Privacy and Cookie policy

This Privacy Policy governs the collection and processing by company GenoSafe of personal data (hereinafter “Personal Data”) of users and customers (hereinafter the “Users”) of the website www.genosafe.com (hereinafter the “Website”). More broadly, this Privacy Policy also governs the processing of Personal Data carried out by GenoSafe in the frame of its activities.

What is Personal Data?

Personal Data is any information used to identify or make identifiable a natural person, and for example: your name, your email address, your phone number or IP address.

This Privacy Policy is applicable to any use by the User of the Website and its various services, including browsing the Website, and the sending of commercial or promotional information, and the processing carried out by GenoSafe for the performance of its business.

1. Identity of the data controller

GenoSafe, a French simplified joint stock company with a capital of 650,000 euros, registered in the Trade and Companies Registry of Evry under No.449 932 474, and whose registered office is located 1 bis rue de l’Internationale – 91000 Evry, FRANCE, is the data controller in charge of the processing of Personal Data carried out through the Website.

As such, GenoSafe undertakes to comply with applicable data protection regulations, and in particular with French amended Law No.78-17 of 6 January 1978 (said “Information Technology and Freedoms”) and the General Data Protection Regulation (“GDPR”).

GenoSafe can be contacted by mail to the above-mentioned address or by email to dpocontacts@genosafe.com.

In the frame of the services it offers, GenoSafe may in some cases process Personal Data on behalf of third parties, as data processor.

In this case, GenoSafe undertakes to process such Personal Data in accordance with the applicable data protection regulation, in particular to ensure security of such Data. GenoSafe also undertakes to enter with the relevant contractual terms with its clients data controllers in order to supervise such processing.

2. Purposes of the processing of Personal Data

When Users visit the Website or use its various services, or hava a relationship of any kind with GenoSafe, they may provide Personal Data to GenoSafe which are subject to a computer processing. Such Personal Data are stored and used by GenoSafe for the following purposes:

• Allow the User to access the Website and use its various functionalities;
• Communicate with Users to answer their potential demands, requests and/or claims;
• Administer or answer to potential disputes or judicial requisitions;
• Measure the performances of the Website, and for instance the number of page views or the number of clicks;
• Produce statistics, use them internally and share them with its processors;
• Register and manage the orders and provide the corresponding services;
• Manage the company’s invoices and accounting;
• Collect and analyze feedback from customers on GenoSafe’s services;
• Manage the Users’ request for the exercise of their rights;
• Manage spontaneous applications for employment within the company.

Furthermore, when the User visits the Website, some navigation data may be collected and processed by GenoSafe or by any third-party processor of its choice for statistical purposes and/or to improve the presentation and use of the Website, and in particular to measure and improve the number of pages visited, the number of visits and the User’s path through the Website.

3. Legal basis of the processing of Personal Data

Some processing of Personal Data carried out by GenoSafe according to the above-mentioned purposes are necessary to allow GenoSafe to:

• Comply with its contractual or pre-contractual obligations towards Users;
• Comply with its legal obligations;
• Meet certain legitimate interests, in particular those relating to the management of its commercial activities.

In all other cases, the processing of Personal Data carried out by GenoSafe is possible insofar as the User has expressly contented to it by clicking a tick-box.

4. Security of Personal Data

GenoSafe undertakes to take all technical and organizational measures necessary to ensure the protection and security of Personal Data, in particular against loss, alteration, dissemination or illegal use.

GenoSafe ensures that such measures are implemented on all operations carried out in the frame of its processing, and in particular when Personal Data is being collected, stored or hosted.

In this regard, GenoSafe also ensures that the third parties it may call upon (technical service providers, suppliers, etc.) comply with this requirement to protect the User’s Personal Data by implementing appropriate measures in accordance with the GDPR. The technical and organizational measures which are implemented may include the use of secured registration forms, encryption of certain data and restricted access to Personal Data.

GenoSafe invites Users to exercise the utmost caution in the communication of their Personal Data by themselves to third parties.

Some messages or requests received may come from malicious persons seeking to obtain personal information about the User for fraudulent use (phishing). If Users receive a message which appears to be a phishing attempt, they are requested not to reply and not to open any attachments, images or links contained in the message. Users can report it by sending an email to dpocontacts@genosafe.com or on www.signal-spam.fr.

5. Recipients of Personal Data

The User’s Personal Data is intended for GenoSafe. However, such Data may be communicated by the latter to third-parties processors to ensure access and use to the Website and its services.

The User’s Personal Data is not subject to any communication or transfer to third parties for commercial or promotional purposes.

The User’s choice to receive offers or commercial prospection messages from GenoSafe and/or its partners is subject to its prior express consent by clicking the corresponding tick-box when asked to provide Personal Data. If the User no longer whishes to receive them, he may unsubscribe at any time through the link included at the bottom of each message received or by contacting Genosafe by email to dpocontacts@genosafe.com.

In some cases, GenoSafe may communicate the User’s Personal Data to any administrative or judicial authority which would make such request, in accordance with the legislation in force.

6. Transfer of Personal Data outside of the European Union

In the frame of its activities of data controller, GenoSafe does not transfer Personal Data outside of the territory of the European Union.

The use of certain tools may also allow such transfer, for instance the use of Google Analytics. In such a case, GenoSafe undertakes to check that the provider of said service, if located outside of the European Union, complies with all the principles and obligations arising from the GDPR.

7. Storage duration of Personal Data

GenoSafe only stores the User’s Personal Data for a limited period of time, which is determined by reference to the nature of Data at issue and the processing involved.

Personal Data is thus stored for the following durations:

• Prospects data: 36 months from last connection or contact;
• Customer data: 36 months from the end of contractual relationship;
• Candidates data: 24 months from last contact;
• Data collected by cookies: see section 9.

Once these durations have been reached, some Personal Data may be subject to an archiving procedure for accounting management purposes and for the management of disputes or requisitions, for a duration which cannot exceed the legal requirements in these matters.

8. Users’ rights

Pursuant to French amended Law No.78-17 of 6 January 1978 (said “Information Technology and Freedoms”) and to the General Data Protection Regulation (“GDPR”), each User has a right to access, rectify, erase or delete all or part of the Personal Data about him/her, a right to object, a right to the limitation of the processing and a right to the portability of Personal Data, which can be exercised by sending a mail to GenoSafe, 1bis rue de l’Internationale – 91002 Evry Cedex, FRANCE, or by email to [to be completed].

For consent-based processing, the User also has a right to withdraw his/her consent at any time.

The User is warned that the exercise of these rights does not affect the validity of the processing operations carried out beforehand, nor the right of GenoSafe to proceed to the archiving of some of the Personal Data in question, in accordance with the principles set out above.

Such requests must be submitted by the User personally and in writing. If required, the User may be invited to prove his/her identity in particular by providing copy of their ID. This information will only be processed for User identification purposes and will not be retained for longer than the time required to process the response. The request will specify the e-mail or postal address to which the possible answer should be sent. GenoSafe will have a one-month period to respond following receipt of the request.

The User also has the right to lodge a complaint with the authorities, and in particular with the CNIL (www.cnil.fr).

9. Use of cookies

When the User visits the Website, cookies or other tracers may be installed on his/her equipment (computer, tablet or mobile phone).

Cookies are generally used to measure and assess the behavior of Users who access a website (number of visitors, duration of visits, most consulted elements, etc.). There are several types of cookies, among which some are non-identifying, and others that are identifying. Some cookies may be combined to other data in order to personalize the User’s experience on the Website. When cookies are identifying, they allow the collection and processing of Personal Data.

GenoSafe uses cookies when the User browses the Website. Such cookies are used for the purpose of measuring the traffic of the Website, providing GenoSafe with information relating to how the User travels on the Website and improving the User’s experience on the Website.

Cookies Necessary

Ces cookies sont absolument essentiels au bon fonctionnement du Site et des services qui y sont offerts. Ils ne peuvent pas être désactivés.

Cookies Analytic

Used to understand how users interact with the Site and to measure its performance.

Third parties may also use cookies to collect data relating to the User’s browsing. GenoSafe is not responsible in any way for any operation related to the use of third-parties’ cookies.

These cookies are subject to their own cookie policies which are accessible on each website of the third parties concerned and that GenoSafe invites the User to review.

In this regard, the User is invited to consult the following links to learn more about how he/she can manage or delete cookies from his/her browser:

• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies;
• Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en;
• Safari: https://support.apple.com/en-us/guide/safari/sfri11471/mac;
• Mozilla Firefox: https://support.mozilla.org/en/kb/activate-deactivate-cookies-preferences;
• Opera: https://help.opera.com/en/latest/security-and-privacy/.

Additional information on how the User may configure his/her browser and limit the action of cookies is available on the CNIL’s website (www.cnil.fr). The User may also consult the following websites: www.youronlinechoices.eu and www.allaboutcookies.org.

If the User decides to disable or block some cookies, the functionalities which are associated to such cookies (for instance personalization of the browsing experience on the Website) may not be applied.

Manage consent

10. Modification of this Privacy Policy

This Privacy Policy has been updated in May 2019 and may be amended by GenoSafe at any time.

In case of amendment of this Privacy Policy, the new version in force will be applicable to the User as of his/her connection to the Website.

In case of a dispute between the User and GenoSafe, the Privacy Policy to be taken into account will be the one in force at the time of the facts at the origin of such dispute.