GDPR Privacy Notice
Geneva
Posted on Apr 5, 2025
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GDPR Privacy Notice
General Data Protection Regulation (“GDPR”)
GDPR Privacy Notice
If you are a resident of the European Union ("EU"), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you have additional rights under the GDPR (or, if you are in the UK, under the GDPR as it forms part of the law of England and Wales by virtue of section 3 of the European Union (Withdrawal) Act 2018) with respect to your Personal Data, and this section titled “GDPR Privacy Notice” applies to you. Under the GDPR, we will be the “controller” of your Personal Data processed in connection with the Services.
Our lawful bases for processing your Personal Data
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include the following:
Legitimate Interest: We process Personal Data in order to provide the Services to you. For example, we collect your full name, username, telephone/mobile number, and other profile information to create and manage user profiles and accounts, communicate with you about the Services, provide support and assistance for the Services, respond to user inquiries, fulfill user requests, resolve disputes, and collect feedback about the Services. We may also automatically collect Personal Data through your use of the Services. For example, we automatically collect IP addresses when you use the Services for security purposes.
Consent: In some cases, we may need to process Personal Data based on the consent you expressly grant to us at the time we collect such Personal Data. If we need to process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Contractual Necessity: We may need to process Personal Data as a matter of “contractual necessity,” meaning that we need to process the Personal Data to perform under our Terms with you, which enables us to provide you with the Services. When we process Personal Data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such Personal Data.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Your rights in the EU, UK, Lichtenstein, Norway or Iceland
If you are located in the EU, UK, Lichtenstein, Norway or Iceland, you have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email legal@geneva.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data by emailing us at legal@geneva.com.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such Personal Data by emailing us at legal@geneva.com.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such Personal Data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the Personal Data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data to the United States
The Services are hosted and operated in the United States (“U.S.”) through Geneva and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Geneva in the U.S. and will be hosted on U.S. servers, and you authorize Geneva to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to EU-U.S. Privacy Shield Framework, the details of which are further set forth below.
While the Privacy Shield is no longer a valid basis on which Geneva may rely to transfer Personal Data from the EU to the U.S. pursuant to the GDPR, Geneva continues to comply with Geneva has certified to the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection and use of Personal Data transferred from the EU. For more information about the Privacy Shield Program, and to view Geneva’s certification, please visit www.privacyshield.gov. Geneva is committed to the Privacy Shield Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the Privacy Shield. The Privacy Shield Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these Privacy Shield Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Geneva’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
Please contact us at legal@geneva.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through JAMS, an alternative dispute resolution provider located in the United States. You can visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means. If there is any conflict between the terms in this GDPR Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification please visit https://www.privacyshield.gov/.
Questions about your Personal Data if you are in the EU, UK, Lichtenstein, Norway or Iceland
If you have any questions about this GDPR Privacy Notice or our data practices generally, please contact us using the following information:
Jack Baylor Stealth Worker 2 Ashton Grove Gardiner’s Hill Cork, Ireland
Canadian Addendum
If you are a resident of Canada, the following Canada-specific provisions apply to you in addition to or in lieu of the relevant sections of the Privacy Policy. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Canadian resident, the portion that is more protective of personal information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at legal@geneva.com.
Transfer of Personal Information
The Services are hosted and operated in the United States (“U.S.”) and other jurisdictions through Geneva and its service providers, and laws in the U.S. and other jurisdictions may differ from the laws where you reside.
We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate. For information about the manner in which we or our service providers treat personal information, please contact us as set out in the “Contact Us” section of the Privacy Policy.
Access
Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody and control. You may request access, updating and corrections of inaccuracies in your personal information in our custody or control by contacting us as set out in the “Contact us” section of this Privacy Policy. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.
Updates
We will update our Terms and Privacy Policy as needed so that they are current, accurate, and as clear as possible. Any changes we make to our Terms or Privacy Policy in the future will be posted on this page and, when mandatory, notified to you directly in the Services.