Confidentiality policy

ARTICLE 1: PREAMBLE

The purpose of this privacy policy is to inform users of the platform about:

• How their personal data is collected. Any information that can identify a user is considered personal data. As such, it may include, in particular: his first and last names, his age, his postal or email address, his location, his IP address;
• the rights they have with respect to this data;
• The person responsible for collecting and processing the personal data collected and processed;
• The recipients of this personal data;
• The cookie policy of the website and the platform.

This policy complements the legal notices and the General Conditions of Use that can be consulted by users at the following address: https://www.genezys.xyz/mentions-legales

ARTICLE 2: PRINCIPLES RELATING TO THE COLLECTION AND PROCESSING OF PERSONAL DATA

In accordance with article 5 of European Regulation 2016/679, personal data are:

• Processed in a lawful, loyal and transparent manner in relation to the person concerned;
• collected for specific, explicit and legitimate purposes (see article 3.1 of this document) and are not further processed in a manner that is incompatible with those purposes;
• Adequate, relevant and limited to what is necessary for the purposes for which they are processed;
• Accurate and, if necessary, updated. All reasonable measures must be taken to ensure that personal data that is inaccurate, in relation to the purposes for which they are processed, are erased or rectified without delay;
• Kept in a form that allows the identification of the persons concerned for a period of time that does not exceed that required for the purposes for which they are processed;
• Processed in such a way as to ensure the appropriate security of the data collected, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

Treatment is only lawful if, and to the extent that, at least one of the following conditions is met:

• The person concerned has consented to the processing of his personal data for one or more specific purposes;
• The processing is necessary for the execution of a contract to which the person concerned is a party or for the execution of pre-contractual measures taken at the request of the data subject;
• The processing is necessary for compliance with a legal obligation to which the data controller is subject;
• The processing is necessary to protect the vital interests of the data subject or of another natural person;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the data controller;
• The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject prevail which require the protection of personal data, in particular when the data subject is a child.

ARTICLE 3: PERSONAL DATA COLLECTED AND PROCESSED WHILE BROWSING THE PLATFORM

Article 3.1: Data collected

The personal data collected as part of our activities are as follows:

• The use of social networks such as Twitter, Facebook, TikTok, TikTok, TikTok, Instagram, Snapchat and LinkedIn to contact us and/or interact with our services.
• User requests and communications through our support channels.
• Creation of your user account: Genezys collects and processes personal data to allow you to create and access your User account. From the creation to the deletion of your User account, the transmission of personal data is essential, including in particular your email address. This treatment is contractual within the meaning of the law and ensures compliance with Genezys Terms and any additional contractual conditions.
• Use of the Genezys platform: The collection of certain personal data allows us to understand and improve the 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 the user's prior consent, Genezys processes this data on the basis of your consent.
• Access and use of the Services: Genezys collects and processes your personal data in order to allow you to access its various Services, including to facilitate the purchase of a Fancard, deposits and withdrawals into your fiat wallet and digital assets or the participation in our commercial or sponsorship operations. The legal basis for these treatments is contractual.
• Both on the primary market (gallery) and on the secondary market (marketplace), the purchase of a Fancard as well as its exchange (trading) may require, in certain circumstances, the collection of your username, telephone number, payment ID and part of your credit card number (the last four digits of the credit card that we have access to through our Payment Service providers but that we do not collect) not and let's not store directly).
• For the distribution of rewards to winners, Genezys may need to process your username and/or phone number. Genezys can post your username and any prizes you've won on its platform and social media accounts.
• To participate in our affiliate or referral program, Genezys may collect and process your email address, telephone 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 site and platform, including your IP address (from which information about your country/state of location can be inferred), your account information and the details of your transactions. The purpose of such collection is to prevent and act in the event of an attempt to hack or a deliberate desire to get out of the General Conditions issued by Genezys (in the latter cases, supporting documents may be requested). When payment fraud is detected, the related personal data will be stored in the Genezys monitoring system and may be used for subsequent verifications.

The collection and processing of this data meets the following purpose (s):

• Access, use and improve the platform and associated services;
• Better understand the needs and interests of users in order to improve the service and navigation on the platform;
• Personalize communications, conduct recruitment and marketing campaigns;
• Prevent and fight against computer 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 decides to collect certain prizes won during a challenge, Genezys may need to collect additional data such as his telephone number, name, postal address, in order to send him the prize.
• During purchase and resale transactions via digital asset wallets not managed by the Genezys platform, an identity verification process will be executed and the data inherent to the execution of this process will be collected.

This data is kept by the data controller under reasonable security conditions, until the user's account is closed, without prejudice to the exceptions provided for by law or regulations.

Genezys is in fact likely to keep certain personal data beyond the date the User's account is closed, in order to fulfill its legal or regulatory obligations.

Article 3.3: Data hosting

The site 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 centers managed by Amazon Web Services (AWS).

Article 3.4: Transmission of data to third parties

Data may be transmitted to our partners as part of Genezys's use of third party Service providers to facilitate, maintain, improve, analyze and secure the platform, and in general the Services, they may have access to certain personal data. This access by the Third-Party Service will be possible for the exclusive purpose of carrying out the specific treatment assigned to it by Genezys.

Third-party Service providers provide sufficient guarantees for the execution of the processing activity concerned in accordance with the requirement to protect personal data.

Article 3.5: Cookie Policy

A “cookie” is a small text file (less than 4 KB) placed when you consult a site on your computer or mobile phone. It has a limited lifespan and does not identify you personally. Cookies are very widely used to facilitate the use of websites and to secure navigation. They also make it possible to collect a certain amount of information relating to your use.

There are session cookies that disappear as soon as you leave the website as well as permanent cookies that remain on your terminal until their lifespan expires or until you delete them using the features of your browser.

We use the following cookies, whether they are specific to www.genezys.xyz or third party cookies:

• Essential cookies: These cookies are strictly necessary for the proper functioning of the site. They guarantee visitors a secure connection and are activated automatically. Visitors cannot refuse them. Cookies used: `fs-cc`, `fs-cc-updated`.
• Third-party functional cookies: These cookies are used to collect information about how visitors navigate on our site, such as the number of visitors, the web page 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 audience measurement tool configured to comply with the recommendations of the CNIL regarding “cookies”. This tool truncates the IP address before storage and performs automatic purges. A process of anonymizing this information allows the monitoring and carrying out of studies over periods of more than two calendar years.

ARTICLE 4: DATA CONTROLLER

Personal data is collected by Genezys SAS, with a capital of €27,353.69, registered in the Grenoble Trade and Companies Register under number 843 274 820.

The data controller can be contacted in the following way:
By post to the address: 93 Cours Berriat, 38000 Grenoble, France;
By email: legal@genezys-app.com

ARTICLE 5: RIGHTS OF USERS IN TERMS OF DATA COLLECTION AND PROCESSING

Any user concerned by the processing of their personal data may exercise the following rights, in application of the General Data Protection Regulation 2016/679 (RGPD) and the Data Protection Act (Law 78-17 of 6 January 1978) (Law 78-17 of 6 January 1978):

• Right to access, rectify and delete data (articles 15, 16 and 17 of the GDPR);
• Right to data portability (article 20 of the RGPD);
• Right to limitation (article 18 of the RGPD) and to oppose the processing of data (article 21 of the RGPD);
• Right not to be the subject of a decision based exclusively on an automated process;
• Right to determine the fate of data after death;
• Right to contact the competent supervisory authority (article 77 of the GDPR).

To exercise your rights, please send your letter to Genezys, 93 Cours Berriat 38000 Grenoble or by email to legal@genezys-app.com.

In order for the data controller to grant his request, the user may be required to provide him with certain information such as: his first and last names, his e-mail address as well as his account number, personal space or subscriber number.

Consult the cnil.fr site for more information on your rights.

ARTICLE 6: CONDITIONS FOR MODIFYING THE PRIVACY POLICY

Genezys reserves the right to modify this Policy at any time in order to ensure that users of the site and the platform comply with the law in force.

Any changes may not have an impact on purchases previously made on the platform, which remain subject to the Policy in force at the time of purchase and as accepted by the User during the validation of the purchase.

The User is invited to read this Policy each time he uses our services, without the need to formally notify him.

This policy, published on 01/08/2023, was updated on 31/10/2024.