Privacy
(1) Introduction
(2) Information we collect
(3) Our use of cookies and urchin tracking modules (UTMs)
(4) How we use your information
(5) Why we process your personal information/data
(6) Disclosing your personal information
(7) Your data protection rights under GDPR, Canada’s PIPEDA, and
California's consumer privacy act
(8) Accessing and updating your personal information
(9) Storing, securing, and transfer of your personal data and information
(10) Data breaches
(11) Third-party links
(12) Children’s privacy
(13) About us
(14) Contact us
(16) Changelog
(1) Introduction
genOTC.com is operated by genOTC SAS, a French company located at 3 square de Luynes 75007 PARIS, which may include its affiliates, subsidiaries, directors, officers, employees, agents, partners, contractors, and/or licensors (together, referred to throughout this Privacy Policy as “genOTC.com”, “us”,or “we”).
genOTC.com offers different services, products, software, and offerings (the"Services"), including but not limited to, all information, tools and services (including any beta services) available from us to you (the 'User'), that are run under the brand "genOTC.com'' and on related genOTC.com websites, conditioned upon your acceptance of all terms, conditions, policies and notices stated in the Terms of Services and this Privacy Policy.
This Privacy Policy explains how genOTC.com collects, uses, stores, and shares your personal information when you use our Services and/or visit our Sites in accordance with various privacy laws. By using the Sites andServices, Users and visitors acknowledge the processing of their personal data in accordance with this Privacy Policy which may be modified or updated
from time to time. Personal data is information that alone or in combination with other information in our possession, or likely to come into our possession, can be used to identify a living individual. We strive to make this Privacy Policy as consumer-friendly as possible, but if you have a question about something, please contact us.
(2) Information we collect
We collect information that you give us or that we get from your use of our Sites and Services, including without limitation, the following categories:
names;
addresses;
country;
email addresses;
telephone numbers;
organizations;
job title;
financial data relating to orders;
IP Addresses;
log files;
CV and and other information when applying to work with us;
and
We may also collect information about you, including your user interactions with our Sites and Services, from cookies and tracking devices if you have consented to their use. We do not explicitly collect any special categories of personal data or
sensitive personal information through our Sites and Services.
(3) Our use of cookies and urchin tracking modules (UTMs)
Cookies are small pieces of data stored on your device (computer or mobiledevice). Cookies can be used to provide you with a tailored user experienceand to make it easier for you to use a site upon a future visit. When used,cookies are downloaded and stored on your device. Such information, on its own, will not identify you personally. It is statistical data. You have the optionto accept all cookies, accept some cookies while rejecting others, or rejectthem all. Rejecting functional cookies may prevent you from using certain portions or functionalities of our sites and Services. We may use such cookiesto deliver and improve our Services. Some third-party services that we use to improve the Services (including usage, measuring performance, and advertising), such as Google Analytics, may also place cookies on your device. Examples of Cookies we use:Strictly necessary cookies. These cookies are necessary for the website to function and cannot be switched off in our systems.Performance & analytic cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Sites.Functional cookies. These cookies enable the website to provide enhanced functionality and personalization.Advertising cookies. These cookies deliver and measure the effectiveness of our marketing campaigns and may be set through our site by our advertising partners.Social media cookies. These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks.The validity period of cookies for our sites and Services is 6 months. We will request a new prior consent after this period.Urchin Tracking Module ("UTM") tags are distinct from cookies as defined above. UTM works as a custom Uniform Resource Locator (“URL”) parameter for marketing campaigns and reports can be viewed in platforms like GoogleAnalytics. UTM tags are appended as part of the visible URL in marketingprograms to understand the specific instance of a link. UTM tag reports are observed in Google Analytics or Marketo to better understand how our visitorsare getting to our websites, and as such, who our visitors are. Such data is collected at an aggregate level, and we will not identify you personally.Customizing the URL with UTM tags allows us to better understand marketingactivity, which then allows us to better serve our customers and audience.As part of this process, non-identifying and non-profiling information (source,medium, campaign, and Click ID), will be stored in your browser in local
storage. No Personally Identifiable Information (“PII”) or personal data will bestored. This information would only be used by genOTC.com if you sign up for and consent to our service. At that point in time, campaign attribution information would be made available to genOTC.com to gauge the effectiveness of the campaign. You may clear your browser cache prior to signing up for our service to opt out.You can manage your cookies preference in our Cookies dashboard. For any questions on cookies or UTM opt-outs, or about our policy listed here, please contact us using the form on our website.
(4) How we use your information
We use the information we collect from you to provide, maintain, protect, and improve our Sites and Services, and to develop new ones.In addition, we may use the information for one or more of the following purposes:To provide information that you request from us relating to our products or Services;To provide information related to products or Services provided by us;To inform you of any changes, offers, updates, or other announcements about our Services when you have opted-in;To allow you to participate in interactive features of our Services when you choose to do so;To provide customer support;To gather analysis or valuable information so that we can improve ourServices;To monitor the usage of our Services and Sites;To better provide technical support to you and to improve our Services and Sites;To detect, prevent, and address technical issues;To provide you with new Services offers and relevant Services information and events unless you have opted not to receive such information. We will never send Users or visitors commercial offers unrelated to our Services; and To detect, prevent, and address fraud and/or abuse of our products or Services.
(5) Why we process your personal information
We may process your personal information because:
We need to provide a requested Service and honor our contractual obligations with you;
You have given us permission to do so; The processing is in our legitimate interest and it is not overridden by
your rights; For payment processing purposes; and to comply with applicable law.
(6) Disclosing your personal information
We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below: Our affiliates and subsidiaries: To provide the Services and for any of the
purposes identified above. Third-party service providers: We use trusted third-party service providers, consultants, and other agents to help us provide, maintain, protect, and improve our Services and Sites. We may provide your personal information to such third-party service providers to perform certain tasks based on our instructions and in compliance with this Privacy Policy. Such third-party
service providers may include data storage, maintenance services, database management, web analytics including user interactions, payment processing providers, and live chatbots.
When we have your consent: We may disclose personal information if we have your specific consent to do so, where you have expressly opted-in/consented to the disclosure of your personal data for a specific purpose. If you wish to withdraw this consent, please contact us. For existing customers, please file a support ticket.Legal: We will share personal information with our regulators, law
enforcement, or fraud prevention agencies, as well as legal advisers, and courts, if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to: comply with legal obligations, meet applicable laws, regulations, or legal processes, or abide by enforceable governmental requests (however,
we will use reasonable efforts to provide notice to genOTC.com’s customers when we receive a request for customer personal data
unless genOTC.com is explicitly prohibited from doing so by applicable laws); enforce applicable Terms of Service or any of our other agreements with you, including investigation of potential breaches; detect, prevent, or otherwise address fraud, security, or technical issues in connection with the Services; protect against harm to the rights, property, liability, or safety of genOTC.com, our Users, customers and our employees, or the general public, as required or permitted by law; prevent an emergency when a person is at risk of potential imminent death or serious physical injury, and genOTC.com may have personal data necessary to prevent such emergency;
protect against apparent instances of child exploitation or missing children detected on genOTC.com’s services; Succession: If we are involved in a merger, acquisition, asset sale, restructuring or reorganization with prospective buyers or sellers of such business or assets. All information you disclose in your public profile, forum posts, blogs, comments, issue queues, or other public portions of our Services becomes public information. Please be careful about what you choose to disclose publicly.
(7) Your data protection rights under GDPR, Canada’s PIPEDA, and California's consumer privacy act
Your rights under GDPR:If you are a resident of the European Economic Area, you have certain data protection and privacy rights. In certain circumstances, you have the following privacy rights: The right to access the information we have on you. The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete. The right of deletion. You can request us to delete the personal information we hold about you. Please note that this is not an absolute right and we might need to retain your personal information for compliance with laws or other legitimate reasons. The right to object. You have the right to object to our processing of your personal information. The right of restriction. You have the right to request that we restrict
the processing of your personal information. The right to data portability. In certain circumstances, You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format. The right to withdraw consent. You also have the right to withdraw your consent at any time when genOTC.com relies on your consent to process your personal information, though we may have other lawful bases for processing your information for other purposes, such as those set above. The right not to be subject to automated decisions including profiling. You have the right not to be subject to a decision based
solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Please note that we may ask you to verify your identity before responding to such requests. Your rights under Canada’s PIPEDA (Privacy rights): The Personal Information Protection and Electronic Documents Act (‘PIPEDA’) is the Canadian federal privacy law that regulates how private-sector organizations handle personal information in the course of commercial activity. genOTC.com continuously strives to comply with PIPEDA Principles. We have procedures in place to receive and respond to any complaints and inquiriesyou may have. Contact us or email our Data Protection Officer at dpo@genOTC.com. For existing customers, please file a support ticket. If you are a resident of Canada you have certain privacy rights: The right to know why your personal information is being collected, how it will be used, and to whom it will be disclosed. This Privacy Policy serves this purpose. You also have the right to access, or correct, your personal information. Your rights under California privacy laws. The California Consumer Privacy Act (‘CCPA’) and the California Privacy Rights Act (‘CPRA’), (together ‘California Privacy Laws’), give California consumers/residents (or your authorized agent) certain privacy rights and impose corresponding, and independent, obligations on businesses processing California consumers’ personal information. genOTC.com does NOT sell your personal information. We do NOT collect sensitive personal information as defined under California Privacy Laws. Where applicable, we have added contractual requirements instructing our
service providers to not further collect, sell, share, or use the consumers’ personal information except as necessary to perform their respective business purpose. If you are a resident of California you have certain privacy rights: Right to know. You have the right to know about the personal information we collect about you and how it is used and shared. This Privacy Policy serves this purpose.
Right to delete. You have the right to request us to delete your personal information and to tell our service providers to do the same.
However, there are many exceptions that allow businesses to keep your personal information. Please note that this is not an absolute right and we might need to retain your personal information for compliance with laws or other legitimate reasons. Right to correct. You have the right to request that we correct any inaccurate personal information about you. Right to portability. You have the right to receive your personal information in a portable and, to the extent technically feasible, readily usable format.Right to opt-out of sale or sharing. genOTC.com does not sell or share your personal information within the meaning of California Privacy Laws.
Right not to be discriminated against for exercising any of your rights. We do not use financial incentive practices that are unjust,
unreasonable, coercive, or usurious, and do not retaliate against those who choose to exercise their rights. Right to limit use and disclosure of sensitive PI. You have the right to direct that we limit the use of sensitive PI to the use that is reasonably necessary to perform the services expected by you. We do not collect sensitive personal information as defined under the CCPA. Right to opt-in for children: Business Obligation Not to Sell or Share Children’s PI unless there is Affirmative Authorization. We do not sell or share personal information as defined under the CCPA nor do we (knowingly) collect children's personal information.
(8) Accessing and updating your personal information
Whenever made possible on your account settings, you can access, update, or request deletion of your personal information and data we held about you directly within your account settings section. Please also file a support ticket to confirm any account changes, or contact us to assist you. If you are unable to perform these actions yourself (e.g. you don’t have an account), please contact us using the various methods detailed below to assist you. For customers located in Australia, you may also email "dpo@genOTC.com".
(9) Storing, securing, and transfer of your personal data and
information
We only collect personal information that is relevant to the purposes set out in this Privacy Policy and do not collect more personal information than what is necessary for those purposes. We also ensure that the information we collect is accurate and sufficient to properly fulfill those purposes. We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent reasonably necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We retain usage data for a reasonable period of time to pursue legitimate business interests, orfor internal analysis purposes. Usage data is generally retained for up to 14 months or less, except when this data requires a longer retention period due to a compliance reason, legal obligation, security purpose, or legitimate business reason that does not outweigh the user's or visitor's interests, such as improving the Services. We take all reasonable measures to protect your personal data and information from unauthorized access to, or unauthorized alteration, disclosure or destruction of, information we maintain. To maintain your trust,
we’ve achieved several independently audited industry certifications, ensuring your data is handled with appropriate care and according to industry standards. We also use physical, organizational, and technological methods and policies to protect and safeguard your personal information.
(10) Data breaches
We will report any unlawful data breaches to any and all relevant persons and authorities within 72 hours (or sooner if it is required under applicable privacy laws) of the breach when such breach is likely to result in a high risk to the rights and freedoms of data subjects. Obligation to report or respond to a personal data breach or security incident will not be construed as an acknowledgement by genOTC.com of any fault or liability with respect to the personal data breach or security incident. Should you have any complaint
about a breach, or the way in which we will handle a breach, please contact us.
(11) Third-party links
Our Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We do not endorse these sites, nor are we responsible for the content or accuracy of any information contained on them. We strongly advise you to review the privacy policies of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
(12) Children’s privacy
To the extent prohibited by applicable law, our Service does not address anyone under the age of 16 (“Children”). By agreeing to our Terms of Service, you represent that you are the age of majority in your state, province, or country of residence, or 16 years of age, whichever is greater. We do not knowingly collect personally identifiable information from children. If you are a parent or guardian and you are aware that your children have provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verifiable verification of parental consent, we will take steps to delete that information from our databases and servers.
(13) DPO
genOTC.com has a designated Data Protection Officer who is accountable for the management of your personal information, including collection, usage, disclosure, retention, and transfer of personal information to third parties for processing. All privacy issues, compliance requests, inquiries, and other requests will be handled by our French parent company, genOTC.com SAS.
(14) Contact us
If you have any questions, requests, feedback, or concerns regarding this Privacy Policy or you want to exercise any of your rights, please contact us using the form on our website. You can also send an email to dpo@genOTC.com. Our procedures are in place to receive and respond to any complaints and inquiries you may have. Sites visitors have several options for correcting personal information or removing their information from our database in order to discontinue future communications from genOTC.com.
Should you deem that we have not satisfactorily handled your request or you have a complaint, you have the right to contact your local Data Protection Authority (or Attorney General). Our GDPR Supervisory Authority is the Commission Nationale de l'Informatique et des Libertés.
(15) Changelog
We may update this Privacy Policy from time to time. We recommend that you revisit this Privacy Policy regularly. When we materially change this Privacy Policy, a prompt notice will be posted on our blog along with the updated Privacy Policy. In accordance with the Terms of Service, in some cases, we will notify you in advance, and your continued use of the Services after the changes have been made will constitute your acceptance of the changes. This policy was last reviewed and updated: July 2024.
