Privacy Policy

Welcome to (the “Site”). The following Privacy Policy sets forth the way in which information you provide to the Site will be used. The words “user,” “you” and “your” as used in this agreement refer to users of the Site, and if you are under the age of eighteen (18), “you” and “your” also include your parents or legal guardians. “We”, “our”, “Gen II” and “us” refer to Gen II Fund Services, LLC, located at 825 Third Avenue New York, NY 10022 and its affiliates.
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.
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.
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:
  • In the context of our Site: to answer any queries from you, or provide requested services, to provide marketing email regarding services you receive from us, managing other requests (e.g. to attend an event) or to notify you about any changes to our services, to make statistics, to process your application for a position within Gen II, to provide you access with our portals, to allow you to log in or log out as a client, to present our Site and its contents in a suitable and effective manner for you, to use our cookies and web beacons, to enforce our Terms of Use and other agreements; 
  • 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 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.
Cookies are files that your web browser saves to your computer’s hard drive when you visit a website. These files contain Information that allows websites to “remember” user activities on a website and user visits to a website. Gen II Fund Services, LLC uses cookies to uniquely and anonymously as the case may be, identify the user preferences. Use of cookies helps us to improve our Site and to deliver a better and more personalized service by enabling us to: (i) estimate our audience size and usage patterns; (ii) store information about your preferences, allowing us to customize our Site according to your individual interests; and (iii) recognize you when you return to our Site and know what parts of the Site you visit, your preferences and what is most relevant to you.

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.
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.
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.
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.
If any provision of this Privacy Policy is found to be illegal, void, or unenforceable, that provision will be deemed severed from the balance of the agreement and will not affect the validity and enforceability of the remaining provisions, which will continue in full force and effect.
By using our Site, you agree to our Privacy Policy that may be subject to changes from time to time. We will notify you of changes to this Privacy Policy by posting them on this page. We reserve the right, in our sole discretion, to change, modify, add or otherwise alter this Privacy Policy at any time. Such changes, modifications and/or alterations are effective immediately upon their posting here. Your use of the Site shall be deemed to confirm your acceptance of this Privacy Policy and any changes, modifications or alterations thereof. Your consent to this and any new Privacy Policy will be required in order for you to continue to use the Site. Your continued use of the Site is deemed to be an acceptance of such changes. You are responsible for periodically reviewing this page. We encourage you to check back and review this Privacy Policy periodically so that you will always know what Information we collect, how we use it, and to whom we disclose it.
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. 
For any question or queries you may have regarding this Privacy Policy, please use the following email address:
This page was last updated on June 1 , 2018.