GENIEX Privacy Policy
Last Updated: September 28, 2022
Effective date: September 28, 2022
The version No. of this Agreement: 20220420V1
GENIEX-TECH NIGERIA LIMITED (hereinafter referred to as “GENIEX”, "we”, “us”, “our”) is the service provider and operator of GENIEX and its Service (hereinafter referred to as “This Application”). We fully respect your privacy and will do our utmost to protect the security of your personal information. We may collect, use or otherwise process your personal information based on your consent or in accordance with the relevant provisions of applicable laws and regulations during your use of this Application or its services (collectively, our “Service”). This Privacy Policy (hereinafter referred to as “Policy”) is meant to help you understand how we collect, use, disclose, process and protect your personal information with regard to your use of GENIEX and its Service, your rights regarding the personal information provided to us, and how we safeguard your rights. This Policy applies to all the products and services provided by GENIEX, including applications, mini-programs, websites, SDK for third-party websites or applications, APIs and other forms that may be available in the future.
It is important to note that this Policy does not apply to services provided to you by other third parties. You may receive links, content, products or services provided by third parties (Including: Palmpay Privacy Policy), please prudently determine whether to access them. We encourage you to carefully review the privacy policies of any Third Parties you access before submitting any personal information.
We have chosen to use plain language in order to make sure that you fully understand this Policy and make your own choices. We have also marked or highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up window when you first use our service to help you understand the core terms of this Policy.
Before using our products or services, providing your personal information to us or allowing us to collect your personal information, please read this Policy carefully to understand our practices regarding your personal information and access it frequently to understand the updates to this Policy. If we update this Policy, we will notify you by announcements in the product or website to let you know about the changes we made. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Privacy Policy. You can check the “Effective Date” posted at the top of the Privacy Policy for the latest update time.
If you have any questions, please feel free to contact us by the following means:
[user-services@geniex.com]
You can also access this Privacy Policy by the following means:
GENIEX APP > ME > Setting > About Us > Privacy Policy
This Privacy Policy will help you understand the following contents:
I. How We Collect and Use Your Personal Information
II. How We Store and Protect Your Personal Information
III. How We Share, Transfer and Disclose Your Personal Information and Data
IV. How Your Personal Information is Transferred Across Borders
V. Your Rights to Your Personal Information
VI. How We Handle the Personal Information of Children
VII. Third-Party Service Providers and Services
VIII. Supplement and Update of the Policy
IX. Joint Controller
X. How to Contact Us
I. How We Collect and Use Your Personal Information
1. Overviews
GENIEX firmly believes that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by GENIEX, regardless of where such natural person lives.
We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. If we intent to use your personal information for other purposes not specified in this Policy, we will obtain your consent at that time.
We may collect your personal information by the following means:
1) information you provide directly to us (such as your nickname, profile picture, name and phone number you provide to us when you login to your account or take part in the promotion activity we held);
2) information we obtain automatically during your use of this Application (such as device information, service log information);
3) information we obtain from other sources.
You have the right to choose whether or not to provide the personal information when you use GENIEX and its Service or when we have requested. You are not required to provide your personal information to GENIEX, but in some cases, if you choose not to do so, GENIEX will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following describes your personal information that we collect:
We may collect and use the following information about you:
• Information you share with us. This is the information about you or relating to you that is voluntarily shared by you on GENIEX. Information you share with us may include without limitation postings that you make on GENIEX (including your public profile, name, identification number, address, email address, social media login details, telephone number, information about your device, your browsing records, the comments you make on GENIEX, as well as account and billing details, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device settings you turn on), any postings from others that you re-post and location data and log data associated with such postings. Information you share with us also includes information about you (including location data and log data) that others who are using GENIEX share about you. Information you share with us will remain publicly-available for so long as you or a user that has shared such information retains it.
• Information on Your Device. We automatically collect certain data from you, including IP address or other unique device identifiers such as Google advertising ID, Android ID, Identifier for Advertising, Cookies (as defined below), mobile carrier, time zone and locale setting, operating system and platform, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names and types, Bluetooth signals, International Mobile Equipment Identity, International Mobile Subscriber Identity, data from device settings: information you allow us to receive through device settings you turn on, such as access to your GPS location, photos, videos and voice recordings and such other information on your device. Any automated decision-making, including profiling, based on the data automatically collected from you, will solely be used in optimizing the Services and tailoring it to your preferences.
• Behavioral information we collect about you. We also collect information regarding your use of the Services, e.g. your comments on GENIEX or any other content that you Posted on or through the Services, views and interactions on GENIEX. In addition, we link your contact or subscriber information with your activity on GENIEX across all your devices using your email or social media log-in details, engagement (including without limitation likes, shares, comments, repeated views) and relate users based on your behavior. Finally, we collect opt-ins and communication preferences.
• Location data We may collect and process information about your location, including location information based on your SIM card, IP address or mobile device location settings, and if activated on your mobile device, by use of a Global Positioning System (GPS). We may use such information to provide you with location-based services, such as features, notifications, marketing, or other content that is influenced by your location. If you do not wish to share your GPS location with us, you can switch off GPS functionality on your mobile device.
• Metadata. When you Post content, including images, text and audio to GENIEX, you automatically upload certain metadata that is connected to the content. In essence, metadata describes other data and provides information about your content that will not always be evident to the viewer. In connection with your content the metadata can describe how, when and by whom the piece of content was collected and how that content is formatted. It further includes information such as your account name that enables other users to trace back the content to your user account. Metadata will further consist of additional data that you chose to provide with the content, e.g. any hashtags used to mark keywords to the comments.
• Information from third parties. We may receive information if you use any of the other websites we operate or other Services we provide. We may also receive information from third parties (such as advertising networks and analytics providers) and from other sources, including business directories and other commercially or publicly available sources.
• Contact Information. We may collect contact information from your contact list, address book and your social network to help you and others find people you may know and enable you to link your GENIEX contact list with the contact lists on your device and/or in your account on third party services. We will ask for your consent to access your contact list and address book before doing so. You may at any time allow or disallow us to access your contact list and address book by changing your settings.
• Third-party Services. If you create a GENIEX account by connecting with a third-party service, such as Facebook, Google, Instagram, Whatsapp or Email, we may collect information from such third-party service, including without limitation your third-party service user name, gender, profile image, birthday and third-party service contact list.
Cookies
We use cookies and other similar technologies (e.g. web beacons, Flash cookies, App cache, etc.) (“ Cookies ”) to enhance your experience using GENIEX. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.
We use the following Cookies:
• Strictly necessary Cookies. These are Cookies that are required for the operation of GENIEX and to keep your account and data safe and secure. They include, for example, Cookies that enable you to log into secure areas of GENIEX.
• Analytical/performance Cookies. They allow us to recognize and count the number of visitors and to see how visitors move around GENIEX when they are using it. This helps us to improve the way GENIEX works, for example, by ensuring that users are able to find what they are looking for easily.
• Functionality Cookies. These are used to recognize you when you return to GENIEX. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting Cookies. These Cookies record your visit to GENIEX, the pages you have visited and the links you have followed. We will use this information to make GENIEX and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
If for any reason you wish to not take advantage of Cookies, you may disable Cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of GENIEX and we will no longer be able to offer to you personalized content. Unless you opt out of Cookies, we will assume you consent to the use of Cookies.
"Do not track" signals are preferences that users can set on their web browser to limit how their activity is tracked across third-party websites or online services. GENIEX does not respond to "do not track" signals in your web browser.
Analytics information
On GENIEX, we use third-party analytics tools to help us measure traffic and usage trends for the Services. Traffic refers to the different data flows surrounding activities of the users on the Services. These tools, for example, collect information sent by your device or our Services, including the pages you visit, add-ons, and other information that assists us in improving the Service. The information will be used to report and evaluate your activities and patterns as a user of GENIEX to provide services in accordance with these activities.
Transaction Data
Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties
2. What information we collect and how we use it in GENIEX
GENIEX mainly provides you with comprehensive services including oriented traffic package ordering service and traffic balance monitoring.
2.1 To provide you with the service of account registration and login services
To fully use the functions and services of the software conveniently, you can login by providing us with your mobile phone, in such case, we will collect your mobile phone number, mobile phone verification code and password. We will assign you an account ID when you finish the registration successfully. If you refuse to provide this information, you will not be able to register a GENIEX account or use relevant functions. However, your normal use of other features of GENIEX will not be affected. You can still browse and use the basic features of the software in tourist mode (i.e. without being a registered user).
When using this Application, you may choose to provide, fill in and modify your nickname (including your real name), profile picture (including your real portrait). However, your refusal to provide additional information will not affect your use of basic business functions.
This Service will rely on the SIMS service provided by the operator. For the purpose of prevention of cyber crime based on the Service, when you use this Service to access networking services, we will encourage you to submit your name and NIN number according to regulatory requirements. You acknowledge and confirm that we will try our best to ensure the security of your personal information, which will be obtained and used only for the purpose of real name authentication, but will not be disclosed or used for any other purpose.
2.2 To provide you with oriented traffic package ordering service
GENIEX provides you with oriented traffic package ordering services. For your normal use of our products and services, we will collect your language, mobile phone model, brand, application package name, OS version and IMEI number. Such information will help us provide appropriate traffic packages and customized applications for your choice according to your mobile device.
When you order traffic packages, to help you complete the payment, we will collect information such as your order number, payment channel, package information, purchase time and amount. You can view the above information through the order list at any time and manage your order. When the third-party payment channel requires you to fill in your email information, we will help the collection of your email address. When you use the third-party payment service, you will be bound by their privacy policy. Please read the privacy policy carefully.
After you successfully subscribe to the traffic package, we will monitor the information such as your usage, remaining amount and package validity to facilitate your review of package use and traffic management.
2.3 To Receive Your feedback
You may submit your suggestions or comments through this Service for any problem of your use of the Service, when we will collect your user ID, mobile phone model, application version number and detailed description or pictures. The above information will help us locate the problems of your use. We will not be able to help you solve the difficulties if you refuse to provide the above information. In order to get in touch with you and provide you with solutions, we will collect your mobile phone number or email address. The provision of such information is optional. When you upload pictures, we will access your camera rights, file and media rights. You will not be able to use the image upload function if you refuse to provide the authorization. However, it will not affect your normal use of other service functions. You may close your authorization at any time via Settings - Application Management - Rights Management - GENIEX.
2.4 To Provide You with Notifications Services
We may also send you service notifications, events, prizes and other messages based on your device identifier, operating system version, user nickname of current device, network information and information about your use of the app. To unsubscribe from notifications, events, prizes, etc., you can withdraw your consent via Settings > Notification Centre > Notification Management, permission management may vary for different versions.
2.5 To provide you with in station transportation marketing activities
When you use GENIEX products and services, we may collect your user ID, mobile phone model and application version number, and show you the promotion contents related to GENIEX operation activities. We will strictly protect your privacy in this process. We may create profiles by analyzing the above information and creating user groups (to save your personal information in one or more fields). Targeted advertisements will only pushed to you to the extent required by applicable laws and with your consent.
2.6 To improve our products or services
We may also collect other information about you that we reasonably need to improve our products or services, including IMEI number, Android ID, your page browsing, click, purchase and package consumption records. This kind of information will help us analyze our service function use statistics, generate group user portraits, and help us optimize service functions and page design, thus we can provide you with better service.
3. Other situations in which your information may be collected
Where permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.
In order to better improve our product layout and provide you with great services, we may conduct research, statistical analysis and prediction on the collected information in an anonymized manner (including machine learning or model algorithm training by using anonymous data). We will take technical measures and other necessary measures to process such data, so that the data cannot be re-identified to specific individuals, nor can it be recovered. In accordance with the applicable laws and regulations, such processed data can be used without separately notifying you or obtaining your consent.
II. How We Store and Protect Your Personal Information
1. How we store your personal information
The personal information collected with your consent will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.
Currently, GENIEX may store your personal information in: Nigeria.
In particular:
The personal information collected and generated during our operations in Nigeria will be stored on servers located in Nigeria.
According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example, we will use encryption and de-identification methods to store the personal information collected. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations.
2. How we protect your personal information
We will take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
We implement security safeguards designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical, and physical safeguards to protect your personal information by taking the types of the personal information, the processing, and the threats posed themselves into account. We are constantly working to improve on these safeguards to keep your personal data secure.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a data breach event occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. In addition to the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you access third-party websites, links, products or services from our services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third-parties carefully. We do not take any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or features in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.
III. How We Share, Transfer and Disclose Your Personal Information and Data
When sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:
1. How we share your personal information
We do not sell any personal information to third parties. In order to provide you with timely services, your personal information may be shared with GENIEX affiliated companies. We will only share your information within GENIEX affiliated companies for legitimate and explicit purposes, and only share the information necessary to provide the services, and are bound by the purposes stated in this Privacy Policy. If a purpose concerned is not included in this Policy, we will state it in the corresponding privacy policy or notice of the specific product or service.
We may share the necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, after-sales service providers, marketing promotion service providers, third-party SDK service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. For example, in order to enable you to share information to third party platforms, use location service and other kinds of services and features, we may embed third party SDK or other similar applications of authorized partners in this Application. We uphold the principles of minimization, necessity, and legality to carry out such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security capabilities and information security qualifications (e.g., grade protection assessment, information security management system). When we embed the third party SDK or other similar applications of authorized partners in this Application, we will notify you promptly and request the SDK service provider that obtains the information to protect your data security.
In order to provide evaluation, analysis or other business services, we may also share your non-personal information with third parties. For example, we may use aggregated data to help partners (e.g., advertising service providers) understand the effectiveness, feedback and usage trends of their services.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if a personal information transfer is involved, we will require the new entity or organization holding your personal information to continue to be bound by this Policy through an agreement or other appropriate measures, and we will require such subject to take confidentiality and security measures of a degree no less than the requirements of this Policy to process personal information.
2. How we transfer your personal information
GENIEX will not transfer your information to any other parties, except in the following circumstances:
(1) Obtain your explicit consent.
(2) If GENIEX is involved in a merger, acquisition or sale of all or part of its assets, which may affect your personal information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your personal information, and any choices you may have about your personal information.
(3) In the case that has been explained in this privacy policy or notified you by other means.
3. How we disclose your personal information
According to the legal requirements, legal procedures, litigation and/or requests from government departments and authorities, GENIEX may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
Additionally, we may share your personal information with:
(1) Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.
(2) Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.
(3) Other third parties, for example, the disclosure of specific information with your authorization.
IV. How Your Personal Information is Transferred Across Borders
For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your personal information to the resources or servers stipulated in section III of this Policy for storage or processing, we may also transfer your personal information to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions. The privacy protection laws of these countries or regions may be different, and the jurisdiction in which these global resources or servers are located may or may not protect personal information to the same standards as in your jurisdiction. However, we will still strive to comply with our Privacy Policy to protect your personal information, and we will follow the legal requirements of the country or region where the personal information is located to carry out the corresponding cross-border transfer and other processing of personal information.
In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
V. Your Rights to Your Personal Information
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.
1 Right to confirm and access
We inform you how we collect and process personal information through this Policy or in the form of a privacy policy or notice of the specific product or service. You have the right to confirm or reject such collection and processing via a check box or other methods. However, after you reject, some features that require your explicit authorization and consent to use may no longer be available. You can directly access the personal information you have provided to us in the interface of our products or services. For those that you are unable to access, you can send an email to [user-services@geniex.com]. We will handle it promptly after receiving your email.
2 Right to correct and delete
When your personal information is changed, or when you find that your personal information collected and processed by us is inaccurate or incomplete, you have the right to ask us to make corrections or additions. You can directly correct or modify some of your personal information on the relevant product/service function pages. When your personal information collected by us has fulfilled the purpose of collection or is no longer required, or when you find that our collection and processing of your personal information violates the provisions of laws and regulations or this Privacy Policy, you have the right to ask us to delete the relevant personal information. For personal information that we have not provided you with a channel for correction or deletion, you can request that it be corrected or deleted by contacting [user-services@geniex.com].
However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when GENIEX is legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.
3 Right to withdraw consent
To achieve the respective features of our various products or services, we will require necessary personal information in accordance with the applicable local laws. This is described in the "How We Collect and Use Your Personal Information" part of this Policy. You can withdraw your consent previously granted to us for a specific purpose by deleting information, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your personal information that we manage or control. You can email us at [user-services@geniex.com] for above operations. We will process your request within a reasonable time after you send the request, and thereafter will not collect, use and/or disclose your personal information in accordance with your request.
If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of GENIEX and its Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
4 Right to complain
You have the right to lodge a complaint by sending us an email at [user-services@geniex.com]. We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information violates your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.
5 Right to control your privacy settings
You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings. For example, you can prefer turn on or turn off the permissions of “Location Access”, “Camera”, “Text Message”; you can also obtain detailed information regarding the device security status in “Settings”. If you have agreed to such permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can turn it off via “Permission Management” > “App Permissions” or contact us via [user-services@geniex.com] to change your decision.
6 Right to cancel a service or account
You can request to cancel through the “Logout” settings provided in the service or by contacting us via [user-services@geniex.com]. Please take full consideration before canceling your account. You acknowledge and understand that after you cancel your account, we will stop the products and services provided based on the account. Unless otherwise required by the applicable laws of the region you reside in, we will delete your personal data under your account. If you are authorized to log in to this Service through a third-party account, please apply to the third party for account cancellation.
7 Rights in some jurisdictions
Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects rights:
(1) Right to restriction processing. You have the right to request our restriction on the processing of your personal information. We shall consider the grounds regarding your restriction request. If the grounds are in the compliance with applicable data protection laws, we will process your personal information under applicable circumstances in such laws and notify you before the restriction of processing is lifted.
(2) Right to automated decision-making. You have the right to refuse the processing based on automated decision-making, including profiling and other automated processing which may have legal or similar effects on you.
(3) Right to data portability. You have the right to apply for your personal information to be transmitted to another data controller in a structured and commonly used format.
We have the right to refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.
VI. How We Handle the Personal Information of Children
GENIEX does not provide our products or services to children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children’s personal data or use children’s personal information for the purposes of marketing. If you find that a child’s information has been collected to us, please send an email to [user-services@geniex.com] to contact us. We will remove the relevant information as soon as possible. If we become aware that a child has provided us with personal information, we will take steps to delete their personal information from GENIEX as soon as possible.
VII. Third-Party Service Providers and Services
With the upgrades of this Application, you may receive links to third-party websites or content and services provided by third parties other than us during your use of GENIEX and its Service, and some third parties’ products or services can be accessed in the form of SDKs and others. You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your personal information. Therefore, when you submit any information to a third party, please carefully review the third party’s privacy policy and take care of your personal information.
The content of [GENIEX] and its services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.
VIII. Supplement and Update of the Policy
We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our business, technology and applicable law and practice. In case of any modification of this Policy, we will notify you of the latest Policy by posting it on [My - About Us - Private Document], or sending you separate notifications. Please follow this web page and the notifications we send to you for the latest updates of this Privacy Policy. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent.
We will ask for your explicit consent again in accordance with applicable laws before we collect additional personal information from you or when we use or disclose your personal information for new purposes. Your continued use of the products and services on the website, mobile and/or any other device constitutes your agreement to the updated Privacy Policy.
The content of GENIEX and its services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.
IX. Joint Controller
[TRANSTECH(SHENZHEN) LIMITED] is a joint controller with us and we are jointly responsible for processing your personal information. [GENIEX-TECH NIGERIA LIMITED] and [TRANSTECH(SHENZHEN) LIMITED] have allocated respective responsibilities according to applicable laws. You can contact us for more details regarding the joint controllership by the contact information in section x. "How to Contact Us".
X. How to Contact Us
If you have any comments, questions or concerns with respect to our Privacy Policy or practices of personal information protection, please contact us via:
Email: [user-services@geniex.com] (Note: This mailbox is used for receiving messages related to our Privacy Policy or our protection of personal information only)
We will review your privacy or personal information requests as soon as possible and respond to you in 15-30 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
If you are not satisfied with our response, especially when you believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your circumstance.
Thank you for your time to read our Privacy Policy!