Legal
Privacy Policy
Effective Date: November 14, 2022
Who we are
Our website address is: www.genesisdigitalassets.com.
Privacy Policy
1. General Provisions
1.1. This Privacy Policy is adopted in accordance with the Russian Federation Law on “Personal Data” No. 152-FZ of 26 July 2006 and sets out the procedure for processing of personal data as well as the measures to secure and protect the personal data by Genesis Digital Assets (hereinafter – the Operator).
1.2. The first and foremost purpose of the Operator’s actions related to personal data is observance of human rights and freedoms while processing personal data, including protection of right to a private life, personal and family secret.
1.3. This Privacy Policy related to processing of personal data (hereinafter – the Policy) shall apply to any information that can be obtained by the Operator with respect to visitors of the following website: www.genesisdigitalassets.com.
2. Key Terms
2.1. Automated personal data processing – processing of personal data using means of computer technology;
2.2. Personal data blocking – temporary suspense of personal data processing (excluding situations when processing is required for any kind of clarification of personal data);
2.3. Website – combination of graphic and information materials as well as hardware and databases that make such materials available in the Internet at: www.genesisdigitalassets.com;
2.4. Personal data information system — combination of personal data contained in databases as well as information technologies and technical means allowing processing of such personal data;
2.5. Personal data anonymization – actions with personal data resulting in inability to identify personal data of a particular User or any other personal data subject without an additional information;
2.6. Personal data processing – any action (operation) or combination of actions (operations) with personal data including collection, record, systematization, accumulation, storage, clarification (update, change), extract, use, transfer (circulation, provision, granting access), anonymization, blocking, deletion and destruction using automatic means or without them.
2.7. Operator – a state body or municipal authority, legal entity or natural person that is responsible, individually or
collectively with other persons, for organization and/or processing of personal data, definition of purposes of personal data processing, scope of personal data to be processed, as well as any actions (operations) related to personal data;
2.8. Personal data – any information directly or indirectly related to a being identified or already identified User of the website www.genesisdigitalassets.com;
2.9. User – any visitor of the website: www.genesisdigitalassets.com;
2.10. Provision of personal data – actions aimed at disclosure of personal data to a specified person or unspecified group of people;
2.11. Distribution of personal data – any action aimed at disclosure of personal data to an unspecified group of people (distribution of personal data) or at making such personal data publicly available, including by means of mass media, data telecommunication networks or any other means;
2.12. Cross-border personal data transfer – transfer of personal data to either the territory of a foreign state, or the foreign state body, or the foreign legal entity or natural person;
2.13. Destruction of personal data – any actions resulting in irrevocable destruction of personal data without possibility of further recovery of its contents within the defined personal data information system and/or resulting in destruction of physical storage of such personal data.
3. Scope of Personal Data being processed
3.1. The Operator can process the following personal data of the User:
Name, Patronymic and Surname;
E-mail address;
Phone numbers;
Anonymized users’ data (including “cookies”) via third-party web analytics services such as Yandex.Metrica, Google Analytics and others.
3.2. The abovementioned data hereinafter collectively referred to as Personal Data.
4. Purposes of Personal Data processing
4.1. Key purpose of the Personal Data processing is general informing of Users via e-mail; conclusion, performance and termination of contracts; granting Users’ access to the services, information and/or materials on the website.
4.2. Operator can notify Users of new products and services, personal offers and various events. The User can unsubscribe from any such newsletter at any time by sending a request to privacy@genesisda.com with a headline “Unsubscribe”.
4.3. Anonymized Personal Data collected using various web analytics tools is necessary for general evaluation of Users’ activity on the website and further improvements of the website’s content and quality.
5. Legal grounds for Personal Data processing
5.1. Operator processes Users’ Personal Data only when the specific forms located on the website www.genesisdigitalassets.com are completed and/or sent to the Operator by Users. By completing the respective forms and sending the Personal Data to the Operator the User agrees to the terms and conditions of this Policy.
5.2. Operator processes anonymized data of Users only if it is allowed by the respective settings of a particular User’s web browser (storage of “cookies” and JavaScript settings are on).
6. The way Personal Data is collected, stored, transferred and processed
6.1. Security of Personal Data processed by the Operator is guaranteed by the implementation of necessary legal, organizational and technical measures that are defined by current legislation of the Russian Federation in the field of personal data protection.
6.2. Operator guarantees protection of Personal Data and takes all necessary measures in order to prohibit access of any unauthorized persons to Personal Data.
6.3. Users’ Personal Data shall in no case be transferred to an unauthorized person, unless such transfer is required by the terms of current legislation.
6.4. In case of any discrepancies found in Personal Data, the User can make necessary clarifications by sending an e-mail to the Operator at privacy@genesisda.com with a headline “Personal Data Update”.
6.5. The term of processing of Personal Data by the Operator is unlimited. The User can withdraw his/her consent to personal data processing at any time by sending an e-mail notice to the Operator at privacy@genesisda.com with a headline “Personal Data Consent Withdrawal”.
7. Cross-border Personal Data Transfer
7.1. Before initiating the cross-border Personal Data transfer the Operator shall make sure that the foreign state receiving any such data provides reliable protection of the personal data subjects’ rights.
7.2. Cross-border Personal Data transfer to territories of the foreign states that do not provide adequate level of data protection can be conducted either with the written consent of the personal data subject for any such cross-border data transfer, or under the terms of an agreement for which the personal data subject is a party to.
8. Final Provisions
8.1. User can obtain all necessary information and clarifications related to processing of his/her Personal Data by way of a direct request to the Operator at: privacy@genesisda.com.
8.2. This Policy shall be in effect for an unlimited period unless it is amended by the Operator and replaced by the new version in due course.
Policy statement
The one of the main priorities of Genesis Digital Assets is the privacy protection. This Privacy Policy describes how and why Genesis Digital Assets might Process the Personal Information about users of this Website.
Reading this Policy will help You (as a Website user) to understand Your privacy rights and choices. If You do not agree with this Policy, please leave this Website. If You have additional questions or concerns, or You require more information about the Policy, do not hesitate to contact our Compliance Team (compliance@genesisda.com).
This Policy applies only to Our online activities, and it is valid for visitors to our Website with regards to the information that they shared and/or collect in the Website. This Policy is not applicable to any information collected offline or via channels other than this Website.
Define terms
“Genesis Digital Assets”, “GDA” “We”, “Us”, or “Our” – Genesis Digital Assets Limited and (or) its affiliates.
“Personal Information“ – any information about a user or visitor of the Website (i.e. about “You”).
“Policy” – this Privacy Policy of . Genesis Digital Assets.
to “Process” – to collect, store, use, and/or share a Personal Information.
“Website” – this website (https://genesisdigitalassets.com/ or https://genesisda.com/).
Your consent
By using this Website, You hereby consent to this Policy and agree to its terms.
We may Process your Personal Information if You have given Us a permission (i.e., a consent) to use Your Personal Information for a specific purpose. You can withdraw Your consent anytime via compliance@genesisda.com.
What Personal Information do We collect?
The Personal Information that You are asked to provide, and the reasons why You are asked to provide it, will be made clear to You at the point We ask You to provide Your Personal Information.
If You contact us directly, We may receive an additional information about You such as Your name, email address, phone number, the contents of the message and/or attachments You may send Us, and any other information You may choose to provide. All information that you provide to us must be true, complete, and accurate, and You must notify us of any changes to such personal information via compliance@genesisda.com.
How do We Process Your Personal Information?
We Process the information we collect in various ways, including to:
- Provide, operate, and maintain our Website;
- Improve, personalize, and expand our Website;
- Understand and analyze how You use Our Website;
- Develop new services, features, and functionality;
- Communicate with You, either directly or through one of our partners, including for customer service, to provide You with updates and other information relating to the Website, and for marketing and promotional purposes;
- Save or protect an individual’s vital interest;
- Send You emails; and/or
- Find and prevent fraud, corruption, and others violations of the applicable legislation (the U.S., EU, UAE, etc.) or internal policies and procedure of Genesis Digital Assets.
How do we keep Your Personal Information safe?
We have implemented the appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Information We Process. However, despite Our safeguards and efforts to secure Your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify Your information. Although We will do our best to protect Your Personal Information.
How long do We keep Your Personal Information?
We will only keep Your Personal Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by a law (such as tax, accounting, or other legal requirements).
When We have no ongoing legitimate business need to Process Your personal information, We will either delete or anonymize such information, or, if this is not possible (for example, because Your Personal Information has been stored in backup archives), then We will securely store Your Personal Information and isolate it from any further Processing until deletion is possible.
Personal Information automatically collected
Some information — such as Your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when You visit the Website. Some information — such as Your Internet Protocol (IP) address and/or browser and device characteristics — may be collected automatically when You visit the Website. This information does not reveal Your specific identity (like Your name or contact information) but may include device and usage information, such as Your IP address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, and other technical information. This information is primarily needed to maintain the security and operation of Genesis Digital Assets, and for our internal analytics and reporting purposes.
Log files
The Website follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this, and it is a part of hosting services’ analytics. The information collected by log files may 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 are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the Website, tracking users’ movement on the Website, and gathering demographic information.
Cookies and web beacons policy
What is the “cookies“? Like any other website, this Website uses ‘cookies’. Cookies are small data files that are placed on Your computer or mobile device when You visit a website. Cookies are widely used by website owners to make their websites work, or to work more efficiently, as well as to provide reporting information.
The cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing Our web page content based on visitors’ browser type and/or other information.
Cookies set by a website owner (in this case, Genesis Digital Assets) are called “first-party cookies.” Cookies set by parties other than a website owner are called “third-party cookies.” Third-party cookies enable a third-party features or functionality to be provided on or through a website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize Your computer both when it visits the website in question and also when it visits certain other websites.
Why do We use cookies? We may use first- and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and We refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable Us to track and target the interests of Our users. Third parties may serve cookies through our Website for advertising, analytics, and other purposes.
How can You control cookies on Your browser? As the means by which You can refuse cookies through Your web browser controls vary from browser to browser, You should visit Your browser’s help menu for more information.
What about other tracking technologies, like web beacons? Cookies are not the only way to recognize or track visitors to a Website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Website or opened an email including them. This allows Us, for example, to monitor the traffic patterns of users from one page within the Website to another, to deliver or communicate with cookies, to understand whether You have come to the Website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
Do We use Flash cookies or Local Shared Objects? We may also use so-called “Flash Cookies” (also known as Local Shared Objects or “LSOs“) to, among other things, collect and store information about a usage of the Website. If You do not want Flash Cookies stored on Your computer, You can adjust the settings of Your Flash player to block Flash Cookies.
Do We serve targeted advertising? Third parties may serve cookies on Your computer or mobile device to serve advertising through our Website. These companies may use information about Your visits to this and other websites in order to provide relevant advertisements about goods and services that You may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. They can accomplish this by using cookies or web beacons to collect information about Your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to You. The information collected through this process does not enable us or them to identify Your name, contact details, or other details that directly identify You unless You choose to provide these.
Advertising Partners privacy policies
Third-party ad servers or ad networks may use technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that may appear on the Website, which are sent directly to a users’ browser. They may automatically receive Your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that You see on websites that You visit.
Note that the Website has no access to or control over these cookies that are used by third-party advertisers.
Third party privacy policies
The Policy does not apply to other advertisers or websites. Thus, We are advising You to consult the respective privacy policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
You can choose to disable cookies through Your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
When and with whom do We share Your personal information?
We may share Your information with Our affiliates, in which case We will require those affiliates to abide this Policy. Affiliates include Our any subsidiaries, joint venture partners, or other companies that We control or that are under common control with us.
In some situations We may share Your information with Our business partners, in which case We will require those partners to abide this Policy. We may do that only with Your written consent.
Do We collect information from minors?
Another part of Our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
The Website does not knowingly collect any personal identifiable information from children under the age of 18. If You think that Your child provided this kind of information on Our Website, We strongly encourage You to contact Us immediately (compliance@genesisda.com) and We will do our best efforts to promptly remove such information from Our records.
What legal bases do We rely on to Process Your Personal Information?
We only Process Your personal information when We believe it is necessary and We have a valid legal reason (i.e., legal basis) to do so under applicable law, like with Your consent, to comply with laws, to provide You with services to enter into or fulfill our contractual obligations, to protect Your rights, or to fulfill Our legitimate business interests.
The CCPA Privacy Rights (“Do Not Sell My Personal Information”)
Under the California Consumer Privacy Act of 2018 (the “CCPA”), among other rights, California consumers have the right to:
- Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers;
- Request that a business delete any personal data about the consumer that a business has collected; and/or
- Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If You make a request, We have one month to respond to You. If You would like to exercise any of these rights, please contact us (compliance@genesisda.com).
The EU GDPR and the UK GDPR Data Protection Rights
The General Data Protection Regulation (the “GDPR”) and UK GDPR require Us to explain the valid legal bases We rely on in order to Process Your Personal Information. As such, We may rely on the following legal bases to process Your personal information:
- Consent. We may process Your information if You have given Us a permission (i.e., a consent) to use Your personal information for a specific purpose. You can withdraw Your consent at any time.
- Legal Obligations. We may Process Your information where We believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend Our legal rights, or disclose Your information as evidence in litigation in which We are involved.
- Vital Interests. We may Process Your information where We believe it is necessary to protect Your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
We would like to make sure You are fully aware of all of Your data protection rights. Every user is entitled to the following:
- The right to access – You have the right to request copies of Your personal data. We may charge You a small fee for this service;
- The right to rectification – You have the right to request that We correct any information You believe is inaccurate. You also have the right to request that we complete the information You believe is incomplete;
- The right to erasure – You have the right to request that We erase Your personal data, under certain conditions;
- The right to restrict Processing – You have the right to request that We restrict the processing of Your personal data, under certain conditions;
- The right to object to Processing – You have the right to object to our Processing of Your personal data, under certain conditions; and/or
- The right to data portability – You have the right to request that We transfer the data that We have collected to another organization, or directly to You, under certain conditions.
If You make a request, We have one month to respond to You. If You would like to exercise any of these rights, please contact us (compliance@genesisda.com).
How can You review, update, or delete any Personal Information We collect from You?
Based on the applicable laws of Your country, You may have the right to request access to the Personal Information We collect from You, change that information, or delete it. To request to review, update, or delete Your Personal Information, please submit a request via compliance@genesisda.com.
How often will We update this Policy?
We may update this Policy from time to time in order to reflect, for example,
changes to the cookies We use or for other operational, legal, or regulatory reasons.
Please therefore revisit this Policy regularly to stay informed about our use for the Private Information.
The date at the top of this Policy indicates when it was last updated.
Contact information
If You have additional questions or concerns, or You require more information about the Policy, do not hesitate to contact Us (compliance@genesisda.com).
