GENESIS

Privacy and Cookies Policy

Genesis Global Technology Limited (“Genesis”) respects the privacy rights of our users and is strongly committed to protecting your privacy online. Please read this Privacy Notice carefully to learn more about how we collect, store, use, disclose and transfer any information about you when you interact or use any of our websites (“Site“) 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. We may change or update this Privacy Notice from time to time. However, your Personal Information will always be processed in accordance with the Privacy Notice that was in effect at the time of collection.

Scope

This Privacy Notice covers our processing of Personal Information when you are accessing or using our Site or Services or when you contact us in any manner. We gather various types of information from our users, including information that identifies you as an individual, including your name, address and online identifiers (“Personal Information“).

Data Collected

We may collect any Personal Information that you choose to send to us or provide to us, for example, on our contact online form. If you contact us through the Site, 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 website we collect Personal Information, such as name and e-mail address, to be able to contact you and/or send you information. The types of information we may collect directly from you include: 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.

When you visit the Site, 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. 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 “Use of Cookies”.

Our use of Data

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

  • To administer our Site, our events and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;
  • To improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
  • Analyze customers’ use of the Site 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 Site safe and secure.

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.

We may also use the information you send to us via the Site 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 Privacy Rights” section below).

By accessing the website you have given consent to the processing for a specific purpose (for example when you give consent in our contact form to enable us to contact you) or the processing is based on Genesis’s legitimate interest to process the Personal Information.

Cookies

“Cookies” are small pieces of information stored on your hard drive as small text files to allow that Site to recognize you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to store your preferences. This helps us to improve our Site and deliver a better and more personalized service.

Our Site 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 Site and Services. We use this information for the following purposes:

  • Assisting you in navigation;
  • Assisting in registration, login, and your ability to provide feedback;
  • Analyzing your use of our products, services or applications; and
  • Assisting with our promotional and marketing efforts.

You can set or amend your web browser controls to accept or reject cookies. If you choose to reject cookies, you can change your web browser’s settings to automatically deny the storage of cookies, or to inform you when a website wants to store cookies on your computer. Previously stored cookies can also be deleted through the web browser. More information can be found through your web browser’s support pages. You may still use our Site and Services, however your access to some functionality and areas of our Site or Services may be severely restricted. Please note that certain areas and functions on this Site require cookies and may not function if cookies are deleted or declined

Sharing Data and Third Parties

We do not rent or sell your Personal Information to anyone. We may share and disclose information (including Personal Information) about our customers only in the following limited circumstances:

Vendors, consultants and other service providers:

We may share your information with third party vendors, consultants and other service providers who we employ to perform tasks on our behalf. These companies include (for example) CRM service providers, email service providers, business-oriented social networks and others.

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.

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 are entirely responsible for maintaining the confidentiality of the information you hold for your account, including your password, and for any and all activity that occurs under your account as a result of your failing to keep this information secure and confidential. You agree to notify Genesis Global Technology Limited immediately of any unauthorized use of your account or password, or any other breach of security.

Transfer of Data

Some of the uses and disclosures mentioned in this Privacy Notice may involve the transfer of your Personal Information to various countries outside the European Union (“EU“). This section sets out the privacy principles we follow with respect to transfers of Personal Information outside of Europe. By submitting your Personal Information, you are agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, 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. If you use our Services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those Services.

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 privacy@genesis.global

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), whereby Genesis will retain your Personal Information for a period of time determined by Genesis based on the nature of the legal basis for processing your Personal Information. If the basis is consent, then we will only keep Personal Information on our ‘opt-out’ list to ensure that we do not contact you again.

Genesis may, instead of destroying or erasing your Personal Information, make it anonymous so that it cannot be associated with you or tracked back to you.

Your Rights

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

The controller of any Personal Information we hold about you is:

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

You can contact the controller at the following address: privacy@genesis.global

You have the right of access, correction 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 privacy@genesis.global

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.

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 privacy@genesis.global

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

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 marketing@genesis.global 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 are constantly trying to improve our Site and Services, so we may need to change these terms from time to time as well. However, your Personal Information will always be processed in accordance with the Privacy Notice that was in effect at the time of collection.

This Notice was last updated in July 2019

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

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your data on request;
  • require genesis to change incorrect or incomplete data;
  • require genesis to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
  • object to the processing of your data where genesis is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact privacy@genesis.global

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

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.