Welcome to the Precisely Privacy Notice.
Last update: February 5, 2021
What does this Privacy Notice Cover?
Precisely and its Affiliates respect your privacy and are committed to protecting your Personal Data. At Precisely, we want to be transparent with you about how we collect and use your Personal Data in making available the websites displayed at es.genesishotelsng.com (the “Site”) and the various products and associated services provided by Precisely and its Affiliates (“Products”), as well as other Personal Data we might collect offline. We also want to make sure you know about your data privacy rights and how the law protects you.
When we refer to “Precisely and its Affiliates”, we are referring to a wider group of different legal entities. Details of both Precisely and those of its Affiliates to whom this Privacy Notice applies are listed at: Legal Entities.
This Privacy Notice is issued on behalf of Precisely and its Affiliates listed from time to time at the link shown above, so when we mention “Precisely”, “we”, “us” or “our” in this Privacy Notice, we are referring to the relevant company(ies) in the list above who are responsible for processing Personal Data about you.
This Privacy Notice is designed to describe:
- Who we are.
- Your rights relating to Personal Data about you.
- Marketing communications preferences.
- What Personal Data we collect.
- How we use Personal Data about you and why.
- What happens when you do not provide necessary Personal Data?
- Personal Data from Third Party Sources.
- Who we share Personal Data about you with.
- How we keep Personal Data about you secure.
- How long we store Personal Data about you.
- Our policy on children.
- Third party links.
This Privacy Notice is intended to meet our transparency obligations as a Controller under, among other applicable laws, the EU General Data Protection Regulation or “GDPR” and our disclosure obligation as a “business” under the California Consumer Privacy Act (“CCPA”). This Privacy Notice does not describe how we process Personal Data on our customers’ or any other person’s instructions (e.g., where we, for example, act as a Processor under the GDPR or as a Service Provider under the CCPA).
In this Privacy Notice, “Personal Data” means any information relating to an identified or reasonably identifiable natural person and, as applicable, a household.
Personal Data does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed).
However, Personal Data does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).
We will post any modifications or changes to this Privacy Notice on this page. Please contact us as described below if you wish to know which listed entity is the Controller of Personal Data about you for GDPR purposes.
Your rights relating to Personal Data about you.
Under certain circumstances, by law you have the right to:
- Request access to Personal Data about you. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of Personal Data about you. This enables you to ask us to delete or remove Personal Data where there is no lawful basis for us to continue to process it. You also have the right to ask us to delete or remove Personal Data about you where you have exercised your right to object to processing (see below).
- Object to processing of Personal Data about you. This right exists where we are relying on our legitimate interest as a legal basis for our processing and, you wish to object to processing on this ground. You also have the right to object where we are processing Personal Data about you for direct marketing purposes.
- Request the restriction of processing of Personal Data about you. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of Personal Data about you. We will provide to you, or a third party you have chosen, Personal Data about you in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent. This right only exists where we are relying on consent as a legal basis to process Personal Data about you (“Consent Withdrawal”).
How to exercise your rights
If you want to exercise any of the rights described above (except Consent Withdrawal, on which see below), please contact us using the contact details shown here How to Contact Us.
We rely on our Legitimate Interests as the legal basis for the processing of Personal Data about you that is involved in sending you marketing communications (see here How we use Personal Data about you and why) for more information on this processing activity). If you wish to exercise your right to object to the processing of Personal Data about you for this purpose, you may do so by following the opt-out processes outlined here: Marketing communications preferences. Following your exercise of your right to object, we will promptly cease processing Personal Data about you for the purpose of sending you marketing communications.
Typically, you will not have to pay a fee to access Personal Data about you (or to exercise any of the other rights outlined above). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access Personal Data about you (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Marketing communications preferences
You can ask us to stop sending you marketing messages at any time by:
- Clicking the “Update your email preferences or unsubscribe” link in the footer of any marketing communications we may send you to update your preferences accordingly; and/or
- Contacting us at any time using the contact details shown here
How to Contact Us
Where you opt-out of receiving these marketing messages, this opt-out will not apply to service-related communications (and any processing of Personal Data about you involved in sending such communications). As examples, these service-related communications may include: emails we may have to send you relating to the management of your account for the Site, your use of the Products, updates to this Privacy Notice, etc.
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
|Category of Personal Data collected||What this means|
|Identity Data||First name, last name, job title, job function, employer, marital status and gender (inferred from your title), contact type (e.g., we would take a note of whether you are a technical support, sales or other contact) username or similar identifier.|
|Contact Data||First name, last name, job title, company, business phone number, mobile phone number, home phone number, business facsimile number, business email address, personal email address, alternate email address, business mailing address, 邮政编码或类似的, state/province, country.|
|Marketing and Communications Data||Your preferences in receiving marketing from us and our third parties and your communication preferences, including your preferred language for such communications.|
|Behavioral Data||Inferred or assumed information relating to your behavior and interests, based on your online activity. This may include information on whether you have filled out a form on our Site, whether you have downloaded assets (e.g., whitepapers, e-books, solution sheets, case studies) from our Site, your activity related to emails we send you (such as ‘opens’, ‘clicks’, and ‘unsubscribes’), your website visit activity (pages visited, including pages on third party websites other than the Site and Products), and your event-related activity (e.g., whether you’ve attended any trade shows or webinars we’ve sponsored, hosted or otherwise been involved in).|
|Technical Data||Internet protocol (IP) address, your login data (including user identification and password), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Site and use the Products.|
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from Personal Data about you, but once in aggregated form it will not constitute considered Personal Data as this data does not directly or indirectly reveal your identity. For example, we may aggregate Behavioral Data about you to calculate the percentage of users accessing a specific feature of the Site or our Products. However, if we combine or connect Aggregated Data with Personal Data about you so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.
We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
What is our “legal basis” for processing Personal Data about you?
In respect of each of the purposes for which we use Personal Data about you, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
How we use Personal Data about you and why
We will only use Personal Data about you for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use Personal Data about you for an unrelated purpose, we will update this Privacy Notice and we will explain the legal basis which allows us to do so.
The table below sets out the purposes for which we use Personal Data, as well as the legal bases we rely on in respect of the relevant purposes for which we use Personal Data about you.
|Purpose||Category(ies) of Personal Data involved||Why do we do this||Our legal basis for this use of data|
||To register you as a new customer, partner/reseller or service provider.||
||To ensure that those people who use and access our Products are properly entitled to do so and are not misusing, infringing or misappropriating our (or our licensors’) intellectual property rights (or any other rights we may have) in or to the Products. To manage Product licenses, license keys, access to Products and updates or support, and for similar purposes.||
||To keep our Site, our Products and associated systems operational and secure.||
|Responding to Requests||
||To respond to inbound requests from you. This will occur in circumstances where you request:
|Site-related communications and notifications||
||To provide information and updates regarding our Site. This will occur in circumstances where:
|Product-related communications and notifications||
||To provide information and updates regarding our Products. This will occur in circumstances where:
||To keep you informed about new products, features and services and/or new educational content. In certain circumstances, this may involve sharing your Personal Data with our Marketing Partners (see here
Who we share your Personal Data with for more information).
|Marketing Segmentation and Information||
||To infer what company you work for and other information about you.||
What happens when you do not provide necessary Personal Data?
Where we need to process Personal Data about you either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. For example, we may not be able to provide you with the functionalities of the Site (e.g., setting up your account) or we may not be able to respond to or fulfil a request you make of us (e.g., for a demonstration of the Products).
In this case, we may have to stop you from using our Site or Products but we will notify you if this is the case at the time.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain Personal Data about you from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
|Third party data source||Publicly available||
Category(ies) or other types of personal data received
|Social Media sites||No||
|Affiliates (e.g., one entity amongst Precisely and its Affiliates may receive Personal Data from others)||No||
|Partners/Resellers and Customers||No||
|Marketing Vendors and Partners (e.g., Event Organizers, Data Brokers, Content Syndication Vendors, Sponsored Content with industry publications).||No||
|Market Researchers (e.g., third parties we engage to conduct research on a market topic to develop analysis or guide our marketing approach)||No||
Who we share Personal Data about you with.
The table below describes who we share Personal Data about you with, what we share and why we share it.
|Recipients||Categories of Personal Data we share.||Status of recipient||Why we share it||Location(s)|
|Affiliates (e.g., one entity amongst Precisely and its Affiliates may share Personal Data with others)||
||Controllers and/or our Processors||Our affiliates help us provide our Products and help manage our customer relationships (including providing customer support, customer liaison, etc.), as well as administrative support (including Finance, IT, HR, Legal, Operations, and other management services/oversight, such as sales and partner management and marketing, etc.).||All Regions listed in this link here:Legal Entities.|
|Partners and Resellers||
||Controllers and/or our Processors||Our Partners and Resellers help us provide our Products and related services (including support, software delivery and installation), as well as marketing of our Products and providing customer feedback.||Both within and outside Europe.|
|Service Providers (e.g., our hosting provider, CRM and marketing tool providers, our accounting and financial service providers)||
||Our Processors||Our service providers provide us with IT, software, content, applications and solutions management, hosting, system administration, management, project‑related, marketing, customer feedback, and other services.||Both within and outside Europe.|
|Consultants and advisers||
||Our Processors||Our attorneys, bankers, accountants, auditors, insurers, consultants and other advisors who provide us with their respective services may need to receive certain elements of your Personal Data to do so.||Both within and outside Europe.|
|Marketing Partners (e.g., our referral, reseller, OEM and other partners)||
||Controllers||In certain circumstances we may co-host, co-sponsor or otherwise be involved in marketing programs (such as trade shows webinars or other events) with our partners. In these circumstances, we may share your Personal Data relevant to the applicable program such partners. We will only share your Personal Data for this purpose with your consent.||Both within and outside Europe.|
|Partners in corporate transactions||
||Controllers||We may disclose Personal Data to third parties to whom we may choose to sell, transfer, or merge all or any parts of our business or our assets. If we undergo a change like this to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.||Both within and outside Europe.|
As you can see from the above, we may share Personal Data about you with both internal parties (i.e., amongst Precisely and its Affiliates) and external third parties who are based outside the European Economic Area (“ Europe”). Any processing of Personal Data about you by these parties may involve a transfer of Personal Data about you outside of Europe where they may receive Personal Data about you from one of Precisely’s Affiliates within Europe.
We endeavor to ensure that third parties to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer Personal Data about you out of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer Personal Data about you to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- Where we use service providers outside Europe or when we transfer Personal Data to Precisely’s Affiliate outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
- Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.
California Privacy Rights
The following section describes your rights if you are a resident of the State of California.
California Civil Code Section 1798.83 permits the users of our website(s) who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please contact us at email@example.com.
If you are a California resident you may also have the right:
- To request disclosure of the categories and specific pieces of Personal Data collected about you;
- To request the disclosure of the business purpose for collecting or selling Personal Data; the categories of third parties with whom it is shared, and the categories of sources from which Personal Data is collected;
- To request the deletion of Personal Data;
- To opt-out of the sale of Personal Data
- not to be discriminated against for exercising the rights guaranteed by the CCPA.
For a list of categories of Personal Data collected and the purposes for the processing of that Personal Data, please refer to “What Personal Data We Collect” and “How We Use Personal Data and Why” above.
Requests to Know
You have the right to request that we disclose:
- The categories of Personal Data we collect;
- The categories of Personal Data we have sold or disclosed for a business purpose;
- The categories of sources from which we collect Personal Data about you;
- Our business or commercial purpose for selling or collecting Personal Data;
- The categories of Personal Data sold or shared about you, as well as the categories of third parties to whom the Personal Data was sold, by category of Personal Data for each party to whom information was sold; and
- The specific pieces of Personal Data collected about you.
Delivery may take place electronically or by mail. We are not required to respond to requests relating to Personal Information more than twice in a twelve (12) month period.
Requests to Delete
With certain exceptions, you have the right to request that we delete any Personal Data we have collected about you. Upon receiving a verified request to delete Personal Data about you, we will do so unless otherwise authorized by law.
We will acknowledge the receipt of requests to know or requests to delete Personal Data free of charge, within ten (10) business days. In order to protect your privacy and the security of Personal Data, we may verify your request by asking you to provide additional Personal Data for us to verify your identity. We will respond to your request within forty-five (45) calendar days of receipt, provided that we have been able to successfully verify your identity.
You may submit a request to know or a request to delete Personal Data via firstname.lastname@example.org.
Sale of Personal Data
In the preceding twelve (12) months we have not “sold” personal information for the purposes of the CCPA and we therefore do not provide an opt-out facility on the Site.
The Right to Non-Discrimination
You have a right not to receive discriminatory treatment for the exercise of your California privacy rights.
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.
Do Not Track (‘DNT’) Settings
California law requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals on the Site. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.
How we keep Personal Data about you secure.
We have put in place appropriate security measures to prevent Personal Data about you from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We limit access to Personal Data about you to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting Personal Data about you.
Despite our efforts to store Personal Data in a secure operating environment that is not available to the public, and despite the measures we have described above, we cannot guarantee the security of Personal Data during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent malicious third-parties from illegally obtaining access to Personal Data. We do not warrant or represent that Personal Data about you will be protected against, loss, misuse, or alteration by third parties.
How long we store Personal Data About You
We will only retain Personal Data about you for so long as we reasonably need to use it for the purposes set out above How we use your Personal Data and why , unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
|Category of Personal Data||Retention period|
|Identity Data||For so long as retention is necessary to fulfill the Purposes for which it is used
(see here How we use your Personal Data and why).
|Contact Data||For so long as retention is necessary to fulfill the Purposes for which it is used
(see here How we use your Personal Data and why).
|Behavioral Data||For so long as retention is necessary to fulfill the Purposes for which it is used
(see here How we use your Personal Data and why).
|Marketing and Communications Data||For so long as retention is necessary to fulfill the Purposes for which it is used
(see here How we use your Personal Data and why).
|Technical Data||For so long as retention is necessary to fulfill the Purposes for which it is used
(see here How we use your Personal Data and why).
Our policy on children
The Site and the Products are not intended for children below 16 and we do not knowingly collect Personal Data relating to such children.
Third party links
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share Personal Data about you. We do not control these third-party websites and are not responsible for their privacy practices When you leave our Site, we encourage you to read the privacy disclosure of every site you visit.
What are cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
We use two broad categories of cookies:
- first party cookies, served directly by us to your computer or mobile device; and
- third party cookies, which are served by our partners or service providers on our Site.
Cookies we use
Our Site uses the following types of cookies for the purposes set out below:
|Type of cookie/technology||Expiry Date||Purpose||Information collected|
|i/adsct||Session||Used by the social networking service, Twitter, for tracking the use of embedded services||Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform|
|wordpress_test_cookie||One year from the date on which that cookie was first placed||Used to check if the cookies are enabled on the browser to provide appropriate user experience to the users||Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform|
|Lang||Session||Remembers the user’s selected language version of a website. LinkedIn cookie|
|_dc_gtm_UA-#||Session||Used for Google Tag Manager|
|_ga||Session||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
|_gid||Session||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
|VisitorStatus||20 Years||Used to collect statistical data on user-defined parameters in Google Analytics.|
|ads/ga-audiences||session||Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behavior across websites.|
|ads/user-lists/#||session||Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behavior across websites.|
|bcookie||2 Years||Used by the social networking service, LinkedIn, for tracking the use of embedded services.|
|BizoID||189 days||Used by the social networking service, LinkedIn, for tracking the use of embedded services.|
|Bscookie||Two years from the date on which that cookie was first placed||Used by the social networking service, LinkedIn, for tracking the use of embedded services.|
|Collect||Session||Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.|
|Eloqua||Two years from the date on which that cookie was first placed||Registers a unique ID that identifies the user’s device upon return visits. Used for auto-populating forms and to validate if a certain contact is registered to an email group.||Eloqua|
|ELQSTATUS||Two years from the date on which that cookie was first placed||Used to auto-populate forms and validate if a given contact has subscribed to an email group. The cookie is only set if the user allows tracking.||ELQSTATUS|
|guest_id||Two years from the date on which that cookie was first placed||Collects anonymous data related to the user’s visits to the website, such as the number of visits, average time spent on the website and which pages have been loaded, with the purpose of person alizing and improving the Twitter service.||guest_id|
|Id||One years from the date on which that cookie was first placed||Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads.||Id|
|IDE||One years from the date on which that cookie was first placed||Used by Google DoubleClick to register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.||IDE|
|Lidc||Session||Used by the social networking service, LinkedIn, for tracking the use of embedded services.|
|personalization_id||Two years from the date on which that cookie was first placed||Used by the social networking service, Twitter, for tracking the use of embedded services|
|PREF||Eight months||Registers a unique ID that is used by Google to keep statistics of how the visitor uses YouTube videos across different websites.|
|UserMatchHistory||179 Days||Used by the social networking service, LinkedIn, for tracking the use of embedded services.|
|VISITOR_INFO1_LIVE||179 Days||Tries to estimate the users’ bandwidth on pages with integrated You Tube videos|
|YSC||Session||Registers a unique ID to keep statistics of what videos from You Tube the user has seen|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.
In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see advertisements, but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
If you would like to make a complaint regarding this Privacy Notice or our practices in relation to Personal Data about you, please contact us at: email@example.com. We will reply to your complaint as soon as we can.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority.
How to contact us
To make dealing with Precisely and its Affiliates as easy as possible for you, we have created a centralized privacy‑related email address for all the entities to whom this Privacy Notice applies:firstname.lastname@example.org.
Contacting us at this email address is the quickest and most efficient method of addressing any issues you may have relating to this Privacy Notice or Precisely’s and/or its Affiliates’ processing of your Personal Data.
Syncsort Incorporated, 2021