Effective Date: 4.5.26
1. Introduction
Emporia Learning Inc. ("Emporia," "we," "us," or "our") respects the privacy of all individuals who interact with our platform. This Privacy Policy describes how we collect, use, share, and protect personal information when you access or use the Emporia platform and all related websites, applications, tools, and features (collectively, the "Service"). Please read this Privacy Policy carefully. By using the Service, you consent to the practices described in this Privacy Policy.
This Privacy Policy applies to all users of the Service, including Clients, Respondents, and visitors. Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in our Terms of Service.
2. Scope
This Privacy Policy governs personal information that Emporia collects and processes as a controller, including information collected from Respondents during registration, screening, and platform use, and information collected from Clients and visitors in connection with their use of the Service.
When Emporia processes personal information on behalf of a Client in connection with a Client's research study (for example, survey responses collected through the Service at the Client's direction), Emporia acts as a service provider or processor on behalf of that Client. The Client's own privacy policy governs the Client's collection and use of such information. If you have questions about how a Client handles your information, please contact the Client directly.
Where required by applicable law or requested by a Client, Emporia will enter into a Data Processing Agreement governing Emporia's processing of personal information on behalf of the Client. Emporia's standard Data Processing Agreement is available upon request.
3. Information We Collect
(a) Information You Provide
We collect information that you provide directly to us, including:
(b) Information Collected Automatically
When you access or use the Service, we automatically collect certain information about your device and usage, including:
We collect this information using cookies, log files, web beacons, tracking pixels, and similar technologies. See Section 8 (Cookies and Tracking Technologies) for more information.
(c) Information from Third Parties
We may receive information about you from third parties, including identity verification services, fraud prevention services, and publicly available sources, to the extent permitted by applicable law.
4. How We Use Your Information
We use the information we collect for the following purposes:
5. AI and Automated Processing
Emporia uses artificial intelligence, machine learning, and other automated tools in connection with the Service, including for:
Where AI or automated tools are used in a manner that could reasonably be perceived as human interaction (for example, AI-moderated interviews or AI-generated communications with Respondents), Emporia will disclose such use to affected participants prior to or at the commencement of the interaction.
To the extent Emporia uses third-party AI or machine learning providers in connection with the Service, Emporia requires by contract that such providers do not retain or use personal information to train their own models or for any purpose other than providing services to Emporia.
6. De-Identified, Aggregated, and Derived Data
Emporia may create De-Identified Data, Aggregated Data, and Derived Data from information processed through the Service, as described in the Terms of Service. Once information has been de-identified or aggregated so that it can no longer reasonably identify any individual, household, or Client, it is no longer considered personal information under this Privacy Policy, and Emporia may use it for any lawful business purpose, including service improvement, product development, analytics, benchmarking, industry reporting, and the creation of commercial data products.
Emporia will not attempt to re-identify De-Identified Data or Aggregated Data except as required by law or with the express consent of the applicable party.
7. How We Share Your Information
We may share your personal information in the following circumstances:
(a) With Clients. If you are a Respondent, we may share your personal information (including profile information, application details, and LinkedIn profile information) with applicable Clients to facilitate your participation in research studies, as described in the Respondent Terms.
(b) With Service Providers. We share information with third-party service providers who perform services on our behalf, including hosting, analytics, payment processing, fraud detection, and customer support. These providers are contractually required to use personal information only to provide services to Emporia and to maintain appropriate security measures.
(c) With Affiliates. We may share information with our corporate affiliates for purposes consistent with this Privacy Policy.
(d) For Legal Reasons. We may disclose information where required by applicable law, regulation, subpoena, court order, or other legal process, or where we believe disclosure is necessary to protect the rights, property, or safety of Emporia, our users, or others.
(e) Business Transfers. In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the successor entity. We will notify you of any such transfer to the extent required by applicable law.
(f) With Your Consent. We may share your information with third parties when you have given us your consent to do so.
We do not sell personal information to third parties for their direct marketing purposes. We do not share your phone number with third-party lead generation services.
8. Cookies and Tracking Technologies
We use cookies, web beacons, tracking pixels, and similar technologies to collect information about your interactions with the Service. These technologies help us:
You can control the use of cookies through your browser settings. Most browsers allow you to refuse cookies or alert you when a cookie is being set. If you disable cookies, some features of the Service may not function properly.
We may also use third-party analytics services (such as Google Analytics) to help us understand how users interact with the Service. You can opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
We do not currently respond to Do-Not-Track ("DNT") browser signals. If a uniform standard for responding to DNT signals is adopted, we will update this Privacy Policy accordingly.
9. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention period depends on the nature of the information and the purpose for which it was collected.
When a Client's engagement with the Service terminates, Emporia will delete or anonymize Customer Data from its active systems in accordance with the Client Terms. De-Identified Data, Aggregated Data, and Derived Data may be retained and used indefinitely, as described in the Terms of Service.
When a Respondent's account is terminated or deleted, Emporia will deactivate or delete the Respondent's personal information from active databases, except to the extent that retention is necessary to: (a) comply with applicable law; (b) prevent fraud or enforce the Emporia Terms; (c) resolve disputes; or (d) maintain De-Identified Data, Aggregated Data, or Derived Data that no longer identifies the Respondent.
10. Data Security
We implement administrative, technical, and physical security measures designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. Data is encrypted and secured using industry-standard practices. Access to personal information is restricted to personnel who require it to perform their job functions.
While we take reasonable steps to protect your information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee the absolute security of your personal information.
In the event of a breach of personal information that triggers notification obligations under applicable law, Emporia will notify affected individuals and applicable regulatory authorities within the timeframes required by law.
11. Your Privacy Rights
Depending on your jurisdiction, you may have certain rights regarding your personal information under applicable privacy laws, including the right to:
The specific rights available to you depend on the laws of your jurisdiction. We will not discriminate against you for exercising your privacy rights.
To exercise any of these rights, please contact us at mark@emporiaresearch.com. We will verify your identity before processing your request and respond within the timeframes required by applicable law.
If you are unsatisfied with our response, you may have the right to appeal our decision or lodge a complaint with your local data protection authority.
Promotional Communications. You may opt out of receiving promotional emails from Emporia by following the unsubscribe instructions in the email or by contacting us at mark@emporiaapp.com. Even if you opt out of promotional communications, we may still send you service-related messages.
12. International Data Transfers
Your personal information may be stored and processed in any country where Emporia maintains facilities or engages service providers, including the United States. By using the Service, you consent to the transfer of your information to countries outside your country of residence, which may have data protection laws that differ from those in your jurisdiction.
Where required by applicable law, we will implement appropriate safeguards for cross-border transfers of personal information, such as standard contractual clauses or other mechanisms recognized under applicable data protection law.
European Economic Area, United Kingdom, and Switzerland. If you are located in the EEA, UK, or Switzerland, Emporia processes your personal information on the following legal bases, as applicable: (a) your consent; (b) performance of a contract with you; (c) compliance with a legal obligation; or (d) Emporia's legitimate interests (such as operating and improving the Service, fraud prevention, and security), provided those interests are not overridden by your data protection rights. You have the right to lodge a complaint with your local supervisory authority if you believe your rights have been violated.
13. Children's Privacy
The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18. If you become aware that a person under 18 has provided personal information to us, please contact us at mark@emporiaapp.com, and we will take steps to delete such information.
14. Third-Party Websites and Services
The Service may contain links to third-party websites or services that are not operated by Emporia. This Privacy Policy does not apply to those third-party services. We are not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party services you visit.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law. Material changes will be posted on the Service with an updated effective date, and we will use commercially reasonable efforts to notify affected users of material changes (which may include email notice, in-product notification, or other conspicuous means). We encourage you to review this Privacy Policy periodically. Your continued use of the Service after the effective date of any updated Privacy Policy constitutes your acceptance of the updated policy.
16. Contact Us
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:
Emporia Learning Inc. 2000 E. 6th St., Suite 7 Austin, TX 78702 mark@emporiaapp.com.