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Privacy Policy

GENERAL TERMS
  1. This Privacy Policy (hereinafter - "Policy"):
    • Describes how GENESIS GROUP AG,CHE-135.623.633, legal address: Chamerstrasse 172 6300, Zug, Switzerland(hereinafter – GENESIS ), collects, obtains (receives), stores, protects, uses, destroys (erase), retrieves and otherwise legally processes Your Personal Data,types and categories of such Personal Data, and purposes and legal grounds of the processing, and
    • informs You about Your rights regarding the processing of Your Personal Data by GENESIS .
  2. GENESIS collects and processes Your Personal Data in accordance with Swiss Federal Data Protection Act (hereinafter referred to as -DPA) and the Data Protection Ordinance (hereinafter referred to asDPO), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter referred to as GDPR), other regulatory enactments, and only:
    • for the legitimateaims and purposes and on the legitimate grounds,which are expressly and clearly defined inthis Policy, and
    • strictly to the extent and in amounts and strictly for the time frames necessary to achieve the purposes, for which the Personal Data is collected and processed, and
    • subject to implementation of the appropriate technical and organisational measures in order to safeguard the rights and freedoms of the DataSubject (You), including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage of Personal Data.
  3. in addition to the definitions, set forth in other sections of this Policy, such definitions are used herein:
    • “Personal Data” means any information relating to You, as an identified or identifiable natural person (‘data subject’);
    • “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
    • “Controller”means- GENESIS GROUP AG, CHE-135.623.633,legal address: Chamerstrasse 172 6300, Zug, Switzerland, email: help@dialoq.com, tel.+44 78 72 25 0555;
    • “You” and/or “Your” means any natural person (Data subject), whose Personal Data is processed by GENESIS , when:
      1. You use GENESIS Services or register as or enquire about becoming a GENESIS customer, subscriber or user;
      2. You apply for a job, and/or establish, amend, terminate employment relations with GENESIS and You submit Your Personal Data or GENESIS acquires Your Personal Data from public databases on/or governmental/municipal/local authorities during employment relations with You in accordance with the law;
      3. You register, enter, post, share, modify Your Personal Data in, or close Your user account;
      4. You offer or provide goods or services to GENESIS ;
      5. You use, visit, surf or browse the or navigate through the Website www.dialoq.com (hereinafter- Website);
      6. You communicate with GENESIS in any way, including, but not limited to orally, in written, by phone, via e-mail, via communication forms on the Website, via GENESIS profile in social networks etc.;
      7. You submit or post any and all Your information, content, including photographs or comments to the Website, Your user profile, or GENESIS profiles in the social networks,
      8. GENESIS receives Your Personal Data from law enforcement authorities or courts and/or other competent authorities;
      9. GENESIS receives Your Personal Data from the Group Account holder;
      10. GENESIS receives Your Personal Data from its’ agents with Your consent, given to this agent;
      11. GENESIS receives Your Personal Data from You or the third party with Your consent, given to this third party;
      12. JARA acquires the information and Your Personal Data from credit reference and fraud prevention agencies (only if required by law);
    • “Processor”means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller;
    • “Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Data relating to him or her;
    • “Personal Data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed;
    • " GENESIS Services" are the services, including DIALOQ call services, and products offered by GENESIS , including, but not limited to call services, internet access services, Messaging Services, sim-cards, equipment and Devices (as smartphones, cellar phones, tablets, etc.) and any and all other services and products provided by GENESIS , as a distributor of Wireless Communications Services ("Services") operators provided in connection to Operators’ services under the trade mark "DIALOQ".; GENESIS Services are not intended for anyone under 18 years of age.
    • “Group account” – User account designated for a group of individuals (natural persons) (ex: members of the family, employees, team etc.) hold by one User, either individual or legal entity.
  4. GENESIS ensures the confidentiality, privacy and security of Your Personal Data, as well as the legality of the data processing in accordance with the DPO, DPAand GDPR, and other related regulatory enactments.
2. SPECIAL TERMS ON DATA PROCESSING WHILE USING GENESIS SERVICES
  1. By using GENESIS Services, You confirm,acknowledge and understand that GENESIS IS ONLY THE DISTRIBUTOR of the Wireless Communication Services, including, but not limited to call services, internet access services, messaging services, sim-cards and other equipment with same functionality, which are provided by the international operators, some of whom are not located in Switzerland or EEA. GENESIS by itself IS NOT A TELECOMMUNICATION, including, but not limited to wireless communication service OPERATOR OR PROVIDER within the meaning of law, and in this respect, by accepting this Policy and using GENESIS Services You acknowledge and agree that some of Your pseudonymized/anonymized Personal Data, for example: location data and traffic data, will be processed by the telecommunication or wireless communication service operator/provider, in order to and within the purposes of providing You the worldwide telecommunication and wireless communication services and making these services technically feasible (e.g. roaming services).
  2. GENESIS warrants, that GENESIS cooperates only with telecommunication or wireless communication service operators/providers, who
    • are the certified, registered or public telecommunication or wireless communication service operators/providers;
    • areproviding sufficient guarantees to implement appropriate technical and organisational measures in such a manner that any Your Personal Data processing will meet the requirements of DPO, DPA and GDPR, and other related regulatory enactments and ensure the protection of the rights of the You as data subject.
  3. GENESIS does not share or provide any and all of Youridentification data, as name, surname, ID document data, correspondence/contact data, payment requisites etc. with or to the telecommunication or wireless communication service operators/providers. GENESIS ensures anonymization and pseudonymisation of any and all data and information, that GENESIS may transfer to the telecommunication or wireless communication service operators/providers, in a manner, that such data and information cannot in any way be associated with You or any other Your data, which the telecommunication or wireless communication service operators/providers have or may have about You.
  4. If provided by law, including international treaties between Switzerland and the residence state of telecommunication or wireless communication service operators/providers, GENESIS may disclose Your identity and contact information to governmental institutions, law enforcement body, court or other authorized institution or organization of the residence state of telecommunication or wireless communication service operators/providers,on the basis of the legal, grounded and valid request of such authority, institution or law enforcement body,court or other authorized institution or organization.
3. THE PERSONAL DATA GENESIS PROCESSES, LEGITIMATE PURPOSES AND GROUNDS AND PERSONAL DATA SOURCES:
Type or Categories of Your Personal Data Purpose Legal grounds for use of Your Personal Data The Source of Personal Data
Agreement (registration data) data
Your identity information, as name, surname, identity code or number, if any, payment method (requisites), date of birth, residence address, e-mail, phone number, - identity document data-when provided by law
  • To identify You;
  • To process any Your applications or registrations and/or to take steps to enter into, to perform, to implicate, to amend, to terminate or to cancel any Agreement with You (including, but not limited to employment, service, purchase, licences and any and all other agreement, You as a natural person may enter into with the GENESIS );
  • to provide GENESIS Services to You, or for GENESIS to receive services and goods from You;
  • To conduct credit and fraud checks if You apply for a monthly price plan account, and to help to verify Your identity and to decide whether to accept Your application or future application (only if required by law).
  • To provide GENESIS customer services.
  • To inform You on important and/or legal events considering the Agreement with You, including legal disputes, violations of terms and conditions etc.;
  • To maintain the accountancy, personnel and employment management.
  • The conclusion, performance, amendment, termination and/or cancelation of the Agreement between You and GENESIS .
  • GENESIS legitimate interests;
  • Your consent, given in Agreement;
  • compliance with legal or regulatory obligations to which GENESIS is subject;
  • Credit refence and fraud prevention agencies, only if required by law;
  • Group Account holder, if applicable.
  • Our agents;
Employment data: Your identity information, as name, surname, identity code or number, if any, payment method, date of birth, residence address, e-mail, phone number, - identity document data-when provided by law data about education, skills, knowledges, work experience and other data defined in law on employment, tax laws and other related regulatory enactments of Switzerland.
  • You;
  • Recruitment and employment agencies, You have provided Your personal data to.
Correspondence data
Your identity information as name, surname and correspondence address /method and other Personal Data You submit to GENESIS by any written or oral correspondence, including claims, complaints, offers, also job offers.
  • To manage Your correspondence, complaints, feedback and queries.
  • Your consent;
  • GENESIS legitimate interests;
  • compliance with legal or regulatory obligations to which GENESIS is subject
  • You;
Promotional data
Your name and surname, e-mail and phone number;
  • To notify You about changes to GENESIS Services, General terms and Conditions, the Website and to keep You up to date, new GENESIS products etc;
  • To contact You for market research purposes.
  • Your consent;
  • GENESIS legitimate business interests;
  • the development of the Services and business activities of GENESIS .
  • You;
Billing and accounting data
Your selected tariff plan: number of minutes of voice call (incoming or outgoing), megabytes of data (incoming or outgoing), messaging (sms), other payments (including salaries) and payment terms, defined in Your agreement with GENESIS and related taxes, fees and other obligatory payments.
  • To organize billing and accountancy management.
  • The conclusion, performance, amendment, termination and/or cancelation of the Agreement between You and GENESIS .
  • GENESIS legitimate interests;
  • compliance with legal or regulatory obligations to which GENESIS is subject;
  • You;
  • The Agreement with You;
  • Public data bases.
Website (cookies) data (See Cookies Policy) Your IP address, Your Device, Your operating system, the date and time of Your access to the Website, the type of browser Your use, Your online activities and Your preferences, the external sites that referred you to GENESIS Services
  • to remember stateful information;
  • to record Your browsing activity (including clicking particular buttons, logging in);
  • to remember arbitrary pieces of information that the user previously entered into form fields.
  • To analyse, administer and improve the Website and the GENESIS Services,
  • to gather statistical information about visits to the Website.
  • Other Users, advertisers and advertising networks that serve ads on the Website may also use their own mechanisms, like cookies. These third-party cookies are governed by the privacy policies of the entities placing the ads and are not subject to this Policy.
  • Your consent;
  • GENESIS legitimate interests;
  • Your Device (Your browser)
Personal Data received from law enforcement authorities or courts and/or other competent authorities.
  • To fulfil legal obligations stipulated by law or competent authorities.
  • compliance with legal or regulatory obligations to which GENESIS is subject.
  • law enforcement authorities or courts and/or other competent authorities.
  • If and when GENESIS receives Your Personal Data from other sources and/or persons, not mentioned above, which are not properly authorized by regulatory enactments or governmental/municipal authorities, GENESIS will not process such Personal Data without Your previous consent.
  1. You are solely responsible for the validity, accuracy, correctness, reliability, quality, stability, completeness or up-to-datenessof Your Personal Data, You personally provide to GENESIS and/or its Agents.
  2. GENESIS does not knowingly collect personal information from or on behalf of someone under 18. If You are under 18 but over 16, do not register on the Website or provide any information about Yourself to GENESIS withoutconsent, which must be given or GENESIS must be authorisedby the holder of parental responsibility over You. GENESIS shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over You, taking into consideration available technology. If You are under 16, do not register on the Website or provide any information about Yourself. If GENESIS learnsto have collected or received Personal Data from or on behalf of someone under 18 without consent of the holder of parental responsibility, or from or on behalf of someone under 16, GENESIS will remove/erasesuch information and/or user account and not make future process Your Personal Data.
  3. GENESIS does not process Your sensitive and other Personal Data, which processing is forbidden or restricted by law.You should not provide sensitive or special data, that is, data concerning racial or ethnic origin, political views, religious or philosophical beliefs, trade union membership, genetic and biometric data, data concerning health, or data concerning your sexual life or sexual orientation, in any material You submit to GENESIS in any way.
  4. GENESIS does not listen to Your calls and read Your SMS;
  5. No automated individual decision making or profiling is performed in the course of the data processing of GENESIS .
  6. When You are using GENESIS Services, GENESIS offers You choices (privacy preferences) regarding how GENESIS contacts You for marketing related communications(Promotional Data) and whether GENESIS uses information regarding Your online activities on the Website for marketing purposes. To learn about ways to register Your privacy preferences with GENESIS please contact GENESIS . You may also register a do- not- contact requests by calling customer care or sending an email to help@dialoq.com. If You register a do-not-contact request, GENESIS may still contact You for non-promotional purposes, such as emails about Your accounts or our ongoing business relations.
  7. You may refuse to accept browser cookies through Your browser settings. However, if You select this setting, You may be unable to access certain parts of GENESIS Services and the Website. Unless You set your browser to refuse cookies, GENESIS system may issue cookies when you direct your browser to GENESIS Services. If You disable cookies on Your Internet browser, GENESIS also may stop some processing of Your Personal Data when You visit the Website. For more details on how GENESIS uses cookies see Cookies Policy.
  8. If You are member or user of the Group Account (e.g. as family member or employee of the Group account holder), some of Your Personal Data may be provided to GENESIS by the Group Account holder, who is Your Personal Data Controller and who processes, including, but not limited to discloses /transfers Your Personal Data to GENESIS subject to his/her Privacy policy and his/her responsibility and liability and other Personal Data protection and processing regulations.
THE LEGITIMATE INTERESTS OF THE GENESIS
  1. Legitimate interests of GENESIS are:
    • To enter into and to perform the Agreement between You and GENESIS ;
    • Toensure and protect the interests and rights of GENESIS (for example, to file an objection, claim or pretension, and/or to bring an action to a court or arbitrage);
    • To provide GENESIS Services;
    • To ensure the cyber, network and information security of GENESIS systems;
    • To develop and to enchase the GENESIS Services and business activities;
    • To support and analyse the performance of the Webpage;
    • To detect and prevent fraud, including the violations against GENESIS and its rights;
    • To maintain the personnel and employment management;
    • To maintain the accountancy management;
    • To comply with local and foreign law, law enforcement, court and regulatory bodies’ (governmental and municipal /local authorities) requirements;
    • To operate the day-to-day running of the business and plan for strategic growth, including managing of customer, client, user, vendor, contractor, supplier and other relationships, sharing intelligence with stakeholders, implementing safety procedures, and planning and allocate resources and budget (General Corporate Operations and Due Diligence);
    • To protect the rights or property of GENESIS , its agents, members, customers, and others including to enforce GENESIS agreements, policies and terms of use of its Services.
    • To respond to emergencies;
    • To communicate with the users, clients, customers, suppliers etc business partners of GENESIS (send and receive Your correspondence, and provide the correspondent with an accurate, timely and apropos reply to You);
    • To initiate, render, bill, and collect payments for GENESIS Services;
    • To facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement; or determine eligibility for government benefits.
    • To comply with legal or regulatory obligations to which GENESIS is subjected.
5. YOUR CONSENT
  1. When and where the processing of Your Personal Data is a subject to Your Consent, You may give Your Consent and GENESIS shall consider that Your Consent is received, if:
    • You have provided GENESIS with Yourfreely given, specific, deliberate, informed and unambiguous reference, or statement of Your consent on the processing of Your Personal Data, or
    • You have performed a clear affirmative activity confirming Your consent to the processing of the Personal Data, or
    • You have -in any way (in writing, orally or electronically)- accepted this Policy, including, but not limited to:
      1. When browsing, using, surfing or visiting the Website - You have read and accepted this Privacy policy by clicking “I have read and accept” button.
      2. When coming into agreement with GENESIS - You have read and accepted this Privacy policy and acknowledged it in the agreement;
      3. When submittingany Personal Data to GENESIS within any correspondence (including, claims, orders, letters, questions, job applications, posts on the Website or social networks)-You have submitted the information and Personal Data, voluntarily,and to the extents and in amounts that You independently and at Your sole discretion considered to be necessary for the GENESIS to process.
  2. 2) You are entitled to withdraw Your consent in any time, bysubmitting Yourrequest (withdrawal) in written to GENESIS GROUP AG, Chamerstrasse 172, 6300, Zug, Switzerland, or email: help@dialoq.com.
    • In case if, upon receipt of Your withdrawal, GENESIS has reasonable doubts concerning Your identity, GENESIS may request the provision of additional information necessary to confirm Your identity.
    • Upon receipt of Yourwithdrawal, GENESIS shall ascertain Your identity and will stop processingYour Personal Data, based on Your prior consent given for this processing purpose.
    • Please note and evaluate, that in case, if the processing is based on the legitimate interests of GENESIS , You have a right to object to processing rather than withdrawal of consent.
    • The withdrawal of Yourconsent will not affect the lawfulness of Your Personal Data processing based on Your consent, performed before GENESIS has received Your withdrawal.
    • If and when after withdrawal of the consent, You perform any of the confirmative actions set forth in this Clause, GENESIS will consider that the consent is given again.
6. THE RECIPIENTS OF YOUR PERSONAL DATA/DISCLOSURE of YOUR PERSONAL DATA
  1. GENESIS may disclose Your Personal Data to third parties, as follows, who provides sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of GPDR , DPA and DPO and ensure the protection of the rights of the data subject (You):
    • GENESIS business partners, suppliers and contractors, who help GENESIS to provide GENESIS Services, including, but not limited to the banks, payment service providers, information system consultants and analytical and research service providers;
    • GENESIS professional advisers (including accountants and lawyers) that assist GENESIS in carrying out its business and legal activities;
    • law enforcement agencies and other authorized persons in connection with the prevention,investigation and detection of crime or any suspected criminal, administrative or civil wrongdoing;
    • to the courts, law enforcement, court and regulatory bodies’ (governmental and municipal /local authorities)third parties, if GENESIS is under a duty to disclose or share Your Personal Data in order to comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), or in order to enforce or apply the terms of any agreements GENESIS has with or otherwise concerning You (including agreements between You and us) or to protect rights, property or safety of customers, employees of GENESIS or other third parties of the GENESIS .
    • to third parties and in cases, defined in Clause 2 of this Policy.
    • GENESIS may also disclose Your Personal Data to other third parties, for example:
      1. in the event that GENESIS sells or buys any business or assets GENESIS will disclose Your Personal Data to the prospective seller or buyer of such business or assets;
      2. if GENESIS or substantially all of GENESIS assets are acquired by a third party, Personal Data held by GENESIS will be one of the transferred assets;
      3. Group Account Holders. Only if Your Personal Data is processed within Group Account. The account holder for Group Accounts is the entity or natural person that buys GENESIS Services or product for its employees, family members or other authorized users. You (as the user of a device) may receive service, certain pricing, terms or other benefits through a Group Account. If so, GENESIS may share with that Group Account HolderYour registration and other information related to Your use of GENESIS Services.
      4. Other Third Parties with Your Consent. GENESIS may share information with other third parties with your previous consent.
  2. Third Party Application and Service Providers. You may choose to use services and products offered by third parties through GENESIS Services or devices like third party applications. In each case, the procession of Your Personal Data you give a third party will be subject to its terms, conditions, and policies—not this policy. You should review a third party’s privacy policy and terms of service before providing your information or using the service.
  3. You may also choose to give personal information directly to third parties when using GENESIS Services or when cooperating with GENESIS in other ways (employment, business cooperation etc.). In each case, Personal Data you give a third party will be subject to its terms, conditions, and policies—not this policy. You should review a third party’s privacy policy and terms of service before providing your information or using the service.
7. DURATION OF THE STORAGE
  1. GENESIS will process Your Personal Data as long as there is at least one of the following conditions:
    • While is valid /not withdrawnYour consent to the processing of Your Personal Data, provided that there is no other legal basis or legitimate purpose of Your PersonalDataprocessing.
    • While is valid Your Agreement with GENESIS .
    • while Your Personal Data is necessary for the legal grounds, the legitimate purpose and / or aims for which they were received/collected or other way processed;
    • while in accordance with the procedures prescribed by regulatory enactments, GENESIS or Youmay exercise their rights and legitimate interests (for example, to submit objections or claims, or to bringany action or claim before a court or arbitrage);
    • while GENESIS has a legal obligation to keep Your Personal Data(for example, in accordance with the Accounting regulatory enactments, etc.);
  2. After termination of the conditions indicated in this Clause, Your Personal Data will be deleted /erased or, in cases specified in regulatory enactments, transferred to the state archive (in state storage).
  3. Job application and Your CVPersonal Datashall be stored within 3 (three)month upon GENESIS has received, excluding if You expressly defined other processing terms in Your application form,for recruitment purposes.
  4. Cookies Data shall be stored within time, set forth in Cookies Policy.
8. YOUR RIGHTS CONCERNING THE PROCESSING OF YOUR PERSONAL DATA
  1. You have the following rights concerning the processing of Your Personal Data:
    • Right to withdrawYourconsent - You have the right to withdraw Your consent as set forth in part 2) of Clause5 of this Policy.
    • Right of access to Your Personal Data- You have the right to receive a copy of Your Personal Data that GENESIS processes about You, subject to certain exemptions provided by regulatory enactments.
    • Right to rectify Your Personal Data- You have the right to ask GENESIS to correct Your Personal Data that GENESIS processes where it is incorrect or incomplete.
    • Right to erasure of Your Personal Data-You have the right to ask that Your Personal Data be deleted/erased in case if:
      1. Your Personal Data is no longer necessary in relation to the purposes for which they were processed, collected or otherwise used by GENESIS ;
      2. You withdraw Your consent and there is no other legal ground or legitimate purpose for which GENESIS may processYour Personal Data;
      3. You object to the processing of Your Personal Data (as set out below);
      4. GENESIS has used Your Personal Data unlawfully; or
      5. Your Personal Data needs to be erased to comply with a legal obligation.
    • Right to restrict the use of Your Personal Data- You have the right to suspend processing of Your Personal Data, in case if:
      1. Youbelieve thatYour Personal Data is inaccurate and only for such period to enable GENESIS to verify the accuracy of Your Personal Data;
      2. the processing of Your Personal Data is unlawful and You oppose the erasure of Your Personal Data and request that it is suspended instead;
      3. GENESIS no longer needsYour Personal Data, but Your Personal Data is required by You for the establishment, exercise or defence of legal claims; or
      4. You have objected to the processing of Your Personal Data and GENESIS is verifying whether its grounds for the processing of Your Personal Dataare of the highest importance than Your objection.
    • Right to data portability- You have the right to obtain Your Personal Data in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the processing of Your Personal Data is based on Your consent or for the performance of Your Agreement with GENESIS , and when the processing ofYour Personal Data is carried out by automated (i.e. electronic) means.
    • Right to object to the processing ofYour Personal Data -You have the right to object to the processing of Your Personal Data in certain circumstances, where
      1. You have grounds relating to Your particular situation and GENESIS processesYour Personal Data for legitimate interests (or those of a third party) of the GENESIS including for profiling; and
      2. You object to the processing of Your Personal Data for direct marketing purposes, including profiling (to the extent it relates to direct marketing).
    • Right to object to decision which is based solely on automated processing- You have the rightsto object to being subject to a decision which is based solely on automated processing without human intervention.
    • Right to complain to the relevant data protection authority- see part 2) of the Clause 9.
  2. You may submit a request for the exercise of Your rights in writing to GENESIS GROUP AG: Chamerstrasse 172, 6300, Zug, Switzerland, or email: help@dialoq.com.
  3. Ifupon receipt of Your request GENESIS has reasonable doubts concerning Your identity GENESIS may request the provision of additional information necessary to confirm Your identity.
  4. Upon receipt of Your request, GENESIS shall ascertain Your identity, examine and reviewYour request and execute / or reasonably reject in accordance with the GDPR,DPO, DPAand other related Data protection regulatory enactments.
  5. GENESIS well send a reply toYour request to a mailing (contact) address provided by You in Your request, by registered mail or other way, as Youasked in Your request if technically feasible, within 30 (thirty) days from the date of receipt of the request. Please note, that if You haven’t provided Your contact address and / or other way of receiving the reply, GENESIS will not be able to send it to You and You should contact GENESIS personally to arrange the way and time You can receive it.
  6. Information provided and any communication and any actions taken under this Clause shall be provided free of charge. Where requests from You are manifestly unfounded or excessive, in particular because of their repetitive character, GENESIS may either:
    1. charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
    2. refuse to act on the request.
9. COMPLAINTS
  1. If you have any concerns or complaints regarding the privacy of Your Personal Data GENESIS processes You may submit a request for the exercise of Your rights in writing to GENESIS GROUP AG, Chamerstrasse 172, 6300, Zug, Switzerland, or email: help@dialoq.com.
    • If upon receipt of Your request GENESIS has reasonable doubts concerning Your identity GENESIS may request the provision of additional information necessary to confirm Your identity.
    • Upon receipt of Your request, GENESIS shall ascertain Your identity, examine and review Your request and provide a reply in accordance with the GDPR, DPO, DPA and other related Data protection regulatory enactments.
    • GENESIS well send a reply to Your request to a mailing (contact) address provided by You in Your request, by registered mail or other way, as You asked in Your request, if technically feasible, within 30 (thirty) days from the date of receipt of the request. Please note, that if You haven’t provided Your contact address and / or other way of receiving the reply, GENESIS will not be able to send it to You and You should contact GENESIS personally to arrange the way and time You can receive it.
  2. The reply provided and any communication and any actions taken under this Clause shall be provided free of charge. Where requests from You are manifestly unfounded or excessive, in particular because of their repetitive character, GENESIS may either:
    • charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or
    • refuse to act on the request.
  3. You have the right to address any Your claim concerning Your Personal Data processing by GENESIS to the competent personal data protection supervisory authority which, in case of GENESIS , is Office of the Federal Data Protection and Information Commissioner FDPIC, Feldeggweg 1, CH - 3003 Berne, phone: +41 (0)58 462 43 95, Telefax: +41 (0)58 465 99 96 or Cantonal data protection and Information Commissioners (for more information see-https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection---switzerland.html).
PERSONAL DATA SECURITY
  1. As soon as GENESIS collected YourPersonal Data, GENESIS uses various security features and procedures, taking into account industry standards, to protect Your Personal Data and to prevent unauthorized access to that information. GENESIS maintains a variety of appropriate technical and organisational physical, electronic, and procedural safeguards and measures, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage of Personal Data. These safeguards help protect Your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. These safeguards include:
    • ensuring the pseudonymisation and encryption of Personal Data;
    • ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
    • ensuring the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
    • ensuring the process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing of Personal Data.
  2. GENESIS will do all the best to protect Your information and Personal Data, for use of GENESIS Services, You have to keep Your User Account, User Profile dataas well as all the information and dataYou issue, send, post, publish share etc on/or via the Website and or Social networks and/or other way, safe by using a strong password and by complying with obligations, set forth in Terms and Conditions on use of GENESIS Services/ and or Your agreement with GENESIS .
  3. In accordance with the recommendations of Payment Card Industry Security Standards Council, customer card details are protected using Transport Layer encryption - TLS 1.2 and application layer with algorithm AES and key length 256 bit.
9. COMPLAINTS
  1. If You have any questions about, or complaints that concern this Policy, please call GENESIS at +44 78 72 25 0555 or email GENESIS athelp@dialoq.com.
  2. GENESIS may change this Policy at any time. When GENESIS changes the Policy, GENESIS shall post that changes on the Website. In case of material changes to how GENESIS process Your Personal Data, GENESIS shall notify You by email to the email address specified by You. You are responsible for ensuring GENESIS has an up-to-date, active and deliverable email address for You. You are also responsible for reviewing this Policy from time to time to check for any changes. All changes are effective immediately when GENESIS posted them.
  3. This Policy is effective from
  4. The date Policy was last revised is identified at the top of the page.