Privacy policy

The website www.genioo.com is operated by Genioo AG, with registered office at Bundesplatz 1, 6300 Zug, Switzerland, registered in the Commercial Register of the Canton of Zug under the number CHE-351.818.455.

We are the controller and hence responsible for the collection, processing and use of your personal data in accordance with the law. 

We take data privacy very seriously and are committed to the protection of your personal data. We comply with the legal requirements of the Swiss Federal Data Protection Act (FDPA), the Ordinance on the Federal Data Protection Act (OFDPA) and other data protection provisions that may be applicable, in particular the General Data Protection Regulation of the European Union (GDPR). 

In this privacy policy, we would like to inform you on which personal data we process, for which purposes and based on which legal basis. 

Please note that we may amend this privacy policy from time to time and post the amended version on our website. We therefore recommend that you consult this privacy policy regularly. 

1.    Scope and purpose of the collection, processing and use of personal data

1.1.    When you visit our website

When you visit our website, our servers temporarily store each access in a log file. The following data is collected and stored, without any action on your part, until it is automatically deleted after twelve months: 

• the IP address of the requesting computer, 
• the name of your Internet access provider (usually your Internet access provider), 
• date and time of access, 
• name and URL of the data retrieved, 
• the website from which our domain was accessed (referrer URL), and the search term used, as applicable, 
• the operating system of your computer and the browser used (type, version and language), and 
• the transmission protocol used (e.g. HTTP/1.1). 

The IP address will be evaluated for clarification and defence purposes only in the event of an attack on the website's network infrastructure or in case of a suspicion of unauthorized or abusive use of the website. It may further be used for identification purposes in criminal proceedings and in the context of civil and criminal proceedings against the concerned individual, as necessary and required. We rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR to process the data for these purposes. 

Lastly, when you visit our websites, we use cookies as well as applications that are based on the use of cookies. Please see our Cookie Policy for further details.

1.2.    When you sign up to receive marketing communications

If you subscribe to receive marketing communications from us by using a contact form located on our website, we collect the following information from you:

• First name*
• Surname*
• Email-Address*
• Company

We use this data to provide you with our newsletter, exclusive news and invitations to Genioo events. 

We rely on your explicit, freely given prior consent within the meaning of Art. 6 para. 1 lit. a GDPR to process your above data for the mentioned purposes. You have the right to withdraw your consent at any time by clicking on the 'unsubscribe' button in our communications or by contacting us directly. You can also object to this data processing at any time.

1.3.    When you use a contact form

If you contact us by using a contact form located on our website, we collect the following information from you:

• First name*
• Surname*
• Email-Address*
• Telephone number*
• Company
• Your message

The fields marked with * are mandatory.

We use this data to respond to your query or provide the services you request and, if necessary, to contact you by telephone. We never use your personal data for marketing purposes without your prior consent.

We rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR to process your above data for the mentioned purposes. You can object to this data processing at any time.

1.4.    When you contact us via email

You may contact us by using the email-address info@genioo.com or by emailing one of our employees directly. In this case we collect the personal data you provide us. We need this information to process your contact request. You are responsible for any communications or content you transmit to us. 

We recommend that you do not transmit sensitive information via email. Personal data is only collected if you voluntarily provide it to us. It is therefore up to you what information you provide us with. In order to be able to answer your contact inquiries, we may require additional information from you, e.g. your address, your telephone number, etc. We will only collect personal data from you if required to process and answer your enquiry or to deliver the services you request. 

We use such data to respond to your query or provide the services you request and, if necessary, to contact you by telephone. We never use your personal data for marketing purposes without your prior consent.

We rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR to process your data for the mentioned purposes. You can object to this data processing at any time (see Section 13 Contact). 

1.5.    When you apply to join our team

If you apply to join our team through our website, we collect the following information from you:

• First Name*
• Last Name*
• Email*
• Phone*
• Resume (file upload)*
• Cover Letter (file upload)*

Depending on the position that you apply for, additional information may be collected from you, such as:

• LinkedIn Profile
• Expected total compensation*
• Possible start date*
• Authorized to work in Switzerland, the EU or US*
• Willingness to travel*
• Number of years working in the respective industry*
• Working experience in the position you apply for*
• Number of years of working experience*
• Languages*

The fields marked with * are mandatory.

We process the personal data you provide us for the purpose of examining your application and concluding a work contract with you. Please note that you are responsible for the content of the files that you transmit to us. It is therefore up to you what information you provide us with. In order to assess your application, we may ask you to provide us with additional information, e.g. references, etc. We will only collect those personal data from you which are necessary to assess your application. 

For this purpose, we will use your consent in accordance with Art. 6 para. 1 lit. a GDPR as the basis to process your personal data and further base the data processing on steps to be taken prior to entering into a contract according to Art. 6 para. 1 lit. b GDPR. You may withdraw your consent for this processing at any time. 

If your application is unsuccessful, we will delete your personal data within six months, unless you provide us your active, freely given prior consent to join our candidate pool to stay up to date with upcoming job opportunities.

1.6.    When you apply to become an independent consultant with us

If you apply to become an independent consultant with us through our website, we collect the following information from you:

• First Name*
• Surname*
• Email Address*
• Telephone number*
• Source*
• (file upload)*

Moreover, we collect the following additional information through the skill self-assessment:

• Name *
• Surname*
• Email Address*
• Phone Number*
• Country of residence*
• Source*
• Registered Status*
• Address*
• Earliest start date*
• CV (file upload)*

The fields marked with * are mandatory.

Additional information in the skill self assessment are voluntary and relate to past jobs, experiences, languages spoken and other relevant information to assess your application.

In the skill self assessment you can provide the following information (voluntary):

• Name
• Surname
• Email address
• Phone number
• Registered status
• Earliest start date
• Willingness to travel
• Valid work permit/visa
• Additional CV information
• Experience/skill level in the different fields (e.g. Life Sciences, Healthcare, Financial Services, Consumer Goods & Retail, Transportation & Logistics, High Tech & IT, Industrial Products, Services, Strategy, Operations, Organization, Corporate Finance, Marketing & Sales, Market Research, Leadership Skills, Change Management Skills, Technical Skills, Project Skills etc.)
• CV (file upload)
• Professional Photo (file upload)
• Project examples (file upload)

We process the personal data you provide us for the purpose of examining your application. Please note that you are responsible for the content of the files you upload or the information that you transmit to us. It is therefore up to you what information you provide us with. In order to assess your application, we may ask you to provide us with additional information, e.g. references, etc. We will only collect those personal data from you which are necessary to assess your application. 

For this purpose, we will use your consent in accordance with Art. 6 para. 1 lit. a GDPR as the basis to process your personal data and further base the data processing on steps to be taken prior to entering into a contract according to Art. 6 para. 1 lit. b GDPR. You may withdraw your consent for this processing at any time with effect for the future. 

If your application is unsuccessful, we will delete your personal data within twelve months, unless you provide us your active, freely given prior consent to join our candidate pool to stay up to date with upcoming job opportunities.

1.7.    When you login to the professional portal (https://portal.genioo.com/public/login.php)

If you login the professional portal on our website, we collect the following information from you:

• Email-Address*
• Password (encrypted)*

The fields marked with * are mandatory.

Alternatively, you can log in with your "Genioo Account" provided by Genioo and operated by Google LLC. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"), using the so-called Single Sign On technique. The Google-Login on our website can be recognized by a button with the Google logo. Alternatively you can sign up with any other personal email-address to the professional portal. 

The purpose and scope of the data collection and the further processing and use of the data by Google as well as your rights and setting options for the protection of your privacy can be found in Google's privacy policy: https://policies.google.com/privacy?hl=en&gl=ZZ 

We use this data to provide you with a tool where you as an independent contractor can upload your personal data, timecards and expenses.

For this purposes, we base this data processing on a contract in accordance with Art. 6 para. 1 lit. b GDPR and further base the data processing on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR. You can object to this data processing at any time (see Section 13 Contact).

1.8.    Analysis of you application data with Talent Fit Index

When you apply through our website and provide us with the information as outlined above, we store your personal data in the web application (“Talent Fit Index”). When you take the analytical test we store your name and email-address as well as your results of the test and the time management. 

Talent Fit Index data is stored by Greenhouse Software, Inc., 110 5th Ave 3rd Floor, NY 10011, New York, USA (“Greenhouse”). Please note that data is shared with Greenhouse. Additional information on how Greenhouse processes personal data can be found under: http://www.greenhouse.io/privacy-policy 

Through Talent Fit Index we run analytical assessments of your application that allows us to evaluate, if an application fits the profile of an open position. For this purpose, we will use your consent in accordance with Art. 6 para. 1 lit. a GDPR as the basis to process your personal data and further base the data processing on steps to be taken prior to entering into a contract according to Art. 6 para. 1 lit. b GDPR. You may withdraw your consent for this processing at any time with effect for the future (see Section 13 Contact). 
 

2.    Central Storage

We store the data indicated in the above Section in a central electronic data processing system. The data concerning you is systematically recorded, linked and evaluated for processing your application and contractual services.

At the same time, we inform you that the personal data mentioned in the previous Sections is migrated to our CRM system, which is operated by Salesforce Inc., 1 Market St #300, San Francisco, CA 94105, USA, where they can be stored and processed centrally. The data in the central CRM system is evaluated by us for providing you with tailored opportunities. We also evaluate the data in the CRM system to improve services. In addition, we use the relevant data for the other purposes mentioned in this privacy policy. 

We base this processing on our legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in a customer-friendly and efficient customer data management. In addition, we base the processing of this data on the fulfilment of the contract within the meaning of Art. 6 para. 1 lit. b GDPR. 

3.    Disclosure of data to third parties 

We will only transfer your personal data to third parties if you have given your explicit consent, if there is a legal obligation to do so, or if it is necessary for the enforcement of our rights, in particular to assert claims arising out of the contractual relationship. 

In addition, we will transfer your data to third parties as far as it is necessary for the use of the website, the processing of your contact requests, the sending of marketing communications, and the analysis of your user behaviour. The use of the data forwarded for these purposes by third parties is strictly limited to the stated purposes. 

Third-party service providers are explicitly mentioned in this Privacy Policy. The data is passed on for the purpose of providing and maintaining the functionalities of our website.

For this processing we rely on our legitimate interests within the meaning of Art. 6 para. 1 lit. f GDPR.  

4.    Cookies 

When you access our website, we collect information by means of cookies. 

Cookies are information files that your web browser automatically stores on your computer's hard drive when you visit our website. Cookies neither damage the hard disk of your computer nor do they transmit your personal data to us. 

Among other things, cookies help us make your visit on our website easier, more pleasant and more meaningful. 

Most Internet browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or that a warning message will always appear when a new cookie arrives. You can also use our cookie solution to manage your cookie preferences, including opting into/out of non-essential cookies.

Please note that deactivating cookies may prevent you from using all the features of our website. 

For more information, please refer to our Cookie Policy.

5.    Tracking Tools

For the purposes of needs-based design and the continuous optimisation of our web pages, we use the web analysis service Google Analytics. In this respect, pseudonymised user profiles are created and small text files stored on your computer are used. In addition to the data listed under Section 1 above, we may receive the following information generated by the cookie about your use of our website:

• the navigation path that a visitor takes on the site,
• the duration of stay on the website or subpage,
• the subpage on which the website is left,
• the country, region or city from which it is accessed,
• the terminal (type, version, color depth, resolution, width and height of the browser window), and
• returning or new visitor.

These data are sent to servers of Google Inc., a company of the holding company Alphabet Inc., in the US and stored there. As part of this, before this data is sent within EU member states or other states that are party to the agreement on the European Economic Area and Switzerland, the IP address is truncated through this website's IP anonymization (“anonymizeIP”). The anonymized IP address transmitted by your browser in the context of Google Analytics is not consolidated with other data from Google. The entire IP address is sent to a Google server in the US and truncated there only in exceptional cases. In this case, we ensure by contractual means that Google Inc. observes a sufficient level of privacy protection.

The information is used to analyze the use of the website, to compile reports about website activities and to provide us with further services relating to websites and internet use for the purposes of market research and needs-based design for these websites. This information is also forwarded to third parties where this is required by law or if third parties have been commissioned to process this data. Under the terms of Google, under no circumstances will the IP address be used in connection with other data relating to the user.

We also use Google Tag Manager in order to manage cookies and pixels for tracking tools and other tools. The Tag Manager tool itself is a cookie-free domain and does not collect any personal data. Instead, the tool triggers other tags that may in turn collect data. If you have performed a deactivation at domain or cookie level, this remains in place for all tracking tags implemented using Google Tag Manager.

Our website further uses DoubleClick by Google, a service provided by Google to serve ads based on the use of previously visited websites. Google uses the so-called DoubleClick cookie, which enables your browser to be recognized when you visit other websites. The information generated by the cookie about your visit to these websites (including your IP address) will be transmitted to and stored by Google on servers in the US.

For uniform representation of fonts, our website uses web fonts provided by MyFonts. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. Our website uses the MyFonts Counter, a web analytics service provided by MyFonts Inc., 500 Unicorn Park Drive, Woburn, MA 01801, USA. Due to the license terms, a page view tracking is performed by counting the number of visits to our website for statistical purposes and transmitting them to MyFonts.

MyFonts collects anonymous data. If your browser does not support web fonts, a default font will be used by your computer. The passing on of the data takes place by the activation of Java Script code in the browser of the user. In order to prevent the execution of Java script code from MyFonts as a whole, the user can install a Java Script Blocker. Further information on data protection and the cookies used by MyFonts can be found at: http://www.myfonts.com/info/terms-and-conditions/#Privacy

6.    Links to our social media presences 

On our website, we have incorporated links to our social media profile on the following social network: 

• LinkedIn, LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA.

If you click on the relevant social network icon, you will be automatically redirected to our profile on the relevant social network. In order to use the functions of the relevant network, you must partially login to your user account. 

When you open a link to our social media profile, a direct connection is established between your browser and the server of the relevant social network. This gives the network the information that you have visited our website with your IP address and accessed the link. If you access a link to a network while being logged in to your account on the relevant network, the content of our website may be linked to your profile in the network, which means that the network can link your visit to our website directly to your user account. If you want to prevent this, you should logout before clicking on the relevant links. An assignment takes place in any case, if you login to the relevant network after clicking on the link. 

For more information about the purpose and scope of the data collection and further data processing by the abovementioned social media network and your particular rights and data protection options, please see its respective privacy policy. 

• YouTube, YouTube LLC, 901 Cherry Ave., 94066 San Bruno, CA, USA

Genioo publishes videos on websites of the company YouTube, LLC, 901 Cherry Ave., 94066 San Bruno, CA, USA (hereinafter: "YouTube"), a company of Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter: "Google"). If you click on the relevant links or icons on our website, you will be transferred to the YouTube site.

According to YouTube, in the "extended data protection mode", your data will only be transmitted to the YouTube server in the USA when you click on the presented play button to watch the video. By clicking on the video, you consent to this transmission with the effect that your data, in particular which pages from the Genioo website you have visited and device-specific information including the IP address, is transmitted to YouTube (and Google). If you are logged in to YouTube (or other Google accounts) at the same time, this information will be associated with your YouTube account (or other Google account) and, as the case may be, with data collected from both permanent and session cookies implemented and used by YouTube, Google and/or other parties associated with them. You can prevent this by logging out of your member account(s) before clicking on the embedded video and by blocking the use of cockies. For more information about YouTube-related privacy, please see Google's Privacy Policy published on https://policies.google.com/privacy?hl=en-GB. 

7.    Cross-border data transfers      

We are a global network of firms and, much like other professional service providers, we use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes transfers to countries outside the European Economic Area (EEA) and to countries that may not have laws that provide the same degree of protection for personal data as your home country. In accordance with applicable legal requirements, we take appropriate measures to facilitate adequate protection for any information so transferred.

Where we transfer personal information outside of the EEA to a country or framework not determined by the European Commission as providing an adequate level of protection for personal information, the transfers will be under an agreement which covers European Union requirements for such transfers, such as standard contractual clauses.

For the sake of completeness, we note that, as part of US legislation, US authorities are able to take surveillance measures, under which the general storage of all data sent from the EU to the US is possible. This takes place without distinction, limitation or exception, on the basis of the objective pursued and without objective criteria that would allow it to limit access by US authorities to personal data and its subsequent use to specific, strictly limited purposes that justify access to this data. 

Furthermore, we would like to point out that there are no legal remedies available in the USA for the data subjects from Switzerland or the EU that would allow them to gain access to the data concerning them and to obtain their correction or deletion, and there is no effective legal protection against general access rights of US authorities. We explicitly draw attention to this legal and factual situation to the data subject so that he or she may make an informed decision as to the consent to the use of his or her data. 

For individuals residing in EU Member States, please note that from the point of view of the European Union, the US does not have sufficient data protection levels due, inter alia, to the issues mentioned in this Section. To the extent that we have explained in this Privacy Policy that recipients of data are located in the US, we will ensure that your data is adequately protected by our partners by way of a contract. In addition to the contract, and in accordance with the latest jurisprudence, we assess the risk and implement supplementary measures for the transfer of EU personal data. Such additional measures include data minimization, using identifiers with a unique ID, or the division of steps of a processing activity between different processors.
 

8.    Information disclosure

We will only share personal data when we are legally permitted to do so. When we share data, we put contractual arrangements and security mechanisms in place as appropriate to protect the information and to comply with our information protection, confidentiality and security standards. 

In addition to any information sharing practices described in the relevant Section, we share personal information with the following categories of recipients:

Other Genioo member firms

For details of our company locations, please check https://www.genioo.com/contact/.

We may share personal data with other Genioo member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from Genioo consultants based in different locations).

Third-party organizations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems – for example, providers of information technology, cloud-based software-as-a-service providers, talent management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in data centers around the world, and personal information may be stored in any one of them. 

Accountants, auditors, professional advisors and insurance providers. 

We engage auditors and other professional advisors, for example, law firms, accountants and insurance providers as necessary to establish, exercise or defend our legal rights and obtain advice in connection with the operation of our business. Personal information may be shared with these advisors as necessary in connection with the products and services they have been engaged to provide, e.g. payroll management, handling of insurance claims. 

Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfill requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

Third-party organizations in connection with a corporate transaction. 

We may disclose your information to a third party as necessary in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital.

9.    Your privacy rights          

You may have certain rights under your local law in relation to the personal data we process about you. We will respond to your request without undue delay, at the latest within one calendar month after receipt. Please note that we may ask you to verify your identity before responding to such requests.

In particular, you may have a legal right to:

Right to access

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data and obtain certain other information about how and why we process your personal data

Right to rectification    

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your address) and to have incomplete personal data completed.

Right to withdraw consent    

If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. This includes cases where you wish to opt out from marketing messages.

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal basis for the processing. To stop receiving emails from us, please click on the "unsubscribe" link in the email you received from us.

Right to erasure

You have the right to delete your personal data in the following cases:

• the personal data is no longer necessary in relation to the purposes for which they were collected and processed;
• our legal ground for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
• our legal ground for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to the processing and we do not have overriding legitimate grounds;
• you object to processing for direct marketing purposes;
• your personal data has been unlawfully processed; or
• your personal data must be erased to comply with a legal obligation to which we are subject.

Right to restriction of processing

The right to restrict personal data processing in the following cases:

• for a period enabling us to verify the accuracy of personal data where you contested the accuracy of the personal data;
• your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
• your personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data is required by you to establish, exercise or defend legal claims; or
• for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.

Right to portability    

The right to receive your personal data provided by you to us and the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

Right to object to processing    

The right to object to the processing of your personal data in the following cases:

• our legal ground for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or
• our processing is for direct marketing purposes.

Right to lodge a complaint with a supervisory authority    

You have the right of appeal to a data protection supervisory authority if you believe that the processing of your personal data violates data protection law.
In Switzerland: Federal Data Protection and Information Commissioner, Feldeggweg 1, CH-3003 Bern
 

10.    Data retention 

We only store personal data for as long as necessary to: 

• provide you with services that you have requested or for purposes as to which you have given your consent, 
• enable the above-mentioned analysis services within the scope of our legitimate interests. 

Please note that legal retention periods may apply for certain data. Such data must be stored by us until the end of the retention period. We block any such data in our system and use them exclusively to comply with our legal obligations. 

11.    Data security 

We take reasonable technical and organizational security measures that we deem appropriate in order to protect your stored data against manipulation, loss, or unauthorized third party access. Our security measures are continually adapted to technological developments. 

We also take internal data privacy very seriously. Our employees and the service providers are required to maintain secrecy and to comply with applicable data protection legislation. In addition, they are granted access to personal data only insofar as this is necessary for them to carry out their respective tasks or mandate. 

12.    Contact 

If you have any questions regarding our data protection practices or if you would like to exercise your data protection rights, please contact us by email at privacy@genioo.com. 
Alternatively, you can write to: 

Genioo AG
Data Privacy
Bundesplatz 1
6300 Zug 
Switzerland 

The contact details of our data protection representative in the EU are as follows:

Genioo Germany GmbH
Data Privacy
Lyoner Str. 14
D-60528 Frankfurt am Main
Germany