Effective Date: 9/14/2023
If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
You may have additional rights based on your jurisdiction. Please click the relevant link below for more information:
We collect information about you when you use our Services, including information you provide when you register an account, update your profile, access our content, make a purchase, participate in a promotion, contact support, or apply for a job. The categories of information we collect include:
● Contact Data, including your first and last name, email address, and non-Genvid account IDs.
● Demographic Data about you tied to your personal information, such as your age and/or date of birth, country/region of residence, and preferences.
● Job Applicant Data, including your employment and education history, portfolio, references, and background check information as necessary to consider your job application for open positions.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
In addition, we automatically collect information when you use our Services. The categories of information we automatically collect include:
● Service Use Data, including data about features you use, pages you visit, emails you view, products and services you view, the time of day you browse, and your referring and exiting pages.
● Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address, device ID, and Ad Id (which is a user-resettable identifier associated with your mobile device).
● Location Data, including non-precise location data (such as location derived from an IP address or data that indicates a city or postal code level).
● Customer Support Data, including interactions with customer support representatives for purposes of quality assurance.
The types of tracking technologies we use to automatically collect this information include:
For further information on how we use tracking technologies for analytics, and your rights and choices regarding them, see the “Analytics” and “Your Rights and Choices” sections below.
We also collect information from other sources. We protect information obtained from other sources according to the practices described in this statement, plus any additional restrictions improved by the source of the information. The categories of sources from which we collect information include:
● Mobile platforms send us information when you purchase our apps. This information is limited to username or screen name and/or device ID and the fact a purchase was made, but no other sensitive or financial information is shared unless you authorize the mobile platform providers to send us that information.
● Service providers may collect any of the categories of personal information described above to provide services on our behalf, including helping us determine your device’s general location (based on IP address) to customize certain aspects of the Services to your location, provide you with a more convenient experience, and provide us additional security measures to protect our Services.
● Affiliates and Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
● Publicly-available sources, including information from social networks (including your name, screen name, and content you post) and in the public domain. We may use such data for purposes such as measuring public reaction to our Services.
Providing our Services to you, and to improve our Services.
Preventing and addressing fraud, breach of policies or terms, or threats or harm.
Understanding trends, usage, and activities, including through tracking technologies or surveys, to make business and marketing decisions.
Communicating with you about updates, security alerts, changes to policies, and other transactional messages.
Personalizing your experience to show you content we believe you will find interesting.
Engaging in direct marketing, promotional communications, and non-personalized advertising.
To protect ourselves, the personal safety of users of our Services, or the public in our sole discretion.
To comply with a legal obligation or to exercise our legal rights, including but not limited to defend against liability.
Fulfilling any purpose at your direction.
With notice to you and your consent.
Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
For the purposes listed above, we may also link or combine information about you with other personal information we receive from third party sources.
We may store and process personal information in the United States and other countries or regions that may not have the same types of data protection laws as those in your country.
● Service Providers and Contractors. We disclose information to service providers and contractors that process information on our behalf. Service providers and contractors assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support.
● Analytics. We disclose information to vendors and other parties for analytics related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on analytics, see the “Analytics” section below.
● Partners. We disclose information to our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
● Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we disclose information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
● Public Forums. We disclose information you make public through our Services, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
● Merger or Acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
● Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, our Services or anyone else.
● Facilitating Requests. We disclose information where you direct us to disclose the information.
● Consent. We disclose information with notice to you and your consent. Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.
We offer parts of our Services through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.
Some examples include:
● Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
We use analytics services, such as Google Analytics, to help us understand how users access and use our Services.
For further information on the types of tracking technologies we use on our Services and your rights and choices regarding analytics please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
You can contact us at [email protected] with requests to delete, access, and update your personal information.
● Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings,to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
● Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless required by applicable law, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove tracking technologies some parts of our Services may not function correctly.
You can prevent tracking of emails we send you by changing your settings to turn off HTML or disable downloading of images. In addition, Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout. Please note that the above opt outs only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of any opt outs offered by other entities.
● E-mails. You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email. Please note that you cannot opt out of transactional messages. Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.
● In-App / On-Device Notifications. You can opt out of in-app notifications by using the notification settings in your mobile device.
Our Services are not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at [email protected]. We will delete the personal information in accordance with COPPA.
We implement and maintain reasonable administrative, organizational, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
The California Consumer Privacy Act (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”), provide additional rights to California residents. This section addresses those rights and applies only to California residents.
Our Service is intended to provide information and services to job applicants and business clients. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) us conducting due diligence regarding, or providing or receiving a product or service to or from your employer.
We have collected the following categories of personal information (as described in the CCPA/CPRA) in the past 12 months. For further details on the personal information we collect and how we obtain this information, please review the “Information Collection” section above.
● Identifiers, including name, email address, and online identifiers (such as IP address).
● Internet activity, including browsing history, search history, and interactions with a website or email.
● Non-precise geolocation data, including location derived from an IP address.
● Professional, employment, or education-related information.
● Inferences drawn from any of the information identified in this section.
We collect and use this personal information for the business and commercial purposes set out in the “Use of Information” section above.
We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above.
We do not “sell” or “share” your personal information as those terms are defined by the CCPA/CPRA.
We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
● The categories of personal information we have collected about you;
● The categories of sources from which the personal information was collected;
● The categories of personal information about you we disclosed for a business purpose or sold or shared;
● The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
● The business or commercial purpose for collecting or selling or sharing the personal information; and
● The specific pieces of personal information we have collected about you.
Unless you specify otherwise, the response we provide will cover the 12 month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve a disproportionate effort.
In addition, you have the right to correct (effective January 1, 2023) or delete the personal information we have collected from you.
To exercise any of these rights, please email us at [email protected]. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information.
To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
The General Data Protection Regulation (“GDPR”) provides additional rights to individuals located in the European Economic Area, Switzerland, and the United Kingdom, (collectively, “Europe”). This section addresses those rights and applies only to those individuals.
Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Genvid acts as a controller with respect to personal data collected as you interact with our Service.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where:
(a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.
Please note that we retain information as necessary to fulfill the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.