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Privacy Policy
Effective Date: May 1st, 2022.
1. Introduction & Overview
This Privacy Policy provides a comprehensive description of how gen.video (“gen.video,” “we,” “our,” or “us”) collects, uses, and discloses information about you as well as your rights and choices regarding such information. It applies to any online location controlled by us that links to this Privacy Policy (the “Service”).
This Privacy Policy does not govern information we process on behalf of our brand clients. For details about the processing of brand client data, please see the “Information from Our Brand Clients” section below.
By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.
If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section.
You may have additional rights based on your jurisdiction. Please click the relevant link below for more information:
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California
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Nevada
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European Economic Area, Switzerland, and United Kingdom
2. Information Collection
A. Information You Provide.
We collect information about you when you use the Service, including information you provide when you schedule a product demonstration or apply for a job. The categories of information we collect include:
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Contact Data, including your first and last name, company name, email address, and postal address.
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Account Credentials, including your password and password hints.
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Job Applicant Data, including your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
B. Information Collected Automatically.
In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:
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Service Use Data, including data about features you use, pages you visit, emails you view, services you view, the time of day you browse, and your referring and exiting pages.
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Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.
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Location Data, including non-precise location data (such as location derived from an IP address or data that indicates a city or postal code level).
The types of tracking technologies we use to automatically collect this information include:
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Cookies, which are small data files stored on your browser that save data about your visit. Cookies often include a unique identifier (e.g., cookie #123). We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate our website and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and expire on a set expiration date or when they are deleted manually.
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Pixels (also known as web beacons), which is code embedded in a service that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a service that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser, or collect other information about your visit.
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Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.
We may also use tracking technologies on behalf of our brand clients for personalized advertising purposes. Information regarding such data collection and choice is available in the applicable brand client’s privacy policy, and is not governed by this privacy policy.
For further information on how we use tracking technologies for analytics, and your rights and choices regarding them, see the “Analytics” and “Your Rights and Choices” sections below.
C. Information from Our Brand Clients.
We provide products and services to our brand clients, and collect and process information about individuals (including through tracking technologies) at the direction of our brand clients (“brand client data”). Brand client data has historically included contact data, service use data, device data, and location data, among other information. Our processing of brand client data is governed by the terms of our service agreements with our brand clients, and not this Privacy Policy. In the event we are permitted to process brand client data for our own purposes, we will process the brand client data in accordance with the practices described in this Privacy Policy. We are not responsible for how our brand clients treat the information we collect on their behalf, and we recommend you review their own privacy policies.
For further information on your rights and choices regarding brand client data, see the “Your Rights and Choices” section below.
D. Information from Other Sources.
We also collect information from other sources. The categories of sources from which we collect information include:
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Social media platforms and rating services with which you interact.
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Publicly-available sources, including data in the public domain.
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Vendors and Partners, including those who provide affiliate links.
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Influencers we engage.
3. Use of Information
We collect and use information in accordance with the practices described in this Privacy Policy. Our purposes for collecting and using information include:
Providing the Service to you.
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Preventing and addressing fraud, breach of policies or terms, or threats or harm.
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Understanding trends, usage, and activities, including through tracking technologies, to make business and marketing decisions.
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Communicating with you about updates, security alerts, changes to policies, and other transactional messages.
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Fulfilling any purpose at your direction.
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With notice to you and your consent.
Notwithstanding the above, we may use publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) for any purpose to the extent permitted by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
gen.video use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.
By agreeing to the terms of service you are agreeing to be bound with YouTube Terms of service along with the following Google Privacy policy, and Google Security Settings. The API Client uses YouTube API Services.
4. Disclosure of Information
We disclose the information we collect in accordance with the practices described in this Privacy Policy. The categories of persons to whom we disclose information include:
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Service Providers and Contractors. We disclose information to our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
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Brand Clients. We disclose information to our brand clients in connection with the services we provide to them. Our brand clients are independent entities and their processing of information is subject to their own privacy policies.
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Vendors and Partners. We disclose information to our vendors and partners, including in connection with affiliate links they provide. We do not receive personal information from affiliate links for our own use or benefit.
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Influencers. We disclose information to influencers we engage as subcontractors in connection with services they perform on our behalf or our brand client’s behalf.
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Merger or Acquisition. We disclose information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
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Security and Compelled Disclosure. We disclose information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also disclose information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
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Facilitating Requests. We disclose information where you direct us to disclose the information.
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Consent. We disclose information with notice to you and your consent.
Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law. For information on your rights and choices regarding how we disclose information about you, please see the “Your Rights and Choices” section below.
5. Other Parties
We offer parts of our Service through websites, platforms, and services operated or controlled by other parties. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.
Some examples include:
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Links. Our Service includes links that hyperlink to websites, platforms, and other services not operated or controlled by us. We may get a commission if you purchase a product after clicking on a link that leads to an affiliate’s website.
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Brand Pages and Messaging. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via a messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with gen.video in a tweet or post), we may use your reference on or in connection with our Service.
Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
6. Analytics
We use analytics services, such as Wix, to help us understand how users access and use the Service.
As indicated above, vendors, partners, and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
7. Your Rights and Choices
In addition to the rights and choices below, you may have additional rights based on your jurisdiction. Please click the relevant link at the top of this Privacy Policy or visit the applicable section below for more information.
A. Tracking Technology Management.
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Cookies. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
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Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.
B. Communication.
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E-mails. You can unsubscribe from receiving promotional emails by following the unsubscribe instructions at the bottom of the email, or emailing us at privacy@gen.video with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt out of transactional messages.
Please note that your opt out is limited to the email address used and will not affect subsequent subscriptions.
8. Children.
The Service is not directed toward children under 13 years old, and we do not knowingly collect personal information (as that term is defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information from children, please contact us at privacy@gen.video. We will delete the personal information in accordance with COPPA.
9. Data Security.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
10. International Transfer.
We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, disclosure, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. Where required by applicable law, we will provide appropriate safeguards for data transfers, such as through use of standard contractual clauses.
11. Changes to this Privacy Policy.
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.
12. Contact Us.
If you have any questions about our data practices, or experience any difficulty accessing the information in this Privacy Policy, please contact us:
By email: privacy@gen.video
By mail:
gen.video
Attn: General Counsel
269 Conant Road
Weston, MA 02493
13. California.
The California Consumer Privacy Act (“CCPA”), and its replacement the California Privacy Rights Act (“CPRA”), provide additional rights to California residents. This section addresses those rights and applies only to California residents. Any rights specifically relating to the CPRA shall not take effect until January 1, 2023.
We acknowledge that you may have rights under the CCPA/CPRA in connection with the personal information we process on behalf of our brand clients. If personal information about you has been processed by us as a service provider on behalf of a brand client and you wish to exercise any rights you have with such personal information, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our brand client on whose behalf we processed your personal information. We will refer your request to that brand client, and will support them to the extent required by applicable law in responding to your request.
A. Notice of Collection.
We have collected the following categories of personal information (as described in the CCPA/CPRA) in the past 12 months. For further details on the personal information we collect and how we obtain this information, please review the “Information Collection” section above.
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Identifiers, including name, email address, and online identifiers (such as IP address).
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Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
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Non-precise geolocation data, including location derived from an IP address.
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Professional, employment, or education-related information.
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Inferences drawn from any of the information identified in this section.
We collect and use this personal information for the business purposes set out in the “Use of Information” section above.
We disclose this personal information to the categories of persons set out in the “Disclosure of Information” section above.
We do not “sell” or “share” your personal information as those terms as defined by the CCPA/CPRA. To the extent we engage in any personalized advertising on behalf of a brand client, information regarding data collection and choice is available in the applicable brand client’s privacy policy, and such processing is not governed by this Privacy Policy.
B. Retention.
We retain each category of personal information for the length of time that is reasonably necessary for the purpose for which it was collected, and as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
C. Right to Know, Correct, and Delete.
You have the right to know certain details about our data practices. In particular, you may request the following from us:
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The categories of personal information we have collected about you;
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The categories of sources from which the personal information was collected;
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The categories of personal information about you we disclosed for a business purpose or sold or shared;
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The categories of persons to whom the personal information was disclosed for a business purpose or sold or shared;
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The business or commercial purpose for collecting or selling or sharing the personal information; and
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The specific pieces of personal information we have collected about you.
Unless you specify otherwise, the response we provide will cover the 12 month period preceding our receipt of the request. Starting with personal information collected on or after January 1, 2022, you may request that we disclose details beyond the 12-month period, and we shall do so unless doing so proves impossible or would involve a disproportionate effort.
In addition, you have the right to correct (effective January 1, 2023) or delete the personal information we have collected from you.
To exercise any of these rights, please email us at privacy@gen.video. If you have an account with us, we may require you to use the account to submit the request. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.
D. Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
E. Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
F. Shine the Light.
Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
14. Nevada.
If you are a Nevada consumer, you have the right to direct us not to sell any covered information (as that term is defined by NRS 603A.340) that we have collected or will collect about you. A “sale” under Nevada law is the exchange of covered information for monetary consideration by a business to a third party for the third party to license or sell the covered information to other third parties. If you are a Nevada consumer and wish to exercise this right, please contact us as at privacy@gen.video and specify you wish to exercise this right.
15. European Economic Area, Switzerland & United Kingdom.
The General Data Protection Regulation (“GDPR”) provides additional rights to individuals located in the European Economic Area, Switzerland, and the United Kingdom, (collectively, “Europe”). This section addresses those rights and applies only to those individuals.
A. Roles.
Data protection laws in the distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). gen.video acts as a controller with respect to personal data collected as you interact with our Service. In some instances, gen.video acts a processor on behalf of a brand client, which is the controller. Any questions that you have relating to the processing of personal data by gen.video as a processor should be directed to the relevant brand client.
B. Lawful Basis for Processing.
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers, partners, or brand clients; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
C. Your Rights.
You have the right to access, rectify, or erase any personal data we have collected about you. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Contact Us” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request. If personal data about you has been processed by us as a processor on behalf of a brand client and you wish to exercise any rights you have with such personal data, please inquire with our brand client directly. If you wish to make your request directly to us, please provide the name of our brand client on whose behalf we processed your personal data. We will refer your request to that brand client, and will support them to the extent required by applicable law in responding to your request.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.