Personal Information” refers to information that may be reasonably associated with, linked to, or used to identify an individual, allowing that individual to be personally identified or contacted. Genea may collect Personal Information from individuals accessing or using the Site or Offerings. We may also collect Personal Information from users of the Offerings. The Personal Information we collect may be obtained automatically through the operation of the Site or Offerings or voluntarily through the use of the Site or Offerings. Examples of voluntary sources of Personal Information may include, registrations, responses, reviews, comments, confirmations, surveys, and emails, messages and other communications and interactions through the Site or Offerings. In addition to your name, the types of Personal Information we may collect from you are:

• E-mail address
• Work Contact information (including, address, zip code, country, and phone number)
• Password
• Domain name and Internet Protocol (IP) address
• Information about the device used to access our websites and product offerings
• Statistics regarding when and how you access to the Site or Offerings
• Information you may volunteer through your interactions with the Site or Offerings.

Genea may also obtain the following types of Personal Information from third parties:

• We obtain Personal Information collected by our customers (“Customers”) and uploaded through use of our Offerings
• We obtain the E-mail addresses of individuals from suppliers who use automated prospecting tools.

If you wish to apply for a job within the careers section of the Site, we will collect personal information about you such as name, email address, and phone number. We will also ask you to provide us with a cover letter and a resume. We use this information to contact you regarding the position in which you expressed interest, to determine whether or not you are qualified for the position and to contact you regarding setting up an interview.

We post customer testimonials/videos on our Site which may contain personal information. We do obtain the Customer’s consent via email prior to posting the testimonial or video to post their name along with it.

We post customer testimonials/videos on our Site which may contain personal information. We do obtain the Customer’s consent via email prior to posting the testimonial or video to post their name along with it.

Genea Mobile App Specifics

For users of our mobile applications, we may collect and use the following:

From Your Device:

• We collect all necessary information to identify and confirm that all users of the mobile application are authorized to have access to the application. We use the collected information to block access for all unauthorized users. Genea does NOT track user location. Genea uses a location geofence to wake the mobile app when it is within range of supported doors.

From Your Microphone:

• The mobile application supports speech recognition used for data collection. We do not record or store any speech.

From Your Camera:

• The mobile application creates photographs for validation of data collection. The photographs are stored on the Genea platform. We store all mobile application created photographs in a clearly identifiable, separate photo album. We only transfer the contents of that album to the Genea platform. We do not access any other photos on your device, period.

From Your SD Card/Internal Storage:

• The mobile application stores it’s configuration and collection data on your device using external and/or internal storage media. We do not read or access any storage media in your device for any other purpose.

From Your Calendar:

• The mobile application creates events to notify you of critical mobile application related events on your calendar in a clearly identifiable, custom calendar object. We do not interact with any other calendar object on your device in any way

Your Device May Notify Us:

• We are automatically notified of any critical errors that may occur during your usage of the mobile application . The notifications ensure a prompt resolution of any identified issues.

Genea may use the Personal Information we collect and obtain through the Site or Offerings as described in this Policy. YOU SHOULD NOT PROVIDE ANY PERSONAL INFORMATION THROUGH THE SITE OR OFFERINGS UNLESS YOU WOULD LIKE THAT INFORMATION TO BE USED IN ACCORDANCE WITH THIS POLICY. The Personal Information that Genea collects and obtains will only be used to provide the Site and the Offerings:

• Providing Customers with information regarding users and their use of the mobile application
• Providing Customers with the tools and services offered through the Site and Offerings
• Customizing and improving the Site and Offerings
• Providing maintenance, support, and service for the Site and Offerings
• Providing notices to Customers regarding the Site and Offerings
• Analyzing data and patterns regarding interactions with the Site and Offerings
• Developing additional tools, services, and functionality for the Site and Offerings
• Contacting Customers for information verification purposes

In addition to the other uses of Personal Information described in this Policy, we may share to third parties the Personal Information we collect and obtain in the following ways:

• Service Providers. We may share Personal Information regarding Users and Customers with third parties that help us provide various services relating to the Site or Offerings rather than performing the services ourselves. For example, we may contract with a third party to: (a) maintain and manage our databases; (b) to host our Site or Offerings; (c) assist us with Personal Information collection; (d) provide analysis or testing of our Site or Offerings; (e) to enhance or overlay Personal Information with other information and data obtained from third parties; (f) provide other services to assist us in our business, or (g) in conjunction with job applications.

You should not provide Genea with any information regarding medical or health conditions, race or ethnic origin, political opinions, religious or philosophical beliefs, financial or account data or other sensitive information in order to use the Site or Offerings. Genea does not need or want such sensitive information.

The Site and Offerings are intended for a general audience and are not directed to children under 16 years of age. Genea does not knowingly receive, collect, or obtain Personal Information from children under 16 years of age.

Though we make reasonable and appropriate efforts to preserve user privacy as stated in this Policy, we may need to disclose certain of your Personal Information of Customers or Users when we have a reasonable and good-faith belief that the disclosure is necessary to enforce the Genea Terms of Use for the Site and Offerings, to comply with a judicial proceeding, court order or other legal processes, to avoid injury to a third party, or to otherwise enforce or protect Genea’s rights under applicable law, including, without limitation, Genea’s intellectual property rights. In these situations, we will use reasonable efforts to provide notice of our disclosure to you if your information included is in the disclosure, to the extent permitted or possible under the circumstances.
We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

We provide Customers with a choice whether to receive certain emails or other messages through the Site and Offerings and the opportunity to ‘opt-out’ of having their Personal Information shared for certain purposes.

If a Customer no longer wishes to receive certain messages from Genea through the Site or Services or to have their Personal Information shared in the manner permitted by this Policy, they may seek to opt-out of receiving those messages from us or having their Personal Information shared in that manner. In some cases, opting out of receiving messages or having Personal Information shared will not affect the ability to use or access the Site or Offerings. However, some messages are necessary to the operation of the Site and Offerings. Likewise, some sharing of Personal Information is necessary to operate and provide the functionality for the Site and Offerings.

If a Customer wishes to opt-out of receiving these messages or of sharing Personal Information this manner, we may be required to limit or cancel their access to and use of the Site or Offerings. Note also that a User is required to contact the Customer offering use of our mobile application directly toh the mobile application. All opt-out requests to Genea can be made by contacting us opt-out of receiving emails or other messages from that Customer or throug at privacy@getgenea.com or our publicly-listed phone number. Note that it may take up to 10 days to remove contact information from our lists, so messages from us may continue for a time after a removal request is made.

We and our third party service providers use automated tracking technology, such as “cookies,” “Flash cookies,” and “web beacons,” to monitor and collect Information regarding interaction with the Site and Offerings. “Cookies” and “Flash cookies” include pieces of information in the form of small files that are placed on an individual’s computer or mobile device to allow us to recognize a particular computer or mobile device. “Web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images embedded in the Site or Offerings used to pass information from a particular computer to us.

We may use tracking technologies that expire once a web browser is closed or that persist and stay on a computer or mobile device until they are deleted. Most browsers will allow cookies to be erased from a computer or mobile device or to be blocked from the computer or device. Browsers may also enable receipt of a warning before a cookie is stored. Browsers or email software may also enable refusal of certain web beacons by adjusting the settings on the browser or email software. Please refer to the instructions or help screen for the browser or email software to learn more about these functions. On our Sites’ pages, a banner is displayed which allows you to choose to accept or decline cookies.

To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. All individuals have the right to access the personal information/data that we maintain about them. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to privacy@getgenea.com. If requested to remove data, we will respond within a reasonable timeframe. Your email should include adequate details of your request.

We will notify Customers of any changes to this Policy. Notification will be made by way of an email to Customers or by posting of the changes on our Site. Continued use of the Site or Offerings by a Customer after any change has become effective will constitute acceptance by that Customer of that change. Unless we seek and receive consent from a Customer, we will use the Personal Information we collect in accordance with the version of this Policy effective when the Personal Information was last collected. Customers may contact us as described above regarding any change to this Policy, including to prevent their Personal Information from being used pursuant to any change to this Policy.

Genea is committed to protect and secure your Personal Information. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your Personal Information will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to insure the safety and security of your Personal Information. This includes using at least industry standard security measures to protect the loss, misuse, and unintended alteration of the Personal Information under our control. All employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personally identifiable information on are kept in a secure environment.

If Genea elects, in its reasonable discretion, to transfer ownership or control of the Site or any Offering to a third party, whether or not in the context of an acquisition, merger, or reorganization, you consent, to the extent this is required, to the transfer of your Personal Information by Genea to that third party, provided that all use and sharing of your Information by that third party remains subject to the terms of this Policy and any applicable changes.

We are committed to protecting your privacy. If you have any comments or questions regarding our Privacy Policy, or Personal Information that we may be storing and using, please contact us at privacy@getgenea.com.

If you are a California resident (“Consumer”), you can exercise certain rights under the CCPA. The CCPA provides California residents with specific rights regarding their personal information. Depending on the capacity in which you provide your personal information to us, you may exercise your CCPA rights as outlined below:

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • For sales – the personal information categories that each category of recipient purchased; and
  • For disclosures for a business purpose – the personal information categories  that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Emailing us at privacy@getgenea.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

If we are unable to verify your identity based on your request, we will reach out to you for additional information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability 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 verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

GDPR expands the privacy rights of individuals based in the European Economic Area (“EEA”), and places new obligations on all organizations that handle personal information of these individuals. This section provides helpful information on your rights as an individual based in the EEA, and how and why we use your personal information.

Your Rights Under GDPR

• If you reside in the European Economic Area (“EEA”), you have the right as a data subject to exercise the following rights by contacting us via the email and postal address in Section 16 below:
• Right of access – you can request access to your personal information and information about how we process it
• Right to rectification – you can request to have your personal information corrected if it is inaccurate and/or outdated and to have incomplete personal information completed
• Right to withdraw consent – you can withdraw consent at any time if you have previously consented to a certain processing of your personal information (e.g., withdrawing consent previously given to send you marketing communications).
• Right to erasure (also known as the Right to be Forgotten) – you can request to have your personal information erased, where applicable (e.g., if personal information is no longer necessary in relation to the purposes for which it was collected/processed).
• Right to restriction of processing – you can restrict the processing of your personal information in certain situations (e.g., if the accuracy of your personal information is contested).
• Right to data portability – you have the right to receive your personal information electronically in a standard format to transmit it to another controller, where applicable (e.g., if processing is based on your consent).
• Right to object – you have the right to object to processing of your personal information
• Rights regarding automated individual decision making, including profiling – you have the right to not be subject to a decision based solely on automated individual decision making, including profiling.
• Right to lodge a complaint – you have the right to lodge a complaint with a data protection supervisory authority if you believe we are mishandling your personal information under the GDPR requirements.

Your personal information may be processed in countries outside of the EEA. Your personal information may be transferred to and stored by us in the United States and in other countries in which we operate. If your personal information is transferred outside the EEA, we will protect your data by ensuring the recipient has adequate levels of protection in place (e.g., executing Standard Contractual Clauses with the recipient).