ERGO GLOBAL PRIVACY POLICY
INTRODUCTION
Ergo Global provides this Privacy Policy (“Privacy Policy”) to inform you (“you,” “your,”, or “user”) of our policies and practices regarding the collection, use, disclosure, and protection of personal information when you:
- visit our website at https://ergoglobal.com/ (the “Website”), regardless of the location from which you access it;
- use the ErgoEval and/or ErgoWOW web applications, and any other features, applications, widgets, or online services that are owned or controlled by Ergo Global and that reference or link to this Privacy Policy; or
- provide information to us offline while participating in onsite ergonomics assessments.
(collectively referred to as “Services”)
This Privacy Policy also explains the choices you have regarding your personal information, including how you may access, update, or correct it. For your convenience, please refer to the Glossary included in this Privacy Policy for definitions of certain terms used herein.
By accessing or using the Services, you consent to the information collection, disclosure, and use practices described in this Privacy Policy. Please note that certain features referenced in this Privacy Policy may not be offered on the Services at all times. Please further note that all capitalised terms not specifically defined herein shall have the meaning ascribed in our Terms and Conditions located at https://ergoglobal.com/terms-conditions/.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED]
4. [COOKIES]
5. [HOW WE USE YOUR PERSONAL DATA]
6. [DISCLOSURES OF YOUR PERSONAL DATA]
10. [YOUR CHOICES AND LEGAL RIGHTS]
11. [GLOSSARY]
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how Ergo Global collects and processes your personal data through your use of the Services, including any data you may provide through the Website when you sign up for our newsletter, purchase a product or service, or take part in a competition.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy 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.
WHO WE ARE
Ergo Global is made up of different legal entities, details of which can be found in Section 13 “COMPANY GROUP STRUCTURE”. This Privacy Policy is issued on behalf of the Ergo Global Group, so when we refer to “Ergo Global,” “Company,” “we,” “us,” or “our” in this Privacy Policy, we are addressing the relevant entity within the Ergo Global Group responsible for processing your data. Ergo Global acts as a Data Controller when it collects personal information directly from users through its Services or obtains such information from third parties, as further detailed in this Privacy Policy. In certain instances, the Company also processes personal data of individuals on behalf of its customers in the capacity of a Data Processor, in which case we will provide you with additional information accordingly. We will inform you which entity of the Ergo Global Group will serve as the data controller for your information when you purchase a product or service from us. This information may be provided before or at the time of processing your order, referenced in any invoice issued to you, or communicated to you at another appropriate time. You are always welcome to contact us to inquire about the specific entity currently responsible for controlling your data.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise the rights granted to you under this Privacy Policy, see Section 10 “YOUR CHOICES AND LEGAL RIGHTS” or please contact our DPO using the contact details set out below in the first instance.
CONTACT DETAILS
For the attention of: DPO
Mailing address: 74, South Bridge Road
#02-01
Wong Shee Fun Building,
Singapore 058704
Email: [email protected]
If you are not satisfied with the resolution provided by the DPO, you always have the right to make a complaint to your local data protection supervisory authority (“DPSA”). We would, however, appreciate the chance to deal with your concerns before you approach the DPSA, so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Privacy Policy under regular review. Historic versions can be obtained by contacting us. We will notify you of any substantial changes in the management of personal information. Notification may be provided through various means, including the contact information you have supplied. The revised Privacy Policy will take immediate effect upon posting unless otherwise specified. Your continued use of the Services after the effective date of the updated Privacy Policy will signify your consent to these modifications. However, we will not use your personal data in a significantly different manner than disclosed at the time of collection without obtaining your consent. If you disagree with the changes, you shall stop using our Services.
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. We hold no responsibility for your failure to timely notify us of any update or change in your personal data, and the associated costs and damages resulting from such failure.
THIRD-PARTY LINKS
Our Services may include links to third-party websites, services, plug-ins, and applications (collectively “Third-Party Services”). 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 Services and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every third party you visit.
CHILDREN DATA
Our Services are designed for a general audience and are intended for adults 18 and older. We do not knowingly collect personal information from minors, anyone younger than age 18. If we become aware that a child younger than 18 has provided us with personal information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that we have collected personal information from your child, please contact us at: [email protected].
CHILDREN DATA
Our Services are designed for a general audience and are intended for adults 18 and older. We do not knowingly collect personal information from minors, anyone younger than age 18. If we become aware that a child younger than 18 has provided us with personal information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that we have collected personal information from your child, please contact us at: [email protected].
2. 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 as follows:
● Identity Data includes first name, last name, or similar identifier.
● Contact Data includes billing address, delivery address, personal and work email addresses, and telephone numbers.
● Financial Data includes bank account and payment card details, as well as other payment information such as credit card, PayPal, or other financial account information.
● Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
● Technical Data includes internet protocol (IP) address, your login data, timestamps, diagnostic logs, device type, browser type, and version, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Services.
● Account & Profile Data includes information you provide when creating or managing your account, including your name, email address, and password. This also includes your height, which we use to calibrate ergonomic measurements, and any preferences, interests, or feedback you share with us, including responses to surveys or questionnaires.
● Media Data includes user-uploaded video clips and photos used for posture and movement analysis in the course of your ergonomic assessment.
● Assessment & Ergonomic Data includes information generated or provided in the course of your ergonomic assessment, including your answers to multiple-choice questions and free-text prompts about your work tasks, role, and working environment, self-reported physical discomfort or pain, and the ergonomic analysis outputs produced from your uploaded images or videos (joint angles, posture scores, risk indicators, and generated reports). This category also includes any information you voluntarily share to help contextualise your assessment results.
● Chat & Communication Data includes Information you share when using our in-platform chat, whether with our AI-powered assessment assistant or with a human consultant. This includes the content of your messages, any personal information you choose to include in them, the date and time of each conversation, and a record of the conversation as a whole.
● Usage Data includes information about how you use our Services.
● Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.
● Location Data includes information about your IP address, the country code/region/state/city associated with your device, and the time zone.
● Sensitive Information includes user-reported information, such as self-reported information about physical discomfort or pain that you choose to share with us.
Note: 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 the requested services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
SENSITIVE INFORMATION
As part of providing ergonomics assessments, we collect self-reported information about physical discomfort or pain that you choose to share with us. This may include descriptions of musculoskeletal discomfort, pain location, or physical symptoms relevant to your working posture or environment.
This information is collected voluntarily and used exclusively to provide contextual ergonomic recommendations. It is not used for medical diagnosis, does not constitute a medical record, and is not shared with healthcare providers or insurers. We do not make any clinical assessment of your health based on this information.
This processing is carried out on the basis of your explicit consent, given at the point of collection. You may withdraw your consent at any time without affecting the validity of processing carried out before withdrawal, and without affecting your ability to use the core assessment features of the platform.
We do not collect or process information regarding criminal convictions or offences.
INFORMATION WE DO NOT NEED FROM YOU
We do not require, and we ask you not to volunteer, information beyond what is necessary for your ergonomic assessment. In particular, please do not share formal medical diagnoses, medical history, prescription information, or medical records through the platform’s chat or free-text fields. This information is not needed to complete your assessment and is outside the scope of what our service is designed to handle.
If you choose to include such information in a free-text response or chat message, it may be stored as part of your conversation record. We will treat any health-related information you share as sensitive data subject to the protections described in this section, but we are not in a position to apply the same safeguards as a regulated healthcare provider, and the Services are not a substitute for medical advice.
AGGREGATED DATA
We also collect, use, and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data could be derived from your personal data, but is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Service feature or Profile Data to receive feedback about our Service and improve it. 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 Policy.
If you choose to include such information in a free-text response or chat message, it may be stored as part of your conversation record. We will treat any health-related information you share as sensitive data subject to the protections described in this section, but we are not in a position to apply the same safeguards as a regulated healthcare provider, and the Services are not a substitute for medical advice.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect and process the following data about you:
● Information you give us. This is the information (including Identity, Contact, Financial, Marketing and Communications Data, and Sensitive Information) that you consent to provide to us by filling in forms on the Website or using any of our Services, or by corresponding with us (for example, by post, email, or chat). This includes personal data you provide when you:
● apply for our products or services;
● purchase our products or services;
● obtain services requested;
● subscribe to our marketing newsletter;
● share data via our social media functions;
● schedule a meeting with us through the Website;
● schedule an ergonomics evaluation through our ErgoEval or ErgoWOW web applications;
● perform ergonomics assessments through the platforms offered by the Company;
● enter in a competition, promotion, survey; or
● give us feedback or contact us by any available means.
● Automated technologies or interactions. We and our third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the Services. As you interact with our Website or web applications offered by us, we will automatically collect Location Data, Technical Data, and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see Section 4 “COOKIES” below for further details.
● Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
1. Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
2. Identity and Contact Data from social media profile information, marketing leads, and search results and links, including paid listings (such as sponsored links). We may collect limited data from publicly available databases, marketing partners, and other outside sources.
4. COOKIES
When you visit our Website, our servers automatically record data that is transmitted by your browser. The technology used to collect information automatically from users may include cookies and other tracking technologies. For detailed information about the tracking technologies employed on our Website, please refer to our Cookie Policy.
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 obligation.
- Where you provide your consent for the specific purposes of the processing of your personal data (e.g., before sending direct marketing communications to you via email). You have the right to withdraw consent to marketing at any time by contacting us at the details provided below.
Review the Lawful Basis section in the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new customer |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Location Data (e) Technical Data (f) Usage Data |
(a) Performance of a contract with you |
|
To provide the requested Services |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Chat & Communication Data (e) Location Data (f) Technical Data (g) Usage Data |
(a) Performance of a contract with you |
|
To respond to your queries, requests, questions, suggestions or complaints |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Chat & Communication Data (e) Technical Data (f) Usage Data (g) Location Data |
(a) Performance of a contract with you
|
|
To process and deliver your order, including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Chat & Communication Data (e) Financial Data (f) Transaction Data |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|
|
To notify you about important changes to our Terms and Conditions or this Privacy Policy |
(a) Identity Data (b) Contact Data (c) Account & Profile Data |
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
|
|
To reschedule and manage a meeting requested by you |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Chat & Communication Data (e) Location Data (f) Technical Data |
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (specifically, maintaining a customer database for internal administrative purposes)
|
|
To conduct an ergonomics evaluation and prepare a report based on assessment findings |
(a) Identity Data (b) Contact Data (c) Location Data (d) Account & Profile Data (e) Media Data (f) Assessment and Ergonomic Data (g) Chat & Communication Data (h) Sensitive Information
|
(a) Performance of a contract with you
(b) With your consent
|
|
To enable you to partake in a prize draw, competition, or complete a survey |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Chat & Communication Data (e) Usage Data (f) Location Data (g) Marketing & Communications Data |
(a) With your consent
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and grow our business)
|
|
To administer and protect our business, Website, and web applications (including troubleshooting, testing, system maintenance, support, fraud prevention, reporting, data hosting, and contacting you with administrative communications) |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Chat & Communication Data (e) Technical Data (f) Usage Data (g) Location Data |
(a) Necessary for our legitimate interests (e.g., running our business, provision of administration and IT services, network security, preventing fraud, and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
|
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Usage Data (e) Technical Data (f) Marketing & Communications Data (g) Location Data |
(a) With your consent
(b) Necessary for our legitimate interests (to study how customers use our products/services, develop them, grow our business, and implement our marketing strategy)
|
| To use data analytics to improve our Services, marketing, customer relationships, and user experience |
(a) Technical Data (b) Usage Data (c) Location Data |
(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business operations) |
|
To manage our marketing email campaigns |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Technical Data (e) Usage Data (f) Marketing & Communications Data (g) Location Data |
(a) With your consent
(b) Necessary for our legitimate interests (to study how customers use our products/services, develop them, grow our business, and implement our marketing strategy)
|
|
To enforce and comply with the law, including conducting an investigation, protecting the property and rights of the Company or its users |
(a) Identity Data (b) Contact Data (c) Account & Profile Data (d) Chat & Communication Data (e) Technical Data (f) Usage Data (g) Location Data |
(a) Necessary for our legitimate interests (including the prevention and investigation of fraud or unlawful activities, as well as the protection of the Company’s rights and interests or those of its users)
(b) Necessary to comply with a legal obligation |
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we intend to use your personal data for a purpose other than that for which it was originally collected, we will provide you with prior notice and explain the legal basis permitting such use. Where required by applicable law, we will also obtain your consent before proceeding.
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 share your personal data with the parties set out below for the purposes set out in the table above.
-
- Internal Third Parties as set out in the “Internal Third Parties” section below within the Glossary.
-
- External Third Parties as set out in the “External Third Parties” section below within 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 Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with this Privacy Policy and applicable law. We do not allow our third-party service providers 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.
We may also disclose your personal information in other circumstances as required by law:
- Legal and Investigative purposes. We may also disclose your personal information as required by law for legal and investigative purposes. This includes sharing information with government agencies, law enforcement, or private parties to comply with legal obligations, conduct investigations, protect the rights and interests of Ergo Global or third parties, ensure public safety, or prevent unlawful, fraudulent, or unethical activities. Disclosure may occur when we deem it necessary or appropriate to:
-
- Respond to applicable laws, regulations, legal processes, or government requests.
- Detect, prevent, or address fraud, security, or technical issues.
- Protect the rights, property, or safety of Ergo Global, our users, or the public.
-
7. INTERNATIONAL TRANSFERS
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Singapore, European Union, United Kingdom and the United States of America. If you access our Website or use our Services from outside these locations, please note that your personal information may be transferred to, stored, and processed in jurisdictions other than your country of residence, including, for example, on servers in the United States or in other countries where our third-party service providers operate. Additionally, certain information may also be stored locally on the devices you use to access the Services.
Please be aware that these jurisdictions may not provide the same level of data protection as your home country. For example, personal information stored in these jurisdictions may, under certain circumstances, be subject to access by law enforcement and national security authorities.
Whenever we transfer your personal data outside of the European Economic Area (“EEA”), we ensure that an adequate level of protection is maintained in accordance with applicable European data protection laws. To this end, we rely on various transfer mechanisms, including but not limited to the following:
● Adequacy Decisions. In accordance with Article 45 of the GDPR, we may transfer personal data to recipients located in countries for which the European Commission, the UK Information Commissioner’s Office, or the Swiss data protection authority have issued an adequacy decision, confirming that such jurisdictions provide an adequate level of data protection (“Adequacy Decisions”). For example, we rely on Adequacy Decisions to transfer personal data to recipients in the EU, the United Kingdom, and Switzerland. You can find more information about current Adequacy Decisions at the following links:
– UK Adequacy Decisions;
– Swiss Adequacy Decisions.
● Data Privacy Frameworks. We may transfer personal data to our external third-party service providers in the United States from the EEA, Switzerland, and the UK pursuant to the EU-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework, and the UK Extension to the EU-U.S. Data Privacy Framework (collectively, the “Data Privacy Frameworks”). These Frameworks are supported by adequacy decisions recognising the adequacy of protection they provide for such transfers.
● Standard Contractual Clauses (“SCCs”) and Other Transfer Mechanisms. In the absence of an Adequacy Decision, we rely on appropriate safeguards as provided under Article 46 of the GDPR to ensure an adequate level of data protection when transferring personal data to countries outside the EEA, UK, or Switzerland. These safeguards may include:
a) Standard Contractual Clauses approved by the European Commission;
b) Binding Corporate Rules;
c) Approved codes of conduct or certification mechanisms.
We share your personal data within the Ergo Global Group. This will involve transferring your data outside the EEA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. DATA SECURITY
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
Ergo Global holds certification for compliance with ISO/IEC 27001, the internationally recognised standard for information security management. ISO/IEC 27001 establishes a framework of security management best practices and comprehensive security controls, the foundation of which is the development and implementation of a robust Information Security Management System (ISMS). Compliance with this standard is assessed and certified by independent, accredited third-party auditors.
Our certification under ISO/IEC 27001 reflects our organisation-wide commitment to information security and demonstrates that our security programme is designed, implemented, and maintained in accordance with globally recognised industry best practices. We regard this certification as an ongoing obligation and it underpins our approach to protecting the confidentiality, integrity, and availability of all information assets entrusted to us.
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.
We implement the following security technical measures:
a) TLS Encryption Technology: Use of Transport Layer Security (TLS) technology for encryption during all-access to the Services.
b) SSL Data Encryption: Implementation of Secure Socket Layer (SSL) technology for data encryption during information upload and transmission between our facilities.
c) HTTP Strict Transport Security: Utilisation of HTTP Strict Transport Security to provide an additional layer of protection for users.
d) Regular Evaluation: Periodic evaluation of personal data collection, storage, and processing procedures, including physical security safeguards, to prevent unauthorised access to our systems.
We have further implemented the following organisational measures:
a) Need-to-Know Access: Access to user personal data is granted to Ergo Global employees and contractors exclusively on a need-to-know basis.
b) Confidentiality Commitments: Our personnel are obligated to confidentiality commitments through Non-Disclosure Agreements (NDAs) and employment contracts.
c) Access Mechanism Security: Implementation of a secure mechanism for granting and revoking access to data hosting.
d) Annual Data Security Training: All personnel undergo annual mandatory training on data security measures and knowledge of the data breach policy.
e) Education on Data Protection Standards: Education of the personnel on personal data protection standards outlined in the Company’s internal policies on data protection.
9. DATA RETENTION
We retain your personal information for a period consistent with the business purposes outlined in Section 5 “HOW WE USE YOUR PERSONAL DATA”, or as long as necessary to fulfil our legal obligations. Typically, we store personal data for up to one year from the date you provided your data – for example, by signing in or otherwise using our Services.
We may retain your personal information for a longer period if necessary to resolve a complaint, enforce our agreements, or if we reasonably anticipate litigation in connection with our relationship with you.
The length of time we retain personal information is determined based on several factors, including:
● The specific purposes for which the personal information was collected (e.g., maintaining your account while it remains active to provide ongoing support and communication);
● The type, volume, and sensitivity of the personal information;
● The potential risk of harm from unauthorised use or disclosure;
● Whether the intended purposes of processing can be achieved through alternative means or with less data; and
● Applicable legal, regulatory, or contractual requirements, including statutes of limitation that mandate retention of certain records.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for five years after they cease being customers for financial and tax purposes.
In some circumstances, you can ask us to delete your data: see Section 10 “YOUR CHOICES AND LEGAL RIGHTS” below for further information.
In some circumstances, we will anonymise 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.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. YOUR CHOICES AND LEGAL RIGHTS
At Ergo Global, we ensure that all users have choices regarding their personal information. Regardless of location, we provide the following options for users to manage the privacy of their data:
- Managing Marketing Communications: You have the option to unsubscribe from our marketing newsletter by utilising the “unsubscribe” link at the bottom of each newsletter and following the provided instructions. Alternatively, you can opt out of all communications by contacting us at [email protected]. If you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.
- Correcting Your Personal Information: To request the correction or update of any personal information we hold about you, please contact us at [email protected].
- Accessing Your Personal Information: You may request a copy of the personal information we maintain about you by contacting us at [email protected].
- Deleting Your Personal Information: You may request the deletion of your personal information by contacting us at [email protected].
- Opting Out of Targeted Advertising. As mentioned earlier, we and our advertising partners may utilise your personal information to deliver targeted advertisements or marketing communications that may be of interest to you. For a comprehensive understanding of how targeted advertising functions, you can refer to the Network Advertising Initiative’s (“NAI”) educational page. You may be able to opt out of interest-based advertising by visiting the NAI Opt-Out Page or the Choices Opt-Out Page (or the Digital Advertising Alliance of Canada Opt-Out Page, if you are based in Canada).
To opt out of targeted advertising of some ad networks, you can use the following links:
● Facebook: https://www.facebook.com/settings/?tab=ads
● Google: https://www.google.com/settings/ads/anonymous
● LinkedIn: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
Furthermore, you can also visit the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/ to opt out of some of these services.
In certain circumstances, residents of specific countries are granted particular rights under applicable data protection laws concerning their personal data. Below is a list of these country-specific rights for the respective residents:
Residents of Europe, including those in the European Economic Area (“EEA”), the United Kingdom (“UK”) (including Gibraltar), and Switzerland
General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”), UK Data Protection Act 2018 (“UK GDPR”), and Federal Act on Data Protection of 25 September 2020 (known as “FADP”), provide residents of the EEA, UK, and Switzerland with the following rights:
• Request access to your personal data.
• Request correction (rectification) of your personal data.
• Request the erasure of your personal data.
• Object to the processing of your personal data.
• Request the restriction of processing your personal data.
• Request the transmission of your personal data to another controller.
• Right to withdraw consent at any time.
• Right to human intervention and not to be subject to a decision based solely on automated means.
• Right to lodge a complaint with a supervisory authority. The EU residents may find the list of the competent DPSA by the link: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en, the UK residents may contact the UK Supervisory Authority at https://ico.org.uk/global/contact-us/, and Swiss residents may contact the Swiss Data Protection and Information Commissioner at https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer at the following details:
Ergo Global Limited
Address: Geashill, Ballinlough, Dunshaughlin Co.
Meath, Ireland
Attention: Data Protection Officer
Email: [email protected]
Residents of Canada
Personal Information Protection and Electronic Documents Act, S.C. 2000, also known as “PIPEDA”, entitles residents of Canada with the following rights:
- Request access to your personal data.
- Request correction (rectification) of your personal data.
- Right to withdraw consent at any time.
- Right to lodge a complaint with a supervisory authority (namely, the Office of the Privacy Commissioner of Canada).
To exercise any of the rights set out above, please contact our Data Protection Officer at the following details:
Attention: DPO
Ergo Global Limited
Address: 74, South Bridge Road #02-01, Wong Shee Fun Building
Singapore 058704
Email: [email protected]
California Residents
California Business and Professions Code Section 22575, also known as the California Online Privacy Protection Act (“CalOPPA”), entitles our users who are residents of California to exercise the following rights:
- Request a review of your personal data.
- Request changes to your personally identifiable information.
To exercise any of the rights set out above, please contact our Data Protection Officer at the following details:
Attention: DPO
Ergo Global Limited
Address: 74, South Bridge Road #02-01, Wong Shee Fun Building
Singapore 058704
Email: [email protected]
For additional details regarding these rights and their interpretation, please refer to the Glossary.
NO FEE USUALLY REQUIRED
We typically do not impose a fee for processing or responding to user requests unless exceptional circumstances warrant such charges. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances. If we are unable to fulfil a request, an explanation for the refusal will be provided.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us verify your identity and ensure your right to access your personal data (or 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 1 (one) month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. GLOSSARY
Non-Identifying Information means any information whose disclosure, alone or in combination with other information, does not reveal the identity of the user to whom it relates.
YOUR LEGAL RIGHTS
a) 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.
b) Request correction (rectification) 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.
c) Request the 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.
d) Object to the 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 your fundamental rights and freedoms. You also have the right to object when 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.
e) Request the restriction of the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- 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.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
f) Request the transmission 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 that you initially provided consent for us to use or where we used the information to perform a contract with you.
g) 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
h) Right to human intervention and not to be subject to a decision based solely on automated means, including profiling, if the decision produces legal effects concerning you or significantly affects you in a similar way.
i) Lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the applicable law.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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.
Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent means the processing of your personal data where you have explicitly agreed to such processing for one or more specific purposes outlined in this Privacy Policy. For example, this may include the processing of your personal information for our own or third-party marketing purposes.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Ergo Global Group and its affiliates.
EXTERNAL THIRD PARTIES
- Service providers who provide IT and system administration services.
- Professional advisers and consultants, including lawyers, bankers, auditors, insurers, and ergonomics consultants, that provide consultancy, banking, legal, insurance, accounting, and ergonomics-related services.
- Regulators and other authorities based in Singapore, the EEA, the UK, Switzerland, or other countries that require reporting of processing activities in certain circumstances.
- Market researchers and web and mobile analytics who provide web, mobile, and market analytics services such as Google Analytics.
- Price comparison sites that provide price comparison services.
- Booking assistance and customer support service providers who provide customer support services, such as Microsoft Bookings.
- Service providers that offer various services related to our Website and Services. For more details about the full list of service providers we use, please refer to the table below.
- Ad servers and network advertisers that serve our advertisements on other websites, within mobile apps, and elsewhere online and provide us with information regarding the use of the Services and the effectiveness of our advertisements, such as Google, LinkedIn, and others. Such ad servers and network advertisers may collect certain information about your visits to and activity on the Website as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. We may also share certain Non-Identifying Information with these parties in connection with the services they provide to us.
|
Service Provider |
Processing Purpose |
Location |
Legal Basis of Data Transfer |
Link to Privacy Policy and/or DPA
|
|
Amazon Web Services, Inc.
Address: 2021 7TH Ave Seattle, Washington 98121-2601 Attn: Greg Luloff Associate General Counsel, Privacy Amazon.com, Inc. Phone: (206) 266-1000
|
To host users’ data securely within the cloud provider.
To manage user registration and the account, and to facilitate access to and use of the Website.
To administer and protect our business, to resolve disputes or troubleshoot problems, and to prevent potentially prohibited or illegal activities.
To host and operate the Website chat/support channel; store chat conversations; generate AI support responses.
AWS (Bedrock) is serving as an infrastructure for the Claude chatbot component of the ErgoWOW AI platform. |
European Economic Area
United States
|
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
https://www.dataprivacyframework.gov/list
|
DPA – https://d1.awsstatic.com/legal/aws-dpa/aws-dpa.pdf
Privacy Policy – https://aws.amazon.com/privacy/ |
|
MongoDB, Inc.
Attn: DPO [email protected] Phone: 1-866-692-1371
|
To host users’ data securely within the cloud provider. |
European Economic Area
United States |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
https://www.dataprivacyframework.gov/list
|
DPA – https://www.mongodb.com/legal/data-processing-agreement
Privacy Policy – |
|
Cloudflare, Inc.
Address: 101 Townsend St. San Francisco, CA 94107 Attention: Data Protection Officer
|
To increase the performance, security, and availability of our Website. |
European Economic Area
United States |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
https://www.dataprivacyframework.gov/list
|
Privacy Policy – https://www.cloudflare.com/privacypolicy/
|
|
Microsoft Corporation
Attn: Data Protection Address: One Microsoft Place South County Business Park Leopardstown Dublin 18, D18 P521, Ireland Privacy web form: http://go.microsoft.com/?linkid=9846224
|
To provide customer support services – facilitate scheduling of meetings through the Website functionality.
To back store the database of personal data. |
European Economic Area
United States |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
https://www.dataprivacyframework.gov/list
|
Privacy Policy – https://www.microsoft.com/en-us/privacy/privacystatement#mainenterprisedeveloperproductsmodule
|
|
Google LLC
Address: 1600 Amphitheatre Parkway Mountain View, California 94043 Attn: Chief Privacy Officer Google Data Protection Office
|
To measure interest in and improve our products and Services, and to customise user experiences through an analytics services provider used for behavioural analytics.
To deliver personalised ads tailored to user preferences and interests.
|
United States |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
|
Privacy Policy – https://policies.google.com/privacy?hl=en-US
|
|
Google Gemini provided by
Google Ireland Limited (in the EEA and Switzerland)
Address: Gordon House, Barrow Street Dublin 4, Ireland
and by
Google LLC (everywhere else)
Address: 1600 Amphitheatre Parkway Mountain View, California 94043 Attn: Chief Privacy Officer Google Data Protection Office
|
To process the redacted frames as part of the ErgoWOW AI functionality for the sole purpose of workspace analysis.
|
European Economic Area
United States |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
|
Cloud Data Processing Addendum – https://cloud.google.com/terms/data-processing-addendum |
|
The Rocket Science Group LLC d/b/a Mailchimp
Address: 2700 Coast Avenue Mountain View, CA 94043 Attn: Liza Schmitt Sr. Program Manager – Global Privacy Program Email: [email protected]
|
To manage your marketing email subscription and deliver our marketing newsletter and promotional offers to you.
|
United States
European Economic Area |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
|
Privacy Statement – https://www.intuit.com/privacy/statement/
|
|
SendGrid (Twilio Inc. and Twilio Ireland Limited)
Address: 101 Spear St, Ste 500, San Francisco, CA 94105 Attention: Privacy Team Email:
|
To send transactional emails to users and notify them about important updates on the Services
|
United States
European Economic Area |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
|
Privacy Notice – https://www.twilio.com/en-us/legal/privacy
DPA – https://www.twilio.com/en-us/legal/data-protection-addendum |
|
Usercentrics GmbH Address: Havnegade 39, 1058 Copenhagen Denmark Phone: + 45 50 333 777 Email: [email protected]
|
To manage cookie consents on the Website, collect and store user choices regarding which cookies can be used, and ensure compliance with data privacy regulations by displaying consent banners and blocking cookies without proper consent |
European Economic Area |
N/A |
Privacy Policy – https://www.cookiebot.com/en/privacy-policy/
DPA – https://www.cookiebot.com/en/wp-content/uploads/sites/7/2023/08/DPA_01_2023.pdf |
|
HubSpot, Inc.
Address: 25 1ST St Ste 200, Cambridge, MA 02141 Attn: Nicholas Knoop Director, Senior Corporate Counsel Email: [email protected]
|
To administer and manage our customer database via CRM system
|
United States |
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
|
Privacy Policy – https://legal.hubspot.com/privacy-policy
DPA – https://legal.hubspot.com/hubfs/DPA%20PDF%20-%20April%2014%202026.pdf |
|
Squarespace, Inc. (Squarespace Ireland Limited)
For residents having a principal place of business in the US:
Squarespace, Inc. Attention: Legal – Privacy Address: 225 Varick Street, 12th Floor New York, NY 10014 United States Email: [email protected]
For residents having a principal place of business anywhere other than the US:
Squarespace Ireland Limited Attention: Legal – Privacy Address: Squarespace House Ship Street Great Dublin 8, D08N12C Ireland Email: [email protected]
|
To facilitate scheduling an evaluation within the web applications through a scheduling software service provider |
United States
European Economic Area
|
EU-U.S. Data Privacy Framework (“DPF”)
Swiss-U.S. DPF
UK Extension to the EU-U.S. DPF
|
Privacy Policy – https://www.squarespace.com/privacy/#section-12
DPA – |
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
13. COMPANY GROUP STRUCTURE
| No. | Entity | Registration Details |
| 1 | Ergo Global Pte. Ltd. | Registration number 201838625E and registered office address at 74, South Bridge Road #02-01 Wong Shee Fun Building, Singapore 058704, doing business as Ergo Global. |
| 2 | Ergo Global Limited |
Registration number 671620 and registered office address at Geashill, Ballinlough, Dunshaughlin Co. Meath, Dunshaughlin, Meath. |
14. APPENDIX 1: PRODUCT-SPECIFIC TERMS
The following Product-Specific Terms apply to the Services and offerings specified below and supplement the Privacy Policy or another agreement entered between a user and Ergo Global. Capitalised terms used and not defined in this Appendix 1 have the meanings given to them in the Privacy Policy.
ErgoWOW AI Platform
While using our ErgoWOW AI web application, we use AI models at two points in the ergonomic assessment process: to power the chat assistant you interact with directly, and to analyse your workspace environment from your uploaded images and videos. This section describes both uses, the models involved, and the protections that apply.
1. Chat Assistant
Our ErgoWOW AI in-platform chat assistant is powered by Claude, an AI model developed by Anthropic. The assistant guides you through your ergonomic assessment, answers questions about your results, and provides personalised recommendations based on your assessment data. The assistant does not receive any identifiable information about you, such as your name, email address, account ID, or any other information that directly identifies you. Each request is processed as a standalone, anonymous interaction.
When you send a message, your chat input is transmitted alongside your assessment context, including your ergonomic scores, identified equipment, and workspace observations, to generate a relevant, personalised response.
The underlying AI model is provided by Anthropic. Anthropic does not receive your messages, does not have access to your assessment data.
Your Chat & Communication Data is not used to train AI models or improve any AI system.
Your chat transcript is stored in our own database and linked to your assessment record. Your conversation history is retained as part of your assessment record and is subject to the same retention and deletion rights as your other assessment data, as described in Section 10 “YOUR CHOICES AND LEGAL RIGHTS”.
Chat conversations may be reviewed by our team for quality assurance, safety monitoring, or where you raise a concern that requires human follow-up. Access is limited to authorised personnel and is subject to confidentiality obligations.
2. Workspace Analysis
We use Google’s Gemini model to assist with analysing your workspace environment, identifying equipment such as your chair, monitor, keyboard, and lighting conditions, as part of generating your ergonomic assessment.
Before any image or video frame is transmitted to Gemini, it undergoes a mandatory privacy-preserving transformation. Your body region is replaced with a neutral silhouette, and only a stylised skeleton overlay representing your joint positions is retained. Your face and body are completely masked.
Gemini receives the workspace image with this overlay, it never receives an identifiable image of you. Your name, email address, account ID, and all other personal identifiers are never included in any transmission to Gemini. The frame is sent without any information that could be used to identify you as an individual.
Your images and videos are not used to train or improve AI models.
Your original uploaded images and videos are deleted from our systems immediately after the redaction and analysis process completes. Only the redacted frame (the masked workspace image with skeleton overlay) is retained as part of your assessment record.
