Privacy Policy
Last updated: December 1, 2025
INTRODUCTION
This Privacy Policy (the “Policy”) describes the practices of Genezio SRL with is registered office at Bucharest, 1st District, 12. Lt. D. Darian Street (hereinafter “Genezio”, “we” or “us”) with respect to the Personal Information collected, stored, used, transferred, shared and otherwise processed from data subjects when and to the extent Genezio is a controller of such data subjects (“you”).
“Personal Information” means, as applicable, information related to an identified or identifiable natural person as defined by Regulation (EU) 2016/679 (“GDPR”).
This Policy sets forth your rights and remedies under the GDPR, so please read it carefully.
This Privacy Policy does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers, including where we offer to our customers various products and services through which our customers (or their affiliates collect), use, share or process Personal Data.
For detailed privacy information related to a Genezio customer or a customer affiliate who uses Genezio products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Policy.
For questions or requests regarding the Policy and the exercise of any of your rights hereunder or under the Law, please do not hesitate to contact us by e-mail at privacy@genezio.com.
THE POLICY DESCRIBES, AMONG OTHERS:
- what Personal Information we collect and process;
- the purposes for which we collect and use your Personal Information;
- the grounds on which the processing is carried out;
- general information on retention periods;
- your rights and how to exercise them;
- to whom we may disclose your Personal Information;
- the countries to which we may transfer your Personal Information;
PROCESSING ACTIVITIES
This Privacy Policy applies to the processing of Personal Data collected by Genezio when you:
- Visit our websites;
- Visit our branded social media pages;
- Visit our offices;
- Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, texts or faxes;
- Use our webistes, products and services (“Services”) where we act as a controller of your Personal Data;
- Register for, attend or take part in our events, webinars, programs, trainings, certifications or contests;
- Act as or work for a service provider or supplier to Genezio, to the extent Genezio acts as a controller with respect to your Personal Data;
- Respond to or apply to hiring or collaboration announceents; or
- Participate in surveys, research or other similar data collection facilitated by us;
We process, as controller, Personal Information we receive from third-parties, inclusing our customers.
In relation to the foregoing, we may process the following data: name; email address; phone number; postal address (including billing name/address); country; job title/occupation; company name; arrival date and time (event attendance logistics); photos; video recordings; voice recordings; biometric information (facial image/facial features used for identification, where you explicitly consent and only for specified events); financial/payment information (e.g., credit card number, bank account information, billing details); online identifiers and device/network data (e.g., IP address and similar identifiers); website/email interaction data collected via cookies, web beacons, and similar technologies (usage/engagement data); service usage data collected via log files and similar technologies (usage data); social media profiles or usernames; areas of expertise and interests; health and other type of required information for employment purposes as required by the law; and any other personal data you voluntarily provide.
PURPOSE AND BASIS OF PROCESSING
We process Personal Information for these non-limited purposes:
| Purpose of processing | Legal basis for the purpose of processing |
|---|---|
| To provide, maintain and facilitate the Service to you, to support the Service functions and your use of the Service | Contract, Legitimate interest, Consent |
| To improve or customize the Service or other offerings (testing, research, internal analytics and product development) | Contract, Legitimate Interest, Consent |
| For making our recommendations and promotional communications to you, for example through emails, including for third-party products and offerings | Consent, Legitimate interest |
| To communicate with you for non-marketing purposes including by sending you Services related e-mails, push notifications, and other messages | Contract, Consent, Legitimate interest, Legal obligation |
| To operate our business, including creating and managing user accounts or other user profiles, analyzing and monitoring our performance, usage and activities in connection with our Services | Legal obligation, Legitimate interest, Consent, Contract |
| To investigate and resolve disputes, to establish, exercise or defend our legal claims, and to enforce our terms | Legal obligation, Legitimate interest, Consent |
| To investigate and resolve security issues | Legal obligation, Legitimate interest, Contract, Consent |
| To understand, diagnose, troubleshoot, resolve a fault or other issues related to the Services provided, and to provide customer assistance | Consent, Contract, Legitimate interest |
| To de-identify/anonymize Personal Information | Legitimate interest, Consent, Contract |
| To fulfil contractual obligations with third parties. | Legitimate interest, Consent, Contract |
| To prevent, detect, investigate fraud, including fraudulent payments and fraudulent use of the Services, abuse, violations and other trust and safety protocols of our terms, unlawful or criminal activity, unauthorized access to or use of Personal Information or Genezio’s systems and networks, to protect our rights and the rights of others, and to meet legal, governmental, and institutional policy obligations | Legal obligation, Legitimate interest, Consent, Contract |
| To process orders and other transactions, including billing. | Contract, Consent |
| Employment and hiring related matters | Legal obligation, Legitimate interest, Consent, Contract |
| Managing, and participating in, webinars, contests, programs, training, certifications or promotions | Consent, Contract, Legitimate interest |
| To conduct survery and/or research | Consent, Contract, Legitimate interest |
COLLECTING YOUR DATA
Where data is requested directly from you, Genezio asks you to provide those categories of Personal Information that we require for the purposes mentioned above.
Genezio may obtain Personal Information from third party sources, including customers, third-party cloud, software or services providers, or third-party tracking technologies such as cookies.
SHARING PERSONAL INFORMATION
There are certain circumstances in which we may disclose, transfer or share your data with certain third parties with or without notifying you in advance, as you will see below:
| Categories of recipients | Reason for data sharing |
|---|---|
| Service providers and Business Partners | For the purposes described in this Policy, such as business and Services functionality purposes, including Services and data hosting, online advertising technologies, cloud hosting, research, auditing, data processing, and to ensure compliance with industry standards, we work with service providers, primarily digital service providers, who work on our behalf and who may need access to certain Personal Information in order to provide their services to us and for us to provide our Services to you. These companies include providers of management services, hosting services, email correspondence, cloud services, database management, advertising services. |
| Law enforcement | We share your Personal Information when we believe in good faith that it is necessary to do so in order to comply with a legal obligation under applicable law. We also share your Personal Information when we have a good-faith belief that doing so is necessary for our legitimate interests, rights and safety or those of a third party. |
| Buyers of our business | We will share your Personal Information if we sell or negotiate the sale of our business, assets and/or data to a buyer or potential buyer, if we are implied in corporate transactions, bankruptcy, change of control or other situation involving the transfer of our business, assets and/or data. |
| Relevant authorities | We will share your Personal Information with governmental regulatory authorities, as required by law, including for legal, tax or accounting purposes, in response to their requests for such information or to assist in investigations, based on their legal obligations. These public authorities or institutions may be relevant data protection authorities or consumer protection authorities. |
| Genezio’s employees and contractors | In order to ensure that the Service is working and to guarantee compliance with the applicable legislation, our collaborators and contractors may process your Personal Information. |
| Third parties | We may also disclose Personal Information to third parties in connection with claims, disputes or litigation, when otherwise permitted or required by law, or if we determine its disclosure is necessary to protect the health and safety of you or any other person, to protect against fraud or credit risk, to enforce our legal rights or the legal rights of others, to enforce contractual commitments that you have made, or as otherwise permitted or required by applicable law. |
| Third Parties and other users You Share Information With | Some features of the Service may enable you to share content with third-party applications or other users. Any information you choose to share with these parties will be governed by their own terms and privacy policies. |
| With an individual’s consent | Genezio will otherwise disclose Personal Information when an individual gives us permission or directs us to disclose this information. |
DATA SECURITY
We have implemented at least reasonable and appropriate physical, technical and organizational measures to protect the data we collect and to prevent unauthorized access, disclosure and misuse of your Personal Information, such as data encryption and access controls.
Our Service involve integrations with third party LLM’s, or may direct you to, websites, apps, and services managed by third parties.
By interacting with these third parties, you are providing information directly to the third party and not to Genezio and you are subject to the third party’s privacy policy.
If you access third-party services, such as social media sites or other sites linked through the Service, these third-party services will be able to collect Personal Information about you, including information about your activity on the Services. If we link a site or service via our Services, you should read their data usage policies or other documentation. Our linking to another site or service doesn’t mean we endorse it or speak for that third party.
CHILDREN
To use our Services, you must be at least 18 years old.
RETENTION PERIOD
We will store and process your Personal Information for the period of time necessary to achieve the purposes described in this Policy and in accordance with our legal and contractual obligations, unless otherwise required by law or unless we have legitimate interests that allow us to do so for a longer term case in which data will be stored for this latter longer term. Thereafter, the data will be erased in accordance with our procedures, which may involve anonymization or destruction.
If you ask us to, we will delete or anonymize your Personal Information so that it can no longer be identified, unless we are permitted or required by law to retain certain Personal Information, including in situations such as the following:
- If there is an unresolved issue related to your use of the Service, such as an outstanding claim or an unresolved complaint or dispute, we will retain the necessary Personal Information until the issue is resolved;
- Where we need to retain Personal Information for our legal, tax, audit and accounting obligations, we will retain the Personal Information required for the period required by applicable law;
- When necessary for our legitimate business interests, such as to prevent fraud or to maintain the security of our users; and/or
- To enforce our rights and those of third parties.
YOUR RIGHTS AS PER GDPR
You have a number of rights in relation to the usage of your Personal Information by Genezio, which you can exercise by sending an e-mail to privacy@genezio.com.
- Right to information. You have the right to know how we handle your Personal Information in an appropriate and transparent way and what rights you can exercise in this respect. In this Policy, we have explained in detail what Personal Information we collect from you and how we handle your Personal Information.
- Right of access. You have the right to access your Personal Information we hold at any time. Please use your Authentication Data. In addition, we may ask you questions to verify your identity.
- Right to rectification. You have the right to rectify the Personal Information we hold about you where it is incorrect or out of date and/or to complete such data where it is incomplete. You can do this yourself 24/7 in your App account.
- Right to withdraw. This right entitles you to object to further processing of your Personal Information under the conditions and within the limits provided by law. In particular, if you have given your consent to our use of your Personal Information, you have the right to withdraw this consent at any time.
- Right to object to direct marketing. If Personal Information is processed for direct marketing purposes, you have the right to object at any time and free of charge to the processing of your Personal Information for direct marketing purposes by clicking on the “Unsubscribe” box when you receive such an email or by emailing us at the email above. If you object to processing for direct marketing purposes, your Personal Information will no longer be processed for such purposes. However, these opt-outs do not apply to communications that relate to order fulfillment, agreements, support, warnings about the safety of our products, or other administrative and transactional notices, where the primary purpose of such communications is not promotional.
- Right to data portability. You have the right to receive the Personal Information you have provided to us, in the context of the agreement you have entered into with us, to store this Personal Information in a database of your own or a third party. Please include your and account ID, name and e-mail address. In addition, we may ask you questions to verify your identity.
- Right to restriction of processing. You have the right to obtain restriction of the processing of your Personal Information in certain cases (for example, where you contest the accuracy of your Personal Information, for a period of time, to allow us to verify the accuracy).
- Right to have your account forgotten/deleted. In some cases, you have the right to be forgotten. In this case, we will assess whether we can delete your data or whether we need to retain certain data to comply with a legal obligation. You can ask us to delete (part of) your Personal Information.
- Right to complain. If you disagree with the way we handle your Personal Information, you have the right to lodge a complaint. If you have a complaint, we would like to resolve it with you first. Please include your name, e-mail address and Authentication Data when contacting us.
At the same time, you have the right to lodge a complaint directly to the National Supervisory Authority for Personal Information Processing (ANSPDP), with headquarters in Bulevardul Gheorghe Magheru nr. 28 - 30, sector 1, Bucharest (postal code: 010336; phone no: 0040 318.059.211).
Please note that under many countries' laws, you have the right to lodge a complaint with the supervisory authority in the place in which you live or work. A full list of EU supervisory authorities’ contact details is available here.
You also have the right to lodge a complaint with the competent court of law against us if you believe that your rights under the GDPR have been violated as a result of our processing your Personal Information, as well as against a legally binding decision of the ANSPDP relating to you and your Personal Information.
There is usually no fee for exercising the above rights.
You will not have to pay a fee to access your Personal Information (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
TRANSFERS TO OTHER COUNTRIES
Transfers from and outside of the EU
Genezio SRL is based in Romania. We do not transfer Personal Information outside the EU.
Whenever we transfer your Personal Information outside the EU, we endeavor to ensure that one of the following safeguards is in place:
- we only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection of Personal Information. For more details in the EU, please see European Commission: Adequacy Decisions;
- where we use certain service providers, we may use specific contracts, which provide the same protection for Personal Information as in the EU;
- where such data cannot be afforded one of the above protections, we will only transfer it outside of these territories if it is necessary for the performance of our contract with you or if we have your free, informed, clear and specific consent.
CHANGES TO OUR POLICY
We may change this Policy from time to time. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Service, or by other means consistent with applicable law) and will take additional steps as required by applicable law.