ARTICLE 1: PREAMBLE
This privacy policy aims to inform users of the platform about:
- How their personal data is collected. Personal data is defined as any information that allows the identification of a user. This may include, for example, the user’s first and last names, age, postal or email address, location, and IP address.
- The rights they have concerning this data.
- The person responsible for the collection and processing of personal data.
- The recipients of this personal data.
- The website and platform’s cookie policy.
ARTICLE 2: PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA
In accordance with Article 5 of the European Regulation 2016/679, personal data is:
- Processed lawfully, fairly, and transparently in relation to the data subject;
- Collected for specific, explicit, and legitimate purposes (see Article 3.1 of this document) and not further processed in a manner incompatible with these purposes;
- Adequate, relevant, and limited to what is necessary for the purposes for which they are processed;
- Accurate and, where necessary, kept up to date. All reasonable steps must be taken to ensure that personal data which is inaccurate, with regard to the purposes for which it is processed, is erased or rectified without delay;
- Stored in a form that permits identification of the data subjects for no longer than is necessary for the purposes for which it is processed;
- Processed in a way that ensures appropriate security of the collected data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, by using appropriate technical or organisational measures.
Processing is lawful only if, and to the extent that, at least one of the following conditions is met:
- The data subject has consented to the processing of their personal data for one or more specific purposes;
- Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at their request;
- Processing is necessary for compliance with a legal obligation to which the data controller is subject;
- Processing is necessary to protect the vital interests of the data subject or of another natural person;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller;
- Processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, particularly where the data subject is a child.
ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED IN CONNECTION WITH NAVIGATION ON THE PLATFORM
Article 3.1: Data Collected
The personal data collected in the course of our activities includes the following:
- Use of social networks such as Twitter, Facebook, TikTok, Instagram, Snapchat, and LinkedIn to contact us and/or interact with our Services.
- Requests and communications from users via our support channels.
- Creation of your User account: Genezys collects and processes personal data to enable you to create and access your User account. From creation to deletion of your User account, the transmission of personal data is essential, including, in particular, your email address. Such processing is contractual in the legal sense and ensures compliance with the Genezys Terms and any additional contractual conditions.
- Use of the Genezys platform: Collection of certain personal data allows us to understand and improve user experience on the platform. This data consists of various browsing information derived from cookies or mobile technical identifiers (see "Cookies"), some of which may include personal data. In countries where the use of cookies requires prior user consent, Genezys processes this data based on your consent.
- Access to and use of Services: Genezys collects and processes your personal data to provide access to its various Services, including facilitating the purchase of a Fancard, deposits and withdrawals in your fiat and digital asset wallet, and participation in promotional or referral operations. The legal basis for this processing is contractual.
- On both the primary market (gallery) and secondary market (marketplace), purchasing a Fancard or trading it may, under certain circumstances, require collection of your username, phone number, payment ID, and part of your credit card number (the last four digits, which we access through our payment service providers but do not collect or store directly).
- For reward distribution purposes to winners, Genezys may need to process your username and/or phone number. Genezys may publish your username and any prizes you have won on its platform and social media accounts.
- To participate in our affiliate or referral program, Genezys may collect and process your email address, phone number, and username.
- Platform and account security: In this context, Genezys collects certain information about your device and browser, such as your browsing data on its website and platform, including your IP address (from which information about your country/state of location can be derived), your account information, and details of your transactions. This collection aims to prevent and respond to hacking attempts or deliberate violations of the Genezys Terms (in such cases, supporting documents may be required). In the event of detected payment fraud, related personal data will be stored in the Genezys monitoring system and may be used for future checks.
The collection and processing of this data serves the following purposes:
- Accessing, using, and improving the platform and associated Services;
- Gaining a better understanding of User needs and interests to improve service and navigation on the platform;
- Personalising communications, conducting recruitment and marketing campaigns;
- Preventing and combating cyber fraud.
Article 3.2: Data Collection Method
When you use our platform, the following data is automatically collected:
- When creating your user account on the platform, we collect your email address.
Additional personal data is collected when you perform the following actions on the platform:
- If the User chooses to claim certain prizes won in a challenge, Genezys may need to collect additional information, such as their phone number, name, and postal address, to deliver the prize.
- For purchase and resale transactions via digital asset wallets not managed by the Genezys platform, an identity verification process will be carried out, and the data required for this process will be collected.
This data is securely stored by the data controller until the user’s account is closed, except where otherwise specified by law or regulations.
Genezys may retain certain personal data beyond the account closure date to fulfil its legal or regulatory obligations.
Article 3.3: Data Hosting
The website
https://www.genezys.xyz is hosted by Webflow, Inc., headquartered at 398 11th Street, 2nd Floor, CA 94103 San Francisco.
User data is hosted in France on servers located in data centres managed by Amazon Web Services (AWS).
Article 3.4: Transmission of Data to Third Parties
Data may be shared with our partners as Genezys relies on third-party service providers to facilitate, maintain, improve, analyse, and secure the platform, as well as the Services in general. These providers may have access to certain personal data solely to perform specific processing tasks assigned to them by Genezys.
The third-party service providers offer adequate guarantees for carrying out the relevant processing activity in compliance with personal data protection requirements.
Article 3.5: Cookie Policy
A "cookie" is a small text file (less than 4 KB) placed on your computer or mobile device when visiting a website. It has a limited lifespan and does not personally identify you. Cookies are widely used to facilitate website use and secure browsing. They also allow for the collection of certain information about your usage.
There are session cookies, which disappear as soon as you leave the website, and persistent cookies, which remain on your device until they expire or you delete them using your browser's settings.
We use the following cookies, whether proprietary to www.genezys.xyz or third-party:
- Essential cookies: These cookies are strictly necessary for the proper functioning of the website. They ensure visitors have a secure connection and are enabled automatically. Visitors cannot opt out of these cookies. Cookies used: `fs-cc`, `fs-cc-updated`.
- Third-party functional cookies: These cookies are used to gather information on how visitors navigate our website, such as the number of visitors, the webpage that redirected them to www.genezys.xyz, and the pages viewed (Google Analytics: `ga`, `gat`, `gid`; Facebook: `fbp`). For the Genezys platform, we use a cookie provided by Posthog (`ph_phc_*`), a free web analytics tool configured to comply with CNIL’s "Cookie" recommendations. This tool truncates the IP address before storage and performs automatic purges. A process aimed at anonymizing this information allows for tracking and conducting studies over periods exceeding two calendar years.
ARTICLE 4: DATA CONTROLLER
Personal data is collected by Genezys SAS, with a capital of €20,000, registered with the Grenoble Trade and Companies Register under number 843 274 820.
The data controller can be contacted as follows:
By mail at the address: 93 Cours Berriat, 38000 Grenoble, France;
By email: legal@genezys-app.com
ARTICLE 5: USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING
Any user whose personal data is being processed has the following rights under the General Data Protection Regulation 2016/679 (GDPR) and the French Data Protection Act (Law No. 78-17 of January 6, 1978):
- Right of access, rectification, and erasure of data (Articles 15, 16, and 17 of the GDPR);
- Right to data portability (Article 20 of the GDPR);
- Right to restrict processing (Article 18 of the GDPR) and right to object to data processing (Article 21 of the GDPR);
- Right not to be subject to a decision based solely on automated processing;
- Right to determine the fate of data after death;
- Right to contact the relevant supervisory authority (Article 77 of the GDPR).
To exercise your rights, please send your request to Genezys, 93 Cours Berriat, 38000 Grenoble, France, or by email to legal@genezys-app.com.
To fulfil your request, the data controller may require specific information, such as your full name, email address, and account, personal space, or subscription number.
For more information on your rights, please visit the website cnil.fr.
ARTICLE 6: CONDITIONS FOR MODIFYING THE PRIVACY POLICY
Genezys reserves the right to modify this Policy at any time to ensure that it complies with current laws for users of the site and platform.
Any modifications will not affect purchases previously made on the platform, which remain subject to the Policy in force at the time of purchase, as accepted by the User at the time of purchase validation.
The User is encouraged to review this Policy each time they use our services, without formal notification being required.
This policy, issued on 08/01/2023, was last updated on 31/10/2024.
