Last updated: 04.11.2025
Version: 2.0.1

Emento Privacy Policy (EU version)

This Privacy Policy describes how Emento collects, processes, and protects personal data when using our services across the European Union.

General Information

Emento is pleased that you are using our service. It is very important to us that we respect and protect your privacy. It is always our intention and goal to process your data responsibly and appropriately.

The personal data you provide to us will be treated confidentially and only used for clear and specific purposes defined either by us or by the organisation assigning your course. We ensure that all processing is compliant with relevant EU data protection regulations.

Who is Emento

Emento develops and owns the digital solutions “Emento” and “Guide”, collectively referred to as “the Service”. These are connected web and mobile applications that enable organisations to guide users through complex processes. These users may be patients interacting with healthcare institutions, citizens engaging with public authorities, or employees undergoing onboarding, training, or other internal workflows.

Emento is committed to protecting personal data and has implemented technical and organisational measures to ensure compliance with applicable EU data protection laws across all its operations
.

Where Does Emento Receive Your Data From?

Emento may receive your personal data from:

• You directly (e.g. profile creation, support contact)
• Your device when using the app (e.g. technical data)
• Public institutions or private organisations that assign your course
• Relatives or guardians, especially if a minor's profile is created by a parent or legal representative

When Does Emento Process Personal Data?

You provide data such as your name, phone number, email, and optional profile picture when using our service. We process personal data when:

• You download the app
• You create a profile
• You accept the privacy policy
• You contact our support

We may also process:

• Technical data (e.g. IP address, device details, log history)
• Identification data (e.g. unique IDs, demographic data)
• Health data (only in health-related courses)
• Communication data (e.g. support requests, messages)

Personal Data of Minors

We may process personal data of minors under the age of 16 when assigned by an authorised organisation (e.g. healthcare, municipalities). A profile for a minor may only be created by a legal guardian, who ensures the child is informed appropriately and, where required by law, consents to the processing.

Emento does not verify age during registration. Responsibility for legal compliance (e.g. obtaining parental consent) lies with the assigning organisation that uses Emento’s service.

When Does Emento Process Personal Data on Behalf of the Controller

Emento acts as a data processor when you:

• View content in the app
• Write a message
• Mark tasks as completed

The assigning organisation remains the data controller and is responsible for lawful processing, including of minors. We follow their instructions strictly and never use such data for other purposes.

Purpose of Use

We process data to:

• Provide the service
• Improve service quality and platform access
• Respond to support requests
• Send identity verification messages

Legal Basis for Processing

General processing may be based on:

• Contract performance (Art. 6(1)(b) GDPR)
• Legal obligations (Art. 6(1)(c) GDPR)
• Consent (Art. 6(1)(a) GDPR and Art. 9(2)(a) for special categories like health data)

Country specific processing may be based on:

• DK: §11.2.2 of the Danish Data Protection Law for the use of the CPR- number.

Personal Data to Third Parties

We share your data only with trusted sub-processors where necessary (e.g. for hosting, login systems). These partners are bound by contract to maintain data protection. All sub-processors are selected carefully and operate within the EU or ensure appropriate safeguards under GDPR.

Storage of Personal Data in Emento

Data is stored as long as needed to provide the service and meet legal requirements. Only limited, authorised personnel have access based on a “need-to-know” principle.

If the data includes information protected by confidentiality laws (e.g. medical data), this confidentiality is extended to Emento and its staff, including through binding instructions and awareness of legal obligations.

Deletion of Personal Data in Emento

You can delete your profile and personal data via the app. If the course is ongoing, deletion must first be confirmed or ended by the course provider.

In addition to you being able to delete your data, we will also automatically delete it when we either don't need it to run our app anymore, or when the law says we have to.

Your Rights under GDPR

You have the right to:

• Access your data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Request erasure (Art. 17)
• Data portability (Art. 20)
• Object to processing (Art. 21)

You can exercise these rights via the app or by contacting Emento. If Emento processes your data on behalf of a course provider, contact them directly. We support such requests but cannot act on them without their authorisation.

Contact Information

If you have questions or concerns about this privacy policy or how your data is processed, you can contact us:

Emento A/S
Olof Palmes Alle 44
DK-8200 Aarhus N
Email: dpo@emento.dk
Phone: +45 72 22 70 70
Web: www.emento.dk

If your data is processed in Germany or Switzerland, or you are using the service within Germany or Switzerland, you may also contact:

Emento GmbH
Am Gierath 20 A
40885 Ratingen
Email: datenschutz@emento.de
Phone: +49 2102 5358010
Web: www.emento.de

To lodge a complaint with a supervisory authority in Denmark:

Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
Tlf. 33 19 32 00
Email: dt@datatilsynet.dk

To lodge a complaint with a supervisory authority in Germany:

State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia
Postfach 20 04 44
40102 Düsseldorf
Email: poststelle@ldi.nrw.de

To lodge a complaint with a supervisory authority in Switzerland:

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)
Feldeggweg 1
3003 Bern
Phone: +415846243 95
Web: https://www.edoeb.admin.ch/de

If you wish to lodge a complaint elsewhere in the EU, you can contact your national data protection authority. Emento’s lead supervisory authority is based in the EU.