Global Privacy Policy

Genesis Global Technology Limited is a company incorporated in England and Wales with registered number 09498568 whose registered address is 1-3 Dufferin Street, London, EC1Y 8NA.

Genesis Global Technology Limited, and our group of companies (“Genesis”, “we”, “us”, “our”) respects your privacy rights and is strongly committed to protecting your privacy online. Please read this Privacy Notice carefully to learn more about how we adhere to applicable law under EU GDPR  and the California Consumer Privacy Act and how we collect, store, use, disclose and transfer any information about you when you interact with us, or when you use any of our websites (“Sites“) or any related events, trade shows, sales or marketing, and/or if you use any of our products, services or applications (including any trial) (collectively the “Services”) in any manner.

Scope

This Privacy Notice covers our processing of your Personal Information as a data controller. For example, when you are accessing or using our Sites or Services or when you contact us in any manner. In these situations, we gather various types of information from our users, customers and business contacts including information that identifies you as an individual, including your name, address and online identifiers (“Personal Information”). Please see the Personal Information We Collect section below for more information.

This Privacy Notice is not intended to cover the processing of Personal Information, which our Customers acting as data controller, share with us as their service provider. For example, this applies to Personal Information our Customers hold about their Customers, which they may share or make accessible to us through the use of our Services. In these situations, we will only process your Personal Information as data processor on behalf of our Customers. Please contact the data controller directly or visit their website to learn more about how they handle your Personal Information.

1. Your Personal Information Rights and Controls

You have the right to be properly notified of the following:

Personal Information We Collect

The types of information we may collect directly from you include: 

• Contact information: name, username, email address, postal address, phone number, job title, as well as any other contact or other information you choose to provide us or upload to our systems in connection with the Services.
• Other Identifying Information: When you visit our Sites, we automatically collect certain information related to your device, such as your device’s IP address, referring website, which of our pages your device visited, and the time that your device visited our Site. 

How We Collect Personal Information and Data

We may collect any Personal Information that you choose to send to us or provide to us, for example, on our contact online form, by email or over the phone. If you contact us through the Sites, we will keep a record of our correspondence. We receive and store information you provide directly to us. For example, when you fill out a form through our websites, by email, or over the phone we collect Personal Information, such as name and e-mail address, to be able to contact you and/or send you information

We keep track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers, type of browser and performance metrics related to their use of the Services.

Log information – we log information about our customers and their users when you use one of the Services including Internet Protocol (“IP”) address.

Information collected by cookies and other similar technologies – we use various technologies to collect information, which may include saving cookies to users’ computers.

For further information, please see the section below headed “Cookies”.

1. Right to Access Your Information 

You have the right of access, correction, erasure and objection to the use of your Personal Information. If you wish to contact Genesis regarding its use of your Personal Information, or if you no longer would like Genesis to process your Personal Information, or if you would like Genesis to restrict its processing in any manner, please email Genesis Global Technology Limited at [email protected]

Access

To request a copy of your Personal Information and data from Genesis, please contact [email protected]

You have the right to request the following covering the 12 months immediately preceding your request:

• The specific pieces of personal information we have collected about you; 
• The categories of personal information that we have collected about you; 
• The categories of sources form which we collected the personal information ;
• The purpose for collecting or selling the personal information;
• The categories of personal information that we have disclosed about you, the purpose for disclosing such personal information and the categories of third parties with whom we disclosed such personal information; 

In addition, you may receive a copy of the Personal Information relating to you and information regarding Genesis’s processing of such Personal Information by applying to Genesis in writing using the address set out above. In such a case, Genesis will provide your Personal Information to you in a commonly used data format and you have the right to transmit that Personal Information to another data controller.

If you have any questions or concerns regarding our Privacy Notice or information we hold about you, please contact us at [email protected]

Rectification

You can contact the controller at the following address: [email protected]

Deletion

You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfil a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.

Please note that an erasure of your Personal Information or a restriction of the processing of your Personal Information may mean that Genesis will not be able to provide its services to you, either in whole or in part. If you contact Genesis, please note the specific information you would like Genesis to consult, correct, update or delete and include a copy of a proper identification. Requests to delete Personal Information will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on Genesis.

Your other rights

Further, you have the right to lodge a complaint to the data protection authority or similar body within your jurisdiction.

If you believe that Genesis has not complied with your data protection rights, you can complain to the Information Commissioner.

1. How we use your Personal Information

We will use the Personal Information we collect from you on our Sites for the following purposes:

• To administer our Sites, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
• To improve our Sites to ensure that content is presented in the most effective manner for you and for your computer;
• Analyze customers’ use of the Sites for trend monitoring, marketing, remarketing and advertising purposes;
• For purposes made clear to you at the time you submit your information – for example, to fulfill your contact request, to provide you with information you have requested about our Services; and
• As part of our efforts to keep our Sites safe and secure.

In doing so, we will rely on our legitimate interests to provide and improve our Sites for our visitors. To the extent you provide your information to enquire about our Services, we will process your information with the view to entering into a contract with you, or your organisation (in which case legitimate interests will apply). If you provide your consent to receive marketing communications, we will rely on your consent for the processing of your Personal Information for marketing purposes.

We will use the Personal Information we collect from our customers and their users in connection with the Services we provide for the following purposes:

• Set up a user account;
• Provide, operate and maintain the Services;
• Process and complete transactions, and send related information, including transaction confirmations and invoices;
• Manage our customers’ use of the Services, respond to enquiries and comments and provide customer service and support;
• Send technical alerts, updates, security notifications, and administrative communications; and
• Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities.

In doing so, our processing will generally be undertaken in accordance with our performance or entry into a contract with you, or your employer, including terms of use applicable to your use of the Site or Services. Our activities may also include broader processing activities on the basis of a legitimate interest relevant to our provision of Services to you (for example to understand your use of our Services, to respond to communications etc)., or processing necessary to comply with or enforce a legal obligation. The foregoing shall also apply to our processing of Personal Information relating to employees of our suppliers and broader business contacts, save that in those instances, we may be acting as customer in receipt of services. We may also use the information you send to us via our Sites and/or Services, to communicate with you via email and, possibly, other means, regarding products, services, offers, promotions and events we think may be of interest to you, if this is in accordance with your marketing preferences. However, you will always be able to opt-out of such communications at any time (see the Marketing Communications information under the “Your Rights Under Applicable Law” section below).

Purpose for using your Personal Information

We collect personal information identified in the lists above to communicate with you, for marketing and promotional purposes, to provide and improve our services. Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Your Rights” heading below.

1. Your rights under applicable Law

California Users Only: 

Your Privacy Rights 

The California Consumer Privacy Act of 2018 (“CCPA”), effective as of January 1, 2020, requires businesses that collect personal information of California residents to make certain disclosures regarding how they collect, use and disclose such information. 

This section addresses those requirements. For a description of all of our data collection, use and disclosure practices, please read this Privacy Notice in its entirety. 

Right to Notice 

You have the right to be properly notified of the following:

• Personal Information We Collect: Please review the section of this Privacy Policy titled [insert JUMPLINK 1] for more information about the personal information we collected about you in the past 12 months.
• Why We Collect Personal Information: Please review the section of this Privacy Policy titled [insert JUMPLINK 2] for more information on why we collect personal information about you in the past 12 months.
• How We Collect Personal Information: Please review the section of this Privacy Policy titled [insert JUMPLINK 3] for more information on how we collect personal information about you in the past 12 months.
• With Whom We Share Your Personal Information: Please review the section of this Privacy Policy titled [insert JUMPLINK 4] for more information on how we share personal information about you in the past 12 months.

Personal Information Collection, Sharing Data with Third Parties and Your Right to Opt out of Sale 

We do not rent or sell your Personal Information to anyone. We may share and disclose your information (including Personal Information) in the following limited circumstances which could be deemed a “sale” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)):

• Our Affiliates. We may share personal information with businesses controlling, controlled by, or under common control with Genesis.
• Our Service Providers. We share personal information with companies and organizations that perform services on our behalf, for example, companies that provide support services to us (such as credit card processing services, data storage services, and web hosting services) or that help us market our products and services (such as third-party marketing companies). These third parties are required by contract to use the personal information we share with them only to perform services on our behalf and to take commercially reasonable measures to protect the confidentiality and security of your personal information.
• Our Business Partners. Under some limited circumstances, we may share our mailing lists or other personal information collected through our sites with companies that are not our service providers and are not members of the Genesis family of businesses. For example, we may share your contact or demographic information with business partners who offer special discounts to qualified customers. Before we share your personal information with our business partners, we will offer you the opportunity to choose whether to have your information shared and used in this way. If you do not want us to share your personal information with our business partners, you may "opt-out" at any time by sending an email or writing to us at the address below.
• Law Enforcement, Courts, and other third parties to comply with laws, protect our rights, and the rights of others. We may disclose personal information when we, in good faith, believe disclosure is required to comply with the law, a court order or a subpoena. We may also disclose personal information to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.
• Aggregate Information. We may share aggregated demographic or survey information with third parties, but this information is in anonymous form and does not contain any Personal Information or data. The aggregate information that we share may include anonymous information that is captured through the use of cookies and other similar digital tracking technology.

We May Also Share Information

• As Described in A Privacy Notice. We reserve the right to disclose your personal information as described in any privacy notice posted on the Web page (or area) where you provide that information. By providing your personal information on that Web page you will be consenting to the disclosure of your personal information as described in that privacy notice.
• As Described in A Click-Through Agreement. We reserve the right to disclose your personal information as described in any click-through agreement (e.g., in the password-protected areas of our Site) to which you have agreed.
• Cookies and Similar Technologies. We use "cookies" and other Web technologies to collect information and support certain features of our sites. A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A session cookie expires immediately when you end your session. A persistent cookie stores information on the hard drive so when you end your session and return to the same website at a later date the cookie information is still available. For example, we may use these technologies to
  • collect information about the ways visitors use our sites – which pages they visit, which links they use, and how long they stay on each page;
  • to manage and determine the effectiveness of our marketing campaigns;
  • to support and improve the quality of the features and functionality of our sites – for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits to our sites; and
  • to personalize your experience when you use our site(s).

Generally, the information we collect using these Web technologies does not identify you personally. If, however, you have created a user identity, for example, by signing up to use a password-protected area on one of our sites, we may link the information we collect using Web technologies to other information that identifies you personally. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave a site. Although you are not required to accept our cookies when you visit our sites, if you set your browser to reject cookies, you may not be able to use all of the features and functionality of our sites.

We use Google Analytics on the Site to collect usage data, to analyze how users use the Site and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

California Consumer Rights 

California Law gives California residents the right to make the following requests with regard to certain information we collect about them, at no charge, two times every 12 months:

• The right to request a copy of personal information we collected or disclosed for a business purpose in the past 12 months;

• The right to request deletion of personal information we collected, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation); and

• The right to request that we disclose personal information we collect, use and disclose.

You can submit a copy, deletion or right-to-know request online by contacting us at [email protected] or by contacting us at [PHONE NUMBER]. We will verify that the information you submit [(which includes first name, last name, email address, company, and country/state)] matches our records before we fulfill the request. You may use an authorized agent to submit a consumer rights request on your behalf using the methods above, however, we will require the authorized agent to provide signed permission to submit the request on your behalf and may still contact you to confirm your identity and that this request was submitted with your permission. We do not discriminate against you for exercising your rights or offer you financial incentives related to the use of your personal information.

California’s Shine the Light Law

California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to request more information under the California Shine the Light law, you can email us on [email protected]. 

EEA and Switzerland Users Only: 

Your Privacy Rights

If you are a resident of the EEA, United Kingdom, or Switzerland you have the following data protection rights. You can exercise the rights listed below by emailing [email protected] :

• The right to access, correct, update, or request deletion of your personal information;

• The right to object to the processing of your personal information by asking us to restrict processing of your personal information or request portability of your personal information; and

• The right to withdraw your content at any time if we collected and processed your personal information with your consent

• Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent

Your Privacy Rights in Respect of Customer Content

If personal information pertaining to you as an individual has been submitted to the Service by or on behalf of a Genesis customer and you wish to exercise any data protection rights you may have in respect of that data under applicable law, including (as applicable) the right to access, port, correct, amend or delete such data, please inquire with the relevant Genesis customer directly. We have a limited ability to access Customer Content. However, if you wish to make your request directly to us, please provide the name of the Genesis customer who submitted your data to our Service. We will refer your request to that Genesis customer and will support them as needed in responding to your request within a reasonable timeframe.

If we transfer your information outside of your country, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this notice. Such measures may include by way of example, reliance on an adequacy decision, or entry into standard contractual clauses approved for use in your jurisdiction

1. Miscellaneous

Change of business ownership and control

We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Apart from the instances listed above, Personal Information will be disclosed or transferred to third parties only when required by law, or to exercise establish or defend our legal rights

Under 18

We do not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Information, please contact us at [email protected]

Storage

Genesis will store your Personal Information as long as it is reasonably necessary to fulfill the purposes for which it was collected (including, but not limited to, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).  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.

Do Not Track

Some internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform signals have not been adopted, we do not current process or respond to “Do Not Track” or “DNT” signals.

Marketing Communications

You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the unsubscribe link in the emails communications we send or by contacting us at [email protected] with the word “UNSUBSCRIBE” in the subject field of the email. If you have any account for our Services, we will still send you non-promotional communications.

Changes to this Privacy Policy

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. This Notice was last updated in July 2022.

Data Security

We use appropriate technical, organizational and administrative security measures to protect any information we hold in our records from loss, misuse, unauthorized access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. You agree to notify Genesis Global Technology Limited immediately of any unauthorized use of your account or password, or any other breach of security.

Cookies

Our Sites and some of our Services use different types of cookies and other similar tracking technologies (like web beacons, tags and scripts) to uniquely identify your browser and to gather information about how you interact with the Sites and Services. Please see our Cookie Notice for more information on why we use them and how you can better control their use.

1. How to Contact us

To exercise your access and delete rights as described above, please submit a consumer request related to your personal information to us by calling us at [PHONE NUMBER] or by emailing us on [email protected]. We will respond to you within a reasonable time and within the time limits established by applicable law. For your protection, we may ask you for additional information to verify your identity. 

For access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee as permitted by applicable law, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Complaints

In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your personal information. We ask that you kindly contact us at [PHONE NUMBER] or on [email protected] so that we have an opportunity to resolve your complaint.

Job Applicant Privacy Notice

As part of any recruitment process, Genesis Global Technology Limited (“Genesis”) collects and processes personal data relating to job applicants. Genesis is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Genesis collect?

Genesis collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration;
• whether or not you have a disability for which Genesis needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and

Genesis may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

Genesis may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. Genesis will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does Genesis process personal data?

Genesis needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, Genesis needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

Genesis has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Genesis to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. Genesis may also need to process data from job applicants to respond to and defend against legal claims.

Genesis may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

For some roles, Genesis is obliged to seek information about criminal convictions and offences. Where Genesis seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, Genesis may keep your personal data on file in case there are future employment opportunities for which you may be suited. Genesis will advise you before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Genesis will only share your data with third parties for the purposes of assessing your application for employment. This will be with authorised third parties that have been engaged by genesis such as professional advisors, external consultants, recruitment agencies etc. If you are successful in your application and we make an offer of employment, we will ask for your nominated referees and contact them in order to obtain references for you and we will use your name within that correspondence, and we may contact the Disclosure and Barring Service to undertake necessary criminal records checks (if required for the nature of the role).

Your data may be transferred outside the European Economic Area (EEA) with hiring managers or those participating in recruitment and selection processes as part of the recruitment process.

However, to ensure that your personal information does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

How does Genesis protect data?

Genesis takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Where we engage third parties to process personal data on our behalf or we share personal data with third parties, those third parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

For how long does Genesis keep data?

If your application for employment is unsuccessful, Genesis will hold your data on file for up to 12 months after the end of the relevant recruitment process. If you agree to allow Genesis to keep your personal data on file, genesis will hold your data on file for up to 12 months for consideration for future employment opportunities. At the end of that period [or once you withdraw your consent], your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file [and retained during your employment]. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Genesis during the recruitment process. However, if you do not provide the information, Genesis may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.

Global Privacy Policy

Genesis Global Technology Limited is a company incorporated in England and Wales with registered number 09498568 whose registered address is 1-3 Dufferin Street, London, EC1Y 8NA.

Genesis Global Technology Limited, and our group of companies (“Genesis”, “we”, “us”, “our”) respects your privacy rights and is strongly committed to protecting your privacy online. Please read this Privacy Notice carefully to learn more about how we adhere to applicable law under EU GDPR  and the California Consumer Privacy Act and how we collect, store, use, disclose and transfer any information about you when you interact with us, or when you use any of our websites (“Sites“) or any related events, trade shows, sales or marketing, and/or if you use any of our products, services or applications (including any trial) (collectively the “Services”) in any manner.

Scope

This Privacy Notice covers our processing of your Personal Information as a data controller. For example, when you are accessing or using our Sites or Services or when you contact us in any manner. In these situations, we gather various types of information from our users, customers and business contacts including information that identifies you as an individual, including your name, address and online identifiers (“Personal Information”). Please see the Personal Information We Collect section below for more information.

This Privacy Notice is not intended to cover the processing of Personal Information, which our Customers acting as data controller, share with us as their service provider. For example, this applies to Personal Information our Customers hold about their Customers, which they may share or make accessible to us through the use of our Services. In these situations, we will only process your Personal Information as data processor on behalf of our Customers. Please contact the data controller directly or visit their website to learn more about how they handle your Personal Information.

1. Your Personal Information Rights and Controls

You have the right to be properly notified of the following:

Personal Information We Collect

The types of information we may collect directly from you include: 

• Contact information: name, username, email address, postal address, phone number, job title, as well as any other contact or other information you choose to provide us or upload to our systems in connection with the Services.
• Other Identifying Information: When you visit our Sites, we automatically collect certain information related to your device, such as your device’s IP address, referring website, which of our pages your device visited, and the time that your device visited our Site. 

How We Collect Personal Information and Data

We may collect any Personal Information that you choose to send to us or provide to us, for example, on our contact online form, by email or over the phone. If you contact us through the Sites, we will keep a record of our correspondence. We receive and store information you provide directly to us. For example, when you fill out a form through our websites, by email, or over the phone we collect Personal Information, such as name and e-mail address, to be able to contact you and/or send you information

We keep track of user activity in relation to the types of Services our customers and their users use, the configuration of their computers, type of browser and performance metrics related to their use of the Services.

Log information – we log information about our customers and their users when you use one of the Services including Internet Protocol (“IP”) address.

Information collected by cookies and other similar technologies – we use various technologies to collect information, which may include saving cookies to users’ computers.

For further information, please see the section below headed “Cookies”.

1. Right to Access Your Information 

You have the right of access, correction, erasure and objection to the use of your Personal Information. If you wish to contact Genesis regarding its use of your Personal Information, or if you no longer would like Genesis to process your Personal Information, or if you would like Genesis to restrict its processing in any manner, please email Genesis Global Technology Limited at [email protected]

Access

To request a copy of your Personal Information and data from Genesis, please contact [email protected]

You have the right to request the following covering the 12 months immediately preceding your request:

• The specific pieces of personal information we have collected about you; 
• The categories of personal information that we have collected about you; 
• The categories of sources form which we collected the personal information ;
• The purpose for collecting or selling the personal information;
• The categories of personal information that we have disclosed about you, the purpose for disclosing such personal information and the categories of third parties with whom we disclosed such personal information; 

In addition, you may receive a copy of the Personal Information relating to you and information regarding Genesis’s processing of such Personal Information by applying to Genesis in writing using the address set out above. In such a case, Genesis will provide your Personal Information to you in a commonly used data format and you have the right to transmit that Personal Information to another data controller.

If you have any questions or concerns regarding our Privacy Notice or information we hold about you, please contact us at [email protected]

Rectification

You can contact the controller at the following address: [email protected]

Deletion

You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfil a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation.

Please note that an erasure of your Personal Information or a restriction of the processing of your Personal Information may mean that Genesis will not be able to provide its services to you, either in whole or in part. If you contact Genesis, please note the specific information you would like Genesis to consult, correct, update or delete and include a copy of a proper identification. Requests to delete Personal Information will be subject to any applicable legal and ethical reporting or document filing or retention obligations imposed on Genesis.

Your other rights

Further, you have the right to lodge a complaint to the data protection authority or similar body within your jurisdiction.

If you believe that Genesis has not complied with your data protection rights, you can complain to the Information Commissioner.

1. How we use your Personal Information

We will use the Personal Information we collect from you on our Sites for the following purposes:

• To administer our Sites, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
• To improve our Sites to ensure that content is presented in the most effective manner for you and for your computer;
• Analyze customers’ use of the Sites for trend monitoring, marketing, remarketing and advertising purposes;
• For purposes made clear to you at the time you submit your information – for example, to fulfill your contact request, to provide you with information you have requested about our Services; and
• As part of our efforts to keep our Sites safe and secure.

In doing so, we will rely on our legitimate interests to provide and improve our Sites for our visitors. To the extent you provide your information to enquire about our Services, we will process your information with the view to entering into a contract with you, or your organisation (in which case legitimate interests will apply). If you provide your consent to receive marketing communications, we will rely on your consent for the processing of your Personal Information for marketing purposes.

We will use the Personal Information we collect from our customers and their users in connection with the Services we provide for the following purposes:

• Set up a user account;
• Provide, operate and maintain the Services;
• Process and complete transactions, and send related information, including transaction confirmations and invoices;
• Manage our customers’ use of the Services, respond to enquiries and comments and provide customer service and support;
• Send technical alerts, updates, security notifications, and administrative communications; and
• Investigate and prevent fraudulent activities, unauthorized access to the Services, and other illegal activities.

In doing so, our processing will generally be undertaken in accordance with our performance or entry into a contract with you, or your employer, including terms of use applicable to your use of the Site or Services. Our activities may also include broader processing activities on the basis of a legitimate interest relevant to our provision of Services to you (for example to understand your use of our Services, to respond to communications etc)., or processing necessary to comply with or enforce a legal obligation. The foregoing shall also apply to our processing of Personal Information relating to employees of our suppliers and broader business contacts, save that in those instances, we may be acting as customer in receipt of services. We may also use the information you send to us via our Sites and/or Services, to communicate with you via email and, possibly, other means, regarding products, services, offers, promotions and events we think may be of interest to you, if this is in accordance with your marketing preferences. However, you will always be able to opt-out of such communications at any time (see the Marketing Communications information under the “Your Rights Under Applicable Law” section below).

Purpose for using your Personal Information

We collect personal information identified in the lists above to communicate with you, for marketing and promotional purposes, to provide and improve our services. Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.  In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “Your Rights” heading below.

1. Your rights under applicable Law

California Users Only: 

Your Privacy Rights 

The California Consumer Privacy Act of 2018 (“CCPA”), effective as of January 1, 2020, requires businesses that collect personal information of California residents to make certain disclosures regarding how they collect, use and disclose such information. 

This section addresses those requirements. For a description of all of our data collection, use and disclosure practices, please read this Privacy Notice in its entirety. 

Right to Notice 

You have the right to be properly notified of the following:

• Personal Information We Collect: Please review the section of this Privacy Policy titled [insert JUMPLINK 1] for more information about the personal information we collected about you in the past 12 months.
• Why We Collect Personal Information: Please review the section of this Privacy Policy titled [insert JUMPLINK 2] for more information on why we collect personal information about you in the past 12 months.
• How We Collect Personal Information: Please review the section of this Privacy Policy titled [insert JUMPLINK 3] for more information on how we collect personal information about you in the past 12 months.
• With Whom We Share Your Personal Information: Please review the section of this Privacy Policy titled [insert JUMPLINK 4] for more information on how we share personal information about you in the past 12 months.

Personal Information Collection, Sharing Data with Third Parties and Your Right to Opt out of Sale 

We do not rent or sell your Personal Information to anyone. We may share and disclose your information (including Personal Information) in the following limited circumstances which could be deemed a “sale” as defined by the CCPA (Cal. Civ. Code 1798.140(t)(1)):

• Our Affiliates. We may share personal information with businesses controlling, controlled by, or under common control with Genesis.
• Our Service Providers. We share personal information with companies and organizations that perform services on our behalf, for example, companies that provide support services to us (such as credit card processing services, data storage services, and web hosting services) or that help us market our products and services (such as third-party marketing companies). These third parties are required by contract to use the personal information we share with them only to perform services on our behalf and to take commercially reasonable measures to protect the confidentiality and security of your personal information.
• Our Business Partners. Under some limited circumstances, we may share our mailing lists or other personal information collected through our sites with companies that are not our service providers and are not members of the Genesis family of businesses. For example, we may share your contact or demographic information with business partners who offer special discounts to qualified customers. Before we share your personal information with our business partners, we will offer you the opportunity to choose whether to have your information shared and used in this way. If you do not want us to share your personal information with our business partners, you may "opt-out" at any time by sending an email or writing to us at the address below.
• Law Enforcement, Courts, and other third parties to comply with laws, protect our rights, and the rights of others. We may disclose personal information when we, in good faith, believe disclosure is required to comply with the law, a court order or a subpoena. We may also disclose personal information to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.
• Aggregate Information. We may share aggregated demographic or survey information with third parties, but this information is in anonymous form and does not contain any Personal Information or data. The aggregate information that we share may include anonymous information that is captured through the use of cookies and other similar digital tracking technology.

We May Also Share Information

• As Described in A Privacy Notice. We reserve the right to disclose your personal information as described in any privacy notice posted on the Web page (or area) where you provide that information. By providing your personal information on that Web page you will be consenting to the disclosure of your personal information as described in that privacy notice.
• As Described in A Click-Through Agreement. We reserve the right to disclose your personal information as described in any click-through agreement (e.g., in the password-protected areas of our Site) to which you have agreed.
• Cookies and Similar Technologies. We use "cookies" and other Web technologies to collect information and support certain features of our sites. A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. A session cookie expires immediately when you end your session. A persistent cookie stores information on the hard drive so when you end your session and return to the same website at a later date the cookie information is still available. For example, we may use these technologies to
  • collect information about the ways visitors use our sites – which pages they visit, which links they use, and how long they stay on each page;
  • to manage and determine the effectiveness of our marketing campaigns;
  • to support and improve the quality of the features and functionality of our sites – for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits to our sites; and
  • to personalize your experience when you use our site(s).

Generally, the information we collect using these Web technologies does not identify you personally. If, however, you have created a user identity, for example, by signing up to use a password-protected area on one of our sites, we may link the information we collect using Web technologies to other information that identifies you personally. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave a site. Although you are not required to accept our cookies when you visit our sites, if you set your browser to reject cookies, you may not be able to use all of the features and functionality of our sites.

We use Google Analytics on the Site to collect usage data, to analyze how users use the Site and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

California Consumer Rights 

California Law gives California residents the right to make the following requests with regard to certain information we collect about them, at no charge, two times every 12 months:

• The right to request a copy of personal information we collected or disclosed for a business purpose in the past 12 months;

• The right to request deletion of personal information we collected, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation); and

• The right to request that we disclose personal information we collect, use and disclose.

You can submit a copy, deletion or right-to-know request online by contacting us at [email protected] or by contacting us at [PHONE NUMBER]. We will verify that the information you submit [(which includes first name, last name, email address, company, and country/state)] matches our records before we fulfill the request. You may use an authorized agent to submit a consumer rights request on your behalf using the methods above, however, we will require the authorized agent to provide signed permission to submit the request on your behalf and may still contact you to confirm your identity and that this request was submitted with your permission. We do not discriminate against you for exercising your rights or offer you financial incentives related to the use of your personal information.

California’s Shine the Light Law

California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to request more information under the California Shine the Light law, you can email us on [email protected]. 

EEA and Switzerland Users Only: 

Your Privacy Rights

If you are a resident of the EEA, United Kingdom, or Switzerland you have the following data protection rights. You can exercise the rights listed below by emailing [email protected] :

• The right to access, correct, update, or request deletion of your personal information;

• The right to object to the processing of your personal information by asking us to restrict processing of your personal information or request portability of your personal information; and

• The right to withdraw your content at any time if we collected and processed your personal information with your consent

• Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent

Your Privacy Rights in Respect of Customer Content

If personal information pertaining to you as an individual has been submitted to the Service by or on behalf of a Genesis customer and you wish to exercise any data protection rights you may have in respect of that data under applicable law, including (as applicable) the right to access, port, correct, amend or delete such data, please inquire with the relevant Genesis customer directly. We have a limited ability to access Customer Content. However, if you wish to make your request directly to us, please provide the name of the Genesis customer who submitted your data to our Service. We will refer your request to that Genesis customer and will support them as needed in responding to your request within a reasonable timeframe.

If we transfer your information outside of your country, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this notice. Such measures may include by way of example, reliance on an adequacy decision, or entry into standard contractual clauses approved for use in your jurisdiction

1. Miscellaneous

Change of business ownership and control

We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.

Apart from the instances listed above, Personal Information will be disclosed or transferred to third parties only when required by law, or to exercise establish or defend our legal rights

Under 18

We do not knowingly collect or solicit Personal Information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us Personal Information, please contact us at [email protected]

Storage

Genesis will store your Personal Information as long as it is reasonably necessary to fulfill the purposes for which it was collected (including, but not limited to, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).  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.

Do Not Track

Some internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform signals have not been adopted, we do not current process or respond to “Do Not Track” or “DNT” signals.

Marketing Communications

You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the unsubscribe link in the emails communications we send or by contacting us at [email protected] with the word “UNSUBSCRIBE” in the subject field of the email. If you have any account for our Services, we will still send you non-promotional communications.

Changes to this Privacy Policy

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. This Notice was last updated in July 2022.

Data Security

We use appropriate technical, organizational and administrative security measures to protect any information we hold in our records from loss, misuse, unauthorized access, disclosure, alteration and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Among other practices, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. You agree to notify Genesis Global Technology Limited immediately of any unauthorized use of your account or password, or any other breach of security.

Cookies

Our Sites and some of our Services use different types of cookies and other similar tracking technologies (like web beacons, tags and scripts) to uniquely identify your browser and to gather information about how you interact with the Sites and Services. Please see our Cookie Notice for more information on why we use them and how you can better control their use.

1. How to Contact us

To exercise your access and delete rights as described above, please submit a consumer request related to your personal information to us by calling us at [PHONE NUMBER] or by emailing us on [email protected]. We will respond to you within a reasonable time and within the time limits established by applicable law. For your protection, we may ask you for additional information to verify your identity. 

For access requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee as permitted by applicable law, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Complaints

In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your personal information. We ask that you kindly contact us at [PHONE NUMBER] or on [email protected] so that we have an opportunity to resolve your complaint.

Job Applicant Privacy Notice

As part of any recruitment process, Genesis Global Technology Limited (“Genesis”) collects and processes personal data relating to job applicants. Genesis is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does Genesis collect?

Genesis collects a range of information about you. This includes:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration;
• whether or not you have a disability for which Genesis needs to make reasonable adjustments during the recruitment process;
• information about your entitlement to work in the UK; and

Genesis may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

Genesis may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks. Genesis will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does Genesis process personal data?

Genesis needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, Genesis needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the UK before employment starts.

Genesis has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows Genesis to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job. Genesis may also need to process data from job applicants to respond to and defend against legal claims.

Genesis may process information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. This is to carry out its obligations and exercise specific rights in relation to employment.

For some roles, Genesis is obliged to seek information about criminal convictions and offences. Where Genesis seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, Genesis may keep your personal data on file in case there are future employment opportunities for which you may be suited. Genesis will advise you before it keeps your data for this purpose and you are free to withdraw your consent at any time.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

Genesis will only share your data with third parties for the purposes of assessing your application for employment. This will be with authorised third parties that have been engaged by genesis such as professional advisors, external consultants, recruitment agencies etc. If you are successful in your application and we make an offer of employment, we will ask for your nominated referees and contact them in order to obtain references for you and we will use your name within that correspondence, and we may contact the Disclosure and Barring Service to undertake necessary criminal records checks (if required for the nature of the role).

Your data may be transferred outside the European Economic Area (EEA) with hiring managers or those participating in recruitment and selection processes as part of the recruitment process.

However, to ensure that your personal information does receive an adequate level of protection we have put in place appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection.

How does Genesis protect data?

Genesis takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

Where we engage third parties to process personal data on our behalf or we share personal data with third parties, those third parties do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

For how long does Genesis keep data?

If your application for employment is unsuccessful, Genesis will hold your data on file for up to 12 months after the end of the relevant recruitment process. If you agree to allow Genesis to keep your personal data on file, genesis will hold your data on file for up to 12 months for consideration for future employment opportunities. At the end of that period [or once you withdraw your consent], your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file [and retained during your employment]. The periods for which your data will be held will be provided to you in a new privacy notice.

Your rights

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to Genesis during the recruitment process. However, if you do not provide the information, Genesis may not be able to process your application properly or at all.

Automated decision-making

Recruitment processes are not based solely on automated decision-making.