Effective on: September 13, 2024

Introduction

Hey there! We at Emergenetics care about keeping your personal information safe. This Youth Privacy Notice (“Youth Notice”) supplements our Privacy Policy. It applies to the Youth Services we provide through your school or youth organization, like when you take the Emergenetics Youth Report. We have summarized the key information here for you, and if you want more details you can read the Privacy Policy. Please note that to the extent there are any differences between the Privacy Policy and the Youth Notice, the Youth Notice governs for Youth Services.

What Is Covered by this Notice? 

This notice is for people (like kids and students) whose personal information we get from our customers (usually schools and youth organizations) when they use our online website for Youth Reports (“Youth Services”). For simplicity, we call our customers “organizations” in this Youth Notice.

This Notice doesn't address: 

• Info from people who just visit our website;
• Info about people who use other services provided by us;
• Info about our workers, people who want to work with us, or others who help Emergenetics; and 
• Info that doesn't tell us who you are. 

Our Role with Your Info

We help organizations by providing services for youth at their direction. Your organization decides who can use your information and for what purposes, like teachers and students. We only use your info in ways the organization tells us to or when the law says we have to. Remember, your organization has its own privacy practices, so if you have questions, please talk to them.

Why Can We Use Your Info? 

We are allowed to use your info because your organization or your parents have asked us to. We work with organizations just like their own employees do. We help with things the organization would have their employees do, we follow the organization's rules about using and taking care of their records, and we don't share your info without permission. You can ask your organization, your teachers, or your parents to tell you more if you have questions. 

What Info We Collect About You and How We Get It

Below is a list of the information we may collect when we provide Youth Services:

• Biographical Information - Your name, your parents' or guardians' names, age, organization, and the special code given to you by Emergenetics. 
• Questionnaire Results – Certain things about you which we learn when you take the Youth Report questionnaire, like how you prefer to think, learn and talk to your classmates and your teachers. 
• Device Information – We may get information about the device you use to complete the questionnaire online, like your computer’s IP address. 

We get this info because you give it to us when you sign up for our Platform, your organization gives it to us, or we conclude based on your answers to the questionnaire. We won't collect more info about you without telling you.

How Do We Use Your Info?

We might use your personal information to do these things:

• Make a special name and secret code for you to use our website.
• Provide Youth Services, such as creating an Emergenetics Youth Report
• Help you use our Youth Services better by:
  • Changing it to match what you like and work with your computer or tablet;
  • Making it easier to use;
  • Keeping it safe and protected;
• See how well our platform is working.
• Help with things you do with your organization.
• Answer any questions or help you if you ask us.
• Follow the law and make sure people follow the rules.
• Make our Youth Services better.

How Long We Keep Your Info

We keep your personal information for as long as the person in charge of your account tells us to (normally, your organization), or until you ask us to stop processing it (as explained below). And after we process your questionnaire responses to generate a Youth Report, we delete your specific responses.

Sharing Your Info with Third Parties

We do not share your information with anyone beyond your organization, except when necessary to operate our service or when required by law.

We use a cloud hosting provider to operate our website and Youth Services, but they can only use your information to help us and must keep your information secure and private.

We might share your information if the law says we have to, or if we think we need to in order to help with important investigations or legal cases. If we share your information with government or law enforcement officials, we can't promise they will keep it private and safe.

We might also share your information if our company joins with another company, sells some of its business, or changes in some way. We will only do this if the new company promises to keep your information safe, like we do.

Notice to Parents

Protecting the privacy of children (under the age of 13) is important to Emergenetics. We work as a contracted service provider to education institutions, and only collect information that is reasonably necessary for providing our services. We do not share children’s information with third parties beyond what is described above. If you believe that you child may have provided us with their information in violation of this Notice or you would like to review or delete their information, please contact your child’s school or contact us at privacy@emergenetics.com.

What Privacy Rights Do You Have? 

You may have specific rights regarding the info about you that we collect and process, such as to access, correct, and delete it. You may also have the right to ask that we limit our processing of such info, as well as the right to object to our processing of such info. You may also have the right to data portability. But since we process your info at the direction of your organization, your organization is responsible for managing those rights and you should speak with your organization if you have any questions.

We also acknowledge the right of EU, UK and Swiss individuals to access their info pursuant to the Data Privacy Framework (as described in the International Transfers section below) and will grant individuals reasonable access to info we received pursuant to the Data Privacy Framework Principles, consistent with our role in supporting organizations. In addition, we will take reasonable steps consistent with our role in supporting organizations to permit individuals to correct, amend, or delete such information that is demonstrated to be inaccurate or processed in violation of the Data Privacy Framework Principles. Additionally, if we have received your info in reliance on the Data Privacy Framework, while you may also have the right to opt out of having your info shared with third parties, that right is not applicable since we do not share your info with third parties. You may also have the right to opt out if your info is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. An individual may request to access their info, or otherwise correct, amend, delete, withdraw their consent or limit the processing of their Personal Data in line with the Data Privacy Framework Principles by contacting the organization.

Data Integrity & Security

At Emergenetics, we take your information seriously and we promise to keep it safe. We have special ways to protect your information from bad people who might try to steal it. Some of the things we do are: we use special technology to make sure no one can read your password, we only let certain people like teachers, school administrators, and organization leaders see your information if they really need to, and we have a team of people whose work is to ensure your information stays safe.

International Transfers

Sometimes we may need to transfer information from the European Economic Area and United Kingdom to the United States, such as if you attend school in certain European countries. In those circumstances, we have committed to protecting your information under something called the Data Privacy Framework. In this section, we include information that is required for the Data Privacy Framework, which basically explains our participation in the framework and how you can contact us and work through any complaints you may have.

Emergenetics complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce.  Emergenetics has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Emergenetics has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov and https://www.dataprivacyframework.gov/s/participant-search, respectively.

Third Parties

If you are in Europe and we transfer your information to third parties outside of Europe, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your information that we do. We remain liable for the protection of your information that we transfer or have transferred to third parties through our designated data transfer mechanism, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.

Dispute Resolution

Where a privacy complaint or dispute relating to Personal Data received by Emergenetics in reliance on the Data Privacy Framework (or any of its predecessors) cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework 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 related to your Personal Data that we received in reliance on the Data Privacy Framework cannot be resolved by us, nor through the dispute resolution mechanism mentioned above, you may have the right to require that we enter into binding arbitration with you under the Data Privacy Framework “Recourse, Enforcement and Liability” Principle and Annex I of the Data Privacy Framework.

U.S. Regulatory Oversight

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

Right to Lodge a Complaint with a Supervisory Authority

If you live in Europe, you can also complain to a supervisory authority in your country about how we use your info if you think we have done something wrong with it. Ask your school or your parents to help you with doing this. Ask your organization or your parents to help you with doing this. 

Changes to This Notice

If we make any changes to this Youth Notice, we will tell you by updating this page and noting the new date. If we do change this Youth Notice and you keep using Emergenetics, it means you agree to the changes.

Contact Us

If you have any questions about this Youth Notice, you can contact Emergenetics’ Data Protection Officer by email, phone, or mail at:

 

VeraSafe, LLC 

experts@verasafe.com

100 M Street SE, Suite 600, Washington D.C., 20003, U.S.A.

(617) 398-7067

 

If you are in the EU or UK and want to contact our representative, please refer to our main Privacy Policy for our representative’s information.