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Privacy Policy
Hush hush things
Genie, accessible at genie.coinhall.org (”Platform)”, and any other related and connected platforms and other online and offline interactions (collectively, the “Services”), are backed by INTERN TECH, located in Singapore, which is the controller for your Personal Data within the scope of this Privacy Policy. Your use of our Services is subject to our Terms of Use. By using the Services, you accept and agree to the practices described in this Policy. If you do not agree with this Policy, please do not use the Services.
If our data processing practices change, we will update this Privacy Policy accordingly to let you know of them upfront and give you the possibility to either provide your consent, object to a particular processing or undertake other action you are entitled to under the regulation. Please keep track of any changes we may introduce to this Privacy Policy. Your continued access to and use of the Platform constitutes your awareness of all amendments made to this Privacy Policy as of the date of your accessing and use of the Platform. Therefore, we encourage you to review this Privacy Policy regularly as you shall be bound by it. If for some reason, you are not satisfied with our personal data processing practices, your immediate recourse is to stop using the Platform. You do not have to inform us of this decision unless you intend to exercise some of the data protection rights stipulated by GDPR and defined below in this Privacy Policy.
By accessing our using the Platform, you represent and warrant that you are at least eighteen (18) years of age. If you are under the age of eighteen (18), you may not, under any circumstances or for any reason, use the Platform. Please report to us any instances involving the use of the Platform by individuals under the age of 18, should they come to your knowledge.
This Privacy Policy applies to all your interactions with us via the Platform and Services and your interactions with us in connection therewith.
Below are the categories of “Personal Information” (any information that directly or indirectly identifies, relates to, describes, or is reasonably capable of being associated, linked, or linkable with a particular individual, including any information that is subject to applicable data protection laws) that may be collected:
- IP address, MAC address, log files, domain server, data related to usage, performance, website security, traffic patterns, location information, browser, and device information through the use of Google Analytics – only when you are using the Platform;
- Wallet addresses (public blockchain addresses), transactions, and balance information (blockchain data) that is accessible when interacting with the Platform; We use public blockchain addresses to identify a user’s journey through our product. We collectively group and analyze these user journeys to improve our product user experience. We do not use this data for any purpose at an individual user level. The legal basis for this processing is our legitimate interests, such as monitoring and improving the Platform, the proper protection of the Platform against risks, and partly the contract performance basis to provide you with the Platform. Note that we are not responsible for your use of any of the blockchains and your data processed in these decentralized and permissionless networks;
- Log Files. Genie follows a standard procedure of using log files by Google Analytics. These files log visitors when they visit websites. All hosting companies do this and this kind of Personal Data may also be collected as a part of hosting services' analytics. The data collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These kinds of data may be linked to data that is personally identifiable. The purpose of the data collection and processing is to analyze trends, administer the website, track users' movement on the website, and gather demographic information;
- Genie may also engage third-party advertising platforms that are triggered only when their technical features (so-called “pixels”) are enabled through the Platform. The mentioned third-party advertising platforms may collect the Personal Data of the Platform’s visitors only with the purpose of optimizing their advertising possibilities through their platforms, targeting you with their advertisements, and possibly sharing your data with other advertising platforms and agencies for further use. Genie may engage with the mentioned Personal Data of Platform visitors.
- Other third-party sources: social media. If you choose to link the User Account with a social media service (Telegram, Twitter, Discord etc.), we collect your permission to access certain information from your profile with that social media service. If you post or engage with a separate social media service or interact with us on our page with any social media service, we may collect Personal Information about you related to those interactions.
In no event, are we going to ask you to share your private keys or wallet seed. Never trust anyone or any website that asks you to enter your private keys or wallet seed.
For more details on personal data collection, please refer to Google’s Privacy Policy and Terms of Service.
We will only process your Personal Information where we have legal grounds to do so. We may use Personal Information for a variety of purposes, including, without limitation:
- Our internal and operational purposes, when: ensuring security, identifying irregular website behavior, preventing fraudulent activity, and improving security at all possible levels;
- Assessing and improving the performance of the Platform: including a better understanding of how users access and use our Services, evaluating and improving our Services and business operations, and developing new features, offerings, and services; to monitor user interest in our products and Services; to troubleshoot problems that may arise on the Services; to improve the accuracy of our user database; to increase our understanding of our user database; and for other research and analytical purposes.
- Analyzing our website visitors’ actions to improve our Platform through the use of Google Analytics (Section “Cookies and Automatically Collected Data”);
- Analyzing the Platform behavior, including via Google Analytics (please refer to Google's Analytics Policy for more information);
- Securing and protecting our business: including protecting and securing our business operations, assets, Services, network, and information and technology resources; to investigate, prevent, detect, and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third-party, or other unauthorized activities or misconduct.
To clear any doubts, we may use the Personal Data described above or any other Personal Data:
- On the basis of contract performance or necessity to enter into a contract (where the Personal Data is required for us to perform our undertakings and obligations in accordance with a contract we are entering into when you use our Services, or where we are at the negotiations phase);
- To respond to legal requests of authorities, provide information upon court orders and judgments, or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants or court orders, and including other similar statutory obligations we or our processors are subjected to;
- On the basis of your consent; and
- On other legal bases set forth in the personal data protection laws.
In continuation of legal bases for collecting and processing the Personal Data, We may disclose any Personal Data about you:
- In connection with a merger, division, restructuring, or other association change; or
- To our subsidiaries or affiliates (if any) only if necessary for operational purposes. If we must disclose any of your Personal Data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy or security of your Personal Data.
- Service providers: We may disclose Personal Information with third-party service providers who use this information to perform services for us, such as hosting providers, auditors, advisors, consultants, customer service, and/or support providers.
- Advertising and Marketing Partners: We may share Personal Information with third parties that provide advertising, campaign measurement, online and/or mobile analytics, and related services. These third parties may receive or access browsing and/or other data about your use of the Services, in order to help us better reach individuals with relevant ads and/or measure our ad campaigns, and/or to better understand how individuals interact with our Services over time and across devices.
Genie maintains Personal Data exclusively within the time needed to follow prescribed herein legal purposes. When we no longer need Personal Data, the limitation period for storage of such Personal Data has expired, you have withdrawn your consent or objected to our or our processors’ legitimate interests, we securely delete or destroy it unless the statutory requirements we, our processors or other controllers are subjected to stipulate otherwise. Aggregated data, which cannot directly identify a device/browser (or individual) and is used for purposes of reporting and analysis, is maintained for as long as commercially necessary till you object to the processing of such data or withdraw your consent.
Sometimes legal requirements oblige us to retain certain data, for specific purposes, for an extended period of time. Reasons we might retain some data for longer periods of time include:
- Security, fraud & abuse prevention;
- Financial monitoring and record-keeping;
- Complying with legal or regulatory requirements;
- Ensuring the continuity of your interaction with the Platform.
As you navigate through and interact with our Platform, Google Analytics may ask your consent to use cookies, which are small files placed on the hard drive/browser of your computer or mobile device, and web beacons, which are small electronic files located on pages of the Platform, to collect certain information about devices you use, browsing actions, and patterns.
The data automatically collected from cookies and web beacons may include information about your web browser (such as browser type and browser language) and details of your visits to the Platform, including traffic data, location data and logs, page views, length of visit, and website navigation paths as well as information about your device and internet connection, including your IP address and how you interact with the Platform. We collect this data in order to help us improve the Platform and interaction with it.
The information we collect automatically may also include statistical and performance information arising from your use of the Platform. This type of data will only be used by us in an aggregated and pseudonymized manner.
You can choose to disable cookies through your individual browser options. To get more detailed information about cookie management with specific web browsers, please find it on the browsers' respective websites:
Under certain circumstances, you may have a number of privacy rights concerning the use, storage, and processing of your Personal Data (e.g., the right to delete your data). Here is a list of privacy rights:
- Right to be informed - we are publishing this Privacy Policy to keep you informed as to what we do with your Personal Data. You can ask us for Personal Data regarding you that we keep at any time. This information concerns, among other things, the data categories we process, for what purposes we process them, the origin of the data if we did not acquire them directly from you, and, if applicable, the recipients to whom we have sent your data.
- Right of access – You may ask us whether we process your Personal Data and you have the right to request a copy of the data we hold about you.
- Right of rectification – You have the right to correct inaccurate or incomplete data about you.
- Right to be forgotten – You can ask for the Personal Data that we hold about you to be erased from our system and we will comply with this request unless we have a legitimate reason, legal requirement, and other statutory basis not to do so. Even if we can delete (erase) the Personal Data subject to our active (ongoing) processing activities and cease its processing, we will nevertheless retain this particular Personal Data in our backup and archive storage to fulfill our statutory and other requirements.
- Right to restriction of processing – where certain conditions apply, you can ask us to ‘block’ the processing of your Personal Data.
- Right to data portability – You have the right to have the data we hold about you transferred to another organization and to receive Personal Data in a structured, commonly used format. Please email to find out whether we currently support the provision of the portable file containing Personal Data we process about you.
- Right to object - You can object to the processing of your data by emailing at any time for reasons that arise from your special situation provided the data processing is based on our legitimate interest or that of a third party, or where we carry out profiling, use machine learning or automated decision-making algorithms. In this case, we will no longer process your Personal Data. The latter does not apply if we are able to prove there are compelling, defensible reasons for the processing that outweigh your interests or if we require your data to assert, exercise, or defend legal claims.
- Right to withdraw consent - withdraw the consent you gave us with regard to the processing of your Personal Data for certain purposes.
- Right to complain - we take your rights very seriously. However, if you are of the opinion that we have not dealt with your complaints adequately, you have the right to submit a complaint to the data privacy protection authorities responsible. You can send your complaints to the EEA supervisory authority of your country of residence.
Please email [email protected] with any questions about exercising any of the above rights.
Transfers to third countries shall be made subject to appropriate safeguards, namely Standard Contractual Clauses adopted by the supervisory authority and approved by the Commission. Copy of the foregoing appropriate safeguards may be obtained by you upon a prior written request sent. We may instruct you on further steps to be taken with the purpose of obtaining such a copy, including your obligation to assume confidentiality commitments in connection with disclosing the Genie proprietary and personal information of third parties as well as terms of their relationships with Genie.
Keep in mind that the use of the Platform based on public blockchains is intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to deanonymisation and the unintentional revelation of Personal Data, in particular when blockchain data is combined with other data. Because blockchains are decentralized or third-party networks that are not controlled or operated by us, we are not able to erase, modify, or alter Personal Data from such networks.
We take data security very seriously. We work hard to protect the Personal Data you provide us from loss, misuse, or unauthorized access. We utilize a variety of safeguards such as encryption, digital and physical access controls, non-disclosure agreements, and other technical and organizational measures to protect the Personal Data submitted to us, both during transmission and once it is at rest.
Please note that no electronic transmission, storage, or processing of Personal Data can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard Personal Data will never be defeated or fail, or that those measures will always be sufficient or effective. Therefore, although we are committed to protecting your privacy, we do not promise, and you should not expect that your Personal Data will always remain private or secure.
Last modified 1mo ago