Privacy Policy

Objective:

This Privacy Policy outlines the principles and practices followed by Genposys Technologies Private Limited (hereinafter referred to as “Genposys”) regarding the collection, processing, storage, use, and protection of personal information. This policy applies to the personal data of customers (including users of our websites, mobile applications, products, and services), employees (current and former), job applicants, vendors, contractors, partners, prospects, and board members whose personal information is processed by Genposys (“Data Subjects”).

This document explains how Genposys collects personal data, the purposes for which it is used, how it is safeguarded, and under what circumstances it may be disclosed. It covers both the information provided directly by you and data collected from other lawful sources, subject to applicable local regulations.

Throughout this Privacy Policy, the terms “Genposys”, “we”, “us”, or “our” refer to Genposys Technologies Private Limited and its affiliated entities.

Scope of this Privacy Policy

This Privacy Policy outlines how Genposys Technologies Private Limited (“Genposys”, “we”, “our”, or “us”) collects, uses, shares, and protects your personal information across its websites and digital platforms that reference or link to this Privacy Policy (collectively referred to as “Genposys Websites”).

This policy is designed to comply with applicable data protection laws and regulations, including but not limited to:

• General Data Protection Regulation (GDPR) – European Union
• California Consumer Privacy Act (CCPA) – United States
• Digital Personal Data Protection Act (DPDP Act) – India

Third-Party Links and Social Media Features

Genposys Websites may include links to third-party websites or platforms, including social media channels. These external sites are governed by their own privacy policies, not this one. If you choose to visit or interact with those platforms, please review their privacy policies before submitting any personal information.

We may also provide social sharing functionalities (e.g., “Like”, “Share”, or “Follow” buttons). These features may collect your IP address, browser details, and set cookies to function properly. Your interactions with these features are governed by the privacy policies of the respective social media platforms.

Age Restrictions

Genposys does not knowingly collect or solicit personal information from individuals under the age of 18. If you are under 18, you may use our website only with the supervision and consent of a parent or legal guardian. By accessing our website, you represent that you are at least 18 years old. If we become aware that we have collected personal data from a child without verified parental consent, we will take immediate steps to delete such information.

Unsolicited Information

Any unsolicited personal information you voluntarily submit to Genposys via forms, emails, chats, or otherwise will be deemed to be provided with your consent. Genposys is not responsible for the privacy or accuracy of such voluntarily provided data, and reserves the right to use such information in accordance with this Privacy Policy.

Personal Information We Collect

We may collect the following types of personal information:

• Full Name
• Email Address
• Phone Number
• Organization Name
• Job Title
• Country and City
• IP Address and Device Information (e.g., browser type, access time)
• Inquiry or Message Content
• Service Preferences and Interests

This information is collected when you:

• Fill out a contact or inquiry form
• Request a quote, demo, or service
• Subscribe to newsletters or updates
• Register for an event or webinar
• Apply for a job or internship
• Communicate with us via email, phone, or chat

We collect this data to provide you with relevant services, respond to inquiries, improve our offerings, and comply with applicable legal obligations.

Data We Do Not Collect

Genposys does not knowingly collect or store the following categories of sensitive personal data unless explicitly required for a legal or contractual obligation, and with proper consent where applicable:

• Financial account numbers or payment card details (unless processed securely via third-party payment gateways)
• Government-issued identification numbers (e.g., Aadhaar, PAN, SSN)
• Biometric or genetic data
• Health or medical information
• Racial, religious, political, or philosophical beliefs
• Sexual orientation or gender identity
• Any information pertaining to minors under 13 years without guardian consent

If such data is ever required for a legitimate business reason, we will notify you in advance and obtain explicit consent in accordance with applicable laws.

Personal Information You Provide to Genposys Directly Through Websites, Emails, or Other Communications

We may collect personal information such as your First Name, Last Name, Email Address, Job Title, Organization Name, Country, City, Phone Number, and Industry Type when you:

• Fill out forms on our websites
• Raise a query or request a callback
• Subscribe to newsletters or marketing content
• Contact us via email, phone, or messaging apps
• Participate in surveys, contests, or promotional activities
• Submit your resume or apply for a position

This information helps us communicate with you effectively and respond to your service or support needs.

Personal Information Automatically Collected When You Use Genposys Websites

When you visit Genposys Websites, we may automatically collect certain data using cookies, web server logs, tracking pixels, and similar technologies. This includes:

• IP Address
• Cookie Identifiers
• Browser Type and Version
• Operating System and Device Information
• Referring URLs
• Geolocation Data (approximate)

Cookies help us recognize returning users and improve website functionality and user experience. The cookie ID is a unique identifier that may be deleted when you clear cookies from your browser. Some tracking technologies may remain until they expire or are manually deleted.

For more information, please refer to our Cookie Policy.

By accessing our websites or microsites, or using our mobile applications, you agree to the processing of your data as outlined in this Privacy Policy.

Personal Information Collected from Third-Party Sources

You may interact with Genposys through third-party platforms, such as social media (e.g., Facebook, LinkedIn, Instagram, Twitter, etc.) or integrated plugins on our website. Depending on your privacy settings on those platforms, we may receive access to your public profile information, such as:

• Name
• Email Address
• Profile Picture
• Connections or Followers
• Job Title or Employer
• Location

This data helps us personalize your experience and tailor communications based on your engagement.

We encourage you to review the privacy settings and policies of these third-party platforms to understand what data may be shared with us.

Personal Information Collected When Accessing Our Websites via Mobile Devices

If you access Genposys Websites from a mobile device, we may collect additional personal information such as:

• Device Type and Operating System
• IP Address
• Advertising Identifier (e.g., IDFA or AAID)
• Location Information (approximate)
• Mobile Network Provider
• Browser and App Usage Data

If you provide your mobile phone number, you consent to its use for the purposes defined in this Privacy Policy—such as service notifications, transactional messages, or support follow-ups. If you choose not to receive such notifications, we will respect your preference and discontinue usage unless legally required or justified by a legitimate business interest.

How We Use Your Data

The personal information collected by Genposys Technologies Private Limited ("Genposys") is used solely for legitimate business purposes and in accordance with applicable data protection laws. We process your data to deliver a seamless, personalized, and efficient experience while engaging with our services and digital platforms.

We may use your personal information to:

• Respond to your inquiries and provide the information or services you request
• Evaluate queries, requirements, and process requests for our products or solutions
• Offer subscription-based content, newsletters, or service updates
• Enable you to download marketing materials, brochures, or service collaterals
• Manage communications, service delivery, invoicing, and general client administration
• Analyze usage data and improve website performance and service quality
• Maintain and manage leads and customer relationships
• Conduct marketing, advertising, or promotional campaigns
• Build and enhance brand recognition and awareness
• Improve service offerings based on user behavior and feedback
• Generate qualified demand and reach relevant audiences
• Promote our products and services under legitimate business interests, subject to applicable law
• Fulfill contractual obligations and manage business relationships
• Conduct surveys, measure satisfaction, and evaluate interest in our solutions
• Perform market research and competitive analysis

Legal Basis for Processing

The legal basis for collecting and processing personal information may vary depending on jurisdiction. However, in general, we rely on:

• Legitimate Interest: When the data processing is necessary to operate our business, improve user experience, and promote our services, especially in a professional context (e.g., business-related browsing behavior).
• Consent: When required by law or when processing involves direct marketing or the collection of certain types of data, we will request your clear, informed, and specific consent.
• Contractual Necessity: When processing is required to fulfill our obligations under a service agreement or commercial engagement.
• Legal Obligation: When we are required to retain or disclose data to comply with legal or regulatory obligations.

We do not process data beyond what is necessary, and we ensure transparency, provide opt-out options, and apply strict retention policies to protect your privacy. Any data you voluntarily submit is processed with your implied or explicit consent, and you may withdraw consent at any time where applicable.

Sharing of Personal Information with Third Parties

Genposys Technologies Private Limited ("Genposys") does not sell your personal information. We only share your personal data with third parties under the following limited and controlled circumstances:

1. To Provide Requested Services

We may share your information with affiliates, partners, vendors, or trusted service providers when it is necessary to fulfill your request for our services, support, or information.

2. With Your Consent

We will share your personal data with third parties only when you have given us explicit permission to do so.

3. Within Our Group Entities

Personal data may be shared with our affiliated companies, branch offices, or subsidiaries for legitimate business purposes, such as business continuity, cross-border service delivery, or consolidated customer support.

4. With Authorized Service Providers

We may share your data with trusted third-party vendors who work on our behalf under binding contractual and confidentiality agreements. These providers assist with:

• Customer communication
• Event and campaign execution
• Lead management
• Data analysis and business insights
• Market research
• Verifying user details or account authenticity

These parties are only permitted to process your personal information as instructed by us and in compliance with applicable privacy laws.

5. For Legal and Compliance Reasons

We may disclose your data:

• To statutory or government authorities to comply with legal obligations
• In response to subpoenas, court orders, or legal proceedings
• To establish or defend legal rights

6. In Case of Risk or Harm

We may share data where we believe it is necessary to investigate or prevent fraud, data breaches, threats to physical safety, violations of our Terms of Use, or other harmful or illegal activities.

7. Business Transfers

In the event of a merger, acquisition, restructuring, or asset sale involving Genposys, your personal information may be transferred to the successor organization after ensuring equal or higher data protection measures.

8. Vendor or Partner Coordination

With your prior consent, we may share your contact details with our authorized vendors or empaneled partners to facilitate business discussions, meetings, or follow-ups.

User Preferences and Control

1. Profile Updates

If you have registered an account or profile with us on our website, you can log in to review and update your contact information and preferences.

2. Newsletters and Emails

If you subscribe to newsletters, event updates, or marketing emails:

• You can unsubscribe anytime using the “unsubscribe” link included in the footer of each communication.
• You may also contact us directly to stop receiving communications.

3. Mobile Devices

If you access our services through a mobile app:

• You can control push notifications via your device settings or the app preferences.
• To stop all data collection via the app, you may uninstall it using your mobile device’s standard process.

Anti-Spam Policy

At Genposys Technologies Private Limited ("Genposys"), we are committed to maintaining a secure and trustworthy digital communication environment. We recognize that the transmission of spam emails unsolicited, bulk, or irrelevant messages is a significant concern for users and businesses alike.

To mitigate the impact and distribution of spam within our systems, we have implemented robust technical and procedural safeguards, including but not limited to:

• Automated spam filters that scan all incoming emails for suspicious content or patterns
• Rejection of spam-marked emails, with appropriate feedback provided to the sender (wherever possible)
• Continuous monitoring and updating of spam control mechanisms to adapt to evolving threats

Any email identified as spam will be blocked from reaching its intended destination within our network. We also reserve the right to report such emails to relevant cybersecurity or regulatory authorities, as deemed necessary.

By enforcing this Anti-Spam Policy, Genposys aims to protect its systems, employees, partners, and clients from the risks associated with spam, including phishing, malware, and data breaches.

If you believe an email was incorrectly flagged or have queries regarding this policy, you may contact us via our official channels.

Data Protection and Confidentiality

Genposys Technologies Private Limited ("Genposys") implements robust physical, technical, and administrative measures to safeguard personal information from unauthorized access, loss, misuse, alteration, or destruction. We are committed to ensuring the confidentiality, integrity, and security of the personal information in our care.

We disclose personal data only for legitimate business purposes, and strictly to:

• Trusted service providers and agents who are contractually bound to maintain data confidentiality and security.
• Parties that agree to uphold a level of data protection in compliance with applicable regulations and our internal policies.

We ensure, via binding contracts, that any third parties we engage with adhere to the same level of data protection as mandated by applicable data protection laws (such as GDPR, LGPD, CCPA, etc.).

All personal data handled by Genposys is processed in a manner that:

• Is fair, lawful, and transparent.
• Involves consent, where required, from the individual.
• Is collected only for legitimate, necessary purposes related to business functions.
• Is available for review, correction, or deletion by the individual.
• Is secured against any unauthorized access, accidental loss, or unlawful processing.

Your Rights as a Data Subject

Depending on the local data protection regulations applicable to you (such as GDPR, LGPD, PIPEDA, CCPA, ARCO, etc.), you may have the following rights:

• Right to be Informed: You can request clear information on how your personal data is used.
• Right of Access: You may ask us what personal data we hold about you.
• Right to Rectification: You can request correction of inaccurate or incomplete personal information.
• Right to Erasure (Right to be Forgotten): You can ask us to delete your personal data, subject to legal limitations.
• Right to Restrict Processing: You can request us to limit the use of your data in certain situations.
• Right to Data Portability: You may request a machine-readable copy of your personal data.
• Right to Object: You may object to processing based on legitimate interest or direct marketing.
• Rights related to Automated Decision-Making and Profiling: You can object to decisions based solely on automated processing.

To exercise any of these rights or lodge a complaint, you can contact us at: info@genposys.com

Note:

• California residents may have additional rights under the CCPA, accessible here.
• EEA residents can reach out to their local supervisory authority.

Right to Opt-Out and Withdraw Consent

You have the right to withhold or withdraw consent to the collection and use of your personal information. This can be done by:

• Unsubscribing from marketing emails using the unsubscribe link.
• Contacting us in writing to formally withdraw your previously given consent.

Note: Withdrawal does not affect the legality of data processing carried out prior to withdrawal.

Access and Rectification of Your Data

If you have an account with Genposys:

• You may log in to update your personal information via your profile.

Otherwise:

• Contact us at info@genposys.com with your request to access or correct inaccuracies in your data. We aim to respond in a timely and transparent manner.

Data Retention

We retain your personal data:

• As long as necessary to fulfill the purposes for which it was collected.
• For legal, regulatory, or contractual compliance.
• To enforce our policies, resolve disputes, and support audits or investigations.

When retention is no longer necessary, we securely dispose of your data.

Disclosure of Information

We may disclose your personal data:

• With your explicit consent.
• To comply with legal obligations or valid legal processes.
• To authorized regulatory or government bodies.
• To protect the rights, safety, and property of Genposys, its users, or others.

We take steps to ensure any third party receiving such information does not disclose it further, unless legally permissible.

International Data Transfers

Your personal information may be transferred and stored outside your country of residence, including jurisdictions with data protection laws that may differ from your own. This includes:

• Transfers between Genposys entities, subsidiaries, or service providers across borders.
• Transfers under legally recognized frameworks such as:
• • Adequacy Decisions by regulatory authorities (e.g., European Commission)
  • Standard Contractual Clauses (SCCs) for EEA-based data transfers
  • Binding Corporate Rules (BCRs) or other legal mechanisms ensuring adequate protection

Transfers may occur when:

• You give your explicit consent.
• Required for contractual performance.
• Necessary for legal claims, public interest, or vital interests.
• The information is publicly available or lawfully disclosed.

Authenticity of Information

Genposys Technologies Private Limited (“Genposys”) shall not be held responsible for the authenticity or accuracy of the personal information provided to us by third-party service providers or individuals. It is the responsibility of the disclosing party to ensure that the information shared is true, correct, and updated.

Grievance Redressal

For any concerns, complaints, or grievances regarding the processing of your personal data, you may reach out to our designated Grievance Officer. We aim to address your concerns as quickly and effectively as possible.

Grievance Officer (India):

Name: TANMOY BARMAN
Position: Privacy Manager
Email: privacy@genposys.com

Effective Date

This Privacy Policy is effective as of 01 January 2025 and supersedes any prior policies related to data protection and privacy.

Changes to this Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in legal, regulatory, technological, or business developments. Any such changes will be published on this page with the revised “Last Updated” date.

We will not reduce your rights under this Privacy Policy without your explicit consent. We encourage you to review this page regularly to stay informed about how we are protecting your information.

Last Updated: 01 January 2025