Last Updated: May 5, 2023

Genuin, Inc., ("Genuin", "us", "we", or "our") cares about how your personal information is used and shared. We take your privacy as a consumer very seriously. We operate the website, www.begenuin.com (our "Website") and the mobile application, 'Genuine' available for download on the iOS App Store and the Google Play App Store (the "App"), both of which offer an all-in-one internet technology service (the "Services"). The terms "you," "your," and "yours" refer to the user, customer, or company using the Services.

Please read the following to learn more about this privacy policy (this "Privacy Policy").

By accessing the Services in any manner, you agree and acknowledge that you accept the terms of this Privacy Policy, and you expressly consent that we may collect, use, and share your information in accordance with this Privacy Policy.

By using the Services, you are at all times subject to our Terms of Service which hereinafter incorporates this Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms not defined herein have the meanings as given to them in our Terms of Service.

1. WHAT IS PERSONALLY IDENTIFYABLE INFORMATION?

   Personally identifiable information ("PII") is any information about an individual that can identify that individual. Examples of PII include (but are not limited to):

   1. name, date of birth, and social security or other identity card number;
   2. contact information such as mailing address, email address, and phone numbers;
   3. credit card and financial account numbers;
   4. health or medical information;
   5. information contained in employee files, including employment history, evaluations, and information collected during the application and hiring process; and
   6. information related to employee benefits, such as the names of dependents, beneficiaries, and insurance policy information.
2. COLLECTION AND USE OF PII AND OTHER INFORMATION

   This Privacy Policy informs you of our policies regarding the collection, use and disclosure of PII when you use the Services, or that is provided to us with your consent by participating partners ("Partners"), but not to the practices of other companies or institutions we don't own or control, or people that we don't manage.

3. A NOTE ABOUT CHILDREN

   We do not knowingly collect or solicit PII from anyone under the age of 13. If you are under the age of 13, please do not attempt to register for the Services or send any PII about yourself to us. If we learn that we have collected PII from anyone under the age of 13, we will delete that PII as quickly as possible. Only persons aged 13 or older have permission to access the Services. If you learn that someone under the age of 13 may have provided us with PII, please contact us at www.begenuin.com.

4. A NOTE TO USERS OUTSIDE OF THE UNITED STATES

   We are based in the United States. By using or accessing the Services or otherwise providing information to us, you consent to the processing, transfer, and storage of such information, including your PII, in and to the United States, where laws regarding processing of PII may be less stringent than the laws in your country of residence.

5. WHY WE COLLECT YOUR PII

   We gather various types of PII from our users, as explained in more detail below, and we use this PII only in connection with the Services, including to personalize, provide, promote, and improve the Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services.

6. WHY ARE WE ALLOWED TO COLLECT YOUR PII AND HOW DO WE USE THE PII?

   We will only process PII where we have a lawful reason for doing so. The lawful basis for processing PII by us will be one of the following:

   1. The processing is necessary for the creation of an account by you and to provide the Services at your request;
   2. The processing is necessary in order for us to comply with our legal obligations (such as lawful subpoena requests or responding to copyright disputes);
   3. The processing is necessary for the pursuit of our legitimate business interests (including that of the delivery and the promotion of the Services);
   4. Processing is necessary for the establishment, exercise or defense of legal claims; or
   5. You have given us consent to the processing of PII for one or more specific purpose, including, but not limited to:
      1. Provide, maintain and improve the Services;
      2. Send you technical notices, updates, security alerts, support and administrative messages;
      3. Respond to your comments, questions and requests and provide customer service;
      4. Personalize and improve the Services and provide content or features that match user profiles or interests;
      5. Communicate with you about products, services, and offers offered by Genuin and others, and to provide news and information Genuin thinks will be of interest to you;
      6. Link or combine with information we get from others to help understand your needs;
      7. Monitor and analyze trends, usage and activities in connection with the Services; and
      8. Carry out any other purpose for which the information was collected, and you were informed.
7. WHAT INFORMATION DO WE COLLECT?
   1. We receive and store any information you knowingly provide to us:

      If you contact us via e-mail or the "Contact Us" button via the App, we may collect your name, e-mail address, phone number, as well as any other content included in the e-mail, in order to send you a reply. When you email us the information contained in your posting will be stored on our service provider's servers. Furthermore, once you have created an account, you will have the option to post PII at your own discretion. You understand that when if you do so, PII may be shared with other users and may be viewable on publicly available areas of the Services, depending on your applicable privacy settings.

   2. Information Collected Automatically:

      Whenever you interact with the Services, we automatically receive and record information on our server logs from your browser or device, which may include your internet protocol ("IP") address, device identification, and "cookie" information. "Cookies" are identifiers we transfer to your browser or device that allow us to recognize your browser or device, provides us with geolocation data and tell us how and when pages and features in the Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device's acceptance of Cookies, but this may prevent you from taking advantage of some of our features.

      We may use third parties to provide analytics services. These entities may use Cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Genuin and others to, among other things, analyze and track data, determine the popularity of certain content, customize the Services, deliver content targeted to your interests on the Services and other websites and better understand your online activity.

      We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

   3. Information Collected from Other Websites and Do Not Track Policy:

      Through Cookies we place on your browser or device; we may collect information about your online activity after you leave the Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy.

      Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. The Services do not support Do Not Track requests at this time, which means that we collect information about your online activity while you are using the Services and after you leave the Services.

8. WILL GENUIN SHARE ANY OF THE PII IT RECEIVES?

   We do not rent or sell your PII in personally identifiable form to anyone, except as expressly provided herein.

   1. Information that's been de-identified:

      We may de-identify your PII so that you are not identified as an individual and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use the Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual person.

   2. Affiliated Businesses:

      In certain situations, businesses or third-party websites that we are affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your PII with that affiliated business only to the extent that it is related to such transaction or service you have requested. One such service may include the ability for you to automatically transmit third party account information to the Services profile or to automatically transmit information in the Services profile to your third-party account. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business' or websites' policies.

   3. User Profiles and Submissions; Privacy Settings:

      Certain user profile information, including your name and location that such user has uploaded to the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for the Services..

      The Services are designed, among other things, to help you share information. If you have a profile on our mobile application, most of the information you provide us through the Services is information you are asking us to make accessible. When you share information or content via the Services, you should think carefully about what you are making accessible.

   4. Business Transfers:

      We may choose to buy or sell assets and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, PII could be one of the assets transferred to or acquired by a third party.

   5. Protection of Genuin and Others:

      We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Genuin, our employees, our users, or others.

9. LEGAL DISCLAIMER

   We reserve the right to disclose your PII as required by law and when we believe that disclosure is necessary to protect our rights (or those of our users) and/or to comply with a judicial proceeding, court order, or legal process served on our Website or App.

   1. Text Messages/SMS:

      We may seek to communicate with you at times by phone either through in-app notifications or by calls, including text messages, if we have been provided with your mobile phone number. When you register and submit your mobile phone number to us, you consent to receive text message alerts from us containing product and service information or promotions that may be sent using automated dialing systems. Text messages may also include information or promotions from Partners you have expressed an interest in directly or while using the Services. The number of messages you receive depends on the number of information requests. Your provider's standard message and data rates may apply. You may elect to stop receiving text messages at any time by contacting us at contact@begenuin.com and it will not affect your ability to use any other services or features.

10. CUSTOMER SERVICE

    We will communicate with you in response to your inquiries, to provide the Services you request, and to manage your account, either by an email you provide to us or via the App.

11. UPDATING PERSONALLY IDENTIFIABLE INFORMATION

    If your PII changes, or if you no longer desire our service, you may update or deactivate it by making the change by emailing our customer support at contact@begenuin.com will retain and use your information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

12. SECURITY

    The security of your PII is important to us. We endeavor to protect the privacy of your account and other PII we hold in our records, but unfortunately, we cannot guarantee complete security. We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure; therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security. It is your responsibility to protect the security of your login information.

13. WHAT PII CAN I ACCESS?

    Through your account settings, you may access, and, in some cases, edit the following information you've provided to us:

    1. name
    2. username
    3. bio
    4. social media profiles

    The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at contact@begenuin.com.

14. WHAT CHOICES DO I HAVE?

    You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. You may be able to add, update, or delete information and adjust your privacy settings as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by contacting us at contact@begenuin.com note that we may retain certain information as required by law or for legitimate business purposes. We may use any aggregated data derived from or incorporating your PII after you update or delete it, but not in a manner that would identify you personally.

15. YOUR RIGHTS IN RELATION TO PII AND HOW TO EXERCISE THEM

    Under certain circumstances you may have the following rights:

    1. the right to ask us to provide you, or a third party, with copies of the PII we hold about you at any time and to be informed of the contents and origin, verify its accuracy, or else request that such information be supplemented, updated or rectified according to the provisions of local law;
    2. the right to request erasure, anonymization or blocking of your PII that is processed in breach of applicable law;
    3. the right to object on legitimate grounds to the processing of your PII. In certain circumstances we may not be able to stop using your PII, if that is the case, we'll let you know why; and withdrawal of consent – when PII is processed on the basis of consent an individual may withdraw consent at any time (this may apply to processing of special categories of PII where you have instructed us to act on your behalf and includes the following: racial/ethnic origin, political opinions, religious or philosophical beliefs and trade union membership). In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you) or contact us at contact@begenuin.com.
16. GDPR

    The General Data Protection Regulation (the "GDPR") gives individual data subjects, located in the European Union in certain circumstances the right to, among other things, access, delete, and make corrections to their personal data. Further, the GDPR requires us to explain the valid legal bases we rely on to process your personal information.

    At its core, the GDPR is focused on transparency, fairness, and accountability. Accordingly, the law requires organizations to maintain documentation about their privacy practices and their decisions about how they handle individuals' personal data. We are committed to facilitating data subject requests consistent with the GDPR, as further described in this Privacy Policy.

17. STATE SPECIFIC PRIVACY LAWS AND REGULATIONS

    This section (this "Supplemental Notice") applies only to information collected about consumers in the following states: (1) California, (2) Colorado, (3) Connecticut, (4) Nevada, (5) Utah, and (6) Virginia and describes our practices regarding the collection, use, and disclosure of PII and provides instructions for submitting data subject requests. Some apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers.

    To the extent terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.

    1. Supplemental Notice for California Residents. This Supplemental Notice for California residents only applies to our processing of personal information that is subject to the California "Shine the Light" law which permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. Further, California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of PII to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your PII to other entities for their own direct marketing purposes.

    2. Supplemental Notice for Colorado Residents. The Colorado Privacy Act provides Colorado residents with the following rights:(i) the right to opt out of the processing of personal data concerning the consumer; (ii) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (iii) the right to correct inaccurate personal data collected from the consumer; (iv) the right to delete personal data concerning the consumer; (v) the right to restrict a business's ability to process PII about the consumer, specifically to opt-out of processing for profiling/targeted advertising purposes; (vi) a prohibition against a business making certain decisions about a consumer based solely on an automated process without human input; and (vii) the right to data portability. When exercising the right to access personal data, a consumer has the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hinderance. A consumer may exercise this right no more than two (2) times per calendar year.

    3. Supplemental Notice for Connecticut Residents. The Connecticut Data Privacy Act provides Connecticut residents with the following rights: (i) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (ii) the right to request that incorrect or outdated personal information be corrected but not deleted; (iii) the right to delete personal data concerning the consumer; (iv) the right to restrict a business's ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (v) the right to request personal information about the consumer be disclosed in a common file format; (vi) the right to opt out of the sale of personal information about the consumer to third parties; and (vii) prohibition against a business making certain decisions about a consumer based solely on an automated process without human input.

    4. Supplemental Notice for Nevada Residents. We generally do not disclose or share personal information for profit. If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. To exercise this right, if applicable, you or your authorized representative may submit a request to contact@begenuin.com. If you have any questions, please contact us at contact@genuin.com and we will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) business days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response.

    5. Supplemental Notice for Utah Residents. The Utah Consumer Privacy Act provides Utah residents with the following rights: (i) the right to confirm whether a business is processing personal data concerning the consumer and to access the consumer's personal data; (ii) the right to delete personal data concerning the consumer; (iii) the right to restrict a business's ability to process sensitive data about the consumer- specifically to opt-out of processing for profiling/ targeted advertising purposes; (iv) the right to request personal information about the consumer be disclosed in a common file format; and (v) the right to request to opt out of the sale of personal information about the consumer to third parties.

    6. Supplemental Notice for Virginia Residents. The Consumer Data Protection Act provides Virginia residents with the following rights: (a) the right to confirm whether or not a controller is processing the consumer's personal data and to access such personal data; (b) the right to delete personal data provided by or obtained about the consumer; (c) the right to obtain a copy of the consumer's personal data that the consumer previously provided to the business in a portable and, to the extent technically feasible, readily usable format; (d) the right to opt out of the processing of the personal data for purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer; and (vi) the right to restrict a business's ability to process personal information about the consumer, specifically to opt-out of processing for profiling/targeted advertising purposes.

    Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers: Unless specifically stated, we do not sell or share PII to third parties for their own use. However, we may share or process one or more of the above categories of personal information with our Partners in arrangements for purposes of targeted advertising, as the terms "sell," "share," "process," and "targeted advertising" are defined in the CPA, VCDPA, UCPA, and CTDPA. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.

18. CHANGES IN THE PRIVACY POLICY

    If we decide to change our privacy practices, we will post those changes to this Privacy Policy, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

    We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we change how we use your personally identifiable information, we will notify you here, by email, or by means of a notice on our home page. Any material changes to this Privacy Policy will be effective upon the earlier of ten (10) calendar days following our dispatch of an e-mail notice to you or ten (10) calendar days following our posting of notice of the changes on our Website and/or mobile application. These changes will be effective immediately for new users of our Website and the App.