Article 1. Personal data
1.1. Information provided by you
When you register, Genscom asks you to provide personal information, including your name, e-mail address, address, communication preference and a password.
1.2. Personal data collection method.
This personal data is collected resp. in the context of:
- Creating an account
- Collaborating with Genscom
- Visiting the Website
- Your use of the services provided by Genscom through the Platform and/or the App, whether or not via a mobile device
- Registering for the newsletter (whether or not via the Website)
- Verification of your identity (e.g. when you contact Genscom’s customer service or recover your password)
- Correspondence with, and from, Genscom
- Sharing ideas with Genscom about improving the services, the Platform and/or the App
- Requesting a quote
- Exchanging business cards
The personal data collected by Genscom is thus expressly and voluntarily provided by you
When you visit the Service, Genscom sends one or more ‘cookies’ – files with a series of characters – to your computer that identify your browser as a unique user. The cookies are used to improve the quality of the Service. Most browsers are configured as standard to accept cookies. However, you can configure your browser to refuse all cookies or alert you when a cookie is sent.
1.4. Log information
When you use the Service, Genscom’s servers automatically save information that your browser sends every time you visit a website. These server logs may include information such as an IP address, browser type, browser language, date and time, and one or more cookies that can identify your browser. We cannot identify you personally on the basis of this data, but it allows Genscom to compile statistics regarding the use of the website/ platform and to send more targeted communication.
When you send an e-mail or other message, we may store those messages to process and respond to your questions and to improve the Service.
1.6. Financial data
Financial details such as your bank account number are processed when you order products on the website or you subscribe to paid services, insofar as this data is necessary for the payment and administrative handling of the products or subscriptions concerned.
Article 2. The use of personal data
Genscom may use your personal data to:
- Create and confirm an account/demo account
- Implement an agreement with Genscom
- Provide Genscom services through the Platform and/or the App
- Provide support
- Send targeted marketing and advertising, updates and promotional offers based on your communication preference
- Send invoices and collect payments
- Optimise the quality, management and content of the Website, the Platform and/or the App
- Statistical purposes
- Compile a quotation
- Conduct customer satisfaction surveys, questionnaires and other market research
Your personal data will not be disclosed to third parties unless this is necessary for the provision of Genscom’s services and the optimisation thereof (such as, but not limited to, maintenance work, payment processing, the distribution of products and database management). If it is necessary for Genscom to disclose your personal data to third parties in this context, the third party concerned is obliged to use your personal data in accordance with the provisions of this Privacy Statement.
Notwithstanding the above, Genscom may also disclose your personal information:
- To the competent authorities (i) if Genscom is obliged to do so by law or in the context of judicial or future legal proceedings and (ii) to indemnify and defend our rights;
- If Genscom or virtually all its assets are acquired by a third party, in which case your personal data – which Genscom has collected – will be one of the assets transferred;
- With the aim of detecting similar profiles such as yours, unless you have explicitly objected to this.
Your personal data will not be used in any circumstances for commercial purposes, and will not be disseminated by Genscom in any other way, unless Genscom (i) has obtained your permission to do so and (ii) has concluded a data processing agreement with the relevant party, which contains the required guarantees regarding the confidentiality and privacy conformity of your personal data.
Article 3. Personal data storage
Unless a longer retention period is required or justified (i) by law or (ii) for compliance with another legal obligation, Genscom will only keep your personal data for the period necessary to achieve and fulfil the objectives, as described in the Privacy Statement under ‘The use of personal data’.
Article 4. Your privacy rights
If you wish to invoke your privacy rights, as set out below, please contact firstname.lastname@example.org or contact Genscom in writing by post:
- Right of access to the personal data Genscom may have about you;
- Right to rectify, complete or update your personal data;
- Right to delete your personal data (‘right to be forgotten’);
- Right to restrict the processing of your personal data;
- Right to transfer your personal data;
- Right to object/oppose the processing of your personal data.
In principle you can exercise these rights free of charge. Moreover, in your account you can, at any time, update, change and/or verify your personal details – which you had to provide when you created your account or demo account.
If you no longer wish to receive newsletters or information about our services, you can unsubscribe at any time by clicking the ‘unsubscribe’ button, included in each e-mail you receive from Lettr/Genscom.
Article 5. Information security
Genscom undertakes to implement reasonable, physical, technological and organisational precautionary measures with the aim of preventing (i) unauthorised access to your personal data, as well as (ii) the loss, misuse or alteration of your personal data.
Genscom shall store all personal data it has collected in the cloud (at data centre(s) within the EU). Notwithstanding Genscom’s security policy, the checks it carries out and the actions it imposes in this context, an infallible level of security cannot be guaranteed. No method of transfer or retransmission via the Internet nor any method of electronic storage is 100% secure, so Genscom cannot guarantee absolute security in this context. Finally, the security of your account/demo account will also partly depend on the confidentiality of your password to gain access to the Platform and/or the App. Genscom will never ask for your password so you are obliged not to share it. If you have nevertheless communicated your password to a third party – for example because this third party has indicated it will offer you additional services – the third party concerned will gain access to your account/demo account and your personal data using your password. In this case you are personally responsible for the actions taken through the use made of your account/demo account. Genscom strongly recommends that if you discover someone has accessed your account/demo account, you immediately change your password and contact us.
Article 6. Cross-border processing of personal data
Any transfer of personal data outside the European Economic Area (EEA) to a recipient who is domiciled or based in a country that is not covered by an adequacy decision issued by the European Commission, will be governed by provisions of a data transfer agreement, which will include (i) the standard contractual clauses, as stipulated in the ‘Decision of the European Commission of 5 February 2010 (Decision 2010/87 / EC)’, or (ii) any other mechanism under privacy legislation, or any other regulation concerning the processing of personal data.
Article 7. Other websites
Article 8. Complaints
If you have any complaints about the way in which Genscom collects, uses and/or processes your personal data, you can submit a complaint to the Privacy Commission.
If you have any questions about the Privacy Statement or about the way in which Genscom collects, uses or processes your personal data, please contact us:
- By e-mail: email@example.com or
- By post: Genscom NV, Louis Frarynlaan 77, 2050 Antwerp (Belgium)