PRIVACY POLICY
Last updated March
08, 2022
This privacy notice
for Genuine Marketing Group Inc. (doing business
as GMG) ("GMG," "we," "us,"
or "our"), describes how and why we might collect, store, use,
and/or share ("process") your information when you use our
services ("Services"), such as when you:
§
Visit our website at genuinemarketinggroup.com,
or any website of ours that links to this privacy notice
§
Engage with us in other related ways ― including any sales,
marketing, or events
Questions or
concerns?
Reading this privacy notice will help you understand your
privacy rights and choices. If you do not agree with our policies and
practices, please do not use our Services. If you still have any questions or
concerns, please contact us at [email protected].
SUMMARY OF KEY POINTS
This summary provides
key points from our privacy notice, but you can find out more details about any
of these topics by clicking the link following each key point or by using our
table of contents below to find the section you are looking for. You can also
click
here
to
go directly to our table of contents.
What personal
information do we process?
When you visit, use, or navigate
our Services, we may process personal information depending on how you interact
with GMG and the Services, the choices you make, and the products and
features you use. Click
here
to
learn more.
Do we process any
sensitive personal information?
We do not process
sensitive personal information.
Do you receive any
information from third parties?
We do not receive
any information from third parties.
How do you process my
information?
We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud
prevention, and to comply with law. We may also process your information for
other purposes with your consent. We process your information only when we have
a valid legal reason to do so. Click
here
to
learn more.
In what situations and
with which parties do we share personal information?
We
may share information in specific situations and with specific third
parties. Click
here
to
learn more.
How do we keep your
information safe?
We have organizational and technical processes and procedures
in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat
our security and improperly collect, access, steal, or modify your information.
Click
here
to
learn more.
What are your rights?
Depending
on where you are located geographically, the applicable privacy law may mean
you have certain rights regarding your personal information. Click
here
to
learn more.
How do I exercise my
rights?
The easiest way to exercise your rights is by filling
out our data subject request form available
here
, or
by contacting us. We will consider and act upon any request in accordance with
applicable data protection laws.
Want to learn more about
what GMG does with any information we collect? Click
here
to
review the notice in full.
TABLE OF CONTENTS
1. WHAT
INFORMATION DO WE COLLECT?
2. HOW DO
WE PROCESS YOUR INFORMATION?
3. WHAT
LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN
AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW
LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO
WE KEEP YOUR INFORMATION SAFE?
7. DO WE
COLLECT INFORMATION FROM MINORS?
8. WHAT
ARE YOUR PRIVACY RIGHTS?
9.
CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO
CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE
MAKE UPDATES TO THIS NOTICE?
12. HOW
CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE
COLLECT?
Personal information you
disclose to us
In Short:
We
collect personal information that you provide to us.
We collect personal
information that you voluntarily provide to us when you express an
interest in obtaining information about us or our products and Services, when
you participate in activities on the Services, or otherwise when you contact
us.
Personal Information
Provided by You.
The personal information that we collect depends on
the context of your interactions with us and the Services, the choices you
make, and the products and features you use. The personal information we
collect may include the following:
§
names
§
email addresses
Sensitive Information.
We
do not process sensitive information.
All personal information
that you provide to us must be true, complete, and accurate, and you must
notify us of any changes to such personal information.
2. HOW DO WE PROCESS YOUR
INFORMATION?
In Short:
We
process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent.
We process your personal
information for a variety of reasons, depending on how you interact with our
Services, including:
§
To save or protect an individual's
vital interest.
We may process your information when necessary to
save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE
RELY ON TO PROCESS YOUR INFORMATION?
In Short:
We
only process your personal information when we believe it is necessary and we
have a valid legal reason (i.e., legal basis) to do so under applicable law,
like with your consent, to comply with laws, to provide you with services to
enter into or fulfill our contractual obligations, to protect your rights, or
to fulfill our legitimate business interests.
If you are located in
the EU or UK, this section applies to you.
The General Data
Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal
bases we rely on in order to process your personal information. As such, we may
rely on the following legal bases to process your personal information:
§
Consent.
We may
process your information if you have given us permission (i.e., consent) to use
your personal information for a specific purpose. You can withdraw your consent
at any time. Click
here
to
learn more.
§
Legal Obligations.
We
may process your information where we believe it is necessary for compliance
with our legal obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your
information as evidence in litigation in which we are involved.
§
Vital Interests.
We
may process your information where we believe it is necessary to protect your
vital interests or the vital interests of a third party, such as situations
involving potential threats to the safety of any person.
If you are located in
Canada, this section applies to you.
We may process your
information if you have given us specific permission (i.e., express consent) to
use your personal information for a specific purpose, or in situations where
your permission can be inferred (i.e., implied consent). You can withdraw your consent
at any time. Click
here
to
learn more.
In some exceptional
cases, we may be legally permitted under applicable law to process your
information without your consent, including, for example:
§
If collection is clearly in the interests of an individual
and consent cannot be obtained in a timely way
§
For investigations and fraud detection and prevention
§
For business transactions provided certain conditions are
met
§
If it is contained in a witness statement and the
collection is necessary to assess, process, or settle an insurance claim
§
For identifying injured, ill, or deceased persons and
communicating with next of kin
§
If we have reasonable grounds to believe an individual has
been, is, or may be victim of financial abuse
§
If it is reasonable to expect collection and use with
consent would compromise the availability or the accuracy of the information
and the collection is reasonable for purposes related to investigating a breach
of an agreement or a contravention of the laws of Canada or a province
§
If disclosure is required to comply with a subpoena,
warrant, court order, or rules of the court relating to the production of
records
§
If it was produced by an individual in the course of their
employment, business, or profession and the collection is consistent with the
purposes for which the information was produced
§
If the collection is solely for journalistic, artistic, or
literary purposes
§
If the information is publicly available and is specified
by the regulations
4. WHEN AND WITH WHOM DO
WE SHARE YOUR PERSONAL INFORMATION?
In Short:
We
may share information in specific situations described in this section and/or
with the following third parties.
We may need to
share your personal information in the following situations:
§
Business Transfers.
We
may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition
of all or a portion of our business to another company.
5. HOW LONG DO WE KEEP
YOUR INFORMATION?
In Short:
We
keep your information for as long as necessary to fulfill the purposes outlined
in this privacy notice unless otherwise required by law.
We will only keep your
personal information for as long as it is necessary for the purposes set out in
this privacy notice, unless a longer retention period is required or permitted
by law (such as tax, accounting, or other legal requirements). No purpose in
this notice will require us keeping your personal information for longer
than 1 year.
When we have no ongoing
legitimate business need to process your personal information, we will either
delete or anonymize such information, or, if this is not possible (for example,
because your personal information has been stored in backup archives), then we
will securely store your personal information and isolate it from any further
processing until deletion is possible.
6. HOW DO WE KEEP YOUR
INFORMATION SAFE?
In Short:
We aim
to protect your personal information through a system of organizational and
technical security measures.
We have implemented
appropriate and reasonable technical and organizational security measures
designed to protect the security of any personal information we process.
However, despite our safeguards and efforts to secure your information, no
electronic transmission over the Internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorized third parties will not be able
to defeat our security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission
of personal information to and from our Services is at your own risk. You
should only access the Services within a secure environment.
7. DO WE COLLECT
INFORMATION FROM MINORS?
In Short:
We
do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly
solicit data from or market to children under 18 years of age. By using the
Services, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the
Services. If we learn that personal information from users less than 18 years
of age has been collected, we will deactivate the account and take reasonable
measures to promptly delete such data from our records. If you become aware of
any data we may have collected from children under age 18, please contact us
at [email protected].
8. WHAT ARE YOUR PRIVACY
RIGHTS?
In Short:
In
some regions, such as the European Economic Area (EEA), United Kingdom
(UK), and Canada, you have rights that allow you greater access to and control
over your personal information. You may review, change, or terminate your
account at any time.
In some regions
(like the EEA, UK, and Canada), you have certain rights under applicable
data protection laws. These may include the right (i) to request access and
obtain a copy of your personal information, (ii) to request rectification or
erasure; (iii) to restrict the processing of your personal information; and
(iv) if applicable, to data portability. In certain circumstances, you may also
have the right to object to the processing of your personal information. You
can make such a request by contacting us by using the contact details provided
in the section “
HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
” below.
We will consider and act
upon any request in accordance with applicable data protection laws.
If you are located in
the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection
supervisory authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
.
If you are located in
Switzerland, the contact details for the data protection authorities are
available here:
https://www.edoeb.admin.ch/edoeb/en/home.html
.
Withdrawing your
consent:
If we are relying on your consent to process your
personal information, which may be express and/or implied consent
depending on the applicable law, you have the right to withdraw your
consent at any time. You can withdraw your consent at any time by contacting us
by using the contact details provided in the section "
HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
" below.
However, please note
that this will not affect the lawfulness of the processing before its
withdrawal, nor when applicable law allows, will it affect the
processing of your personal information conducted in reliance on lawful
processing grounds other than consent.
Opting out of marketing
and promotional communications:
You can unsubscribe from
our marketing and promotional communications at any time by clicking on
the unsubscribe link in the emails that we send, or by contacting us using
the details provided in the section "
HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
" below. You will then be removed
from the marketing lists — however, we may still communicate with you, for
example to send you service-related messages that are necessary for the
administration and use of your account, to respond to service requests, or for
other non-marketing purposes.
If you have questions or
comments about your privacy rights, you may email us
at [email protected].
9. CONTROLS FOR
DO-NOT-TRACK FEATURES
Most web browsers and
some mobile operating systems and mobile applications include a Do-Not-Track
("DNT") feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and
collected. At this stage no uniform technology standard for recognizing and
implementing DNT signals has been finalized. As such, we do not currently
respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about
that practice in a revised version of this privacy notice.
10. DO CALIFORNIA
RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:
Yes,
if you are a resident of California, you are granted specific rights regarding
access to your personal information.
California Civil Code
Section 1798.83, also known as the "Shine The Light" law, permits our
users who are California residents to request and obtain from us, once a year
and free of charge, information about categories of personal information (if
any) we disclosed to third parties for direct marketing purposes and the names
and addresses of all third parties with which we shared personal information in
the immediately preceding calendar year. If you are a California resident and
would like to make such a request, please submit your request in writing to us
using the contact information provided below.
If you are under 18
years of age, reside in California, and have a registered account with
Services, you have the right to request removal of unwanted data that you
publicly post on the Services. To request removal of such data, please contact
us using the contact information provided below and include the email address
associated with your account and a statement that you reside in California. We
will make sure the data is not publicly displayed on the Services, but please
be aware that the data may not be completely or comprehensively removed from
all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of
Regulations defines a "resident" as:
(1) every individual who
is in the State of California for other than a temporary or transitory purpose
and
(2) every individual who
is domiciled in the State of California who is outside the State of California
for a temporary or transitory purpose
All other individuals
are defined as "non-residents."
If this definition of
"resident" applies to you, we must adhere to certain rights and
obligations regarding your personal information.
What categories of
personal information do we collect?
We have collected the
following categories of personal information in the past twelve (12) months:
|
Category
|
Examples
|
Collected
|
|
A. Identifiers
|
Contact details, such
as real name, alias, postal address, telephone or mobile contact number,
unique personal identifier, online identifier, Internet Protocol address,
email address, and account name
|
YES
|
|
B. Personal
information categories listed in the California Customer Records statute
|
Name, contact
information, education, employment, employment history, and financial
information
|
YES
|
|
C. Protected
classification characteristics under California or federal law
|
Gender and date of
birth
|
NO
|
|
D. Commercial
information
|
Transaction
information, purchase history, financial details, and payment information
|
NO
|
|
E. Biometric
information
|
Fingerprints and
voiceprints
|
NO
|
|
F. Internet or other
similar network activity
|
Browsing history,
search history, online behavior, interest data, and interactions with our and
other websites, applications, systems, and advertisements
|
NO
|
|
G. Geolocation data
|
Device location
|
NO
|
|
H. Audio, electronic,
visual, thermal, olfactory, or similar information
|
Images and audio,
video or call recordings created in connection with our business activities
|
NO
|
|
I. Professional or
employment-related information
|
Business contact
details in order to provide you our services at a business level or job title,
work history, and professional qualifications if you apply for a job with us
|
NO
|
|
J. Education
Information
|
Student records and
directory information
|
NO
|
|
K. Inferences drawn
from other personal information
|
Inferences drawn from
any of the collected personal information listed above to create a profile or
summary about, for example, an individual’s preferences and characteristics
|
NO
|
We may also collect
other personal information outside of these categories instances where you
interact with us in person, online, or by phone or mail in the context of:
§
Receiving help through our customer support channels;
§
Participation in customer surveys or contests; and
§
Facilitation in the delivery of our Services and to respond
to your inquiries.
How do we use and share
your personal information?
More information about
our data collection and sharing practices can be found in this privacy notice.
You may contact
us by visiting
http://www.genuinemarketinggroup.com/contact
, or
by referring to the contact details at the bottom of this document.
If you are using an
authorized agent to exercise your right to opt out we may deny a request if the
authorized agent does not submit proof that they have been validly authorized
to act on your behalf.
Will your information be
shared with anyone else?
We may disclose your
personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit
entity that processes the information on our behalf.
We may use your personal
information for our own business purposes, such as for undertaking internal
research for technological development and demonstration. This is not
considered to be "selling" of your personal information.
Genuine Marketing Group
Inc. has not disclosed or sold any personal information to third parties
for a business or commercial purpose in the preceding twelve (12)
months. Genuine Marketing Group Inc. will not sell personal
information in the future belonging to website visitors, users, and other
consumers.
Your rights with respect
to your personal data
Right to request
deletion of the data — Request to delete
You can ask for the
deletion of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the
exercise by another consumer of his or her right to free speech, our compliance
requirements resulting from a legal obligation, or any processing that may be
required to protect against illegal activities.
Right to be informed —
Request to know
Depending on the
circumstances, you have a right to know:
§
whether we collect and use your personal information;
§
the categories of personal information that we collect;
§
the purposes for which the collected personal information
is used;
§
whether we sell your personal information to third parties;
§
the categories of personal information that we sold or
disclosed for a business purpose;
§
the categories of third parties to whom the personal
information was sold or disclosed for a business purpose; and
§
the business or commercial purpose for collecting or
selling personal information.
In accordance with
applicable law, we are not obligated to provide or delete consumer information
that is de-identified in response to a consumer request or to re-identify
individual data to verify a consumer request.
Right to
Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate
against you if you exercise your privacy rights.
Verification process
Upon receiving your
request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. These verification
efforts require us to ask you to provide information so that we can match it
with information you have previously provided us. For instance, depending on
the type of request you submit, we may ask you to provide certain information
so that we can match the information you provide with the information we
already have on file, or we may contact you through a communication method
(e.g., phone or email) that you have previously provided to us. We may also use
other verification methods as the circumstances dictate.
We will only use
personal information provided in your request to verify your identity or
authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if
we cannot verify your identity from the information already maintained by us,
we may request that you provide additional information for the purposes of
verifying your identity and for security or fraud-prevention purposes. We will
delete such additionally provided information as soon as we finish verifying
you.
Other privacy rights
§
You may object to the processing of your personal
information.
§
You may request correction of your personal data if it is
incorrect or no longer relevant, or ask to restrict the processing of the
information.
§
You can designate an authorized agent to make a request
under the CCPA on your behalf. We may deny a request from an authorized agent
that does not submit proof that they have been validly authorized to act on
your behalf in accordance with the CCPA.
§
You may request to opt out from future selling of your
personal information to third parties. Upon receiving an opt-out request, we
will act upon the request as soon as feasibly possible, but no later than
fifteen (15) days from the date of the request submission.
To exercise these
rights, you can contact us by visiting
http://www.genuinemarketinggroup.com/contact
, or
by referring to the contact details at the bottom of this document. If you have
a complaint about how we handle your data, we would like to hear from you.
11. DO WE MAKE UPDATES TO
THIS NOTICE?
In Short:
Yes,
we will update this notice as necessary to stay compliant with relevant laws.
We may update this
privacy notice from time to time. The updated version will be indicated by an
updated "Revised" date and the updated version will be effective as
soon as it is accessible. If we make material changes to this privacy notice,
we may notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this privacy
notice frequently to be informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US
ABOUT THIS NOTICE?
If you have questions or
comments about this notice, you may email us
at [email protected] or by post to:
Genuine Marketing Group
Inc.
345 James Pkwy
Elko New Market
, MN 55054
United States
13. HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable
laws of your country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it in some
circumstances. To request to review, update, or delete your personal
information, please submit a request form by clicking
here
.
This privacy policy was
created using Termly's
Privacy Policy Generator
.