Privacy Statement
GenSight Privacy Policy
POLICIES AND PROCEDURES
Effective starting: January 1st, 2018
PURPOSE OF THIS DOCUMENT
This Privacy Policy explains what information The GenSight Group Ltd and its related entities (“GenSight”) collect about you and why, what we do with that information, how we share it, and how we handle the content you place in our products and services. It also explains the choices available to you regarding our use of your personal information and how you can access and update this information.
SCOPE OF PRIVACY POLICY
This Privacy Policy applies to the information that we obtain through your use of “GenSight Services” via a “Device” or when you otherwise interact with GenSight.
“GenSight Services” include our:
Websites
SaaS Products
On-Premise Products
but does not include:
GenSight products or services for which a separate privacy policy is provided.
Third Party Products. These are third party products or services that you may choose to integrate with GenSight product or services, such as Office Tools. You should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information.
A “Device” is any computer used to access the GenSight Services, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device.
Unless otherwise stated, our SaaS Products and our On-Premise Products are treated the same for the purposes of this document.
By registering for or using GenSight Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.
DEFINITIONS
Configuration: configuration files, code and other resources and that can be used with a GenSight product to add new functionality or to change the behavior of that product’s existing features.
Content: any information or data that you upload, submit, post, create, transmit, store or display in a GenSight Service.
On-Premise Products: GenSight’s downloadable software products that are installed by customers on an infrastructure of their choice.
Information: all of the different forms of data, content, and information collected by us as described in this Privacy Policy.
Personal Information: information that may be used to readily identify or contact you as an individual person, such as: name, address, email address, or phone number. Personal Information does not include information that has been anonymized such that it does not allow for the ready identification of specific individuals.
SaaS Products: GenSight’s “Cloud” hosted solutions.
Websites: GenSight’s websites, including but not limited to GenSight.com.
CHANGES TO THIS POLICY
We may change this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Effective Starting” date at the top of this Policy. If we make any material changes, we will provide you with additional notice (such as by adding a notice on the GenSight Services homepages, login screens, or by sending you an email notification). We encourage you to review our Privacy Policy whenever you use GenSight Services to stay informed about our information practices and the ways you can help protect your privacy.
INFORMATION YOU PROVIDE TO US
We collect the following information:
Account and Profile Information: We collect information about you and your company as you register for product and support resource, create or modify your GenSight log-in details. Information we collect includes
Contact information such as name, email address, mailing address, and phone number
Profile information such as a username and job-role
You may provide this information directly when you enter it in GenSight Services.
In some cases, another user (such as a system administrator) may create an account on your behalf and may provide your information, including Personal Information (most commonly when your company requests that you use our products). We collect Information under the direction of our customers and often have no direct relationship with the individuals whose personal data we process. If you are an employee of one of our customers and would no longer like us to process your information, please contact your employer. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information as described in this Privacy Policy.
Content: We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our SaaS Products or Websites. Such Content includes any Personal Information or other sensitive information that you choose to include (“incidentally-collected Personal Information”).
Other submissions: We collect other data that you submit to our Websites or as you participate in any interactive features of the GenSight Services, participate in a survey, apply for a job, request customer support, communicate with us via third party social media sites or otherwise communicate with us. For example, information regarding a problem you are experiencing with a GenSight product could be submitted to our Support Services or posted in our public forums.
INFORMATION WE COLLECT FROM YOUR USE OF GENSIGHT SERVICES
Web Logs: As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and SaaS Products. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your Devices, your mobile carrier, and system configuration information. In the case of our SaaS Product, the URLs you accessed (and therefore included in our log files) include usernames as well as elements of Content (such as iForm names, Report names, Project ID’s, and Data Queries) as necessary for the SaaS Product to perform the requested operations. Occasionally, we connect Personal Information to information gathered in our log files as necessary to improve GenSight Services for individual customers, such as addressing a support issue for a problem that is affecting specific user’s only. In such a case, we would treat the combined Information in accordance with this privacy policy.
Analytics Information from Website and SaaS Products: We collect analytics information when you use our Websites and SaaS Products to help us improve our products and services. In the SaaS Products, this analytics information consists of the feature and function of the GenSight Service being used, the domain name, the username and IP address of the individual who is using the feature or function (which will include Personal Information if the Personal Information was incorporated into the username), the sizes and original filenames of attachments, and additional information required to detail the operation of the function and which parts of the GenSight Services are being affected. For example:
Analytics information that we collect when a user accesses a Report includes the system-generated numeric identifier of the Report, the project keys of the projects included in the Report, the ID’s of the data fields included in the Report. Similarly, analytics information that we collect when a support issues is logged includes the system-assigned numeric issue id,
As shown in the example above, the analytics information we collect includes elements of Content related to the function the user is performing. As such, the analytics information we collect may include Personal Information or sensitive business information that the user has included in Content that the user chose to upload, submit, post, create, transmit, store or display in a GenSight Service.
As of the date this policy went into effect, we use Google Analytics as an analytics provider. To learn more about the privacy policy of Google Analytics, refer to Google’s Policies and Principles. Use the Google Analytics Opt-out Browser Configuration to prevent analytics information from being sent to Google Analytics.
Analytics Information Derived from Content. Analytics information also consists of data we collect as a result of running queries against Content across our user base for the purposes of generating Usage Data. “Usage Data” is aggregated data about a group or category of services, features or users that does not contain Personal Information. For example, we may query Content to determine the most common types of workflows that users use.
Though we may happen upon sensitive or Personal Information as we compile Usage Data from Content across user instances, this is a byproduct of our efforts to understand broader patterns and trends. It is not a concerted effort by us to examine the Content of any particular customer.
Cookies and Other Tracking Technologies: Cookies are small text files which are transferred from our websites, applications or services and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our websites, applications and services better for you.
Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).
How to disable cookies
You may be able to configure your browser or our website, application or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications or services. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see the www.youronlinechoices.co.ukallaboutcookies.org website.
How we use Information we collect
General Uses: We use the Information we collect about you (including Personal Information to the extent applicable) for a variety of purposes, including to:
Provide, operate, maintain, improve, and promote GenSight Services;
Enable you to access and use GenSight Services, including uploading, downloading, collaborating on and sharing Content;
Process and complete transactions, and send you related information, including purchase confirmations and invoices;
Send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;
Send promotional communications, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, events and sending updates about your team and chat rooms; and providing other news or information about us and our select partners. You have the ability to opt out of receiving any of these communications as described below under “Your Choices”;
Monitor and analyze trends, usage, and activities in connection with GenSight Services and for marketing or advertising purposes;
Investigate and prevent fraudulent transactions, unauthorized access to GenSight Services, and other illegal activities;
Personalize GenSight Services, including by providing content, features, or advertisements that match your interests and preferences;
Enable you to communicate, collaborate, and share Content with users you designate; and
For other purposes about which we obtain your consent.
Notwithstanding the foregoing, we will not use Personal Information appearing in our Analytics Logs or Web Logs for any purpose. The use of Information collected through our GenSight Services shall be limited to the purposes disclosed in this policy.
INFORMATION SHARING AND DISCLOSURE
We will not share or disclose any of your Personal Information or Content with third parties except as described in this policy. We do not sell your Personal Information or Content.
Your Use: When you use GenSight Services, Content you provide will be displayed back to you. Certain features of GenSight Services allow you or your administrator to make some of your Content public, in which case it will become readily accessible to anyone. We urge you to consider the sensitivity of any data you input into GenSight Services.
Collaboration: As a natural result of using GenSight Services, you may create Content and grant permission to other GenSight users (within your own Organization and approved Third-Parties) to access it for the purposes of collaboration. Where this information is sensitive, we urge you to use the various security and privacy features of the GenSight Services to limit those who can access such information.
Access by your system administrator: You should be aware that the administrator of your instance of GenSight Services may be able to:
access information in and about your GenSight account;
access communications history, including file attachments, for your GenSight account;
disclose, restrict, or access information that you have provided or that is made available to you when using your GenSight account, including your Content; and
control how your GenSight account may be accessed or deleted.
GenSight Community: Our Websites offer publicly accessible community services such as blogs, forums, bug trackers, and wikis. You should be aware that any Content you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. To request removal of your Personal Information from the GenSight Community, please contact us using the information listed below. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to and why.
Service Providers, Business Partners and Others: We work with third party service providers to provide website, application development, hosting, maintenance, back-up, storage, virtual infrastructure, analysis and other services for us. These service providers may have access to or process your Information for the purpose of providing those services for us.
Social Media Widgets: The GenSight Services may contain social media features, such as the Twitter “tweet” button. These features may collect your IP address, which page you are visiting on the GenSight Services, and may set a cookie to enable the feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our GenSight Services. Your interactions with these features are governed by the privacy policy of the company providing it.
Testimonials: We may display personal testimonials of satisfied customers on the GenSight Services. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us using the information below.
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights: We may disclose your Information (including your Personal Information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of GenSight’s products and services, (d) to protect GenSight, our customers or the public from harm or illegal activities, or (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Business Transfers: We may share or transfer your Information (including your Personal 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. You will be notified via email and/or a prominent notice on the GenSight Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
Aggregated or Anonymized Data: We may also share aggregated or anonymized information that does not directly identify you with the third parties described above.
With Your Consent. We will share your Personal Information with third parties when we have your consent to do so.
INFORMATION WE DO NOT SHARE
We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes).
DATA STORAGE, TRANSFER AND SECURITY
GenSight hosts data with hosting service providers in numerous countries including the United States, the United Kingdom and Australia. The servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any incidentally-collected Personal Information you choose to store in Websites or SaaS Products are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.
Where data is transferred over the Internet as part of a Website or SaaS Product, the data is encrypted using industry standard SSL (HTTPS).
Where Downloadable Products are used, responsibility of securing access to the data you store in the Downloadable Products rests with you and not GenSight. We strongly recommend that administrators of Downloadable Products configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage used to hold data.
YOUR CHOICES
You may opt out of receiving promotional communications from GenSight by using the unsubscribe link within each email or emailing us to have your contact information removed from our promotional email list or registration database. Although opt-out requests are usually processed immediately, please allow ten (10) business days for a removal request to be processed. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding GenSight’s Services. You can opt-out of some notification messages in your account settings.
ACCESSING AND UPDATING YOUR INFORMATION
You may often correct, update, amend, or remove your Personal Information in your account settings or by directing your query to your account administrator. You may also contact Support Services, or contact us by postal mail using the addresses listed at the top of the Policy. We will respond to your request for access within 30 days.
You can often remove Content using editing tools associated with that Content. In some cases, you may need to contact your administrator to request they remove the Content.
You or your administrator may be able to deactivate your GenSight account. If you can deactivate your own account, you can most often do so in your account settings. Otherwise, please contact your administrator. To deactivate an organization account, please contact Support Services. To deactivate an account made for you without authorization, please contact us at the contact information above.
We will retain your account information for as long as your account is active, or as reasonably useful for commercial purposes or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If your account is managed by an administrator, that account administrator may have control with regards to how your account information is retained and deleted.
OUR POLICY TOWARDS CHILDREN
GenSight Services are not directed to individuals under 13. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information. If you become aware that a child has provided us with Personal Information, please contact our Support Services.