This website and the underlying Service Platform on which it is based are operated by Emmport Limited (Emmport), registered in England & Wales No. 4942796.

By accessing or using any areas of our Web sites (emmport.com and all related websites operated by Emmport Limited and its subsidiaries), you are bound by the terms and conditions of permitted use published on this website. A summary of the terms of use most relevant to individual usage of this website are set forth below, and you are bound by these. If you do not accept these terms and conditions, you may not access or use this Web site. Emmport retain the right to modify these terms and conditions at any time, and any changes affecting individual usage will be notified by posting new terms and conditions on this page.

Permission to Use this Web Site

Some portions of this Web site are available for public viewing and use. You must be an approved and registered employee, agent or associate of a business account holder in order to access other portions of this Web site. Subject to the terms and conditions set out on this page and the terms and conditions of any license or other agreement pursuant to which you use our products or services, Emmport grants you permission to do the following: (i) view and use for intended purposes those portions of this Web site to which we have granted you access; (ii) make one complete, unaltered electronic copy and/or one complete, unaltered paper copy of any page on this Web site to which we have granted you access, provided you retain all copyright, trademark and other proprietary rights notices and that you use it solely for internal business purposes and do not distribute or republish it. Any other use of this Web site or its contents is prohibited without first obtaining written permission from Emmport.

Intellectual Property

Emmport retains all Intellectual Property rights to the website and Service Platform design and underlying technologies, database designs and the business logic embedded within the platform. Neither business account holders, nor any of their employees, agents or associates, nor any Third Party, has the right to access, copy or reverse-engineer any designed component or source code from this website or Service Platform.

User Account, Security and Password

Some of the services available via this website can only be accessed by providing a valid user name and password. If you are permitted to access and use the restricted areas of this site, you will be provided with your personal user name and password information by your site administrator. You are entirely responsible for maintaining the confidentiality of your password and account. Furthermore, you are entirely responsible for any and all activities that occur under your account. You agree to notify your site administrator and/or Emmport immediately of any unauthorised use of your account or any other breach of security. Emmport will not be liable for any loss that you or your business may incur as a result of someone else using your password or account, either with or without your knowledge. However, you could be held liable for losses incurred by Emmport or another party due to someone else using your account or password. You may not use anyone else's account at any time, without the permission of the account holder and your site administrator.

Contact

All comments, queries or requests relating to the use of the website are welcomed and should be addressed to the datacontroller@emmport.com.

Emmport Limited ('Emmport') is a limited company registered in England & Wales No. 4942796.

 

Effective: 25th May, 2018

This Privacy Policy describes how Emmport collects, uses and discloses information, and what choices you have with respect to the information.

Updates in this version of the Privacy Policy reflect changes in data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable by:

• organising it into the sections listed in the Table of Contents below,
• providing a series of examples that help illustrate how the policies may be implemented by Emmport and
• defining and capitalising a few terms that are used more than once for simplicity and brevity.

When we refer to “Emmport”, we mean the Emmport entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

 

Table of Contents:

• Applicability of this Privacy Policy
• Information We Collect and Receive
• How We Use Information
• Data Retention
• How We Share and Disclose Information
• Subprocessors
• Security
• Age Limitations
• Changes to this Privacy Policy
• International Data Transfers
• Data Protection Officer
• Identifying the Data Controller and Processor
• Your Rights
• Data Protection Authority
• Contacting Emmport

 

Applicability Of This Privacy Policy

This Privacy Policy applies to Emmport’s online e-commerce and workplace productivity tools and platform, including the associated Emmport mobile and desktop applications (collectively, the “Services”), emmport.com and other Emmport websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Emmport. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Emmport’s business.

This Privacy Policy does not apply to any third party applications or software that integrate with the Services through the Emmport platform (“Third Party Services”), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any messages, files or other content submitted through Services accounts (collectively, “Customer Data”). The organisation (e.g., your employer or another entity or person) that entered into the Customer Agreement (“Customer”) controls their instance of the Services (their “Workspace”) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

 

Information We Collect And Receive

Emmport may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

• Customer Data. Customers or individuals granted access to a Workspace by a Customer (“Authorised Users”) routinely submit Customer Data to Emmport when using the Services.
• Other Information. Emmport also collects, generates and/or receives Other Information:
  • ?Services Metadata. When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way Authorised Users work. For example, Emmport logs the Workspaces, accounts, people, features, content and links you interact with, the types of files shared and what Third Party Services are used (if any).
  • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  • Device information. Emmport collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
  • Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Emmport may also collect location information from devices in accordance with the consent process provided by your device.
• Workspace and Account Information. To create or update a Workspace account, you or your Customer (e.g., your employer) supply Emmport with an email address, phone number, password, domain and/or similar account details.
• Usage Information.
• ?Cookie Information. Emmport uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.
• Third Party Services. Customer can choose to permit or restrict Third Party Services for their Workspace. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorised Users to enable and disable these integrations for their Workspace. Once enabled, the provider of a Third Party Service may share certain information with Emmport. For example, if a cloud storage application is enabled to permit files to be imported to a Workspace, we may receive user name and email address of Authorised Users, along with additional information that the application has elected to make available to Emmport to facilitate the integration. Authorised Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Emmport. When a Third Party Service is enabled, Emmport is authorised to connect and access Other Information made available to Emmport in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. For more information on Third Party Services, click here.
• Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorised User chooses to import (such as an address book from a device) is collected when using the Services.
• Third Party Data. Emmport may receive data about organisations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to postcodes, zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
• Additional Information Provided to Emmport. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Emmport.

 

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

 

How We Use Information

Customer Data will be used by Emmport in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Emmport is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

Emmport uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Emmport uses Other Information:

• To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an Authorised User’s request.
• As required by applicable law, legal process or regulation.
• To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
• To develop and provide search, learning and productivity tools and additional features. Emmport tries to make the Services as useful as possible for specific Workspaces and Authorised Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, product and account data or expertise to an Authorised User, make Services suggestions based on historical use and predictive models, identify organisational trends and insights, to customise a Services experience or create new productivity features and products.
• To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Emmport. These are marketing messages so you can control whether you receive them.
• For billing, account management and other administrative matters. Emmport may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Emmport may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data”.

 

Data Retention

Emmport will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customise its retention settings and apply those customised settings at the Workspace level, account level or other level. Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please contact Customer. Emmport may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Emmport to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

 

How We Share And Disclose Information

This section describes how Emmport may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Emmport does not control how they or any other third parties choose to share or disclose Information.

• Customer’s Instructions. Emmport will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
• Displaying the Services. When an Authorised User submits Other Information, it may be displayed to other Authorised Users in the same or connected Workspaces. For example, an Authorised User’s email address may be displayed with their Workspace profile.
• Collaborating with Others. The Services provide different ways for Authorised Users working in independent Workspaces to collaborate. Other Information, such as an Authorised User’s profile Information, may be shared, subject to the policies and practices of the other Workspace(s).
• Customer Access. Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Workspace activity, or accessing or modifying your profile details. For information about your Workspace settings please contact your Workspace owner.
• Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth in the Emmport Subprocessors section below.
• Third Party Services. Customer may enable or permit Authorised Users to enable Third Party Services. When enabled, Emmport may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Emmport and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
• Corporate Affiliates. Emmport may share Other Information with its corporate affiliates, parents and/or subsidiaries.
• During a Change to Emmport’s Business. If Emmport engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of Emmport’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Emmport customer the average amount of time spent within a typical Workspace.
• To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please see the Data Request Policy to understand how Emmport responds to requests to disclose data from government agencies and other sources.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Emmport or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With Consent. Emmport may share Other Information with third parties when we have consent to do so.

 

Emmport Subprocessors

To support delivery of our Services, Emmport may engage and use data processors with access to certain Customer Data (each, a "Subprocessor"). The list below provides important information about the identity and role of each Subprocessor.

Emmport currently uses third party Subprocessors to provide infrastructure services, and to help us provide customer support and email notifications. Prior to engaging any third party Subprocessor, Emmport performs diligence to evaluate their privacy, security and confidentiality practices, and executes an agreement implementing its applicable obligations.

1. Infrastructure Subprocessors

Emmport may use the following Subprocessors to host Customer Data or provide other infrastructure that helps with delivery of our Services:

• Rackspace - Cloud Service Provider
• Amazon Web Services - Cloud Service Provider
• Google - Cloud Service Provider

2. Other Subprocessors

Emmport may use the following Subprocessors to perform other Service functions:

• Zendesk - Cloud-based Customer Support Services
• SendGrid - Cloud-based Email Notification Services
• PCA Predict – Cloud-based Address and Geolocation Services
• Dotmailer - Cloud-based Email Notification Services
• New Relic - Cloud Service Provider
• iTagg - Cloud-based SMS Notification Services
• AQL - Cloud-based SMS Notification Services

Emmport may engage further Subprocessors as required and these will be added to this Privacy Policy in future updates.

 

Security

Emmport takes security of data very seriously. Emmport works hard to protect Other Information you provide from loss, misuse, and unauthorised access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, Emmport cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

 

Age Limitations

To the extent prohibited by applicable law, Emmport does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

 

Changes To This Privacy Policy

Emmport may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Emmport will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

 

International Data Transfers

Emmport process Personal Data originating from and sent to a country located in the EU/EEA solely in countries situated in the EU/EEA and will not cause any cross border transfer of Personal Data from a country situated in the EU/EEA to any country situated outside the EU/EEA unless Personal Data is transferred to a country approved by the European Commission as providing an adequate level of protection for Personal Data, or the transfer is made using frameworks such as Privacy Shield developed to enable companies to comply with data protection requirements when transferring personal data from the European Union and Switzerland to other countries situated outside the EU/EEA. 

 

Data Protection Officer

To communicate with our Data Protection Officer, please email dpo@emmport.com.

 

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, Emmport is the processor of Customer Data and the controller of Other Information. Different Emmport entities provide the Services in different parts of the world. Emmport Technologies Limited, an Irish company based in Dublin, Ireland, is the controller of Other Information and a processor of Customer Data relating to Authorised Users who use Workspaces established for Customers outside of the U.S. and Canada. Emmport Technologies, Inc., a US company based in San Francisco, California is the controller of Other Information and a processor of Customer Data relating to Authorised Users who use Workspaces established for Customers in the US and Canada.

 

Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance.

To the extent that Emmport’s processing of your Personal Data is subject to the General Data Protection Regulation, Emmport relies on its legitimate interests, described above, to process your data. Emmport may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to Emmport’s use of your Personal Data for this purpose at any time.

 

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Emmport’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the UK Data Protection Commissioner. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our supervisory authority:

UK Information Commissioner
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113 or 01625 545745
Fax: 01625 524510

 

Contacting Emmport

Please also feel free to contact Emmport if you have any questions about this Privacy Policy or Emmport’s practices, or if you are seeking to exercise any of your statutory rights. You may contact us at feedback@emmport.com or at our mailing address below:

Emmport Limited
Elmswood House
Tarrington Common
Tarrington
Herefordshire
HR1 4HR