Privacy Policy

Click Privacy Policy

Click is a brand name trading under the company name emoquo.

emoquo will not sell your personal data under any circumstances.

emoquo cares about your privacy.

Transparency and honesty are a huge part of our mission at emoquo. We care about your privacy and especially about the psychological safety of the coaching environment.

This Privacy Policy explains how emoquo collects and handles our users' and clients' data for all our services.

1. Definitions

The following definitions apply to this policy.

  • emoquo, we, us, or our refers to emoquo Ltd, 1st Floor, Midas House, 62 Goldsworth Road, Woking, Surrey GU21 6LQ, and its employees.
  • Services means all products (including related mobile applications), services and websites offered by emoquo.
  • Users, user, you means the people to whom we provide Services directly via our platform.
  • Client, organization or company refers to the entities who contract with us to provide Services to their employees or others on the platform.
  • Organization manager means any person who has login credentials to a client account to manage users within the organization and access the reports.
  • Consultants refers to accredited practitioners using the R@W methodology with their clients.
  • Personal data means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.
  • De-identified platform data means any content or data that you submit to emoquo using its Services, unlinked from your Personal Information. This may include your assessment and survey responses, the challenges you create and vote on; and any other ratings or responses you provide when using emoquo’s services.

2. How we protect your data

2.1 Employee practices

All employees and partners of emoquo follow a security policy to keep everybody's data secure.

  • We use two-factor authentication to log into important systems such as databases and communication platforms.
  • We keep our computers password protected and up to date with the latest security updates.
  • We use role-based access controls to limit our access to the minimum needed to do our jobs.
  • We use password managers so that all of our passwords are strong and different between sites.

2.2 Access to confidential, restricted information

  • Access to de-identified platform data is limited to authorized emoquo employees whose job responsibilities require it.
  • Employees of emoquo with access to de-identified platform data or personal data sign a non-disclosure agreement with data protection provisions in order to safeguard the information provided by clients and users.

2.3 Databases

  • Your data is encrypted at rest in our databases.
  • Our systems interoperate inside a virtual private cloud, and your data is always encrypted "in transit" outside of that.
  • All our apps and APIs use https, and if you try to use insecure http you will be automatically redirected.
  • We use various methods to protect data against brute force attacks.
  • We keep rolling backups of databases to prevent permanent data loss.

2.4 In our apps

  • The platform encourages strong passwords for users.
  • Users are assigned permissions that control who can see and change which data.

3. Data we collect

  • Personal Data: We require certain personal data in order to register your account such as your name, your email address, your role or title, your country and state (where applicable), your avatar or photograph (optional). We require this data for the following reasons: (1) to create your account; (2) to ensure that you receive notifications about deadlines with the appropriate time zone; and (3) to ensure that we have minimum location data to honor your specific privacy rights.
  • Usage information: We collect usage data about you whenever you interact with our services. This may include which web pages you visit, what you click on, when you performed those actions, and other activities.
  • Device and browser data: We collect data from the device you use to access our services, such as your IP address, operating system, browser details and time of visit. This information may also tell us your location.
  • Cookies and page tags: We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymous data about visitors to our websites. This data includes usage details and user statistics.
  • Account settings: You may be able to set or update various preferences and personal details on your account settings page or your profile. This includes your name, email address, default language or time zone.

5. Disclosures specific to platform data

  • As part of our services, we might ask you to complete an assessment, questions about your wellbeing and engagement, or questions about your experience of the services and their impact on you and/or your team. Your responses will only be shared with your team (where applicable), the consultant or facilitator (where applicable) and your organization on an aggregated and de-identified basis.
  • Your organization manager will receive access to aggregated and deidentified reports about all users connected to your organization, so long as our data analysts can confirm a minimum threshold of users from your organization in order to maintain anonymity.
  • We may create aggregated de-identified data for any purpose derived from data we hold about you. For example, we may create aggregated de-identified data to share with clients, prospective clients, partners for business or research purposes, or for provision of our services such as our data benchmarks.
  • We may disclose your personal data to the organization or relevant authorities if either your use of our services or your organization manager indicate a serious, imminent risk of harm to you or to others around you.

5. How Long We Retain Data

  • Personal data: Your personal data will be held by us for 36 months after our relationship or contract with your organization is terminated, at which point it will be deleted.
  • Platform data: Platform data will be stored for 36 months after our relationship or contract with your organization is terminated. At this point it will be anonymized and unlinked from any personal data and organization details, and will only be used research purposes, or for provision of our services such as our data benchmarks.

6. Your rights

6.1 General

If you live in certain countries (for example, the United Kingdom or European Union member states) you may have rights regarding your Personal Information, including the right to access, correct, delete, port, limit or stop the use or disclosure of your Personal Information. These rights are more fully explained at https://ico.org.uk/for-organisations/guide-to-the-general-data-protectionregulation-gdpr/individual-rights/.

We will respond to requests to access and correct (if necessary) your Personal Information as soon as possible. You have the following options when exercising your rights:

  • to request a copy of your personal data which emoquo holds about you;
  • to request that emoquo corrects any personal data if it is found to be inaccurate or out of date;
  • to request that your personal data is erased when it is no longer necessary for emoquo to retain such data;
  • to withdraw any consent you have given to the processing of your personal data, at any time;
  • to object to the processing of personal data including for marketing purposes;
  • to lodge a complaint with the Information Commissioner’s Office (ICO).

These rights are explained more fully at https://ico.org.uk/fororganisations/guide-to-the-general-data-protection-regulation-gdpr/individualrights/.

6.2 Requests from clients or organization managers

Clients of emoquo or their designated organization managers can request the following:

  • Access to the organization de-identified platform data in CSV format. To request a data export, please contact us at support@emoquo.com.
  • Under no circumstances will we provide platform data where users are identifiable. On a case-by-case basis, when the client indicates a serious, imminent risk of harm to a user or others around them, we will consider providing identifiable data related to that user only to the relevant authorities.

7. New purpose

If we wish to use your personal data for a new purpose, not covered by this policy, then we will provide you with a new policy explaining this new use prior to commencing the processing and setting out of the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

8. Sharing data

emoquo will not share your data with anyone without your explicit consent.

9. Updating your data

If you wish to update or change any information that we use of yours or how we use it, you can do so by emailing us at support@emoquo.com. Please ensure that you notify us of any updates, amendments and corrections to your information by contacting us via the same email above.

10. Contacting us

Any queries or comments about this Privacy Policy or for requests relating to the rights listed above, please contact emoquo at support@emoquo.com.

If you wish to make a complaint about how we use your information, please contact us in the first instance via email and we will do our best to help. If you are still unhappy, you can contact the Information Commissioner’s Office via their website (www.ico.org.uk).

We will occasionally update this Privacy Policy. We encourage you to periodically review this notice to be notified of how we use your information.

This privacy notice was last updated in October 2022.