Genos North America, Inc. Notice of Privacy Policy Practices

Introduction


This Privacy Policy and Data Protection Policy outlines how Genos North America, Inc. (“GNA,” or “we” or “our,” as applicable) collects, uses, discloses, and protects the personal information we collect in the course of performing our business functions and activities through the use of our website, genosnorthamerica.com (“Site”), applications such as genossurveys.com (“Surveys Application”), and through email, text, and any other electronic communications between you and GNA, including but not limited to accessing any products and services offered by and through GNA (together defined herein as “Genos Products”). We are committed to safeguarding the protection and privacy of the personal information we collect and do so in accordance with

Privacy Act U.S.C. 552a (Privacy Act of USA) and any applicable state privacy laws

Australian Privacy Principles contained in the Privacy Act 1988

General Data Protection Regulation (GDPR), applicable in Europe

Privacy Act 2020 of New Zealand

GNA respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy (“Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit our Site, use or access Surveys Application, or respond to GNA communications as well as our practices for collecting, using, maintaining, storing, protecting, and disclosing that information. 


This Policy generally applies to information we collect, which may encompass any or all of the following, as may be applicable: from you or your legal guardian on or through our Site or Surveys Application; in email, text, and other electronic messages between you and our Site or Surveys Application; in any third party applications you may have specifically consented to use, whose terms of service or privacy policy you may have agreed to separately; through printed documents, records, and materials; and if you interact with our advertising, marketing, and applications on any third-party websites and services, if those applications or advertising include links to this policy through a certain third party application (“modal”), with which you agree to share limited personal information so that GNA may assist you with GNA account set-up and send marketing emails to you. The provision of this information may also be called “User Contributions” where applicable in this notice of privacy practices. 


It would not apply to information we collect -- offline or through any other means, including on any other website operated by GNA or any third-party; or through most third-party websites or applications, including through any application or content (including advertising or marketing) that may link to or be accessible from or on the Site or in the Surveys Application.


Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you are not permitted to use our Site or Surveys Application. By accessing or using our Site or Surveys Application, you will then have been deemed to have agreed to the terms and conditions of this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Site or Surveys Application after we make changes shall constitute your acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 18


Except for any specific Genos Products tailored for individuals who are 16 or 17 years of age, our Surveys Application and Site are not intended for children under the age of 18. We reserve the right to remove any unauthorized or unnecessary information provided by a child under the age of 18 if we become aware of it. Parents and legal guardians are welcome to provide information on behalf of children under 18 so long as the Parents and legal guardians are overseeing the process. 


Information We Collect About You and How We Collect It


We may collect different types of information about you, including information that may directly identify you or be used to identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we may collect directly from you or through automated collection technologies.


This also includes information collected using a modal only after you agree to such access. 


Generally


We may collect several types of personal information from and about users of our Surveys Application and Site, specifically information: 


by which you may be personally identified, such as name; home, shipping, and postal address; e-mail address; home and mobile telephone number; credit card, debit card, or other payment information (solely for payment purposes); date of birth; information that is about you but individually does not identify you, such as statistical and other communication data and the resources that you access and use on the Site and in the Surveys Applications; and/or about your internet connection and the equipment you use to access our Site and Surveys Application and usage details.


We may collect this information: 


directly from you when you provide it to us; automatically as you navigate through the Site or use the Surveys Application and the information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and from third parties, for example, our business partners.


Information You Provide to Us


The information and data we collect on or through our Site and Surveys Application are: 


information that you voluntarily provide by filling in forms on our Site and Surveys Application. This includes information provided at the time of registering to use our Site or Surveys Application, subscribing to our services, posting any material, or requesting further services; when you report a problem with our Site or Surveys Application; records and copies of your correspondence (including email addresses), if you contact us; your responses to surveys that we might ask you to complete for research purposes; and details of transactions you carry out through our Surveys Application and Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Site or our Surveys Application.


The personal information we may collect from you is collected with your consent and required for us to provide you with Genos Products. You may withdraw your consent at any time by terminating your relationship with us; however, we may no longer be able to provide you with our goods and services if you do.


You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Site or transmitted to other users of the Site or third parties (collectively, “User Contributions”). Any such User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share any User Contributions. Therefore, we cannot and do not guarantee that any such User Contributions will not be viewed by unauthorized persons.


Information We Collect Through Automatic Data Collection Technologies


As you navigate through and interact with our Surveys Application and Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, such as: details of your visits to our Site or use of our Surveys Application, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Site or use of our Surveys Application, error information, clickstream data, and other communication data and the resources that you access and use on the Site or in the Surveys Application; and information about your computer and internet connection, such as your IP address, operating system, and browser type.

 

The information we collect may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and Surveys Application and to deliver a better and more personalized service by enabling us to: estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Site and Surveys Application according to your individual interests; speed up your searches; and recognize you when you return to our Site or Surveys Application. Details about the automated data collection technologies and the specific cookies that we use can be found in our Cookie policy linked on our Site. 


Health Information


Though unlikely, we may process some personal information that you voluntarily provide which may also be considered sensitive when necessary to carry out our obligations to you. 


How We Use Your Information


We use any personal information you provide for various purposes described below, including to: 


provide our Surveys Application and Site to you; provide you with information you request from us; enforce our rights arising from contracts; notify you about changes; and provide you with notices about your account.


We use information that we collect or receive about you or that you provide to us, including any personal information: 


to present our Site and Surveys Application and their contents to you; to provide you with information, products, or services that your provider or you request from us; to fulfill any other lawful purpose for which you provide it; to provide you with notices about your relationship, including expiration and renewal notices; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; to notify you about changes to our Site or Surveys Application or any products or services we offer or provide though them; to allow you to participate in interactive features on our Site and Surveys Application; in any other way we may describe when you provide the information; and for any other purpose with your consent.


We may also use your information to contact you about and/or to promote and market our own goods and services that may be of interest to you. With your consent, we may also use your information to contact you through text and voice messages about and/or to promote and market these goods and services. If you wish to opt-out of such emails, you may do so by clicking the unsubscribe link in emails that we send you. You may also unsubscribe or change your choice regarding email, voice, and text communications by sending a written request to: 


GNA, Post Office Box 2523, Oldsmar, Florida 34677, Phone: 813-792-5000 

and via E-Mail: debbie.muno@genosinternational.com.


Disclosure of Your Information


We do not share, sell, or otherwise disclose your personal information for purposes other than those outlined in this Privacy Policy. We may disclose your personal information to a few third parties, including: 


our third-party service providers, subcontractors, and business associates we use to support our business; to any company we might merge with or acquire, or that buys us, or in the event of change in structure of our company of any form; to comply with our legal obligations; to enforce our rights; and with your consent.


We do not share, sell, or otherwise disclose your personal information for purposes other than those outlined in this Privacy Policy. However, we may disclose without restriction aggregated information about our users and information that does not identify any individual. 


We may disclose personal information that we collect or that you provide as described in this privacy policy: 


to our subsidiaries and affiliates; to contractors, service providers, subcontractors, and business associates, and other third parties we use to support our business; to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of GNA assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by GNA about our Site’s and Surveys Application’s users is among the assets transferred; to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide the information; or with your consent.


We may also disclose your personal information: 


to comply with any court order, law, or legal process, including to respond to any government or regulatory request; to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of you, your licensed provider and/or her/his staff, GNA, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.



Choices About How We Use and Disclose Your Information


We may offer you choices on how you can opt out of our use of tracking technology, disclosure of your personal information for third parties to market or advertise to you, our marketing or advertising to you, and other targeted marketing and advertising. We do not control the collection and use of your information collected by third parties. When possible, these organizations are under contractual obligations to maintain appropriate safeguards and protections, to use this data only for providing the services to us, and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes. 


In addition, we strive to provide you with choices regarding the personal information you provide to us. We will only use your contact information to promote or market our own products and services through electronic, voice, text or other means with your express consent. If you wish to consent to such use, you can check the relevant box located on the form on which we collect your personal information or otherwise seek such consent. by sending a written request to: 


GNA, Post Office Box 2523, Oldsmar, Florida 34677, or calling us at: 813-792-5000 for by emailing us at: debbie.muno@genosinternational.com.


We may also use your contact information to promote or market our products and services through email. If we have sent you a marketing or promotional email, you may click the unsubscribe link to be omitted from future email distributions. However, please note if you opt-out or unsubscribe, it may impact our ability to send important and necessary communications about Genos Products that you have purchased or accessed. By still opting out or unsubscribing, you agree that GNA will not be held responsible for any necessary communications that could not be issued due to you opting-out or unsubscribing. 


Accessing and Updating Your Personal Information


You may access, update or otherwise request changes to any personal information by notifying us through the Contact Information (located further below in this Privacy Policy) of any updates, changes or errors in any personal information we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.


Do Not Track Signals


We reserve the right to use automated data collection technologies to track you across websites. Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Site is not designed to respond to “Do Not Track” signals received from browsers.


Data Security


Information transmitted over the Internet is not completely secure, but we do our best to protect your personal information. You can help protect your personal information and other information by keeping your password to our Surveys Application confidential. 


We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and any personal information will be encrypted when being communicated between us and you.


The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Surveys Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information on the Site or in Surveys Application like message boards and other areas where you may post photographs, videos or other content. The information you share in public areas may be viewed by any user of the Site.


Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or from our Surveys Application or Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site, the Surveys Application, or the operating system of your computer or mobile device.


Changes to Our Privacy Policy


We will post any changes to our Privacy Policy on our Site. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.


We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Site’s home page/screen. If we make material changes to how we treat our users’ personal information, we will provide notification through a notice on the Site’s home page/screen. The date this Privacy Policy was last revised is identified at the bottom of the page. You are responsible for periodically visiting our Site and this Privacy Policy to check for any changes.


Contact Information


You may contact us through the contact information below. If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your personal information, or otherwise need to contact us, you may do so at:  


GNA, Post Office Box 2523, Oldsmar, Florida 34677, Phone: (813)-792-5000

or E-Mail us at debbie.muno@genosinternational.com.



Your California Privacy Rights


California Consumer Privacy Act (CCPA). While this Privacy Policy comprehensively describes how GNA and uses personal information about you, the CCPA provides some California residents the opportunity to exercise specific rights relating to data transparency, outlined below.


Right to Know


At your request, GNA will inform you of the categories of personal information we collect about you and the purposes for which those categories of personal information are used for the 12-month period preceding your request, including the following: the categories of personal information we have collected about you; the categories of sources from which your personal information is collected; the business or commercial purpose for collecting or selling your personal information; the categories of third parties with whom we share your personal information; and the specific pieces of personal information we have collected about you.


Right to Delete


You also have the right to request that GNA delete any personal information about you that we have collected from you. GNA will respond to a verifiable request from you to delete your data, except in circumstances where it is necessary for us to maintain your personal information in order to: complete the transaction for which your personal information was collected, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug our systems to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; if you have provided informed consent, 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 our deletion of the information is likely to render impossible or seriously impair the achievement of such research; to enable solely internal uses that are reasonably aligned with your expectations your relationship with us; or Comply with a legal obligation. To submit a requests under your right to know and right to delete, you must contact us at: GNA, Post Office Box 2523, Oldsmar, Florida 34677, Phone: (813) 792-5000 or via E-Mail: debbie.muno@genosinternational.com. From the time GNA verifies the request, we will respond within 45 days, and if additional time is needed, we will communicate extensions with you.


Other Rights


You have the right not to be discriminated against for exercising any of the rights listed above. GNA does not disclose personal information to third parties for their own direct marketing purposes.


Under 18: California Eraser Law Request


If you use our Site or Surveys Application when you are under the age of 18, you may request that we remove your User Contributions under certain circumstances. We do not advertise or market any goods and services that are identified as being inappropriate for children under the age of 18. California law permits minors under the age of 18 to request the removal of her/his User Contributions, subject to certain exceptions. 


If you are under the age of 18 and living in California, you may contact us by sending a written request to: GNA, Post Office Box 2523, Oldsmar, Florida 34677, Call us at: (813)-792-5000, or via email: debbie.muno@genosinternational.com (if you contact us in writing, via email, please use the subject “California Eraser Law Request”). 


We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor’s information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Site or Surveys Application, or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the Internet in the future. We do not advertise or market any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age.

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