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Privacy Notice

Last Updated: May 22, 2018

Emma, Inc. ("Emma", "we" or "us") respect your privacy. This privacy notice ("Notice") explains who we are, how we collect, use and share information about you (“Personal Information”), and how you can exercise your privacy rights.

This Notice covers the Personal Information we collect: (1) about Users of Emma’s Services; (ii) about our User's Contacts (generally recipients of emails sent through the Emma Services); and (ii) through our Websites and in the usual course of our business, including in connection with our events, recruitment, sales and marketing activities.

We recommend that you read this entire Notice to ensure you are fully informed.

However, to make it easier for you to review those parts of this Notice which apply to you, we have divided up the document into the following sections:

We participate in and comply with the EU-US Privacy Shield and Swiss-US Privacy Shield Framework to cover data we process from the European Union ("EU") and Switzerland. For further information, please review our Privacy Shield Notice

The Basics

About Us.

Emma is a company headquartered in Nashville in the United States. We provide email marketing software products and services that allow our Customers and their Users to build and send out marketing emails to their Contacts. Through our application, our Customers can also store information about and track the engagement of their Contacts. You can find out more about us and our products here

Key Terms.

The definitions below apply to capitalized terms in this Notice. Capitalized words that are not otherwise defined in this Notice shall have the meaning ascribed in the Agreement.

  1. “Agreement” means either the Services Agreement located at https://myemma.com/legal/services-agreement or the Services Agreement (formerly referred to as the “Subscription Agreement”) executed by and between you and Emma, Inc
  2. "Customer" means the entity to whom we have contracted to provide the Services, which if you are an User, generally refers to the entity of which you are an employee, contractor, member or other participant.
  3. "Contacts" means any individual: 1) whose information is stored or collected by our Users on or via the Services; and/or 2) to whom Users send emails to or otherwise engage or communicate with via the Services.
  4. "Services" means the Website, Software, products, applications, tools, services (including any applicable support services), and related resources made available by Emma or accessible via the Website (or other websites owned by Emma or its affiliates) and all material comprising the Website and Software.
  5. “Software” means any software, documentation, or data related to the Services.
  6. "User" means any individual who has registered to use and access the Services under the Customer account and who directly builds, sends, collaborates on and/or reviews emails or forms through the Services.
  7. "Website" means any website we own and operate (such as www.myemma.com and any sub-domains).

2. Emma Users

This section applies to Personal Information we collect and process through the Services when you engage with us as a User of the Service. If you are not yet a User, Section 4 (applicable to visitors to our Websites) may be more applicable to you and your data. In this Section, "you" or "your' refer to Users.

a. Information We Process.

  1. Information You Provide To Us. You may provide Personal Information to us through the Services – for example, when you sign up for an Emma account to access the Services, consult with our customer success or support teams, send us an email or communicate with us in any other way. We will usually let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or may be provided on a voluntary basis and the consequences, if any, of not providing the information. The information you provide to us, includes:
    1. Registration Information. You need an Emma account to use the Services as a User. When you register for an account, we ask you to provide contact information such your name, telephone number, job title, and organization name.
    2. Billing Information. If you purchase our Services, you may also need to provide us with payment and billing information such as your credit card details and billing address. We will also maintain a record of your purchases, transactional information, your Services history and usage, and any communications and responses.
  2. Information Collected Automatically. When you use the Services, we automatically collect certain information about your device and use of the Services. We may use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, in more detail below and in our Cookie Notice here.
    1. Device Information. We collect information from your device and applications you use to access our Services, such as your IP address, device attributes (for example: hardware model, operating system, web browser version, as well as unique device identifiers and characteristics), connection information (for example, name of your mobile operator or Internet Service Provider, browser type, language and time zone, and mobile phone number); and device locations (for example, internet protocol (IP) addresses and Wi-Fi information).
    2. Log data. Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services, such as images.
    3. Information relating to your use of the Services. We collect usage data about whenever you interact with our Services, which may include the dates and times you access the Services, page views, which activities and features are used of our Services, crash logs, customer storage configuration settings, and technical data relating to devices accessing and using the Services and the performance of the Services in doing so.
  3. Information We Obtain From Third Party Sources. We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records and provide Services that may be of interest to you. Examples of the types of Personal Information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include name, employer, job title, email address, phone numbers, and other company, contact, and/or employment information.

b. Why We Process Your Information.

We process your Personal Information for our legitimate interests, which include:

  1. To Provide the Services. We process your Personal Information to provide the Services as follows: i) to identify who you are, including both for identification and authentication purposes; ii) to enable you to login and access your account; iii) to respond to your inquiries; iv) to provide you with customer support; v) to send you information as part of the Services; and vi) to provide you with information about your account, including renewals and changes in Services or your account status.
  2. To Market To You. To contact you with marketing and promotional information (in accordance with your marketing preferences) about products and services that we or our Affiliates offer, to provide advertising to you on third party sites (based on your browsing activities on the Website), and to send you information regarding us, our Affiliates, and/or our partners (see the section headed "Your Data Protection Rights" for information about how you can opt-out of receiving marketing communications from us at any time). Marketing data purchased from third parties may be combined with information we already have about you and may be used to create more tailored advertising and products.
  3. To Customize Services to You. To help us deliver a better and more personalized experience (for example, it enables us to tailor our Services according to your interests); and to build a profile about you so as to help direct you to other relevant features and Services we offer and help you in using our Services, by making recommendations for you to optimize use of our Services.
  4. To Improve Our Services. To create new Services, features, content or make recommendations; improve our Services for you and all Users; and to fix bugs and troubleshoot product functionality.
  5. For Business Analytics. To infer your geographic location based on your IP address; to track behavior at the aggregate/anonymous level to identify and understand trends in the various interactions with our Services; and to conduct internal business analysis based on meta-data about usage, feature adoption and forecasting.
  6. To Prevent Abuse/Illegal Activities. To screen for and prevent undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
  7. For Legal Records. To identify who you are, including both identification and authentication purposes; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including for billing and collection); and to respond to legal requests or prevent fraud. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

c. How We Share Your Information.

In the following limited situations, we may disclose information that we collect or that you provide to us:

  1. to our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing, to analyze data, host data, to provide customer support and to deliver online and offline marketing communications about us and/or our Affiliates that we think will interest you.
  2. as required by law, such as to comply with any court order, subpoena or other law or legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a governmental or regulatory request.
  3. to enforce our rights arising from any contracts entered into between you and us and for billing and collection.
  4. to Affiliates of our corporate group for customer support, marketing, technical operations, and account management purposes.
  5. to a buyer or other successor in the event of a merger, sale or transfer of some or all of Emma's assets.

d. Cookies And Tracking Technologies.

We (including our partners and vendors) use various technologies to collect and store information when you use the Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, cookies allow us to collect information such as your IP address, browser, email client type and other similar details. We use this information to measure the performance of our application and to provide analytics information and enhance the effectiveness of our Services. We use page tags (also known as web beacons) in the emails we send to our Users. When you receive and engage with marketing messages we send to you, web beacons track certain behavior such as whether the email sent through the Services was delivered and opened. Links within these emails are tracked to show individual recipient’s clicks. For more information, read about our cookies and other tracking technologies in more detail in our Cookie Notice here.

e. Children.

  1. Our Services are not intended for and may not be used by minors. "Minors" are individuals under the age of 13 (of under a higher age if permitted by the laws of their residence). We do not knowingly collect Personal Information from Minors or allow them to register. If it comes to our attention that we have collected personal data from a Minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
  2. Customers are responsible for ensuring that their emails and data collection practices comply fully with applicable children's data privacy protection legislation, such as the United States' Children’s Online Privacy Protection Act (“COPPA”), including where relevant by obtaining parental consent prior to the collection of Personal Information. We rely upon our Customers to disclose whether or not their use is subject to COPPA.

f. Legal Basis For Processing Personal Information (EEA Residents Only).

  1. If you are a resident in the EEA, then our legal basis for collecting and using Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, where we are processing your Personal Information for our own purposes we normally rely on our legitimate interest to collect Personal Information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your Personal Information, they include the interests described in the sections above headed "Wny We Process Your Information".
  2. In some cases, we may rely on your consent or have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person. If we rely on consent to collect and/or process your Personal Information, we will obtain such consent in compliance with applicable laws.
  3. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Contact Us” heading below.

g. Data Retention.

  1. We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a Service you have requested or to comply with applicable legal, tax or accounting requirements).
  2. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise Personal Information. If this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
  3. We will retain information we process on behalf of our Customers for as long as needed to provide Services to our Customers (unless deletion is requested at an earlier time by the Customer) and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We reserve the right to delete Customer’s, its Users’, and its Contacts’ information at the termination of Customer’s contract with us (unless such deletion is prohibited by applicable laws).

3. Emma Users' Contacts (Generally Email Recipients)

This section applies to Personal Information we collect and process about our User's Contacts through the Services as a data controller. In this Section "you" or "your" refers to a Contact.

Note: While Emma hosts the application used to build and send marketing emails and online forms, our Services are intended for use by our Customers and their Users control the content uploaded to the Services, the content of emails sent, forms built, and information provided at the point of collection of Contacts’ Personal Information-- and for the most part-- what is done with the information received. As a result, for much of the Personal Information we collect and process about our Customers’ Contacts, we act as a processor on behalf of our Customers (the controller). Emma is not responsible for the privacy or security practices of our Customers, which may differ from those set forth in this Notice. We require our Customers to comply with all applicable laws and regulations and to provide Contacts with notice of the collection of data as outlined in this Notice. To understand how Customers and their Users will use your Personal Information, you will need to directly contact the User who sent you the email or whose online form you filled out.

a. Information We Process.

  1. Information We Receive About Contacts from Users A User may provide Personal Information about you to us through the Services in connection with their use of the Services– for example, when a User imports and/or collects email addresses and other Personal Information about their Contacts
  2. Information Collected Automatically. When you interact with the Services (for example receive, open an email sent through the Services), we automatically collect certain information about your device and interaction with the Services. We may use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed in more detail below in more detail below [LINK to cookie section 3.d below] and in here. The information we automatically collect through the Services may include:
    1. Device Information. We collect information from your device and applications you use to view emails sent via our Services, such as your IP address, device attributes (for example: hardware model, operating system, web browser version, as well as unique device identifiers and characteristics), connection information (for example, name of your mobile operator or Internet Service Provider, browser type, language and time zone, and mobile phone number); and device locations (for example, internet protocol (IP) addresses and Wi-Fi information).
    2. Email Engagement Data. Emails sent by or on behalf of our Users through the Services include page tags (also known as web beacons) that allow the sender to collect information about who opened those emails. Additionally, your engagement with any links in emails sent using the Services (for example, when you click a link) is reported to the User. This tracking of email engagement is active by default for all email recipients. Our Users are able to turn off email tracking according to their determination of what is appropriate based on their relationship with their Contacts; or whenever a user withdraws consent for tracking; or based on the User’s determination of their own legal obligations regarding the use of this technology. Our use of cookies and other tracking technologies is discussed in more detail in our Cookie Notice here.

b. Why We Process Your Information.

We process your Personal Information for our legitimate interests, which include:

  1. In Connection With Support Queries. To respond to an enquiry which you may submit to us. For example, our customer support team may use your email address to communicate with you if you have contacted us about an email you received, but we will not send marketing to you unless you have otherwise opted-in to marketing.
  2. To Improve Our Product & Ensure Functionality.
    1. To ensure the full functionality of the Service. We collect information using cookies about your interaction with an email sent to you through the Services. These cookies are used to ensure that the full functionality of our Services is operational; to ensure that the Service experience works well across all possible devices; and to fix bugs and troubleshoot product functionality.
    2. To track behaviour at the aggregate/anonymous level to identify and understand trends in the various interactions with our Services (for example, by inferring geographic location to produce aggregated data around Contact location trends as they relate to open rates). This data will be aggregated and anonymized so we can examine patterns in terms of Contacts’ preferences as they relate to email engagement. We collect and use all this data for our legitimate interests like providing our Customers with metrics around probability of engagement related to email sending times, locations, content and also to help our Customers understand industry trends in marketing.
    3. Our use of cookies and other tracking technologies is discussed more below, in more detail below and in our Cookie Notice here.
  3. To Prevent Abuse/Illegal Activities. To screen for and prevent undesirable, abusive, and/or illegal activity. We use your IP address and an Emma auto-generated Contact ID for abuse monitoring purposes (so we can identify a User who abused the Services by sending spam email or sent an email in any other manner contrary to our usage policies and/or to facilitate a User in complying with their own legal obligations). We also have automated systems that screen content for phishing activities, spam, and fraud.
  4. For Legal Records. To enforce our agreements where applicable (for example we keep a record of the number of emails sent to individual Contacts for to bill for Services used by our Customers). To respond to legal requests or prevent fraud, we may need to disclose any information or data we hold about you. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

c. How We Share Your Information.

In the following limited situations, we may disclose Contact information to someone other than the Customer or their User:

  1. to our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing, to analyze data, host data, deliver content and to provide customer support and other business related functions.
  2. to comply with any court order, law or legal process, including responding to a governmental or regulatory request.
  3. to Affiliates of our corporate group for customer support, technical operations, and account management purposes.
  4. to a buyer or other successor in the event of a merger, ale or transfer of some or all of Emma's assets.

d. Cookies And Tracking Technologies.

We (including our partners and vendors) use various technologies to collect and store information when you interact with a User's email campaign or other content delivered through the Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use page tags (also known as web beacons) in the emails we send on behalf of our Users. When you receive and engage with a User's campaign, web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type and other similar details. We use this information to measure the performance of our User's email campaigns, to improve email deliverability and open rates and to provide analytics information and enhance the effectiveness of our Services. For more information, read about our cookies and other tracking technologies in more detail in our Cookie Notice here.

e. Legal Basis For Processing Personal Information (EEA Residents Only).

  1. If you are a resident in the EEA, then our legal basis for collecting and using Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, where we are processing your Personal Information for our own purposes we normally rely on our legitimate interest to collect Personal Information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your Personal Information, they include the interests described in the sections above headed "Why We Process Your Information".
  2. In some cases, we may have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.
  3. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Contact Us” heading below.

f. Data Retention.

  1. We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to prevent abuse or illegal activities, retain our legal records, or to comply with other applicable legal, tax or accounting requirements).
  2. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise Personal Information. If this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
  3. We will retain information we process (as a data processor) on behalf of our Customers for as long as needed to provide Services to our Customers (unless deletion is requested at an earlier time by the Customer) and as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
  4. To have any Personal Information that is retained by us on behalf of the Customer deleted, please contact the Customer (the controller of that data).

4. Emma Website Visitors

This Section applies to Personal Information that we collect and process through our Websites (for example when you visit our website and sign up for our marketing lists or apply for a job at Emma) and in the usual course of our business, such as in connection with our events, sales and marketing activities.

a. Information We Process.

  1. Information You Provide To Us. Certain parts of our Websites may ask you to voluntarily provide Personal Information (such as your name, contact details and company name). For example, when registering for an account, expressing an interest in obtaining additional information about Emma or our Services, subscribing to marketing, applying for a job, or otherwise contacting us. We may also collect Personal Information, such as your contact and professional background details and feedback, when you attend our events, take part in surveys, or through other business or marketing interactions we may have with you. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we will keep copies of any such communications for our records.
  2. Information Collected Automatically. When you visit our Websites, like most website owners, we may also collect certain information automatically from your device, such as your device type, browser type, broad geographic location (e.g. country or city-level location), the referring website, what pages your device visited, and the time that your device visited our Website. In some countries, including countries in the European Economic Area, this information may be considered Personal Information under applicable data protection laws. We (including our service providers) may use cookies, pixel tags and other similar tracking technologies to collect this information. Our use of cookies and other tracking technologies is discussed more below, in more detail below [LINK to cookie section 4.d below] and in our Cookie Notice here.
  3. Information We Obtain From Third Party Sources. We may receive Personal Information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide Services that may be of interest to you. Examples of the types of Personal Information that may be obtained from public sources or purchased from third parties and combined with information we already have about you, may include name, employer, job title, email address, phone numbers, and other company, contact, and/or employment information.

b. Why We Process Your Information.

  1. To Provide You With Information You Have Requested. To respond to your requests or provide you with information requested by you, including where you apply for a job at Emma or request information about our products or Services.
  2. To Market To You. To contact you with marketing and promotional information (in accordance with your marketing preferences) about products and services that we or our Affiliates offer, to provide advertising to you on third party sites (based on your browsing activities on the Website), and to send you information regarding us, our Affiliates, and/or our partners (see the section headed "Your Data Protection Rights" for information about how you can opt-out of receiving marketing communications from us at any time). Marketing data purchased from third parties may be combined with information we already have about you and may be used to create more tailored advertising and products.
  3. For Business Analytics. To infer your geographic location based on your IP address; to track behavior at the aggregate/anonymous level to identify and understand trends in usage and the various interactions with our Websites and marketing content; determining the effectiveness of our marketing; and to conduct internal business analysis based on meta-data about usage, feature adoption and forecasting to improve our Websites and Services.
  4. For Website Optimization. To administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, and statistical purposes; to understand how our Website is used and to improve our Website to ensure that content is presented in the most effective manner for you and your computer; and as a part of our efforts to keep our Website safe and secure.
  5. For Legal Records. To comply with and enforce applicable legal requirements, agreements and policies.

c. How We Share Your Information.

In the following limited situations, we may disclose information that we collect or that you provide to us:

  1. to our contractors, service providers and other third parties who provide data processing services to us and with whom the sharing of your Personal Information is necessary to undertake the work e.g. to process billing, analyze data, host data, provide customer support, and to deliver online and offline marketing communications about us and/or our Affiliates that we think will interest you.
  2. as required by law, such as to comply with any court order, subpoena or other law or legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a governmental or regulatory request.
  3. to enforce our rights arising from any contracts entered into between you and us and for billing and collection.
  4. to Affiliates of our corporate group for customer support, marketing, technical operations, and account management purposes.
  5. to a buyer or other successor in the event of a merger, sale or transfer of some or all of Emma's assets.

d. Cookies And Tracking Technologies.

We (including our partners and vendors) use cookies and similar tracking technology (collectively "Cookies") on our Websites to collect and use Personal Information about you: (i) to ensure we are complying with our legal obligations (for example, we use cookies to infer your location and if, for example, you are in the EEA, we can ensure that we are compliant with regulations in the EEA); (ii) to serve targeted advertising to you, (iii) to analyse trends, administer the Website, track users' movements around the Website, and (iv) to gather demographic information about our user base as a whole. In addition, certain third parties, such as analytics companies, may use automatic information collection technologies to collect information about you when you use our Services. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites, apps and other online services websites. For more information, read about our cookies and other tracking technologies in more detail in our Cookie Notice here.

e. Legal Basis For Processing Personal Information (EEA Residents Only).

  1. If you are resident in the EEA, then our legal basis for collecting and using Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, where we are processing your Personal Information for our own purposes we normally rely on our legitimate interests to collect Personal Information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your Personal Information, they include the interests described in the sections above headed "Why We Process Your Information".
  2. In some cases, we may rely on your consent or have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person. If we rely on consent to collect and/or process your Personal Information, we will obtain such consent in compliance with applicable laws.
  3. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Contact Us” heading below.

f. Data Retention.

  1. We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with information you have requested or to comply with applicable legal, tax or accounting requirements).
  2. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

5. General Information

a. Your Data Protection Rights (EEA Residents Only).

If you are resident in the EEA, you have the following data protection rights:

  1. You can access, review, change, update or delete your Personal Information at any time by contacting us at support@myemma.com. Please note that we may impose a small fee for access and disclosure of your Personal Information where permitted under applicable law, which will be communicated to you. We do not charge you to update or remove your Personal Information.
  2. To remove your Personal Information from a Website testimonial or request removal of your Personal Information from our blog or community forum, contact us at support@myemma.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
  3. In addition, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. To exercise these rights email support@myemma.com.
  4. You can opt out of receiving marketing communication we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the emails we send you or by visiting our preference center, https://myemma.com/preference-center. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us at marketing@myemma.com. For data privacy concerns, use the contact details provided under the “Contact Us” heading below.
  5. If we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  6. You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area ("EEA"), are available here.

Please note that because most of the information we store can only identify a particular browser or device, and cannot identify you individually, you will need to provide us with some additional information to enable us to identify the Personal Information we hold about you and ensure that accurately fulfil your request. You may also be required to provide ID.

Further Information for Contacts: As described in this Notice, for much of the Personal Information we collect and process about you through the Services, we act as a processor on behalf of our Customers. In such cases, if you want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Emma as a processor on behalf of our Customers, you should contact the relevant Customer that has contracted with Emma for use of the Services, and refer to their separate privacy policies. If you are having difficulties finding this Customer, you can contact us through our support team and we will try our best to help you.

b. Third-Party Websites And Apps.

  1. This Notice only applies to the Emma Website and Services. We are not responsible for the privacy practices or disclosures of third parties that use or access the Emma Website or Services. In addition, the Website or Service may contain links to third-party websites and apps. Any access to and use of such linked websites or apps is not governed by this Notice, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties.

c. How Do We Keep Your Personal Information Secure?

  1. We use appropriate technical and organizational security measures to protect any Personal Information we process against unauthorized access, disclosure, alteration, and destruction. More details of our security measures are available for review here [INSERT LINK: https://myemma.com/trust/security ].
  2. Unfortunately, nobody is truly and completely safe from hackers. Although we do our best to protect your Personal Information, we cannot guarantee security, no Internet transmission can ever be guaranteed 100% secure, and so we encourage you to take care when disclosing Personal Information online and to use readily available tools, such as Internet firewalls, secure e-mail and similar technologies to protect yourself online.

d. International Data Transfers.

  1. The Website and the Services are provided, supported, and hosted in the United States. If you are using the Website or Services from outside the United States, be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your Personal Information, in the United States and other countries. These countries may have data protection laws that are different to the laws of your country.
  2. However, we have taken appropriate measures to require that your Personal Information will remain protected in accordance with this Notice and have implemented appropriate safeguards with our third party service providers and partners. Further details can be provided upon request.

e. EU-U.S. And Swiss US Privacy Shield.

  1. Emma, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Emma, Inc. is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]
  2. Emma, Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Emma, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
  3. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Emma, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Emma, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  4. Where Emma determines the purposes of processing Personal Information originating in the EU, the data subject who the Personal Information is about may be access that Personal Information by contacting privacy@myemma.com with a clear request for disclosure. We may ask the requestor to verify their identity when reasonable to do so. Emma will make any reasonable effort, in concert with the Emma customer(s) involved (if any), to address and correct the issue, including editing or removing any data stored pertaining to that individual. Any unresolved Privacy Shield complaints will be referred to JAMS [https://www.jamsadr.com/eu-us-privacy-shield], our chosen alternative dispute resolution provider. Should this arbitration fail, the complaint may be subject to binding arbitration before the Privacy Shield Panel, in accordance with the Privacy Shield Agreement. All of these remedies are offered at no cost to the complainant, as long as the complainant is an individual.

f. Changes To This Privacy Notice.

  1. We may revise this Notice from time to time in response to changing legal, technical or business developments. The most current version of this Notice will govern our use of your Personal Information. If we make any material changes to this Notice, we will post the updated version here and notify applicable individuals by email or by means of a prominent notice on our Website. You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice. We will seek your consent to any material changes to this Notice if and where required by applicable law.

g. Contact Us.

To communicate with our Data Protection Officer, please email DPO@myemma.com.

Thanks for taking the time to learn about our privacy notice. We hope it was clear and reassuring. If you have any questions, please contact us:

Emma, Inc.
Address:
9 Lea Avenue
Nashville, TN 37210
Email:
privacy@myemma.com


Important Note:
If you are resident in the EEA, the "data controller" of the Personal Information related to the processing activities listed in this Privacy Notice under the sections titled “Why We Process Your Information” is Emma, Inc.

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