1. WHO WE COLLECT PERSONAL INFORMATION FROM

We may collect personal information from the following groups of data subjects: visitors to, and users of, our online and mobile resources; our customers; and third-party vendors and business partners.

Personal information generally means information that can be used to identify you or that can be easily linked to you (for example, your name, address, telephone number, email address, social security number and date of birth). The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the consumers or data subjects they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act (“CCPA”) or other U.S. state-level data privacy laws, our use of the phrase “personal information” includes the unique elements required by such laws.

The categories of information we collect from each of these groups, and the ways in which we use it, differs. As you may have noticed, it’s possible that the same person could fall into more than one group. Most of this statement addresses our processing and sharing of personal information collected from visitors to and users of our online and mobile resources and our customers.

​In addition, like all corporate enterprises, we buy goods and services, lease equipment and office space and attend industry events. In doing so, we interact with many existing and potential vendors and business partners from whom we necessarily collect certain personal information in connection with our contractual and business relationships. As with our customers, this information is typically limited to minimum business contact information. We use and share personal information collected from our vendors and business partners to manage, administer and perform under our contracts with them, or share information about our products. We describe our use of vendor and business partner personal information in greater detail in our confidential contracts with those parties or on the internal vendor management portals we operate.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

4. WHEN/WITH WHOM DO WE SHARE PERSONAL INFORMATION
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We use non-personal information to administer our online and mobile resources, make them better, and to make business decisions about what programs our customers might like.

We use voluntarily provided personal information for our legitimate interests, including to respond to your inquiries and provide you with the services you have requested, amongst other uses as further described below. We do not sell or rent your personal information to third-party data vendors or marketing companies. As you might expect, we disclose your information when required by law. We may use your personal information when we have your consent to do so, where required or permitted under applicable law.

Affiliates.
In addition to those third-parties set forth above, we may share your information, including personal information, within our family of companies. Those companies will use such information in generally the same manner as we do under this privacy statement which includes sending you information about their products, services, or initiatives that may be of interest to you.

Legally Compelled Disclosures.
We may disclose your information, including personal information, to government authorities, and to other third-parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including but not limited to responding to court orders and subpoenas.

To Prevent Harm.
We may disclose your information, including personal information, when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the online and mobile resources, or anyone else that could be harmed by such activities.

Business Transfer.
If we or any of our affiliates, or substantially all of its or their assets, are acquired by one or more third-parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.

Vendors and Business Partners.
We may share your information, including personal information, with our vendors and other third-parties with whom we have a contractual relationship. We may also share your information, including personal information, with vendors who provide third-party software services. We do our best to disclose only the information each of those parties need.

We have adopted standards for those vendors and business partners who receive personal information from us. We attempt to bind such vendors and business partners to those standards via written contracts. We further attempt to contractually restrict what our vendors and business partners can do with the personal information we provide to them such that it is used only to the extent necessary to carry out the business purpose for which it was provided; is not disclosed to anyone else without our consent or under our instruction; remains, as between us and the applicable vendor or business partner, our property; and is not transferred out of the United States without our consent.

Please note, however, that we cannot guarantee that all of our vendors and business partners will agree to these contractual requirements; nor can we ensure that, even when they do agree, they will always fully comply.

5. YOUR RIGHTS AND OPTIONS

You can choose not to provide personal information, but in doing so some of the features of our online and mobile resources may not be available to you. Moreover, you can opt out of certain activities like newsletters and announcements. Data subjects in certain locations, or whose personal data was obtained while they were in certain locations, may have additional rights pursuant to the applicable data protection laws.

In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "CONTACTING US" (last section) below.

We will consider and act upon any request in accordance with applicable data protection laws.

If we are using personal information you provided to us in order to enable us to send you materials, such as newsletters or product alerts via text or email, and you decide you don’t want to receive such materials, you may opt out by following the opt-out instructions in the email or other communication (e.g., by responding to the text with “STOP”), or by contacting us using the contact information below. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. You need to understand it may take a period of time to remove your name from our lists after your request and due to such latency you may still receive materials for a period of time after you opt out. In addition to opting out, you have the ability to access, amend, and delete your personal information by contacting us using the contact information below.

6. CHILDREN’S PRIVACY

Federal laws impose special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from, children under the age of 13. We take those age-related requirements very seriously, and consistent with it do not intend for our online and mobile resources to be used by children under the age of 13 without first obtaining the verifiable consent of such child’s parent or legal guardian. Moreover, we do not knowingly collect personal information from minors under the age of 13, only a parent or legal guardian may provide such information after adhering to our verification process for submitting such information via the online and mobile resources. If we become aware that anyone under the age of 18 has submitted personal information to our online and mobile resources without such parental or legal guardian approval and that is not an integral part to accessing or using our Services, we will delete that information and will not use it for any purpose whatsoever. If you believe that someone under the age of 18 has submitted personal information to our online and mobile resources, please contact us at support@gen225.com. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.​

7. HOW WE PROTECT COLLECTED PERSONAL INFORMATION

We will take all reasonable security precautions to protect your personal information provided to our online and mobile resources. We have adopted a security program that includes technical, organizational, administrative, and other security measures designed to protect, in a manner consistent with accepted industry standards and applicable law, against anticipated or actual threats to the security of personal information (the “Security Program”). We cannot, however, guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or alteration will not occur. Except for our duty to maintain the Security Program under applicable law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information. We have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.

Nonetheless, as part of our Security Program, we have specific incident response and management procedures that are activated whenever we become aware that your personal information was likely to have been compromised. We further require, as part of our vendor and business partner oversight procedures, that such parties notify us immediately if they have any reason to believe that an incident adversely affecting personal information we provided to them has occurred.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

9. U.S. STATE PRIVACY LAWS

This section applies to visitors, users, and others who reside in the states of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, and New Jersey, USA (collectively the “Designated States”). When we collect personal information from residents of the Designated States, where applicable we become subject to, and those residents have rights under, the U.S state level data privacy laws, such as the California Consumer Privacy Act (“CCPA”), as amended (collectively, “State Data Privacy Laws”). This section of our statement is used to allow us to fulfill our obligations under State Data Privacy Laws and explain your rights. For purposes of this section, “Personal Information” has the meaning given in these State Data Privacy Laws.

What did we collect from Residents of the Designated States?

The chart below summarizes how we collect, use and share your personal information, indicating the sources from which we collect Personal Information, the business purposes for which Personal Information is collected and/or shared, and the categories of third-parties with whom Personal Information is shared, describing our practices during the 12 months preceding the effective date of this Privacy Statement. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice and obtaining your consent where required by law.

In the past 12 months, we shared or disclosed all of the categories of Personal Information listed below for the business purposes specified.