Privacy Policy
This Privacy Policy was last updated on December 21, 2023.
thanks for choosing Empirium. At the house of Empirium (« Empirium », “we”, “us”), we respect your privacy and it is important to us that you understand how we collect, use and share data about you. This Privacy Policy covers our data collection practices and describes your rights regarding our use of your personal data.
Unless otherwise stated or provided with a link to another policy, this Privacy Policy applies when you visit or use the websites ofEmpirium, its mobile applications, its APIs or its associated services (the “Services”). It also applies to potential customers of our commercial and enterprise products.
Your use of the Services constitutes your acceptance of the terms of this Privacy Policy. Do not use the Services if you do not agree to this Privacy Policy or any other agreement governing your use of the Services.
Contents
1. What data we collect
2. How we obtain data about you
3. How we use your data
4. Who we share your data with
5. Security
6. Your rights
7. Rules of judicial jurisdiction
8. Updates and Contact
1. What data we collect
We collect certain data that you provide to us directly, for example from information that you enter yourself; data relating to your content consumption; and data from third-party platforms to which you connect throughEmpirium. All data listed in this section is subject to different types of processing: collection, recording, structuring, storage, modification, retrieval, encryption, pseudonymization, deletion, combination and transfer.
1.1 The data you provide to us
We may collect different data from or about you depending on how you use the Services. Here are some examples to help you understand what data we collect.
When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly to us, including:
Personal data category Description Legal basis for processing
Account data To use certain features (such as accessing content), you must create a user account, which requires us to collect and store your email address, password, and account settings. To create an instructor account, we collect and store your name, email address, password, and account settings. When using certain features of the Site, you may be asked to provide additional information, including your occupation, government identification information, photo verification, date of birth, race/ethnicity, interests, and your phone number. When creating the account, we assign you a unique identification number.
Contract performance
Legitimate interests (provision of services, identity verification, fraud prevention and security, communication)
Profile data You may also choose to provide profile information, for example, photo, title, biography, language, website link, profiles on different social networks, countries or other data. Your Profile Data is visible to everyone.
Contract performance
Legitimate interests (enhanced platform functionality, transmission of content source information)
Shared content Certain components of the Services allow you to interact with other users or publicly share content, including by uploading courses and other educational content, posting reviews of content, asking or responding to questions, by sending messages to participants or trainers, posting photos or uploading any other content to the platform. Said shared content may be visible to everyone depending on where it is published.
Contract performance
Legitimate interests (provision of services, enhanced platform functionality)
Training data When you access content, we collect certain data, relating in particular to the courses, exercises and application exercises, workspaces and questionnaires that you have started and completed; content and subscription purchases and credits; subscriptions; certificates of achievement; your interactions with trainers, teaching assistants and other participants; and essays, responses to questions, and other materials provided to satisfy the requirements of the course and related content.
Contract performance
Legitimate interests (provision of services, enhanced platform functionality)
Participant payment data We collect certain data relating to your purchases on Empirium, for example your name, billing address and postal code, in order to process your order. This data may possibly be saved to process subsequent orders. You must provide certain billing and payment information directly to our payment service providers, including your name, credit card information, billing address and zip code. We may also receive limited information from these providers to facilitate payments, for example if you are in possession of a new card and the last four digits of that card. For safety reasons, Empirium does not collect or store sensitive data related to bank cards such as full bank card numbers or data from authorization requests associated with certain bank card transactions.
Contract performance
Legal obligation
Legitimate interests (payment facilitation, fraud prevention and security, compliance)
Trainer payment data If you are a trainer, you can link your PayPal, Payoneer or other payment account to the Services in order to receive payments. When you link a payment account, we collect and use certain information about that account, including your email address, account identification number, physical address, or any other information we need to carry out transactions. payments to your account. In some cases, we may collect ACH or wire information to send payments to your account. To comply with applicable laws, we also work with trusted third-party companies that collect tax data in accordance with legal requirements. This tax information may include contact information, tax identification numbers, biographical information, and other personal information necessary for tax purposes. For safety reasons, Empirium does not collect or store sensitive banking information. The collection, use and disclosure of your billing, payment and tax information is subject to the privacy policy and other terms of your payment service provider.
Contract performance
Legal obligation
Legitimate interests (payment facilitation, fraud prevention and security, compliance)
Data relating to your accounts on other services
We may obtain certain information through your social media or other online accounts if they are connected to your account Empirium. If you log in to the site Empirium through Facebook, or a third-party service or platform, we ask for your permission to access certain information relating to that other account. For example, depending on the platform or service, we may collect your name, profile picture, account identification number, login email address, location, geographic location of the devices you use to access it, your gender, your date of birth and the list of your friends or contacts.
These platforms and services give us access to this information through their APIs. The information we receive depends on what you (through your privacy settings) or the platform or service choose to give us.
If you access or use the Services through a third-party platform or service, or click on any third-party link, the collection, use and sharing of your data will also be subject to the privacy policies and other contracts of the third parties concerned.
Legitimate interests (identity verification, improving user experience)
Lotteries, promotions and surveys We may invite you to participate in a survey or promotion (such as a contest, sweepstakes or challenge), either through the Services or through a third-party platform. If you choose to participate, we will collect and store data that you provide to us as part of that participation, such as your name, email address, postal address, date of birth or telephone number. Such data is subject to this Privacy Policy unless otherwise stated in the official rules of such promotion or in any other privacy policy. The data collected will be used to administer the promotion or survey, including notifying winners and delivering rewards. As part of the award process, we may ask your permission to publish some of your information (for example, on a winner announcement page). When we use a third party platform to administer a survey or promotion, the third party’s privacy policy applies.
Contract performance
Legitimate interests (promotion administration, pricing, compliance)
Communications et support If you contact us for support, to report a problem, or to raise a concern (whether or not you have created an account), we collect and store your contact details, messages, and other data for your purposes. subject such as your name, email address, messages, location, user ID Empirium, refund transaction IDs and any other data that you provide or that we collect by automated means (discussed below). We use this data to study your request and respond to you, in accordance with this Privacy Policy.
Legitimate interests (technical and customer support)
The data listed above is stored by us and associated with your account.
1.2 Data we collect by automated means
When you access the Services (including when you browse our catalog), we collect certain data by automated means, including:
Personal data category Description Legal basis for processing
System data Technical data about your computer or device, such as IP address, operating system type and version, unique device identifiers, browser, browser language, domain and other system data, and platform types.
Contract performance
Legitimate interests (provision of services, customer and technical support, fraud prevention and security, communication and product improvement)
Usage data Usage statistics related to your interactions with the Services, including the content you access, the time spent on certain pages or on the Service, the pages viewed, the functions used, the searches carried out, the elements you click on, the date and time, referrer and other data related to your use of the Services.
Legitimate interests (provision of services, improvement of user experience, improvement of products)
Approximate geographic data Approximate geographic location data, including country, city and geographic coordinates, calculated from your IP address.
Legitimate interests (improving user experience, fraud prevention and security, compliance)
The data listed above is collected through server log files and tracking technologies, as detailed in the section below entitled “Cookies and Data Collection Tools”. They are stored with us and associated with your account.
1.3 Data from third parties
If you are a business Empirium Business or a business prospect, we may, in addition to the information you submit to us, collect certain business contact information from third party business sources.
2. How we obtain data about you
We use tools such as cookies, web beacons and similar tracking technologies to collect the data listed above. For some of these tools, you have the option to opt out of data collection.
2.1 Cookies and Data Collection Tools
We use cookies, small text files saved by your browser, to collect, save and share data about your activities on the Websites, including on Empirium. They allow us to remember certain elements about your visits to Empirium, such as your preferred language, and to facilitate the use of the site. To find out more about cookies, visit https://cookiepedia.co.uk/all-about-cookies. We may also use web beacons in emails to track the correct delivery and open rate of emails.
Empirium and service providers acting on its behalf (such as Google Analytics and third-party advertisers) use server log files and automated data collection tools such as cookies, web beacons (or pixel tags), scripts, links and device or browser fingerprinting (collectively, “Data Collection Tools”). These Data Collection Tools automatically track and collect certain System Data and Usage Data (as described in Section 1) when you use the Services. In some cases, we combine data collected using these Data Collection Tools with other data that we collect as described in this Privacy Policy.
2.2 Why we use data collection tools
Empirium uses the following types of data collection tools for the purposes described:
Strictly necessary: ??These data collection tools allow you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These tools are necessary for the proper functioning of the Services. If you disable them, parts of the site will block or be unavailable.
Functional: These data collection tools remember data about your browser and preferences, provide additional functionality to the site, personalize content to be more relevant to you, and remember settings affecting appearance and behavior Services (such as your preferred language or volume level for playing videos).
Performance: These data collection tools help measure and improve the Services by providing data on usage and performance, number of visits, traffic sources, or where an application was downloaded from . These tools can help us test different versions ofEmpirium to see which features or content users prefer and determine which emails are opened.
Advertising: These data collection tools are used to serve relevant advertisements (on the Site and/or other sites) based on what we know about you, such as your usage and system data (as detailed in section 1), and what advertising service providers know about you from their tracking data. Ads may be based on your recent activity or activity over time and across other sites and services. To facilitate the delivery of personalized advertisements, we may provide these service providers with a hashed and anonymized version of your email address (in non-human readable form) and content you share publicly on the Services.
Social media: These data collection tools enable social media features, such as sharing content with friends and networks. These cookies may track a user or device across other sites and build a profile of the user’s interests for targeted advertising purposes.
You can configure your web browser to alert you when attempts are made to store cookies on your computer, to restrict the types of cookies allowed, or to refuse all cookies. If you disable cookies, you may no longer be able to use some or all of the features of the Services and this may change your experience or make it less functional. To learn more about managing data collection tools, see section 6.1 (Your choices regarding the use of your data) below.
3. How we use your data
We use your information to provide the Services to you, communicate with you, resolve problems, protect your account from fraud and abuse, improve and update the Services, analyze your use of the Services, provide targeted advertising, and for any purpose required by law or necessary for security and integrity reasons. We keep your data for as long as it is necessary to serve the purpose for which it was collected.
We use the data we collect as part of your use of the Services to:
Provide and administer the Services, including to facilitate participation in educational content, issue certificates of achievement, display personalized content and facilitate communication with other users (account data, shared content, learning data, system data, usage data, approximate geographic location data);
Process payments from trainers and other third parties (participant payment data, trainer payment data);
Process your requests and orders for specific educational content, products, services, information or features (account data, learning data, participant payment data, system data, communications and support);
Communicate with you about your account (account data, shared content, learning data, sweepstakes, promotions and surveys, system data, communications and support):
Respond to your questions and concerns;
Send you administrative messages and information, including messages from trainers, participants and teaching assistants; notifications related to changes to the Services; and updates to our contracts;
Keep you informed, via email or message, of your progress in courses and related content, our rewards programs, new services, new features, promotions, newsletters and other available content created by trainers (you can unsubscribe from these communications at any time);
Send you push notifications to your wireless device to notify you of updates and other relevant messages (you can manage these notifications from the “options” or “settings” page of your mobile application);
Manage your account and your account preferences and personalize your experience (account data, learning data, participant payment data, trainer payment data, system data, usage data, cookie data);
Facilitate the technical operation of the Services, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse (account data, participant payment data, trainer payment data, communication and support , system data, approximate geographic location data);
Verify the identity of trainers (account data, trainer payment data);
Solicit user feedback (account data, communications and support);
Marketplace products, services, surveys and promotions (account data, learning data, sweepstakes, promotions and surveys, usage data, cookie data);
Market subscription plans for potential customers (account data, learning data, cookie data);
Learn more about you by combining your data with other data from third-party data providers and/or analyzing the data with the help of analytics service providers (account data, data about your accounts and other services, usage data, cookie data);
Identify unique users across devices (account data, system data, cookie data);
Target ads across devices (cookie data);
Improve the Services and design new products, services and features (all categories of data);
Analyze trends and traffic, track purchases, and track usage data (account data, learning data, participant payment data, communications and support, system data, usage data, approximate geographic location data , cookie data);
Promote the Services on third-party websites and applications (account data, cookie data);
Anything required or permitted by law (all categories of data); Or
Anything we, in our sole discretion, determine is necessary to ensure the security or integrity of our users, employees, third parties, the public or the Services (all categories of data).
4. Who we share your data with
We share certain data about you with trainers, other participants, companies providing services for us, affiliates Empirium, our business partners, data analysis and enrichment service providers, your social media providers, companies helping us run promotional campaigns and surveys, and advertising companies helping us promote our Services . We may also share your data as necessary for security or legal compliance purposes, or as part of a corporate restructuring. Finally, we may share your data in other ways if that data is aggregated or anonymized or if we obtain your consent.
We may share your data with third parties in the following circumstances or as otherwise described in this Privacy Policy:
With your instructors: We share certain data that we have about you (except your email address) with the instructors or teaching assistants of the educational content that you access or about which you request information, so that they can improve their content for you and other participants. This data includes, but is not limited to, your country, browser language, operating system, device settings, the site that redirected you to Empirium and some of your activities on Empirium, such as courses you are enrolled in and your course reviews. We will not share your email address with instructors and teaching assistants (account data, system data, usage data, approximate geographic location data).
With other participants and trainers: Depending on the settings you choose, your shared content and profile data may be visible publicly, including to other participants and trainers. Likewise, if you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly available. (Account Data; Profile Data; Shared Content)
With service providers, contractors and agents: We share your data with third party companies that provide services on our behalf, such as payment processing, abuse and fraud protection, data analysis, marketing and advertising services (including ad retargeting), email and hosting services, and customer support and services. These service providers may access your personal data and are required to use it only as directed by us and for the purposes of our service request (all categories of data).
With affiliates Empirium : We may share your data within our family of companies that are related by common ownership or control to enable or assist us in providing the Services (all categories of data).
With Business Partners: We have entered into agreements with other websites and platforms to distribute our Services and drive traffic to Empirium. Depending on your location, we may share your data with these trusted partners (account data, learning data, communications and support, system data).
With continuing education credit granting organizations: If you are taking a course to satisfy a continuing professional education requirement, we may share this information at the request of the continuing education credit granting organization (account data, training data).
With analytics and data enrichment service providers: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like ZoomInfo, we share certain contact details or anonymized data . Data anonymization involves replacing information that identifies you, such as your name and email address, with an identity token. This allows service providers to provide analysis services or cross-reference your data with information from a public database (including contact and social information from other sources). This allows us to communicate with you in a more efficient and personalized way (account data, system data, usage data, cookie data).
To provide you with social media features: Through social media features in the Services (such as the Facebook Like button), the third party provider of the social network in question may collect information such as your IP address and the Services page you are viewing, and set a cookie to enable this functionality. Your use of these features is governed by the third party company’s privacy policy (system data, usage data, cookie data).
To administer promotional campaigns and surveys: We may share your data as necessary to administer, market or sponsor promotions and surveys in which you choose to participate, as required by applicable law (for example, to provide a list of winners or to make any required deposits), or in accordance with the rules of the promotion or survey in question (account data, sweepstakes, promotions and surveys).
For advertising purposes: In the event we decide in the future to use an advertising-based revenue model, we may use and share some of your System Data and Usage Data with third-party networks and advertisers in order to to present general trends in demographics and preferences among our users. We may also allow advertisers to collect System Data using the Data Collection Tools (as detailed in Section 2.1), use this data to serve you targeted advertisements to personalize your user experience (e.g. through behavioral advertising) and to analyze a website’s audience. Advertisers may also share data they have collected about you with us. To learn more about this or to opt out of behavioral advertising from ad networks, see Section 6.1 (Your choices regarding the use of your data) below. Opting out only concerns targeted advertisements; you will continue to receive generic advertisements (system data).
For security and legal compliance purposes: We may disclose your data (all categories of data) to third parties if we, in our sole discretion, have reason to believe that such disclosure is:
requested in connection with any judicial, governmental or legal investigation, order or proceeding;
reasonably necessary in connection with a subpoena, warrant or other legally valid request;
reasonably necessary to enforce our Terms of Use, this Privacy Policy or any other legal agreement;
required to detect, prevent or combat fraud, abuse, misappropriation, potential violations of law (or rule or regulation) or security or technical issues;
reasonably necessary (in our discretion) for protection in the event of an imminent threat to the rights, property or safety ofEmpirium, our users, our employees, people within the population or our Services;
we may further disclose information about you to our auditors and legal advisors in order to evaluate our disclosure rights and obligations under this Privacy Policy; Or
to the extent required or permitted by law.
During a change of control: If Empirium is the subject of a commercial transaction such as a merger, acquisition, cessation or dissolution of a company (including bankruptcy) or a total or partial sale of its assets, we may share, disclose or transfer all of your data to the successor organization Empirium as part of this transition or in anticipation of a transition (including during due diligence) (all data categories).
After aggregation or anonymization: We may disclose or use aggregated or anonymized data for any purpose.
With your permission: With your consent, we may share data about you with third parties outside the scope of this Privacy Policy (all categories of data).
5. Security
We use appropriate security measures, based on the type and sensitivity of the data that is stored. As with any Internet-connected system, there is always a risk of unauthorized access; It is therefore important that you protect your password and contact us if there is any suspicious activity on your account.
Empirium applies appropriate security measures to prevent unauthorized third parties from accessing, modifying, disclosing or destroying personal data that we collect and store about you. These measures depend on the type and sensitivity of said data. Unfortunately, no system can be 100% secure and therefore we cannot guarantee that no third party will gain unauthorized access to communications between you and Empirium, the Services or any information provided to us in connection with the data we collect through the Services. Your password plays a vital role in our security system and it is your responsibility to protect it. Do not share your password with any third party. If you believe that your password or account has been compromised, you should change your password immediately and contact our Support Team to report your concerns.
6. Your rights
You have certain rights regarding the use of your data. In particular, you can unsubscribe from promotional emails, deactivate cookies and refuse that certain third parties collect data about you. You may update or close your account through our Services, and you may additionally contact us with any individual rights requests relating to your personal data. Parents who believe that we have unintentionally collected personal data about their minor child should contact us so that we can delete this information.
6.1. Your choices regarding the use of your data
You can choose not to provide us with certain information, but please note that you may then not be able to use certain features of the Services.
If you no longer wish to receive promotional communications from us, you can unsubscribe using the unsubscribe mechanism indicated in the communication in question or by changing the notification settings in your account. Please note that regardless of your notification settings, we will send you operational and relational messages related to the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about our policies.
If you are located in the European Economic Area, you can opt out of certain Data Collection Tools by clicking on the “Cookie Settings” link at the bottom of each page.
The browser or device you use may allow you to manage cookies and other types of local data storage. To find out more about how to manage cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to determine whether location or other data is collected and shared.
To learn more about cookies used for targeted advertising by participating companies and how to opt out of this type of advertising, visit the Network Advertising Initiative and Digital Advertising Alliance web pages (sites in English), or the Your Online Choices site if you are in the European Economic Area. If you are located in Japan, visit the Digital Advertising Consortium site. To opt out of Google display advertising or customize Google Display Network ads, visit Google Ads Settings. To opt out of Taboola’s targeted ads, click the unsubscribe link in the company’s Cookie Policy (currently in English).
To no longer allow Google Analytics, Mixpanel, ZoomInfo or Clearbit to use your data for analytics or data enrichment, see the following links: Google Analytics Opt-out Browser Add-on, Mixpanel Opt-out Cookie , ZoomInfo Policy and Clearbit Data Recovery Mechanism.
Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to manage in-app targeted ads. For other devices and operating systems, we recommend checking your privacy settings on that platform.
6.2 Access, update and deletion of your personal data
To view and update the data thatEmpirium collect and store about you, follow these steps:
To update the data you provide to us directly, log into your account and update it at any time.
To close your account:
If you are a participant, visit your profile settings page and follow the steps detailed there.
If you are a trainer, follow the steps detailed here.
If you have problems canceling your account, contact our Support Team.
Note: Even after your account is deleted, some or all of your data may remain visible to other individuals, including, without limitation, any data that has been (a) copied, stored, or distributed by d other users (including comments on content); (b) shared or distributed by you or others (including in your Shared Content); or (c) posted on a third-party platform. Even once your account is deleted, we retain your data for as long as we legitimately need it (and in accordance with applicable law), including for compliance with legal obligations, resolution of disputes and execution of our agreements . We may retain and disclose such data under this Privacy Policy after closing your account.
To request access to, rectify or delete your personal data, use our online form available here. We will respond to you within 30 days. For security reasons, we may ask you to use the email address associated with your account to send us your request, and we may need to verify your identity before processing your request. Please note that we retain certain data for legal reasons, including to meet record-keeping obligations and to complete transactions.
6.3. Our children’s policy
We recognize children’s rights to privacy and encourage parents and guardians to be actively involved in their children’s online activities and interests. Persons under the age of 18, but of the age required to consent to use online services in their country (for example, 13 in the United States or 16 in Ireland), cannot create an account, but may ask a parent or guardian to open an account and help them access appropriate content. Persons under the age required for consent to use online services may not use the Services. If we learn that we have collected personal data from a child under the minimum age, we will take reasonable steps to delete it.
Parents who believe thatEmpirium may have collected personal data concerning a minor under the required minimum age may send a request for deletion of this data.
7. Rules of judicial jurisdiction
If you are a California resident, you have certain rights regarding access to and deletion of your data and the right to know with whom we share your data. If you reside in Australia, you have the right to make a formal complaint to the relevant government agency. Users who reside outside the United States are reminded that we transfer data to the United States and other areas outside the European Economic Area.
7.1 Users residing in California
Users who reside in California have certain rights under the California Consumer Privacy Act (CCPA). If you are an eligible user residing in California, you have these rights:
“Right to Know” — You have the right to request to know more about the categories and specific pieces of personal information we have collected about you and to access a copy of your personal information.
“Right to correction” — You have the right to have inaccurate personal information about you corrected.
“Right to Deletion” — You have the right to request deletion of the personal information we have collected about you.
“Right to Non-Discrimination” — If you choose to exercise your rights under the CCPA, Empirium will continue to treat you like any other user. In other words, you will not be penalized for exercising your rights under the CCPA.
“Right to Opt-Out” – You have the right to opt-out of the sale and sharing of your personal information.
The CCPA has a specific definition of “sale” and “sharing” and althoughEmpirium does not sell, in the traditional sense, your personal information or that of any of its users, we use cookies that make non-personally identifiable information available to selected third parties, including for cross-context advertising. To opt out of such “selling” and “sharing,” click the “Do not sell or share my personal information” link at the bottom of this page.
To exercise these rights under the CCPA, send a letter to Empirium, Attn: 4th Floor 205 Regent Street, London, England, W1B 4HB. The CCPA allows you to designate an authorized agent to make these requests on your behalf. For security reasons, we may ask you to use the email address associated with your account to send us your request, and we may need to verify your identity and/or that of your agent before processing your request .
To learn more about the type of personal information we collect and how we collect it, see the sections above titled “What Data We Collect” and “How We Obtain Data About You.”
To learn more about the business purposes for which your personal data is collected and the categories of service providers that have access to your personal data, see the sections above titled “How we use your data” and “With whom We share your data.”
As a California resident, you have the right to request certain details about the personal information about you that we share with third parties for those third parties’ direct marketing purposes. To send a request, write to Empirium providing the name of the applicable law, “California Shine the Light,” as well as your mailing address, state of residence, and email address.
Because there is no commonly accepted standard for the browser-initiated Do Not Track signal, we do not currently recognize or respond to browser-initiated Do Not Track signals.
7.2 Users residing in Nevada
Empirium does not sell the personal information or data of its users. However, if you are a Nevada resident you have the right to request that your personal information not be sold, you may request to opt out of participating in the sale of personal information by sending a letter Empirium.com or by writing to us at the following address: Empirium 4th Floor 205 Regent Street, London, England, W1B 4HB
7.3 Users residing in Australia
If you are resident in Australia and wish to make a complaint, contact the Office of the Australian Data Protection Officer (“OAIC”). You can contact the OAIC via its website www.oaic.gov.au, by email at enquiries@oaic.gov.au, by telephone on 1300 363 992 or by post at GPO Box 5218, Sydney NSW 2001. You can contact our Privacy Team at 4th Floor 205 Regent Street, London, England, W1B 4HB to make a complaint about a breach of the Australian Privacy Principles, which will be responded to within 30 days.
7.4 European Economic Area (“EEA”) and United Kingdom (“UK”) Users
If you are located in the EEA or the United Kingdom, you have the right to request access to your personal data in a portable format and to request rectification, erasure, restriction of processing or object to their processing. You can use the information in Section 6.2 to submit your request. Additionally, if you are located in the EEA, UK or Switzerland, you also have the right to lodge a complaint with your data protection supervisory authority.
Personal data is also processed outside the UK, Switzerland and the EEA by our group companies Empirium or by our service providers, including to carry out transactions, facilitate payments and provide support services as described in Section 4. We use the standard contractual clauses between controller and processor adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers and group companies Empirium in order to limit and regulate their processing of your data. By providing your data or using our Services, you consent to this transfer, storage and processing by Empirium and by the data controllers it has designated.
7.5 Data protection framework (for EU/EEA, UK and Swiss data subjects)
Empirium, Inc. complies with the EU-U.S. Data Protection Framework (EU-U.S. DPC), the extension of the EU-U.S. DPC. for the United Kingdom and the Swiss-U.S. Data Protection Framework (Swiss-U.S. DPC) as defined by the U.S. Department of Commerce. Empirium, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. CPD Principles (EU-U.S. CPD Principles) with respect to the processing of personal data received from the European Union building on the EU-U.S. CPD. and from the United Kingdom (and Gibraltar) relying on the extension of the EU-U.S. CPD. for the United Kingdom. Empirium, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Protection Framework Principles (Switzerland-U.S. DPC Principles) with respect to the processing of personal data received from the Switzerland based on the Swiss-U.S. CPD. If there is a conflict between the terms of this Privacy Policy and the EU-U.S. CPD Principles. and/or the Swiss-U.S. CPD Principles, the Principles will control. To learn more about the Data Privacy Framework (DPF) program and to view our certification, visit https://www.dataprivacyframework.gov/.
The Federal Trade Commission is responsible for compliance ofEmpirium Inc. to the EU-U.S. Data Protection Framework (EU-U.S. DPC), the extension of the EU-U.S. DPC. for the United Kingdom and the Swiss-U.S. Data Protection Framework (Swiss-U.S. DPC).
We are committed to subjecting all personal data received from the European Union, United Kingdom, Gibraltar and Switzerland to the CPD Principles. The types of personal data collected are described in Section 1 of this Privacy Policy. The purposes for which we collect and use personal data are described in Section 3 of this Privacy Policy. The types of third parties to whom we disclose personal data are described in Section 4 of this Privacy Policy. We remain responsible for your personal data shared with third parties in accordance with the Onward Transfer Principle for external processing on our behalf. In addition, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Empirium, Inc. remains liable in accordance with the CPD Principles if its agents process personal information in a manner that contravenes the CPD Principles, unlessEmpirium, Inc. does not prove that it is not responsible for the event giving rise to the damage.
Data subjects have a right of access to their personal data. Instructions for exercising this right are set out in Section 6.2 of this Privacy Policy. Data subjects may also limit the use and disclosure of their personal data as described in Section 6.1.
In accordance with the EU-U.S. CPD, the extension of the EU-U.S. CPD for the United Kingdom and the Swiss-U.S. CPD, Empirium, Inc. is committed to resolving complaints related to the CPD Principles regarding the collection and use of your personal information. EU, UK and Swiss data subjects wishing to submit inquiries and complaints regarding our processing of personal data received in reliance on the EU-U.S. DPC, the extension of the EU DPC -U.S. for the United Kingdom and the Swiss-U.S. CPD, must contact Empirium primarily at 4th Floor 205 Regent Street, London, England, W1B 4HB.
In accordance with the EU-U.S. CPD, the extension of the EU-U.S. CPD for the United Kingdom and the Swiss-U.S. CPD, Empirium, Inc. will refer unresolved complaints regarding our processing of personal data received in reliance on the EU-U.S. DPC, the EU-U.S. DPC Extension. for the United Kingdom and on the Swiss-U.S. DPC, before the International Center for Dispute Resolution/American Arbitration Association (ICDR-AAA), a provider of alternative dispute resolution services based in the United States. If you do not receive timely acknowledgment from us regarding your CPD Principles complaint, or if we have not responded to your CPD Principles complaint to your satisfaction, please contact You can visit https://go.adr.org/dpfeufiling.html for more information or to file a complaint. ICDR-AAA services are provided to you free of charge. Under certain conditions, you may resort to mandatory arbitration for complaints regarding compliance with the CPD that have not been resolved by one of the other mechanisms of the CPD, as described in more detail on the following page: https: //www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2
7.6 Users outside the United States
In order to provide you with the Services, we must transfer your data to the United States and process it there. If you use the Services outside of the United States, you consent to the transfer, storage and processing of your data in the United States or other countries.
8. Updates and Contact
If we make material changes to this policy, we will notify our users by email, in-product notification, or any other mechanism required by law. Changes take effect on the day they are published. Contact us by email or post with any questions, concerns or disputes 4th Floor 205 Regent Street, London, England, W1B 4HB.
8.1. Changes to the Privacy Policy
We update this Privacy Policy from time to time. In the event of material changes, you will be notified by email, by notice posted on the Services or as required by applicable law. This notification will also include a summary of the main changes. Unless otherwise stated, changes take effect on the day they are posted.
To the extent permitted by applicable law, your continued access and/or use of the Services after the effective date of any changes constitutes acceptance of, and agreement to follow, the revised Privacy Policy. comply with and be bound by it. The revised Privacy Policy replaces all prior Privacy Policies.
8.2 Interpretation
All capitalized terms not defined in this policy have the meanings assigned to them in the General Terms of Use.Empirium. Any version of this Privacy Policy in a language other than English is provided for convenience. In the event of a conflict between the English version and a non-English version, you agree that the English version shall prevail.