Emergenetics International Privacy Policy


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Effective on: May 2, 2018

Introduction and Scope

The Browning Group International, Inc. doing business as Emergenetics International and its legal affiliates, including, without limitation, STEP, LLC, Emergenetics Europe Limited, and Emergenetics Caelan & Sage PTE Ltd (collectively, "Emergenetics," "we," "us," "our") takes the protection of personal data very seriously. This Privacy Policy (the "Policy") addresses data subjects whose personal data we may process via the following information systems:

The data subjects whose personal data we process within the context of this Policy include individuals who have taken one of our proprietary psychometric profiles, including, without limitation, the Emergenetics Profile, a STEP Youth Report, and/or an ESP Candidate Report (each, a "Profile"), including Emergenetics Associates and other representatives of our Partners (as defined below) who took a Profile as part of their Emergenetics training.

This Policy does not apply to personal data we collect by other means, such as personal data that we receive through our sales and marketing systems or personal data concerning our employees.

Categories of Personal Data

We may process the following types of personal data:


In the context of this Policy, Emergenetics typically acts as a joint data controller for the data we process with each of our Partners. If you sign up to use our services directly via our website as an individual participant or by invitation from an Emergenetics employee located in the United States, Ireland, or Singapore, Emergenetics acts as a data controller for your personal data.

Basis of Processing

Within the scope of this Policy, we may rely on one or more of the following legal grounds for processing your personal data:

Purpose of Processing

We process personal data for the purposes of:

Data Retention

When the purposes of processing are satisfied, we will delete such personal data within six months.


A "cookie" is a small file stored on your hard drive that contains information about your computer. We may use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. If you would prefer not to accept cookies, you can alter the configuration of your browser to reject all cookies or some cookies. Note, if you reject certain cookies, you may not be able to access all of our Platform features. For more information, please visit https://www.aboutcookies.org/.

Sharing Personal Data with Service Providers

We share personal data with our service providers, who process personal data on behalf of Emergenetics. Such third parties include those:

Our service providers may be located outside of the United States; however, we will either obtain your explicit consent to transfer your personal data to such third parties, or we will require that those third parties maintain at least the same level of confidentiality that we maintain for such personal data. Emergenetics remains liable for the protection of your personal data that we transfer to our service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.

Sharing Personal Data with Emergenetics Partners

Emergenetics works with a variety of individuals and organizations in the Americas, Europe, and Asia to bring Emergenetics science to participants around the world. Our partners include Emergenetics client organizations, independent Emergenetics, STEP, and ESP Associates, Country Representatives, Domain Administrators, and other third parties providing Emergenetics services globally (collectively, the "Emergenetics Partners" or the "Partners").

In order to process your Profile(s), Emergenetics shares data with our Partners, who typically act as joint controllers with Emergenetics over the personal data processed via the Platform. If you took a Profile at the invitation of an Emergenetics, STEP, or ESP Associate, are an employee or member of a corporate client or client organization, or are a STEP participant, we likely received your data from a Partner. Emergenetics shares your personal data with its Partners in order to provide the Platform and services to you.

Other Disclosure of Your Personal Data

We may disclose your personal data (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders, or (ii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any personal data, about users of our Platform and services as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

If we must disclose your personal data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your personal data will maintain the privacy or security of your personal data.

Data Integrity & Security

Emergenetics has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect personal data from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.

Access & Review

If you are a data subject about whom we store personal data, you may have a right to request access to, and the opportunity to update, correct, or delete, such personal data. To submit such requests or raise any other questions, please contact the Emergenetics Partner that initially collected your personal data or contact Emergenetics directly by one of the methods described in the "Contact Us" section below.

Restriction & Objection to Processing; Portability

If you are a data subject whose personal data we process, you may have the right to ask that we limit our processing of your personal data, as well as the right to object to our processing of your personal data. To exercise such rights, where applicable, please contact us using the information in the Contact Us section of this Policy.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

With respect to personal data processed in the scope of this Policy, Emergenetics complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (the "Privacy Shield") as adopted and set forth by the U.S. Department of Commerce regarding the processing of personal data. Emergenetics commits to adhere to and has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

To learn more about the Privacy Shield, and to view Emergenetics’ certification, please visit https://www.privacyshield.gov and https://www.privacyshield.gov/list, respectively.

VeraSafe Privacy Program

Emergenetics is a member of the VeraSafe Privacy Program, meaning that with respect to personal data processed in the scope of this Policy, VeraSafe has assessed Emergenetics’ data governance and data security for compliance with the VeraSafe Privacy Program Certification Criteria. The certification criteria require that participants maintain a high standard for data privacy and implement specific best practices pertaining to notice, onward transfer, choice, access, data security, data quality, recourse, and enforcement.

Dispute Resolution

Where a privacy complaint or dispute cannot be resolved through Emergenetics’ internal processes, Emergenetics has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Privacy Shield Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

Binding Arbitration

If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by VeraSafe, you may have the right to require that we enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

Regulatory Oversight

In the United States, Emergenetics is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

If you are a data subject whose personal data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union member states.

Changes to this Privacy Policy

If we make any material change to this Policy, we will post the revised Policy to this webpage and update the "Effective" date above to reflect the date on which the new Policy became effective.

Contact Us

If you have any questions about this Policy or our processing of your personal data, please write to our General Manager by email at privacy@emergenetics.com or by postal mail at:

Emergenetics International
ATTN: General Manager
2 Inverness Dr East, Suite 189
Centennial, CO 80112

Please allow up to four weeks for us to reply.

VeraSafe is Emergenetics’ representative in the European Union (Article 27 representative). To contact VeraSafe, please use this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative

Alternatively, VeraSafe can be contacted at:

Matthew Joseph
Zahradníčkova 1220/20A
Prague 15000
Czech Republic
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P