PRIVACY POLICY

This Privacy Policy was last updated on [20^th of April 2022.]

ABOUT THIS USER POLICY

We at GENLEAP Ecosystem Private Limited (“GENLEAP”, “we”, “us” and “our”) respect your privacy and we take privacy, security and complying with data protection and privacy laws seriously. Please read our Privacy Policy carefully to get a clear understanding of how we collect, use or otherwise handle your data/information. This Privacy Policy (“Privacy Policy”) applies when you visit or use the GENLEAP website, mobile applications or APIs (“GENLEAP Platform”), register on the GENLEAP Platform or when you avail the offerings, products and services available on the GENLEAP Platform from time to time (“Services”).

By using, accessing, or visiting any part of the GENLEAP Platform, becoming a registered user of the GENLEAP Platform, or by clicking through an acknowledgement, you agree to the terms of this Privacy Policy and consent to our collection, use, processing and disclosure of data/information in accordance with this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, you should not use or register on the GENLEAP Platform.

In addition to this Privacy Policy, users of the GENLEAP Platform should also consult the GENLEAP General Terms & Conditions as well as Product Specific Terms & Conditions that may apply.

1.    INFORMATION COVERED UNDER THIS USER PRIVACY POLICY

1.1.  This Privacy Policy applies to information we collect from you, automatically, when you are visiting/browsing through, or interacting with, the GENLEAP Platform. You can visit/browse any part of the GENLEAP Platform anonymously, without revealing any personal information/data.

1.2.  Personal Information (defined hereinafter) may be collected through this platform only when you voluntarily submit it when you register on the GENLEAP Platform and for availing the Services.

1.3.  Providing Personal Information is up to you. If you do not want your Personal Information collected, please do not submit it. If you choose not to give Personal Information to us, we may not be able to provide you with access to some pages on the GENLEAP Platform or our Services.

1.4.  This Privacy Policy also applies to information we collect from you when you create an account and place an order to avail any of the Services.

1.5.  When you register for an account on the GENLEAP Platform and place an order to avail any of the Services, we request that you provide certain Personal Information.

1.6.  ‘Personal Information’ refers to any information which may identify you in some way, either alone or in combination with other information. GENLEAP collects and stores the following types of Personal Information:

1.6.1.  Registration Information: information you provide about yourself when registering for and/or purchasing our offerings, products and services (e.g. name, email, phone number, address, user ID and password, and payment information);

1.6.2.  Genetic Information: information regarding your genotypes (i.e. the As, Ts, Cs, and Gs at particular locations in your genome), generated through processing of your DNA sample by GENLEAP and, or its partner service provider.

1.6.3.   Self-Reported Information: personal information you provide directly to us, including personal traits, ethnicity, family history and other information that you enter into surveys, forms, assessment tests/psychometric tests or features while signed into your GENLEAP account to avail any of the offerings, products or services on the GENLEAP Platform.

1.7.  You are responsible for ensuring the accuracy of the Personal Information you submit to GENLEAP. Inaccurate information may affect your ability to use and access the GENLEAP Platform, the information you receive when using the GENLEAP Platform, our ability to use and process your Personal Information, to provide/ deliver you with the offerings, products and services that you have placed an order for, and our ability to contact you.

2.    WHO COLLECTS THE DATA/INFORMATION

Subject to this Privacy Policy, the Terms of Use, and any other rules or policies applicable to the GENLEAP Platform, GENLEAP and certain third parties collect the information described in this Privacy Policy through the GENLEAP Platform.

2.1.  The GENLEAP Platform makes use of first and third-party cookies, web beacons, pixels and dynamic tags which may allow us and, or third parties to collect information about you and your activities on the GENLEAP Platform and provide you, or enable others to provide you, with functionality within our platform, additional personalization, or with targeted advertising. A cookie is a small text file that may be stored on the hard drive of your computer when you access the GENLEAP Platform. You are free to limit the types of cookies you allow or decline cookies altogether, but by doing so, you may not be able to use certain features on the GENLEAP Platform or take full advantage of all of our offerings and your experience may be different or less functional.

2.2.  GENLEAP and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints and web beacons when you access and use the GENLEAP Platform. These data collection tools automatically track and collect certain data/information when you use the GENLEAP Platform.

2.3.  The GENLEAP Platform may provide links to third-party websites and third-party managed pages, which are provided for your convenience only and to provide you with a better, more fulfilling experience when using/ accessing the GENLEAP Platform. We do not control and are not responsible for the security and content of such third-party websites, all of which have their own privacy policies and terms of use. You access them at your own risk. Inclusion of any linked third-party site on the GENLEAP Platform does not imply our approval or endorsement of the site, their content, their owners or their practices. Please be sure to read that company’s privacy and cookies policies before using or putting your personal information on their website. The same applies to any third-party websites or content you connect to using our products and services.

2.4.  Third party websites that you visit, from time to time, may drop their own cookies, web beacons, pixels or other tracking technologies on your browser or device. GENLEAP is not responsible for the information collected by those third parties or their privacy practices.

3.     INFORMATION WE COLLECT

3.1.  The types of information we may collect depend on the ways in which you engage with the GENLEAP Platform. This may include, where applicable:

3.1.1.      Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, internet service provider (ISP), browser software, browser language, domain names and other systems’ data, and platform types;

3.1.2.      Usage statistics about your interactions with the GENLEAP Platform, including content accessed, time spent on pages or the GENLEAP Platform, the number of times you return to the GENLEAP Platform, pages visited, the order in which they were visited, which hyperlinks were clicked, features used, your search queries, clickstream data, date and time and other data regarding your use of the GENLEAP Platform. We do not combine this non-personal information with your personal information;

3.1.3.      An approximate geographic location, including information like country, city, geographic coordinates, calculated based on your IP address;

3.1.4.      Information from the URLs from which you linked to the GENLEAP Platform;

3.2.  GENLEAP also collects and processes your Personal Information when you create an account, place an order for any of the Services, complete the assessment tests, surveys, sign-up for counselling, contact customer care, etc.

3.3.  We may also collect your DNA sample in connection with certain products and Services. We take your consent to analyze your DNA sample in order to provide you with the Services you have purchased.

3.4.  Below are some examples to help you better understand the Personal Information we collect:

3.4.1.  When you create or update your account, we collect and store the data you provide, like your email address, password, phone number, occupation, skill interests, gender, race, ethnicity, government ID information, verification photo, age, date of birth, and account settings;

3.4.2.  You also provide us with Personal Information when you take assessment tests/psychometric tests or engage with other features while signed into your GENLEAP account to avail any of the offerings, products or services on the GENLEAP Platform;

3.4.3.  When you make purchases, we collect certain data about your purchase (such as your name and ZIP code) as necessary to process your order. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new card and the last four digits of that card, from payment service providers to facilitate payments. For security, GENLEAP does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data;

3.4.4.  We may obtain certain information through your social media or other online accounts if they are connected to your GENLEAP account. If you login to GENLEAP via Facebook or another third-party platform or service, we ask for your permission to access certain information about that other account. For example, depending on the platform or service we may collect your name, profile picture, account ID number, login email address, location, physical location of your access devices, gender, birthday, and list of friends or contacts. Those platforms and services make information available to us through their APIs. The information we receive depends on what information you (via your privacy settings) or the third-party platform or service decide to give us. If you access or use the GENLEAP Platform through a third-party platform or service, or click on any third-party links, the collection, use, and sharing of your data will also be subject to the privacy policies and other agreements of that third party;

3.4.5.  If you contact us for support or to report a problem or concern, we collect and store your contact information, messages, and other data about you like your name, email address, messages, location and any other data you provide. We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.

3.5.  If you are a business enterprise or corporate prospect, we may collect certain business information from third-party commercial sources.

3.6.  We continuously work to enhance our Services with new products, applications and features that may result in the collection of new and different types of Personal Information. We will update our Privacy Policy as needed.

4.    HOW WE USE DATA/INFORMATION WE COLLECT

4.1.  We use information we automatically collect from you to improve your experience with the GENLEAP Platform and to provide you with opportunities and information you may be interested in. Our use of your information collected when accessing/browsing/visiting the GENLEAP Platform will be consistent with this Privacy Policy.

4.2.  We also use the information we automatically collect from you to render, administer and improve the platform, our products and services and our business. It helps us improve our platform and to deliver a better and more personalized service.

4.3.  Purposes for which we may use your information include, but are not limited to, the following:

4.3.1.      Presenting the GENLEAP Platform and its contents to you;

4.3.2.      Conducting research to improve our content and services and help to dynamically generate content on the platform;

4.3.3.      Statistically monitoring how many people are using the GENLEAP Platform;

4.3.4.      Tracking generic user behavior;

4.3.5.      Determining the popularity of certain content;

4.3.6.      Enabling us and our advertisers and social media partners to display online or printed advertisements to appropriate target audiences, including through behavioral advertising. The advertisements can be based on your recent activity or activity over time across other sites;

4.3.7. Storing information about your preferences, allowing us to provide additional platform functionality, personalizing content you may be interested in and remembering settings affecting the appearance and behavior of the platform. For example, we may use your approximate location to provide content that has been translated;

4.3.8. Providing other companies with statistical information about our users. This information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis;

4.3.9. For other commercially reasonable purposes, including measuring advertising and promotional effectiveness and assessing which areas of the GENLEAP Platform to re-market to you after you leave our platform;

4.3.10. Monitoring performance of the GENLEAP Platform and user experiences in order to trouble-shoot errors and performance issues and responding more effectively to customer inquiries;

4.4.  We use your information in compliance with mandatory legal obligations as may be required by law enforcement agencies, government bodies, regulatory organizations, courts or public authorities, or any other third party or body where such disclosure is required to satisfy any applicable law, or other legal or regulatory requirement. 

4.5.  We also use first and third party automatic data collection technologies to collect information about your online activities over time and across third party websites or other online services to deliver content and advertisements tailored to your interests, both on the GENLEAP Platform and on third party websites (including but not limited to search engines and social media websites). Third parties who provide us with third-party automatic data collection technologies may use these technologies to collect information about you when you use the GENLEAP Platform to provide you with advertisements based on your visit to the GENLEAP Platform or to collect data regarding the efficacy of advertising placed with us.

4.6.  GENLEAP may maintain a presence on third-party social networking sites such as Facebook, LinkedIn, Google, YouTube, Instagram, Twitter, and others. GENLEAP does not control or have responsibility for the collection, tracking, use, or disclosure of your information gathered through these social networking sites, including through the GENLEAP Platform or otherwise because of your participation on social networking sites. Third-party social networking sites may have the ability to link the information they collect about you when you use the GENLEAP Platform with other information they collect about you elsewhere on the internet and build a profile of user interests for targeted advertising purposes. The third-party social networking sites are not obligated to follow or apply this Privacy Policy.

4.7.  We use a variety of analytics and mathematically driven analysis techniques on large and varied data sets and information to uncover hidden patterns and trends. Analytics are used by us to conduct market research and carry out research and statistical analysis, frame our marketing campaigns and personalization efforts and provide reports to third parties (such reports would contain de-identified/anonymous data).

5.    HOW WE USE PERSONAL INFORMATION WE COLLECT

5.1.  We use the Personal Information we collect to provide you with Services, open your account, enable purchases and process payments, communicate with you and analyze and improve our Services. Our use of your information and any communications from you to us will be consistent with this Privacy Policy.

5.2.  Our legal basis for processing your Personal Information, in accordance with this Privacy Policy and Terms of Use, is based on your consent. You may withdraw your consent at anytime.

5.3.  Below are some examples to help you better understand how we use the Personal Information we collect:

5.3.1.  opening your account, enabling purchases and processing payments, communicating with you, and implementing your requests (e.g., referrals);

5.3.2.  processing and analyzing your genetic tests scores, birth-related information, psychometric test results and self-reported information to provide you with our Discovery Report (analyzing your traits and competencies providing you with an individualized competency profile), based on the Services purchased.

5.3.3.  sharing it with our third-party service providers as required to perform functions on our behalf in connection with the Services. To do so, it may be necessary for us to transmit your personal information to outside the applicable jurisdiction and you agree to this transfer.

5.3.4.  contacting you about your account, responding to your questions and concerns, sending you administrative messages and information, including messages from counselors, mentors, etc., sending you information about your status and progress and sharing any relevant information about our offerings, products and services;

5.3.5.  providing you with information about the offerings, products and services on the GENLEAP Platform, promotional and other offers from us and our partners. However, at the point of collection of your information we will provide you either an "opt in" or "opt-out" mechanism. An "opt-in" mechanism will provide you the opportunity to positively indicate that you would like, or do not object to, our sending you such further communications and we will not send it to you any unless you have "opted-in". An "opt-out" mechanism will provide you the opportunity to indicate that you do not want us to send you such further communications, and if you "opt-out", we will not send you any such communication. Please note, by opting-out, however, you may not be able to participate in certain activities on the GENLEAP Platform;

5.3.6.  providing customer support, as necessary to answer your questions, resolving disputes and, or investigating and troubleshooting problems or complaints;

5.3.7.  for other purposes set out when your information is collected or in any additional terms and conditions applicable to the particular offerings, products and services of the GENLEAP Platform;

5.3.8.  for disclosures required by law, regulation or court order;

5.3.9.  for the purpose of, or in connection with, legal proceedings or necessary for establishing, defending or exercising legal rights.

6.    WHO WE SHARE YOUR DATA/INFORMATION AND PERSONAL INFORMATION WITH

6.1.  Data/Information not being Personal Information:

6.1.1. As part of our use of third-party analytics tools, and we share certain data/information as needed. This allows these providers to provide analytics services. We do this to communicate with you in a more effective and customized manner.

6.1.2. The social media features (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the GENLEAP Platform you are visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.

6.1.3.  We may use and share certain data/information with third-party advertisers and networks to show general demographic and preference information among our users and to use this data to offer you targeted advertisement delivery to personalize your user experience (through behavioral advertising), and to undertake web analytics. Advertisers may also share the data they collect about you with us.

6.1.4.   We may disclose your data/information to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:

6.1.4.1.   Permitted or required by law;

6.1.4.2.   Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;

6.1.4.3.   Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;

6.1.4.4.   Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;

6.1.4.5.    Reasonably necessary, in our discretion, to protect against imminent harm to the rights, property, or safety of GENLEAP, our users, employees or members of the public; or

6.1.4.6.    We may also disclose your data/information to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy.

6.1.5.     If GENLEAP undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data/information and Personal Information to the successor organization during such transition or in contemplation of a transition (including during due diligence).

6.1.6.  We may disclose or use aggregated or de-identified data for any purpose. De-identified data means data where we have removed details like your name and email address and replaced it with a token ID.

6.2.  Personal Information:

6.2.1.  We may share your Personal Information with certain third parties including with your mentor, counsellor, employer, companies performing services for us, our business partners, educational partners, recruitment service providers, agents, suppliers or subcontractors insofar as necessary to facilitate and fulfill the contemplated transaction on the GENLEAP Platform. We may also share Personal Information for order fulfillment and shipping of the DNA sample with our logistics services providers to ship your DNA collector kit to you and to help you return your kit for processing, with our customer support, our cloud storage and IT service providers as well.

6.2.2.  We may also share certain Personal Information with your social media providers, companies helping us run promotions and surveys and advertising companies who help us promote our platform. We may also share your Personal Information as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we may share Personal Information in other ways if it is aggregated or de-identified or if we get your consent.

6.2.3.  Our service providers act on our behalf. We implement procedures and maintain contractual terms with each service provider to protect the confidentiality and security of your Personal Information. However, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.

7.    SECURITY

7.1.  GENLEAP maintains reasonable and appropriate safeguards designed to protect your Personal Information from unauthorized access, use, disclosure, alteration or destruction. For example, we limit our collection and use of your Personal Information to the extent necessary to provide you with the Services.

7.2.  However, as with any internet-enabled system, no system can be entirely secured, so we cannot guarantee the security of your data/information that we collect through the GENLEAP Platform. We cannot accept responsibility for any unauthorized access that is beyond our control. To the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorized access, misuse, or destruction of your data/information or Personal Information.

7.3.  We recognize the privacy interests of children and encourage parents and guardians to take an active role when they sign up on behalf of their children to avail our services. Individuals younger than 18 years of age, may not set up an account, but may have a parent or guardian open an account and help them access the appropriate content and share relevant and appropriate information.

7.4.  GENLEAP will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with others. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify GENLEAP of any unauthorized use of your password. GENLEAP cannot secure Personal Information that you release on your own or that you request us to release.

8.    RETENTION OF PERSONAL INFORMATION

8.1.  We retain your Personal Information for no longer than the period necessary for satisfying the purpose for which the Personal Information is collected and processed. We may also retain your Personal Information for longer if consented to by you or as necessary to comply with any obligation under law.

9.    YOUR RIGHTS

9.1.  You have certain rights around the use of your data. You can request GENLEAP to: correct inaccurate or misleading Personal Information; complete any incomplete Personal Information; erase Personal Information which is no longer necessary for the purpose for which it was processed; or terminate your account, by writing to GENLEAP at [support@genleaop.co].

9.2.  You can also update Personal Information you provide directly by logging into your account at any time.

9.3.  Parents who believe that we have unintentionally collected Personal Information about their underage child should contact us for help deleting that information.

10. MODIFICATIONS TO THIS USER PRIVACY POLICY

10.1.  From time to time, we may update this Privacy Policy. Unless stated otherwise, modifications will become effective on the day they are posted. The most recent version of the Privacy Policy will be posted on the GENLEAP Platform. Please be sure to review the most recent version of the Privacy Policy each time you visit the GENLEAP Platform. If you continue to use the GENLEAP Platform after the effective date of any change, then, your access and/or use will be deemed an acceptance of, and agreement to follow and be bound by, the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

11. JURISDICTION

11.1.  All matters relating to the GENLEAP Platform shall be governed by and construed in accordance with Indian laws, without regard to the rules relating to conflict of laws. This platform can be accessed from any place around the world. However, by accessing this platform you agree that the laws of India will apply to all matters relating to your use of the GENLEAP Platform. Users of the GENLEAP Platform accessing it from places outside India acknowledge that they do so voluntarily and are responsible for complying with local laws.

12. CONTACT US

12.1.  If you have any privacy related questions, suggestions or complaints, please feel free to contact us at support@genleap.co ]