Other Covered Entities

STEP, LLC

Industries

  • Business and Professional Services
  • Corporate Training Services

Participation

UK Extension to the EU-U.S. Data Privacy Framework Framework: Active

Original Certification Date: 10/17/2023
Next Certification Due Date: 7/2/2024
Data Collected: NON-HR

Swiss-U.S. Data Privacy Framework Framework: Active

Original Certification Date: 6/22/2020
Next Certification Due Date: 7/2/2024
Data Collected: NON-HR

EU-U.S. Data Privacy Framework Framework: Active

Original Certification Date: 3/6/2017
Next Certification Due Date: 7/2/2024
Data Collected: NON-HR

Purpose of Data Collection

Emergenetics International (“Emergenetics”) processes personal data for the purposes of: • creating a psychometric profile of your personality based on your responses to profile questions; • where applicable, creating a candidate report of your work preferences and abilities based on your responses to an ESP assessment question; • where applicable, enabling your use of the platform; • where applicable, responding to client companies for debriefing purposes related to profiles; • where applicable, sending you information about your profile results by mail; • where applicable, sending you email marketing communications relating to Emergenetics which we think may be of interest to you; • responding to your inquiries, and/or other requests; • sending you email notifications about updates or changes to the platform or our services; and • performing research and analysis to ensure that the profiles remain accurate and current with societal norms. Emergenetics processes the following types of personal data: • biographical information such as your first, last name, gender, and the language you speak; • contact information such as your email address, mailing address, and phone number; • professional information, such as your role/job title or function; and • to the extent they constitute personal data under the law, your responses to questions in a profile. Emergenetics may share Personal Data with: • Other Emergenetics users: The Emergenetics platform includes a social feature called “Connections” which allows you to connect with and share your profile with other users. You have complete control over whether your profile is private or public; • Service providers who process personal data on behalf of Emergenetics, such third parties include those: providing web and application hosting services; and providing software development services; • Emergenetics partners: Emergenetics works with a variety of individuals and organizations in the Americas, Europe, and Asia to bring Emergenetics science to participants around the world. Our partners are Emergenetics client organizations, independent Emergenetics, STEP, and ESP Associates, country representatives, domain administrators, and other third parties providing Emergenetics services globally. Emergenetics shares your personal data with its partners in order to process your profile(s) and provide the platform and services to you; and • Emergenetics may disclose your personal data (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders, or (ii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above. We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any personal data, about users of our Platform and services as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

Privacy Policy

Non-HR Data

Description:

The Browning Group International, Inc. doing business as Emergenetics International and its legal affiliates, including, without limitation, STEP, LLC, Emergenetics Europe Limited, Emergenetics Caelan & Sage PTE Ltd., and Emergenetics Asia, Pte. Ltd. (collectively, “Emergenetics,” “we,” “us,” “our”) takes the protection of personal data very seriously. This Privacy Policy (the “Policy”) addresses data subjects (each a “User”, and collectively, “Users”) whose personal data we may process via the following information systems: • our hosted Emergenetics+ web application located at plus.emergenetics.com; • our hosted ESP web application located at esp.emergenetics.com; • our Emergenetics+ mobile application for iOS and Android; • our website, located at emergenetics.com; and • our offline mailing system (the “Emergenetics Platform”). The data subjects whose personal data we process within the context of this Policy include individuals who have taken one of our proprietary psychometric profiles, including, without limitation, the Emergenetics Profile, a STEP Youth Report, and/or an ESP Candidate Report (each, a “Profile”), including Emergenetics associates and other representatives of our partners who took a Profile as part of their Emergenetics training. This Policy does not apply to personal data we collect by other means, such as personal data that we receive through our sales and marketing systems or personal data concerning our employees.

Effective Date: 2/6/2023

Dispute Resolution

Questions or Complaints?

If you have a question or complaint regarding the covered data, please contact Emergenetics International at:

Steven Douglas
Director of IT
Emergenetics International
2 Inverness Dr E, Suite 188
Centennial, Colorado 80112

Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you have not received a timely or satisfactory response from Emergenetics International to your question or complaint, please contact the independent recourse mechanism listed below


NON-HR RECOURSE MECHANISM



Appropriate statutory body with jurisdiction to investigate any claims against Emergenetics International regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission