Privacy Policy
Last updated: October 20, 2024
GENIENEXUS LTD is committed to safeguarding the privacy of all individuals who interact with
GENIENEXUS. In this Privacy Policy, when we use the term ‘we’ or ‘us’, it means GENIENEXUS
LTD, and its affiliates and other group companies. This Privacy Policy (together with our Terms of Use,
Promotion Rules and any other documents referred to in it or in the above documents) sets out how we
collect, use and manage your PI (“PI”) through GENIENEXUS’ website and services. In this context,
‘PI’ is data which relates to you, and which personally identifies you either directly or indirectly. This
Privacy Policy explains the basis on which any PI that we collect from you, or that you provide to us,
will be processed and used by GENIENEXUS. Please read this Privacy Policy carefully to understand
our views and practices regarding your PI and how we will treat it. By visiting genienexus.com (the
“Website”), you are accepting and consenting to this Privacy Policy.
Changes to this Privacy Policy: We may amend this Privacy Policy from time to time to make sure it
is up-to-date and accurate. Any changes we may make to our Privacy Policy will be posted on the
Website, and where appropriate, notified to you by email. Please check back frequently to see any
updates or changes to our Privacy Policy. We will assume that you agree to the Privacy Policy or revised
versions of the Privacy Policy if you continue to use the Website and online services after the effective
date shown at the top of the Privacy Policy.
Data Controller: For the purpose of the Data Protection Act 2018, General Data Protection Regulation
2018 and the Privacy and Electronic Communications Regulations (the “Legislation”), the data
controller is GENIENEXUS LTD. Fountain Street House, Fountain Street, Ulverston, Cumbria, LA12
7EQ, UK. Registration Number: Z1333679.
Data Protection Officer: We have appointed a Data Protection Officer who is responsible for
overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy
Policy, including any requests to exercise your legal rights, please contact our Data Privacy Manager
using the details set out below. Our full details are:
Full name of legal entity: GENIENEXUS LTD
Email address: info@genienexus.com
Postal address: 91 Waterloo Road, SE1 8RT, London, UK
Your right to complain: You have the right to complain at any time to the Information Commissioner’s
Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,
however, appreciate the opportunity to respond to your concerns before you approach the ICO.
How do we obtain your PI? We may collect and process the following data about you:
- Information you give us. You may give us PI about you by filling in forms on the Website or
by corresponding with us by phone, e-mail or otherwise. This includes information you provide
when you register to use the Website, subscribe to any of our services, participate in discussions
with us or with other users, enter a competition, promotion, survey or any other activity and
when you report a problem with the Website. The information you give us may include your
name, address, e-mail address and phone number, and financial and credit card information. - Information we collect about you. With regard to each of your visits to the Website, we may
automatically collect the following information:
o Technical information, including your Internet protocol (“IP”) address, your login
information, browser type and version, time zone, browser plug-in types and versions,
operating system and platform;
o Information about your visits, including the URL clickstream to, through and from the
Website (including date and time); pages and other items you viewed or searched for;
page response times, download errors, length of your visits to certain pages, page
interaction information (such as scrolling and clicks), and methods used to browse
away from the page and any phone number used to call our user service number.
PI that we collect and receive from third-parties
We may receive PI about you if you use any of the other websites we operate or the other services we
provide. We are also working closely with third parties (including, without limitations, business
partners, sub-contractors, technical and payment services and advertising networks) and may receive
information about you from them.
Examples of information collected: You provide information to us when you:
• Use any of our services (including joining any competitions or promotions);
• view or use the content on a device, or through any service or application on a device;
• provide information in your GENIENEXUS Account;
• configure your settings on, provide data access permissions for, or interact with the Website;
or
• communicate with us by phone, e-mail, or otherwise.
Following the above actions, you may provide us with information such as: your name; address and
phone number; payment information; age; location information; your IP address; addresses and phone
numbers, content included in e-mails to us; financial information and device log files.
Automatic information: Examples of information we collect and analyse include:
• Internet protocol (IP) address;
• Login, e-mail address and password;
• location of your device;
• information about your internet service provider (ISP) or other content interaction information;
• use history, which we sometimes aggregate with information from other users;
• URL clickstream to, through and from the Website (including date and time);
• Pages or content you viewed or searched for;
• response times, length of visits to certain pages, page interaction information (such as scrolling
and clicks).
How do we use your PI and on what basis do we process your PI? We have set out below, in a table
format, a description of all the ways we may use your PI, and which of the legal bases we rely on to do
so. Where appropriate, we have also identified our legitimate interests in processing such data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new user. | (a) Identity (b) Contact (c) Profile |
Performance of a contract with a user. |
| To confirm your identity and protect against money laundering activity. | (a) Identity (b) Contact (c) Profile |
Performance of a contract with a user. Necessary for our legitimate interests of ensuring user activity and payments are not fraudulent. |
| To process and deliver your activity, including managing payments, fees and charges. | (a) Identity (b) Contact (c) Financial (d) Transaction |
Performance of a contract with a user. |
| To carry out fraud assessments and credit risks to allow third parties to process your PI in order to protect against and detect fraud and other criminal activity. | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical |
Necessary for our legitimate interests of ensuring payments are not fraudulent. |
| To notify you in relation to our legal obligations and documents, including changes to our terms or Privacy Policy. | (a) Identity (b) Contact (c) Profile |
Necessary for our legitimate interests of ensuring our users are updated on these changes. Necessary for a legal requirement. |
| To help us improve our offering to our users, including asking you to leave a review or take a survey, or provide user insights. | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
Necessary for our legitimate interests (to study how users use the Website and services, to improve our offering to you, to develop new features and grow our business). |
| To enable you to partake in a prize draw or competition. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
Performance of a contract with a user to fulfill the promotion and run the competition/prize draw. We may also subsequently use your entries for the legitimate interest of understanding our user base more effectively. |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, maintenance, support, reporting and hosting). | (a) Identity (b) Contact (c) Profile (d) Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). |
| To deliver relevant website content, advertisements and other marketing material to you and measure or understand the effectiveness of the advertising we serve to you. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business to inform our marketing strategy and to improve our offering to users). |
| To use data analytics to improve the Website, products/services, marketing, user relationships and experiences. | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of users for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy). |
| To make suggestions and recommendations to users about services that may be of interest to you. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
With users’ consent (to develop our services and grow our business, and to improve our offering to users). |
| To comply with our legal obligations. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Financial |
Necessary to adhere to a legal requirement. |
| To display interest-based Advertising. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
With users’ consent (to develop our services, grow our business, and improve our offering to users). |
Cookies
The Website uses cookies to distinguish you from other users of the Website. This helps us to provide
you with a good experience when you browse the Website and also allows us to improve the Website.
For more information, please visit our Cookies Policy.
Interest-based Advertising
GENIENEXUS may display interest-based advertisements on the Website and on other, unaffiliated
websites. Interest-based advertising is displayed to users based on information collected from their
activities, including, without limitations, browsing or entering into competitions or other activities, on
or through the Website or on third party websites, or based on users’ responses to our marketing efforts
(collectively, the “Services”). For instance, users may see an advertisement on a GENIENEXUS or
third party website for products or services, based on information indicating such users’ interest in
similar products or services.
• Information collected: Pursuant to this Privacy Policy, the information collected and used for
interest-based advertising may contain the following, without limitation: age, gender, device
unique identity or other device identifiers and applicable settings, information about users’ use
of the Services or other websites, information about advertisements or our marketing emails
viewed by users.
• Third party technologies: Analytics tools and advertisements serving technologies may use
server log files, web beacons, cookies, tracking pixels and other technologies to collect the
above information. They may combine the information collected through our products and
Services with: (a) information collected from third party websites, products and services and/or
(b) with demographic, advertisement, market and other analytics data. In addition, some of
these technologies can sync or connect users’ behaviour across different websites, mobile apps
and devices. GENIENEXUS makes its best efforts to provide users with: (a) the list of third
parties whose advertisements serving technologies are used in its Services, (b) links to these
third parties’ own privacy policies according to which their technologies and services are used,
and (c) when available, a link to allow users to opt-out from these third parties’ services. Opting
out does not mean users will not see any ads; but rather that the advertising users will see may
be less relevant to their interests.
• Custom content: We may, depending on users’ preferences, also combine their PI with the
information they have independently provided to various third parties, in order to tailor
advertisements for them on our Services and/or on third party websites.
• Do not track: At this time, we adhere to the standards set out in this Privacy Policy.
Uses made of information. We use information held about users in the following ways:
Information Users Give to Us
• to carry out GENIENEXUS’ obligations arising from any contracts entered into between
GENIENEXUS and you and to provide you with the information, products and services that
you request from GENIENEXUS;
• to provide you with information about other goods and services GENIENEXUS offers that are
similar to those that you have already purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about goods or
services that GENIENEXUS feels may interest you. If you are an existing user, GENIENEXUS
will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to
you. If you are a new user, and where GENIENEXUS permits selected third parties to use your
data, GENIENEXUS (or they) will contact you by electronic means only if you have consented
to this.;
• to notify you about changes to GENIENEXUS’ service; and
• to ensure that content from the Website is presented in the most effective manner.
Information GENIENEXUS collects about you
• to administer the Website and for internal operations, including troubleshooting, data analysis,
testing, research, statistical and survey purposes;
• to improve the Website to ensure that content is presented in the most effective manner for you
and for your computer;
• to allow you to participate in interactive features of GENIENEXUS’ service when you choose
to do so; as part of GENIENEXUS’ efforts to keep the Website safe and secure;
• to measure or understand the effectiveness of advertising GENIENEXUS serves to you and
others, and to deliver relevant advertising to you; and
• to make suggestions and recommendations to you and other users of the Website about goods
or services that may interest you or them.
GENIENEXUS does not collect any special categories of PI about you (this includes details about your
race, your ethnicity, your religious or your philosophical beliefs, your sex life, your sexual orientation,
your political opinions, your trade union membership, information about your health and genetic and
biometric data). Nor do GENIENEXUS collect any information about criminal convictions and
offences.
Where GENIENEXUS needs to collect PI by law, or under the terms of a contract GENIENEXUS has
with you and you fail to provide that data when requested, GENIENEXUS may not be able to perform
the contract it has or is trying to enter into with you. In this case, GENIENEXUS may have to cancel a
service you subscribed to or ordered however, GENIENEXUS will notify you if this is the case at the
time.
Who we share your PI with. GENIENEXUS may share your PI with any member of its group, which
means its subsidiaries, its ultimate holding company and its subsidiaries, as defined in section 1159 of
the UK Companies Act 2006.
We may share your information with selected third parties including:
• Business partners, suppliers and sub-contractors for the performance of any contract
GENIENEXUS enters into with them or you.
• Advertisers and advertising networks that require the data to select and serve relevant adverts
to you and others. GENIENEXUS does not disclose information about identifiable individuals
to its advertisers, but it may provide them with aggregate information about its users.
GENIENEXUS may also use such aggregate information to help advertisers reach the kind of
audience they want to target. GENIENEXUS may use the PI it has collected from you to enable
it to comply with its advertisers’ wishes by displaying their advertisements to that target
audience. When GENIENEXUS shares PI with these companies it requires them to keep it safe,
and they must not use your PI for their own marketing purposes.
• Analytics and search engine providers that assist GENIENEXUS in the improvement and
optimisation of the Website.
We may disclose your PI to third parties:• In the event that GENIENEXUS sells or buys any business or assets, in which case
GENIENEXUS may disclose your PI to the prospective seller or buyer of such business or
assets. If the transfer or sale goes ahead, the organisation receiving your PI can use your data
in the same way as GENIENEXUS.
• If GENIENEXUS or substantially all of its assets are acquired by a third party, in which case
PI held by it about its users will be one of the transferred assets. If GENIENEXUS is under a
duty to disclose or share your PI in order to comply with any legal obligation, or in order to
enforce or apply its terms of use or terms and conditions of supply and other agreements; or to
protect the rights, property, or safety of GENIENEXUS, its users, or others. This includes
exchanging information with other persons or companies for the purposes of fraud protection
and credit risk reduction.
Cross-border transfers of your PI
Some GENIENEXUS partners and/or suppliers are based outside the European Economic Area (EEA).
The processing of your PI for the purposes of providing you with our services may involve a transfer
of data outside the EEA or to countries deemed to provide an adequate level of protection for PI by the
European Commission. GENIENEXUS will only transfer your PI from the European Economic Area
(EEA), United Kingdom or Switzerland to third countries, i.e. countries outside the EEA, on the basis
of appropriate safeguards or if otherwise authorised by applicable law. In other cases, GENIENEXUS
provides the necessary safeguards, e.g. through the conclusion of data protection contracts with the
recipients.
How long we keep your PI for
GENIENEXUS keeps your PI in accordance with its internal retention procedures, which are
determined by its legal, regulatory and professional obligations including applicable data protection
laws and in accordance with good practice. The retention periods may differ depending upon the nature
of the data GENIENEXUS holds and the reasons why its is holding it and are subject to change.
GENIENEXUS only keeps your PI for as long as it needs to. When your information is no longer
required, GENIENEXUS will delete it securely.
How we protect your PI
GENIENEXUS is committed to ensuring that your PI is kept secure. In order to protect your information
from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction
or accidental loss, GENIENEXUS has put in place appropriate technical, physical and managerial
procedures. All employees and any third parties we engage to process your information are obliged to
respect the confidentiality of your PI.
The data that GENIENEXUS collects from you may be transferred to and stored at, a destination inside
the European Economic Area (“EEA”). It may also be processed by staff operating inside the EEA who
work for GENIENEXUS or for one of its suppliers.
All information you provide to GENIENEXUS is stored on its secure servers. Any payment transactions
will be encrypted by GENIENEXUS using SSL technology. GENIENEXUS does not store payment or
credit card details nor does it share user details with any third parties other than for the purposes
previously described.
Where GENIENEXUS has given you (or where you have chosen) a password which enables you to
access your account or certain parts of the Website, you are responsible for keeping this password
confidential. GENIENEXUS asks you not to share your password with anyone. Unfortunately, the transmission of information via the internet cannot be completely secure. Although
GENIENEXUS will always do its best to protect your PI, it cannot guarantee the security of your data
transmitted to the Website; therefore, any transmission is at your own risk. Once GENIENEXUS has
received your information, it will use strict procedures and security features to try to prevent
unauthorised access.
Your rights under applicable laws
Access to information. The Legislation gives you the right to access information held about you. Your
right to access can be exercised in accordance with the Legislation.
You have the right to ask GENIENEXUS not to process your PI for marketing purposes. You can
exercise your right to prevent such processing by checking certain boxes on the forms we use to collect
your data if applicable or by contacting us at: info@genienexus.com. Under certain circumstances, you
have rights under data protection laws in relation to your PI. Please read below to find out more about
these rights.
Request access to your PI. This enables you to receive a copy of the PI we hold about you and to check
that we are lawfully processing it.
Request correction of the PI that we hold about you. This enables you to have any incomplete or
inaccurate data GENIENEXUS holds about you corrected, though it may need to verify the accuracy
of the new data you provide to GENIENEXUS.
Request the erasure of your PI. This enables you to ask us to delete or remove PI where there is no
good reason for GENIENEXUS continuing to process it. You also have the right to ask GENIENEXUS
to delete or remove your PI where you have successfully exercised your right to object to processing
(see below), where GENIENEXUS may have processed your information unlawfully or where it is
required to erase your PI to comply with local law. Please note however, that GENIENEXUS may not
always be able to comply with your request of erasure for specific legal reasons which will be notified
to you, if applicable, at the time of your request.
Object to processing of your PI where GENIENEXUS is relying on a legitimate interest (or those of a
third party) and there is something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have
the right to object where GENIENEXUS is processing your PI for direct marketing purposes. In some
cases, GENIENEXUS may demonstrate that it has have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request restriction of processing of your PI. This enables you to ask GENIENEXUS to suspend the
processing of your PI in the following scenarios: (a) if you want GENIENEXUS to establish the data’s
accuracy; (b) where GENIENEXUS’ use of the data is unlawful but you do not want GENIENEXUS
to erase it; (c) where you need GENIENEXUS to hold the data even if it no longer requires it as you
need it to establish, exercise or defend legal claims; or (d) you have objected to GENIENEXUS’ use of
your data but it needs to verify whether it has overriding legitimate grounds to use it.
Request the transfer of your PI to you or to a third party. GENIENEXUS will provide to you, or a
third party you have chosen, your PI in a structured, commonly used, machine-readable format. This
right only applies to automated information which you initially provided consent for GENIENEXUS to
use or where GENIENEXUS used the information to perform a contract with you.
Withdraw consent at any time where GENIENEXUS is relying on consent to process your PI.
However, this will not affect the lawfulness of any processing carried out before the consent was
withdrawn. If you withdraw your consent, GENIENEXUS may not be able to provide certain products or services to you. GENIENEXUS will advise you if this is the case at the time you withdraw your
consent.
If you wish to exercise any of the rights set out above, please contact us at: info@genienexus.com.
You will not have to pay a fee to access your PI (or to exercise any of the other rights). However,
GENIENEXUS may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, GENIENEXUS may have legitimate grounds to refuse to comply with your
request in these circumstances.
GENIENEXUS may need to request specific information from you to confirm your identity and ensure
your right to access your PI (or to exercise any of your other rights). This is a security measure to ensure
that PI is not disclosed to any person who has no right to receive it. GENIENEXUS may also contact
you to ask you for further information in relation to your request to speed up our response.
GENIENEXUS aims to respond to all legitimate requests within one month. Occasionally, it may take
longer than a month if your request is particularly complex or you have made more than one request.
In this case, GENIENEXUS will notify you and keep you updated.
Contact
For any questions or other inquiries regarding this Privacy Policy and your rights under the Legislation,
please contact us at: info@genienexus.com.