emails, or direct mail from a EmployMe employee. Each such party operates as a EmployMe representative.
We may disclose information to third parties (with consent if required by law) to other organisaions with whom we have an obligation to inform of your current status.
Organisations may include, but are not limited to:
- Government organizations and agencies, and other governmental agencies.
- Private organizations and agencies.
- If, in future, we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may disclose/transfer the information we have collected from you to the acquiring company.
TRANSFERRING PERSONAL INFORMATION NATIONALLY
National data transfer
We operate on a national basis. This means that your personal information may be transferred to and stored in Denmark, which may be subject to different standards of data protection than your country of residence.
We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, are carefully managed to protect your privacy rights and interests. To this end:
- we ensure transfers within EmployMe will be covered by an agreement entered into by EmployMe entities (an intra group agreement) which contractually obliges each such entity to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within EmployMe;
- where we transfer your personal information outside EmployMe or to third parties who help provide our Services, we obtain contractual commitments from them to protect your personal information.
You have a right to contact us for more information about the safeguards we have put in place, to ensure the adequate protection of your personal information when this is transferred as mentioned above.
HOW WE PROTECT AND STORE PERSONAL INFORMATION
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction, or loss, or unauthorised disclosure or access to such information appropriate to the nature of the information concerned, including:
- (where appropriate) password protection, encryption, and use of secure communication transmission software (known as “secure socket layering” or “SSL”) to protect our Site;
- placing confidentiality requirements on our employees and service providers;
- destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected; and
- following strict security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it. Whilst we take appropriate technical and organisational measures to safeguard your personal information, no transmission over the Internet can ever be guaranteed to be secure. Therefore, we cannot guarantee the security of any personal information that you transfer over the Internet to us and any such transmission is at your own risk.
As the security of personal information depends in part on the security of the computer you use to communicate with us, you should take steps to protect against unauthorized access to your computer, and web-enabled devices, among other things, by signing off after using a shared computer, inserting a password on your web-enabled device, choosing a password that nobody else knows or can easily guess, keeping your password private, and periodically changing your password.
Storing your personal information
We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this Policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner. In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements.
In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
EXPLAINING MORE ABOUT DIRECT MARKETING
How we use personal information you keep you up to date with our Services
We may use personal information to let you know about our Services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communications channels that we think you may find helpful.
When and how we undertake profiling and analytics
- We aggregate personal information and remove any identifying elements in order to better understand how users access and use our Site and Services for other research purposes, as set out above in HOW WE SHARE PERSONAL INFORMATION WITHIN EMPLOYME AND WITH OUR SERVICE PROVIDERS, REGULATORS AND OTHER THIRD PARTIES.
We undertake profiling and analytics to improve our Site and Services by providing personalized experiences, location customization, personalized help, and instructions.
Based on our analysis, we then send or display communications or content specifically tailored to your interests and needs.
You may have the right to object at any time to the use of your personal data for “profiling”.
Some of the legitimate purposes for which we profile personal information include:
- to obtain a better understanding of what you would like to see from us and how we can continue to improve our services for you;
- to personalise the service and offers you receive from us;
- to share marketing material we believe may be of interest to you, including from other EmployMe entities and our third party partners; to help us operate our services more efficiently;
- to detect and prevent fraud.
A cookie is a small text file containing small amounts of information which is downloaded to / stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.
Cookies may collect personal information about you. Cookies help us remember information about your visit to our Site, like your country, language and other settings. Cookies allow us to understand who has seen which webpages and advertisements, to determine how frequently particular pages are visited and to determine the most popular areas of our Site(s). They can also help us to operate our Site more efficiently and make your next visit easier.
LEGAL RIGHTS AVAILABLE TO EU DATA SUBJECTS HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, if you are an EU data subject, you may have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have:
- To access personal information
- To rectify / erase personal information
- To restrict the processing of your personal information
- To transfer your personal information
- To object to the processing of personal information
- To object to how we use your personal information for direct marketing purposes
- To lodge a complaint with your local supervisory authority
If you wish to access any of the above-mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.
We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by emailing info@ Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
You can exercise this right by emailing email@example.com.
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- to comply with a legal obligation to which EmployMe is subject.
You can exercise these rights by emailing firstname.lastname@example.org.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
EmployMe regularly reviews its policies, procedures and practices regarding personal information and this Policy.
The primary point of contact for all issues arising from this Policy is our Data Protection Officer. Our Data Protection Officer can be contacted in the following ways:
If you have any questions, concerns or complaints regarding our compliance with this Policy, the information we hold about you or if you wish to exercise your rights, we encourage you to first contact us. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before your local supervisory authority.