Some information we collect may be considered as personal data within the meaning of applicable data protection laws and namely, the European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data, meaning any information allowing the direct or indirect identification of an individual natural person (the “Information”).
In the context of the Site, Gen II acts as data controller (i.e. the organization which determines why and how to process Information) for your personal data.
We will process your Information in compliance with applicable laws.
We may collect and use Information relating to Individuals (including clients) who use or visit our Site;
Our Policy does not apply to information collected on any third-party website that may link to, or be accessible from, our Site.
INFORMATION WE COLLECT
You may provide us with your Information when you download material, apply for a job or an internship on the Site, use our web based portal, log in and log out, follow us by clicking on social media buttons and search on our Site.
We may collect Information from and about you in relation to the use of our Site, or in relation to other individuals where Information of other individuals is obtained from you, or a third party with individuals’ knowledge, including for example the following types of Information:
- IT-related Information such as when you navigate, including IP addresses, cookies and web beacons, records and copies of your correspondence including e-mail address;
- Identification Information, such as your name, date and place of birth, gender;
- Contact and details Information, such as postal address, e-mail address, phone numbers, country of residence, nationality, company you work for, cv;
- Types of services received or provided;
- Financial and banking Information; and
- Other relevant Information or Information reasonably related to the conduct of our business.
We do not knowingly collect or process Information from children under the age of eighteen (18), or under another older age according to applicable laws.
WHY WE PROCESS YOUR INFORMATION
We may only process your Information for at least one of the following legitimate basis and purposes:
(i) The processing is necessary for the performance of an agreement, or for entering into an agreement with you;
(ii) The processing is necessary for us to comply with a legal obligation, for instance to allow us to comply with commercial, or tax laws and any regulatory obligations and to allow us to respond to requests and comply with requirements from public authorities;
(iii) The processing is necessary for our, or a third party’s, legitimate interest, for example:
- Outside the context of our Site browsing: to provide our services, to manage our relationships with our suppliers, services provider and subcontractors as well as to prevent fraud and credit risk, manage litigation and to protect the rights, property, or safety of Gen II Fund Services, LLC and its affiliates; and
(iv) You have given your prior consent, for example, to receive commercial communications from us, or third parties, or to use third party cookies and web beacons, unless otherwise required by applicable laws.
USAGE DETAILS, IP ADDRESSES, COOKIES AND LINKS
Usage details and IP addresses
We may collect statistical Information about our Site users’ equipment, browsing actions and patterns. Such Information derives from your navigation of the Site. The Information may include, for example: (i) traffic, location data, logs and other communication data; (ii) Information regarding the resources that you access; and (iii) Information about your computer and Internet connection (e.g. including your IP address, operating system and browser type), for system administration.
We use the following kinds of cookies on our Site:
- Session cookies, which last only for the duration of your visit. These enable us to identify that the same person is moving from page to page. We store and collect a unique ID to track your session from page to page via session cookies;
- Persistent cookies, which last beyond your session enabling an enhanced user experience when you return to the Site;
The Site may contain links to other websites. Gen II Fund Services, LLC is not responsible for the privacy practices of such other websites. You should read the privacy policies of all websites that are linked to the Site.
DISCLOSURE AND TRANSFER OF INFORMATION
In order to achieve the purposes listed above, we may disclose the Information generated as a result of activity on our website to recipients such as companies within Gen II, contractors, suppliers, subcontractors and third party service providers we interact with to support our business and our Site, to public authorities and related bodies, and to the extent required under applicable laws.
You are informed that certain recipients mentioned above may be located outside the territory of the European Union in countries that do not offer a level of protection equivalent to the one granted in the European Union. Any Information transfer to such recipients will, depending on the nature of the transfer:
- be covered by appropriate safeguards such as standard contractual clauses approved by the European Commission (e.g. your Information obtained from cookies may be stored and processed in the United States, or any other country where Gen II Fund Services, LLC maintains its servers), in which case you may obtain a copy of such safeguards by contacting us; or
- be otherwise authorized under applicable data protection law, as the case may be, as such transfer is necessary for the performance or execution of a contract concluded in your interest or for the establishment, exercise or defense of legal claims, or for the performance of a contract between you and us.
HOW LONG DO WE STORE YOUR INFORMATION
We will store your Information only for as long as necessary for the relevant processing activity to be completed and/or for the retention period permitted under applicable laws.
SECURITY OF YOUR INFORMATION
We have implemented commercially reasonable administrative, technical and physical safeguards for our Site to protect your Information from loss, misuse, unauthorized access, disclosure, unauthorized alteration or unlawful destruction. In addition, we require IT and security service providers to put in place reasonably appropriate technical and organizational security measures in respect of any of your Information.
Unfortunately, the transmission of Information via the Internet is not guaranteed to be secure. Although we do our best to protect your Information, we cannot guarantee the security of your Information transmitted to our Site. Any transmission of Information is at your own risk.
You have the following rights regarding the processing of your Information by us, subject to applicable exemptions:
- right to access the Information held about you and receive additional information about how it is processed;
- right to correct, or complete any inaccurate or incomplete Information;
- right to request erasure of your Information from our systems (e.g. where the Information is no longer necessary in relation to the specified purposes);
- right to restrict the processing of your Information in certain circumstances (e.g. where you contest its accuracy or object to its processing);
- right to receive your Information in an interoperable format, or have it directly transmitted to another organization;
- right to withdraw your consent at any time where you have provided us with your consent to the processing of Information;
- right to object the processing of your Information (in particular where we rely on legitimate interests, including for profiling); and
- right to lodge a complaint with the competent European Union Data Protection Authority (which generally is located in your country of residence).
We will respond to individual complaints and questions relating to privacy and will investigate and attempt to resolve all complaints. We will only be able to answer favorably to any of the above requests related to the right to oppose, right of erasure and right of restriction provided that it does not interfere with, or contradict our legal obligations (e.g. a legal obligation to keep the related Information) or due to any other impediment that would justify that we would not be able to grant such requests. We undertake to handle each request within a reasonable timeframe of one (1) month.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 allows users who are California residents to request information about the disclosure of their Information to third parties for direct marketing purposes by contacting us.
This page was last updated on June 1 , 2018.