Your privacy is important to Genwise Inc. and its affiliates (“Genwise”) so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information on our website and mobile application and in using and providing our other products and services (collectively, the "Services"). This policy covers Personal Information obtained through your use of the Genwise website www.genwise.com, mobile applications, emails to Genwise and its affiliates and on Genwise desktop clients (our “System”) and is applicable worldwide. We consider your Personal Information to be yours, and in order to provide the Services, we retain an irrevocable worldwide, royalty-free license to use such Personal Information as provided in this Privacy Policy. Genwise will never sell your Personal Information to third parties, although we may provide your Personal Information to a member of our network within our System upon your request as part of the Services.

This policy outlines our handling practices and how we collect and use the Personal Information you provide during your online and offline interactions with us. As used in this Privacy Policy, “Personal Information” means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, postal or other physical address, credit or debit card number, title, and other personally identifiable information. Personal Information is not your work product or documentation that you upload or store to our System for your own use or in connection with the Services, such data shall remain yours.

Genwise Inc. will be the controller of your Personal Information that is provided, collected and/or processed pursuant to this Privacy Policy in order to, for example, respond to requests for information or services, conclude a business transaction, provide the Services to you, or otherwise for Genwise’s internal business purposes. Genwise will be a processor of data that is entered into our System when a Customer uses the System (see “User-Generated Information”, below.). If you have any questions about whether any of the foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.

This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our System. If we propose to make any material changes, we will notify you by means of a notice on this page prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Collection of your Personal Information

We may collect, either as controller or processor, the following categories of Personal Information about you when you use or otherwise interact with our System:

Name
Title
Email address
Home/work/mobile telephone number
Postal or other physical address or other geographical or geolocation data
Credit/debit card information
Cookies, and other automatically generated log or tracking capabilities. Cookies are small text files which are placed on your computer. Cookies help us identify return visitors and allow us to optimize the site for you. Cookies do not give us access to your computer. The information we automatically collect may include your IP address, referring webpage, browser or mobile device information, and information about your visit
IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
Device identifiers, as further described in the “Mobile Application” section below
Our servers automatically record certain information when you use the System, including your IP address, operating system type and version, client version, IP addresses along the network path, and the MAC address of your internet connection (“Host Information”)
We also automatically record information about your usage of the System, including actions taken, date and time, frequency, duration, quantity, quality, network connectivity, and performance information related to logins, clicks, messages, contacts, content shared, calls, use of video and screen sharing, meetings, cloud recording, and other feature usage information (“Usage Information”)
Information to facilitate orders of the Services or to engage third-party providers through the Genwise website or mobile application. When you order Services from Genwise or transact with third parties through the System, we may need to contact you for additional information to complete or facilitate your order.
Information from surveys and newsletters. From time to time, we may contact you to participate in surveys or with our email newsletter. We may collect your responses. You may opt out of these emails by following the instructions contained in such emails.
Information or data entered into our System by you, or posted or uploaded User-Generated Information into our System. Including, without limitation, interacting with other Genwise users and guests on our community forums or visiting any of our websites or our mobile applications.
Other information or content you upload, provide, or create while using our System ("User-Generated Information"), as further detailed in the “User Generated Information” section below

How we use Your Personal Information
We collect and retain for our use, generally as a processor and in order to provide the Services, Personal Information and other information you upload, provide, or create while using the System ("User-Generated Information"), including information related to:

In general, we use Personal Information and User-Generated Information to enhance the user experience and to facilitate and complete orders for services. We may use your Personal Information in the following ways:

i. To facilitate and complete Services.

ii. To customize or set up Services.

iii. To facilitate transactions between you and third parties through our System as part of the Services.

iii. To track your purchases and purchase history to enhance your use of our Services and to help us identify and to suggest specific offers that we think might be valuable to you.

iv. To answer your questions and provide customer support for the Services and the System.

v. To optimize and customize your experience while on the System.

vi. To log, analyze, and test our System’s functionality.

Passive Collection

Genwise and our third-party service providers automatically collect some information about you when you use the System and our Services, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or System.

In addition, when you use some of our Services or our System, network information is transmitted back to us such as product usage information. This information is transmitted back to us, so we can determine how users are interacting with our System, to assist us with improving our System and our Services, and to correct any problems that may occur.

Mobile Application

When you download and use our System, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Processing of your Personal Information

We will use your Personal Information only in accordance with our Privacy Policy. Your documents and your work product that you store or work on while using our System remains yours at all times. If you do not wish us to continue collecting your Personal Information in this manner, you can request that your account be deactivated by contacting us as specified in the “Contact Us” section. Please note that deactivation may cause the information stored on our System to be deleted and irretrievable.

We will only process your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Services) and our “legitimate interests” or the legitimate interest of others (e.g. our other users),

We process Personal Information when you use our website, desktop client and mobile applications to use or sign-up to use our Service for purposes such as:

Account configuration
Account maintenance
Enabling meetings and webinars between users and third-party participants
Hosting and storing Personal Information from meetings and webinars (only to provide the Service)
Personalizing, improving or operating our System and business
Fulfilling requests you make related to the Services
Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity
Providing reports based on information collected from use of our System
Processing your orders and delivering the Services that you have ordered
Providing support and assistance for our System and our Services
Providing the ability to create personal profile areas and view protected content
Providing the ability to contact you and provide you with shipping and billing information
Providing customer feedback and support
Complying with our contractual and legal obligations, resolving disputes with users, enforcing our agreements

We process Personal Information when you visit our website:

To keep you up to date on the latest product and service announcements, software updates, software upgrades, System enhancements, special offers, and other information
To provide customer feedback and support (genwise.com/support)
To provide and administer opt-in contests, sweepstakes or other marketing or promotional activities on the www.genwise.com or affiliate websites
Providing you with information and offers from us or third parties as part of the Services
To the extent you choose to participate, to conduct questionnaires and surveys in order to provide better products and services to our customers and end users
To support recruitment inquiries (Genwise.com/careers)
To personalize Genwise marketing communications and website content based on your preferences, such as in response to your request for specific information on products and services that may be of interest
To contact individuals that you refer to us and identify you as the source of the referral, in accordance with the “Referral” section below

Referrals

If you choose to use our referral service to tell a friend about our products, you represent that you have their consent to provide us your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the website. Unless we are authorized by your friend, we will only use your friend’s name and email address for the purpose of sending this one-time email and maintaining an activity log of our referral program.

Choice

You can choose whether to provide Personal Information to Genwise, but note that you may be unable to access certain options, offers, and services if they require Personal Information that you have not provided. You can sign-up, and therefore consent, to receive email or newsletter communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.

Data Subject Rights

You have certain rights with respect to your Personal Information as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Information, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.

Access: You can request more information about the Personal Information we hold about you. You can also request a copy of the Personal Information.
Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
Objection: You can contact us to let us know that you object to the collection or use of your Personal Information for certain purposes.
Erasure: You can request that we erase some or all of your Personal Information from our systems. Data subjects who want their data deleted can do so by deactivating their account. Deactivation will delete all account usage and related information that specifically identifies Customer or their accounts. If you are not a Genwise customer and would like your data deleted, please contact us directly about deleting information.
Portability: You have the right to ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please contact our Privacy Team at legal@genwise.com.

Data Retention

How long we retain your Personal Information depends on the type of data and the purpose for which we process the data. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

Cookies and Tracking Technologies

Genwise and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information based on IP addresses. Users can control the use of cookies at the individual browser level.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.

To provide business services and insights we collect data through your interaction with Genwise Systems. Your use of our Systems constitutes consent to this data collection regardless of any browser-based "Do Not Track" or similar settings.

We may use Google Analytics or similar tracking software on our System. Google Analytics is a web analysis service provided by Google. Google utilizes the data collected to track and examine the use of the System and other Services, to prepare reports on the activities of its users, and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Geolocation

We collect information about where you are located when you are using our System. We use this information for purposes such as optimizing your connection to our data center, supporting compliance, and suggesting customizations to your experience with our System (for example, without limitation, your language preference).

Sharing your Personal Information

We do not sell or rent your Personal Information to third parties for any purposes, including marketing.

We share Personal Information within Genwise and its affiliated companies, and with our partner third-party service providers for purposes of data processing or storage.

We also share Personal Information with business partners, service vendors and/or authorized third-party agents or contractors in order to provide requested Services or transactions, including processing orders, processing credit card transactions, hosting websites, hosting event and seminar registration and providing customer support. We provide these third parties with Personal Information to complete/utilize the requested product, service or transaction.

In some cases, we may choose to buy or sell our assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Information and other related information, if necessary. We also may use Personal Information and other related information to establish or exercise our legal rights or defend against legal claims.

We collect and possibly share Personal Information and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Genwise's General Terms of Use www.genwise.com/genwise-general-terms-of-use, or as otherwise required by law.

Security of your Personal Information

We employ various security safeguards to protect it from inadvertent disclosure or access. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use or disclosure. When we transfer credit card information over the internet through points of sale on our System, we use third-party credit card processors such as QBO, Veem, PayPal, and Stripe who have their own data protection and privacy policies and procedures and those third parties are responsible for protecting your data. However, it is impossible to guarantee that your Personal Information will not be intercepted when transmitted to us across the internet. Therefore, any Personal Information transmitted to the Company is transmitted at your own risk and the Company will not be responsible for any damages incurred as a result of any data breach. We recommend you take every precaution in protecting your Personal Information when you are on the Internet. For example, change your passwords often, use a combination of upper and lower-case letters, numbers, and symbols when creating passwords, and make sure you use a secure browser.

While navigating Genwise's website or System, you may be directed to content or functionality that is hosted by a third-party (“Third-Party Links”). When information is collected on behalf of Genwise exclusively, Genwise's Privacy Policy will be referenced and will govern how your information is used. For Third-Party Links, the site/service owner's privacy policy will be referenced. You should review such third party’s privacy and security policies prior to use.

Newsgroups/forums

If you participate in a Genwise discussion forum or chat room on the System, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside Genwise, who have access to that discussion forum or chat room. Also, please recognize that individual forums and chat rooms may have additional rules and conditions. Each participant's opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Genwise.

International Transfers and Storage of Personal Information

Our System is hosted and operated in the United States (“U.S.”) through Genwise and its service providers. We may transfer your Personal Information to the U.S., to any Genwise affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage.

We may transfer your Personal Data to the U.S., to any Genwise affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Products or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers. We may also offer non-US outsourced service providers in our marketplace that you may use. If you choose to use a non-US service provider your data will be shared with that service provider

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Genwise participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield. Genwise is committed to subjecting all Personal Data received from EU member countries, Switzerland, and the United Kingdom, in reliance on the Privacy Shield Frameworks, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List, https://www.privacyshield.gov/list.

Genwise is responsible for the processing of Personal Data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Genwise complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, Switzerland, and the United Kingdom including the onward transfer liability provisions.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Genwise is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Genwise may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you can invoke binding arbitration when other dispute resolution procedures have been exhausted.

Standard Contractual Clauses

In certain cases, Genwise will transfer Personal Data from the EU in accordance with the European Commission-approved Standard Contractual Clauses, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.

To address your individual rights or if you have any privacy-related questions or comments related to this privacy policy, please send an email to privacy@Genwise.com . You can also contact us by writing to this address:

Genwise Inc.

Attention: CEO

3201 Bee Caves Rd Ste 120 PO BOX 162232 Austin, TX 78746

The Company may modify or replace this Agreement at any time by updating this document on the System. You agree to be bound by the most recent version of the Agreement as posted on the System.

California Users

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the email address above.

To address your individual rights or if you have any privacy-related questions or comments related to this privacy policy, please send an email to privacy@genwise.com.

Genwise Privacy Policy

Effective Date: March 8, 2021