Effective Date: April 30, 2019

Introduction

Emerge Training is a brand owned by Job and Esther Technologies Oy and is the entity that primarily controls the website you are visiting. Job and Esther Technologies Oy and its subsidiaries and affiliates ("Emerge") respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), handle your personal data in connection with this website, and tell you about your privacy rights and how the law protects you ("Privacy Policy"). This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at Section 10 to understand the meaning of some of the terms used in this privacy notice.

1. Important Information And Who We Are

This privacy notice aims to give you information on how Emerge collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up, request for quote, or take part in a webinar. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Job and Esther Technologies Oy is the entity that is the controller and responsible for emerge.training website. We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights in your personal data, please contact the Data Protection Officer using the details set out below.

2. Our Trainings

If your company availed of a solution from Emerge and or contracted Emerge to run or conduct a training for your company, please contact your company's authorized personnel with any privacy questions related to your participation in any of the solution or training program Emerge conducted. If there is a conflict between this Privacy Policy and an agreement between Emerge and your company, then the agreement between Emerge and the company will prevail. In such cases, authorized personnel at your company may have access to your personal information processed by Emerge, and your company may have policies applicable to your use of them. Emerge is not responsible for our business customers' policies and practices related to data privacy and security, which may be different from this privacy notice and any applicable notice provide by our business customers.

Changes to this Privacy Notice and Your Duty to Inform Us of Changes

The privacy policy is GDPR compliant. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

3. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, title, your employer.
• Contact Data includes business address, corporate or personal email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, solutions and trainings.
• Marketing and Profile Data includes your interests and preferences in receiving marketing from us and select third parties, your communication preferences and survey responses.

As noted in Section 2 (above), if your company contracted Emerge training, please contact your company with any privacy questions related to the personal information processed in connection with that Emerge training. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with solutions and/or trainings). In this case, we may have to cancel a training you have with us but we will notify you if this is the case at the time.

4. How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may share with us some of your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• inquire about our solutions or trainings;
• apply for a job opening;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.
• Third parties or publicly available sources. We may receive analytics and advertising data about you from the sources listed below, as well as, public sources. Please use the following links for more information about how Google, LinkedIn and Facebook collect and use data when you visit their partners websites or apps:
• Google - https://www.google.com/policies/privacy/partners/
• LinkedIn - https://www.linkedin.com/legal/privacy-policy
• Facebook - https://www.facebook.com/privacy/explanation

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our or third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by updating your email preferences.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer or contact	(a) Identity (b) Contact	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Marketing and Profile	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/trainings)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT trainings, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Usage (d) Marketing and Profile (e) Technical	Necessary for our legitimate interests (to study how customers use our trainings, to develop solutions, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, trainings, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our solutions and trainings, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or trainings that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Profile	Necessary for our legitimate interests (to develop our solutions, trainings and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We have made available for you means to established your preference on receiving marketing communications and where you can view and make certain decisions about your personal data use OR the following personal data control mechanisms:

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which solutions, trainings and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or availed of solutions or trainings from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your opt-in consent before we share your personal data with any company outside the Job and Esther Technologies group of companies for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the "Unsubscribe" links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [availed solution and training, registration, training experience or other transactions].

Cookies

We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you've provided to them or that they've collected from your use of their services. You consent to our cookies if you continue to use our website.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

How Long Will You Use My Personal Data For?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data: see "Request erasure" in the Glossary at Section 11 below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please fill-out our form for personal information requests.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these or other legitiamte circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. Finally, we can only act on requests related to the personal information we have collected through our websites. If you have availed and undergone trainings through private training runs like company sponsored, please contact your company with any questions or requests related to your personal information. That said, if we cannot process your request, we will explain the reason(s) why. For example, a request might impact the rights of another person or company.

10. GLOSSARY

Lawful Basis Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best solutions and trainings. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties Other companies in the Job and Esther Technologies Group include the following entities:

Entity	Location	Trainings Provided
Job and Esther Technologies Oy	Finland	Business Readiness
Eqela	Philippines	Eqela Trainings
Eqela	Finland	Eqela Trainings

External Third Parties External third parties are limited to Google, LinkedIn and Facebook as described at further described in Section 4 (above).

Your Legal Rights You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or trainings to you. We will advise you if this is the case at the time you withdraw your consent.