Published: 11 October 2026 · version 2026-10-11-3
Definitions
Subscription: A subscription is created for the Company.
Application: The Emplio measurement tool and selected additional modules.
Application Data: Data belonging to the User and processed in the Application, including information about the Company’s employees and their responses.
User: The person who has created an Emplio account.
Usage Data: Data generated through use of the Application, including technical and traffic information such as operating system, browser type, keyboard language and IP address, and aggregated operational figures such as session duration, number of surveys and number of employees in the account. Usage Data does not include employee responses or other Application Data.
Controller: The entity that determines the purposes and means of processing Personal Data.
Processor: The entity that processes Personal Data on behalf of the Controller.
Emplio Account: The account made available when a User is created.
Personal Data: Information relating to an identified person or information that can directly or indirectly identify a person.
Company: The company whose eNPS is processed in the Application.
1. Acceptance of the terms
1.1 A released version of these Terms is entered into through express acceptance with a record of the version and time. Publication alone does not amend existing agreements. During signup, an authorised representative may accept both these Terms and the Data Processing Agreement on behalf of the Company through one checkbox that explicitly names and links to both agreements. Acceptance is recorded with the version identifying both agreements. Acceptance of the Terms alone does not include the Data Processing Agreement.
1.2 These Terms apply between Emplio ApS, CVR no. 46460316, Rugmarken 21, 2860 Søborg, Denmark, and you as the User.
1.3 The Application is offered exclusively to businesses as a business-to-business service. Accordingly, there is no consumer right of withdrawal when purchasing subscriptions for your Emplio Account.
2. Duration of the Emplio Account
2.1 The agreement between the User and Emplio takes effect on account creation and continues until the user relationship ends in accordance with these Terms.
3. Use of the Application
3.1 Emplio grants the User non-exclusive access to the Application. Access is solely for the User and the User’s advisers. The Application may not be used by others or to process data or provide services for others. The User is fully responsible for persons to whom the User grants access or who use the User’s login.
3.2 When creating Companies under an Emplio Account, the User personally warrants that the User is legally authorised to accept these Terms on the Company’s behalf.
3.3 The User may not transfer the Emplio Account to a third party. A Company associated with the account may be transferred to another User with Emplio’s prior written consent.
3.4 The User must ensure that the Application is not used in a way that damages Emplio’s name, reputation or goodwill or breaches applicable legislation or regulation.
3.5 The User is solely responsible for the content and legality of the User’s data and must not transfer or process harmful code or data, such as viruses, into or through the software.
4. Subscription prices and payment
4.1 Current prices are available at emplio.io. Prices exclude VAT and are stated in Danish kroner (DKK).
4.2 Emplio reserves the right to change the composition, content and prices of products and subscriptions by notice by email or on its websites.
4.3 A Subscription renews automatically at the end of the subscription period unless cancelled.
4.4 Unless expressly agreed otherwise or stated in the subscription conditions, subscription fees are charged in advance for the selected period.
4.5 By entering into a subscription, the User authorises Emplio to charge the recurring subscription fee to the User’s payment card. Additional services and extended features are charged separately when used. An invoice for renewals and additional services is sent to the User’s registered email address.
5. Application Data
5.1 The User (the Company) is the Controller of Personal Data about employees and other persons entered, imported or collected in the Application. The User owns and may dispose of its own content. Emplio processes Personal Data as Processor on the User’s behalf and only on documented instructions under the data processing agreement between the User and Emplio (the Data Processing Agreement). The User is responsible for the legal grounds and for informing data subjects, including where a survey may contain health data.
5.2 Emplio processes identifiable Application Data solely on the Company’s documented instructions to provide, maintain and secure the agreed features and provide necessary support. Emplio does not use employee information for its own advertising, sales, marketing or model training.
5.3 Scores, measurement history and ordinary free-text comments are retained during the active customer relationship for as long as necessary for the Company’s documented purposes. These categories have no automatic age limit. The Company reviews necessity at least annually. Earlier deletion requirements and the shorter periods for other categories in the Data Processing Agreement continue to apply. After termination, only necessary wind-down processing and the periods in the Data Processing Agreement apply.
5.4 Disclosure of identifiable Application Data to third parties or authorities takes place only on documented instructions or under a specific legal requirement and in accordance with the Data Processing Agreement. Bankruptcy, death or similar circumstances do not in themselves provide general permission to disclose data.
5.5 The Data Processing Agreement takes precedence in a conflict concerning processing of Personal Data. General provisions on changes, licensing, assignment and liability do not override that agreement or mandatory data protection obligations.
5.6 AI processing through direct Google Cloud/Vertex AI in the EU requires the Company’s separate documented instructions and fulfilment of Appendix D of the Data Processing Agreement. Processing generates suggested management, HR and employee reports for ordinary workplace wellbeing and management follow-up. The entire dataset for the instructed report, including wellbeing figures, free-text responses and relevant, scoped report history, is processed automatically without prior manual review of responses. This does not include all Company data or the entire report archive. OpenRouter is not involved. Ordinary account creation, acceptance of terms or export does not itself constitute an AI instruction. Output requires human review and must not be used for automated decisions producing legal or similarly significant effects on employees. Planned WHO-5 and intended processing of health data require separate clarification under Appendix A. Appendices B and D govern suppliers, processing locations, logging and any transfers; EU model processing does not itself establish that all support and logging take place in the EU.
5.7 The absence of names and the use of group statistics do not guarantee anonymity. Technical links, teams, demographics, timestamps and comments may make individuals identifiable. The Company must accurately inform employees about processing and access.
5.8 Free text and unintended data: Emplio does not request health data or other special categories of personal data under GDPR Article 9. The purpose does not include collecting or analysing such data or handling sensitive individual cases. Before responses are submitted, the Company must instruct respondents not to enter health data or other sensitive data in free-text fields and to omit names and other identifying details about themselves or others. Free text may nevertheless unintentionally contain such data or criminal offence data. Predefined system instructions require the AI model to summarise only overarching work-related themes and omit sensitive data, individual cases and identifying information from the final report, as set out in C.5 of the Data Processing Agreement.
5.9 The system instructions are neither prescreening nor a guarantee of complete exclusion or anonymisation. Unintended sensitive data may be processed in raw data and AI input even if omitted from the report. Omission from output does not delete raw data or supplier copies. Respondent guidance and system instructions do not themselves provide a legal basis or an exception under Article 9. On becoming aware of specific data outside the instructions, Emplio restricts further use, including export and AI, and the DPO coordinates clarification with the Company without undue delay. The Company must give documented, lawful instructions on handling; rectification, restriction and deletion, and follow-up on reports and supplier copies, take place under C.5.1–C.5.2 of the Data Processing Agreement. This does not limit Emplio’s own data protection obligations.
The Data Processing Agreement is available in English at /en/databehandleraftale and in Danish at /da/databehandleraftale. It may be accepted together with these Terms through the explicit combined signup acceptance.
6. Usage Data
6.1 Emplio is Controller of Usage Data to the extent it contains Personal Data about the User, such as contact details, IP address and technical information, including a CVR number that can be linked to an individual.
6.2 Emplio may use Usage Data for operation, billing, statistics, analysis and development of the Application.
6.3 Emplio does not combine Usage Data with identifiable Application Data. Statistics used for Emplio’s own purposes contain no employee Personal Data and cannot be linked to individuals.
7. Service stability
7.1 Emplio seeks the highest possible service stability but disclaims liability for outages and operational disruption, including disruption caused by matters outside Emplio’s control, such as power failures, equipment failures and internet or telecommunications problems. The Application and service are provided as available, and Emplio disclaims warranties, representations and other terms, whether express or implied, subject to section 12.8.
7.2 In the event of disruption, Emplio seeks to restore normal operation as soon as possible.
7.3 Planned interruptions are preferably scheduled between 21:00 and 06:00 CET. Where interruption is necessary outside that period, advance notice will be given as far as possible.
8. Termination
8.1 The User may contact hi@emplio.io to request closure of the Emplio Account and cancellation of associated Subscriptions. Emplio verifies the authority and scope of the request. Account closure, subscription expiry and final data deletion are separate events. The termination date for the affected service is confirmed to the Company and starts the periods in the Data Processing Agreement. A specific earlier deletion instruction is handled under that agreement.
8.2 If a Subscription is cancelled or an account deleted during a subscription period, the User remains liable for payment until the Subscription expires. The User’s obligations under the agreement continue throughout the subscription period.
8.3 A Company on a Starter subscription may be considered inactive after 15 months without activity. Emplio may give at least one month’s notice by email of termination and closure of ordinary access, stating the termination date. Secure return and deletion then follow the Data Processing Agreement, including the six-month retrieval window where return is chosen. Inactivity does not permit this process to be bypassed.
8.4 Cancellation must be made through the Application or by contacting Emplio as described in section 8.1 no later than the day before a new subscription period begins.
8.5 If the User fails to pay, for example because of insufficient funds, Emplio may suspend access to the Company associated with the Subscription immediately after non-payment is recorded and until payment is made.
8.6 Emplio may terminate a Subscription on three months’ notice.
8.7 Emplio may terminate a Subscription without notice in the event of bankruptcy or insolvency of the associated Company.
8.8 A material breach of these Terms may result in immediate termination of Subscriptions and closure of the Emplio Account.
8.9 At termination, the customer chooses deletion or return followed by deletion. For return, an export is prepared at planned termination, otherwise without undue delay and within 14 calendar days. The customer may retrieve it for six months after termination. All active copies are deleted by the same six-month deadline and remaining backups within 12 months of termination. The periods run from the same date and are not cumulative. Earlier deletion requirements and shorter backup rotations take precedence. Ordinary use, surveys and AI analysis stop at termination; retrieval does not allow continued use of the Application. The full provisions are in section 9 and Appendix C of the Data Processing Agreement.
9. Changes
9.1 Emplio may update and improve the Application and change its structure and services. Changes affecting processing of Personal Data are subject to the Data Processing Agreement’s requirements for security, instructions, information and supplier approval. This provision does not permit changes to processing purposes or deletion of customer data contrary to the agreement.
9.2 The User must keep contact details up to date to receive necessary information about changes and other matters.
9.3 Emplio may amend these Terms where objectively justified by changes in law, security, technical conditions, functionality, suppliers or delivery costs. Changes must be proportionate and apply prospectively only. Individually negotiated terms require a separate agreement to change.
9.4 Material changes require at least 30 days’ notice by email to the Company’s registered contractual contact. An in-Application notice may supplement the email. The notice describes the change, reason, effective date and any termination right and provides a means to save the full new version. A popup or continued use does not in itself constitute new express acceptance.
9.5 For material changes detrimental to the Company, the Company may terminate the affected service without additional charges before the effective date, taking effect on that date despite any otherwise applicable minimum term. Prepaid fees for the remaining unused period will be refunded proportionately. Changes outside the agreed amendment power require a separate agreement.
9.6 Purely editorial corrections with no change in meaning may be made without advance notice. Where a binding legal requirement or urgent security risk necessitates shorter notice, changes are limited to what is necessary and the customer is informed as soon as possible with reasons. This does not permit unannounced commercial detriment.
9.7 Changes to the Data Processing Agreement, new AI or WHO-5 instructions and supplier approvals follow their own requirements. An updated privacy policy provides information and does not itself constitute consent or expand the legal basis for processing. This amendment clause applies only once validly agreed with the customer; publication does not amend previously concluded agreements.
10. Intellectual property
10.1 The Application and information produced by it, except Application Data, are protected by copyright and other intellectual property rights and belong to or are licensed to Emplio. Individually developed software also belongs to Emplio unless otherwise agreed in writing. The User must inform Emplio of any actual or potential infringement or unauthorised use of which the User becomes aware.
10.2 No intellectual property rights in the Application or other material on the website or Application are transferred to the User.
10.3 The User grants Emplio and approved suppliers the limited permission to use uploaded material and Application Data necessary to provide the agreed services. For Personal Data, permission is limited by the Data Processing Agreement and does not independently permit model training, marketing or international transfers. The User warrants that uploaded material does not infringe third-party rights or applicable law.
11. Assignment
11.1 Emplio reserves the right to assign its rights and obligations towards the User to a group company or a third party, subject to section 5.5.
12. Liability
12.1 Emplio disclaims liability relating to these Terms, services or use of the service, whether in contract or otherwise, including consequential or indirect loss and loss arising from ordinary negligence, subject to section 12.8.
12.2 Emplio is not responsible for third-party solutions available in or integrated with the Application, including the accuracy, completeness, quality or reliability of their information or results, or their availability, security or functionality and resulting damage or loss, subject to section 12.8. The User bears the burden of proving that a loss is not attributable to third-party solutions.
12.3 Regardless of the type of loss or basis of liability, Emplio’s total liability is limited to the User’s payments during the 12 months preceding the event giving rise to liability, and in all cases to a maximum of DKK 10,000, subject to section 12.8. The User agrees to indemnify Emplio for product liability damage, third-party losses and other third-party claims arising from use of the Application.
12.4 The User agrees to indemnify Emplio against claims or losses arising from product liability, third-party loss or liability towards third parties to the extent arising from the User’s use of the Application, subject to section 12.8.
12.5 Emplio is not responsible for outages or temporary interruptions, power or internet failures, vandalism including viruses and hacking, or other circumstances outside Emplio’s control, subject to section 12.8.
12.6 Reports, AI-generated suggestions, support and other communications from Emplio are guidance and require human review. AI output may contain errors and must not be the sole basis for significant decisions about employees. This does not limit Emplio’s data protection obligations.
12.7 Information on the website, in the Application or in additional products or services does not constitute legal, tax, accounting or other advice or services.
12.8 The exclusions in these Terms do not limit mandatory rights or liability under data protection law. They do not relieve Emplio of its obligations under the Data Processing Agreement or responsibility for approved subprocessors’ fulfilment of their data protection obligations.
13. Confidentiality and data security
13.1 Processing of Personal Data for which the Company is Controller is governed by the Data Processing Agreement between Emplio and the Company. Emplio’s processing as Controller is described in the privacy policy.
13.2 Emplio is subject to confidentiality regarding all information it obtains about the User.
13.3 Where the User provides information, usernames or passwords relating to third-party information or services, the User warrants that disclosure and Emplio’s processing do not infringe third-party rights or agreements. The User must indemnify Emplio for losses in connection with this provision, subject to section 12.8.
14. Changes to the Terms
14.1 Changes are notified with a clear version and effective date. A new text on the website does not itself constitute the customer’s acceptance. Changes to the Data Processing Agreement and separate AI or WHO-5 instructions require documented acceptance or instructions under the relevant agreement; silence or continued use is not converted into such acceptance.
15. Disputes
15.1 Disputes between the User and Emplio are governed by Danish law, with the Copenhagen City Court as the court of first instance.
16. Effective date
Version 2026-10-11-3 was published on 11 October 2026 and applies upon the Customer’s acceptance. Existing agreements change only under their agreed amendment procedure or separate acceptance; publication alone does not replace them.