Customer loyalty software

Privacy Policy

This privacy notice for GenLoyal LLC (“Company”, “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 www.genloyal.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]

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. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO NOT TRACK FEATURES
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO MEXICAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO WE MAKE UPDATES TO THIS NOTICE?
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

In short: We collect personal information that you provide to us. We collect personal information that you voluntary provide to us when tou register on the Services, 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 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
- Phone numbers
- Email addresses
- Usernames
- Passwords
- Contact or authentication data

Sensitive Information. We do not process sensitive information.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS” below.

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. Information automatically collected

In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”) and hardware settings).

- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location. Browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration 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 facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and loo in your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/ offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested services.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns and exchanges made through the Services. - To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To post testimonials. We post testimonials on our Services that may contain personal information.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests and exercise, establish, or defend our legal rights.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In shot: 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.

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.

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 manner.
- 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 of 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 applicable laws.
- 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.
- 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.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers. Contractors, or agents (“third-parties”) who perform services for us or on our behalf and require access to such information to do that work.
We may also 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 acquisitions of all or a portion of our business to another company.
- When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API).
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookies Notice.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such social media platform.

We will use information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes 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 the period of time in which users have an account with us.

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.

8. 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 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.

9. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from or market 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 ate at least 18 years or that you are the parent or guardian of such 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 that any data we may have collected from children under age 18 please contact us at [email protected]

10. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In some regions, such as Canada, United States and Mexico, 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, 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 certification 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 sure a request by contacting us by using the contact details provided in section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” bellow.

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 Member State data protection authority or UK data protection authority.

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” bellow.

However, please note that this will not affect the lawfulness of the processing before is 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 the unsubscribe link in the emails we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” bellow. You will then be removed from the marketing list. However, we may still communicate with you- for example, to send your 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.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

- Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our services.

If you have questions or comments about your privacy rights, you may email us at [email protected]

11. 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.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes, if you are a resident in 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 disclose to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediate preceding calendar year. If you are a California resident and would like to make sure 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 services (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 its 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?

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 classNameification characteristics under California or federal law	Gender and date of birth	YES
D. Commercial Information	Transaction information, purchases history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voice prints	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.	YES
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. Interferences 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 will use and retain the collected personal information as needed to provide the Services or for:

- Category F: as long as the user has an account with us.

We may also collect other personal information outside of these categories through 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 inquires.
,br>How do we use and share your personal information?

GenLoyal LLC collects and shares your personal information through:

- Targeting cookies/ marketing cookies
- Social media cookies
- Beacons / Pixels / Tags More information about data collection and sharing practices can be found in this privacy notice.

You may contact us by email at [email protected] 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 of 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, following the same strict privacy protection obligations mandated by the CCPA.

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.

GenLoyal LLC has not sold or shared any personal information to third-parties for a business or commercial purpose in the preceding welve (12) months.
GenLoyal LLC has disclosed the personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.
The categories of third parties to whom we disclosed personal information for business or commercial purpose can be found under WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Your rights respect your personal data
Right to request the deletion data – Request to delete

You can ask for 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 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 or share personal information to third-parties.
- The categories of personal information that e sold, shared, or disclosed for business purpose
- The categories of third-party top whom the personal information was sold, shared or disclosed for a business purpose.
- The business or commercial purpose for collecting, selling, or sharing personal information, and
- The specific pieces of personal information we collected about you

In accordance with applicable law, we are not obliged 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.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer´s sensitive personal information.

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 veriication 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 informationso 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 mail) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provded in your request to verify your identity or authority tomake the request. To the extent possible, we will avoid requesting additional information from you fro 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 purpose of verifying your identity and for the 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 or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasible possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at [email protected] 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.

13. DO MEXICAN RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes, if you are a resident in Mexico, you are granted rights to access, rectify, cancel or oppose (the “ARCO Rights”) regarding access and treatment to your personal information.

You have the right at all times to access, rectify, cancel or oppose the treatment we give to your personal data (the “ARCO Rights”), as well as to revoke the consent given for the treatment of the same; a right which you may exercise through the Special Unit for the Protection of Personal Data of GenLoyal LLC, whose details appear below. It is important that although the exercise of your ARCO Rights is free of charge, GenLoyal LLC may charge you for justified shipping costs and reproduction costs.

This request must contain at least your name, full address or other means of communicating the answer to your request, documents proving your identity and specifying clearly and precisely the personal data from which you are requesting access, rectification, updating or cancellation, the elements or documents in which the personal information can be found and indicating the reasons why you wish to access your personal information, or the reasons why you consider that your data should be updated, rectified or cancelled.

At the same time, in order to limit the use and disclosure of the personal information, you may additionally register with the Public Registry to Avoid Advertising or Public Registry of the Consumer (Registro Público para Evitar Publicidad o Registro Público del Consumidor), which is in charge of the Federal Consumer Protection Office (Procuraduría Federal del Consumidor), which guarantees that the personal information is not used to receive advertising or promotions by the companies of the telecommunications, tourism and commerce sectors, in their marketing practices. For further information about this registration, you can consult the PROFECOs website.

In addition, we ask you to consider that it is possible that GenLoyal LLC may deny access to the personal information or may not be able to rectify, cancel, block or grant opposition to the processing of all your personal information in accordance with the laws applicable to you, particularly in the following cases:

- When the applicant is not the holder of the personal information, or the agent is not duly accredited to do so;
- When in its database, the personal information of the applicant is not found;
- When there is a legal impediment, or the resolution of a competent authority, which restricts access to the personal information, or does not allow the rectification, cancellation or opposition thereof, and;
- When the rectification, cancellation or opposition has been previously made.

We will inform you within a maximum period of fifteen (15) days from the date on which we receive the request for access, correction, cancellation or opposition, of the determination made, so that, if appropriate, it becomes effective within fifteen (15) days from the date on which the response is communicated.

We inform you that you may initiate the procedure for the protection of ARCO Rights, before the National Institute of Transparency, Access to Information and Protection of Personal Data (Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales), within fifteen (15) days from the date on which your request has been answered and this is not satisfactory to you, or, if the term indicated has elapsed, your request has not been answered.

For any doubt or clarification, as well as for the exercise of your ARCO Rights, please contact us by email at the following address: [email protected] or by referring to the contact details at the bottom of this document.

If you have any questions, you can also contact INAI at http://inicio.inai.org.mx/SitePages/ifai.aspx

14. 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 updates “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.

15. 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 contact us by post at:

GenLoyal LLC
651 N Broad St, Suite 201
Middletown, DE, 19709, USA

16. 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. To request to review, update, or delete your personal information please email us at [email protected]