Privacy Statement

Protecting the individual's privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual`s right to data protection and privacy. This Privacy Statement outlines how we handle information that can be used to directly or indirectly identify an individual ("Personal Data").

  1. General Information
  2. Processing Based on a Statutory Permission
  3. Processing Based on Consent
  4. Cookies & Similar Tools

A. General Information

Who is the Data Controller? The data controller of www.mygenio.co.uk and Genio is The Online Coach Limited, 17 The Weavers, Allington, Maidstone, Kent, ME16 0NZ United Kingdom.  Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection, but it is in any case displayed on the individual registration form’s privacy statement. The Genio data protection officer can be reached at privacy@mygenio.co.uk 

What Personal Data does Genio collect? When you visit the Genio application or websites, Genio stores certain information about your browser, the operating system, and your IP address.

If, the Account Manager you will use a registration form, and Genio will collect the information you provide, which consists of your first and last name, email addresses, telephone numbers, location (country, state/province, city), company name, job title and role, department and function, current relationship to Genio, and your company’s industry if applicable. As a User, you will provide only your first and last name and your email address for registration and identification.

Why does Genio need your Personal Data? Genio requires your Personal Data to provide you with access to this application; to deliver any ordered goods or services; and to comply with statutory obligations, including checks required by applicable export laws. Further information on why Genio needs your Personal Data can be found in Section B, below, if Genio’s use of your Personal Data is based on a statutory permission. Further information on why Genio needs your Personal Data can be found in Section C, below, if Genio’s use of your Personal Data is based on your consent. 

How long will Genio store my Personal Data? Genio will only store your Personal Data for as long as it is required:

  • to make goods and services requested available to you, including use of the Genio Application;
  • for Genio to comply with its statutory obligations resulting inter alia from applicable export laws;
  • until you object against such use by Genio, if Genio’s use of your Personal Data is based on Genio’s legitimate business interest as further stated in this Privacy Statement;
  • until you revoke your consent granted in this Privacy Statement, if Genio is processing your Personal Data based on your consent;
  • by applicable mandatory law to retain your Personal Data longer or where your Personal Data is required for Genio to assert or defend against legal claims, Genio will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

Who are the recipients of your Personal Data and where will it be processed? Your Personal Data will not be passed on to third parties. 

Genio uses the UK & EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. You can obtain a copy (redacted to remove commercial or irrelevant information) of such standard contractual clauses by sending a request to contact@mygenio.co.uk You can also obtain more information from the European Commission on the international dimension of data protection. 

What are your data protection rights?

You can request from Genio: access at any time to information about which Personal Data Genio processes about you and the correction or deletion of such Personal Data. Please note, however, that Genio can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Genio to retain it. Kindly note further that if you request that Genio deletes your Personal Data, you will not be able to continue to use any Genio service that requires Genio’s use of your Personal Data.

If Genio uses your Personal Data based on your consent or to perform a contract with you, you can further request a copy of the Personal Data that you provided to Genio. To do so, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. Genio will carefully consider your request and discuss with you how it can best fulfil it.

Furthermore, you can request from Genio that Genio restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data Genio has about you is incorrect, subject to the time Genio requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for Genio processing your Personal Data and you demand that Genio restricts your Personal Data from further processing, (iii) Genio no longer requires your Personal Data but you state that you require Genio to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by Genio based on Genio’s legitimate interest (as further set out below under Section C.), subject to the time required for Genio to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.

For individuals within the State of California, you instead have the right:

  • to request from Genio access to your Personal Data that Genio collects, uses, discloses, or sells (if applicable) about you;
  • to request that Genio delete Personal Data about you;
  • to non-discriminatory treatment for exercise of any of your data protection rights; and
  • in case of request from Genio for access to your Personal Data, for such information to be portable, if possible, in a readily usable format that allows you to transmit this information to another recipient without hindrance; and
  • to opt-out of the sale of Personal Data. In accordance with the disclosure requirements under the California Consumer Privacy Act (“CCPA”), Genio is exempt from providing a notice to opt-out because it does not and will not sell your Personal Data.

Please note, however, that Genio can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Genio to retain it. Kindly note further that if you request that Genio deletes your Personal Data, you will not be able to continue to use any Genio service that requires Genio’s use of your Personal Data.

How can you exercise your data protection rights? Please direct any requests to exercise your rights to contact@mygenio.co.uk 

For individuals within the State of California, you may also exercise your rights as follows:

You can designate an authorized agent to submit requests to exercise your data protection rights to Genio. Such authorized agent must be registered with the California Secretary of State and submit proof that you have given authorization for the agent to act on your behalf. If you are a person with a disability, contact Genio at the above address to access the Privacy Statement in an alternative format.

How will Genio verify requests to exercise data protection rights? Genio will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, Genio will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by Genio. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by Genio.

In accordance with the verification process set forth in the CCPA, Genio will require a more stringent verification process for deletion requests, or for Personal Data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your Personal Data.  If Genio must request additional information from you outside of information that is already maintained by Genio, Genio will only use it for the purposes of verifying your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.

Genio will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.

Right to lodge a complaint. If you take the view that Genio is not processing your Personal Data in accordance with the requirements in this Privacy Statement or under applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state where Genio has its registered seat.

Can I use Genio’s goods and services if I am a minor or child?

Children. Genio websites and online services are not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16, you cannot register with and use this websites or online services.

U.S. Children’s Privacy. Genio does not knowingly collect the Personal Data of children under the age of 13. If you are a parent or guardian and believe Genio collected information about a child, please contact Genio as described in this Privacy Statement. Genio will take steps to delete the information as soon as possible. Given that Genio websites and online services are not directed to users under 16 years of age and in accordance with the disclosure requirements of the CCPA, Genio does not sell the Personal Data of any minors under 16 years of age.

B. Processing based on a statutory permission

Why does Genio need to use my Personal Data and on what legal basis is Genio using it?

Processing to fulfill contractual obligations. Genio requires your Personal Data to deliver goods or services you order under a contract Genio has with you, to establish a contract for goods or services between you and Genio, or to send you invoices for ordered goods or services. Genio processes Personal Data to fulfil contractual obligations pursuant to Article 6(1), lit. b GDPR or under the equivalent article under other national laws, when applicable.

Processing when necessary to fulfil Genio’s contractual obligation includes responding to your related inquiries, processing your feedback or providing you with support. This can also include conversation data that you may initiate or enable such as through the chat functionalities on Genio or other local Genio web presences, through contact forms, emails, or by telephone. In this Privacy Statement, “goods and services” includes access to Genio’s web services, offerings, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.

Furthermore, Genio communicates on a regular basis by email with users who subscribe to its services and will also communicate by phone to resolve your or other customer complaints or to investigate suspicious transactions.

CoachPro will use your email address to confirm your opening of an account, to send you notice of payments (where applicable), to send you information about changes to its products and services, and to send notices and other disclosures as required by law. Generally, users are discouraged to opt out of these communications because these communications are required for the relevant business relationship and not marketing-related in nature, however you can do so if you wish.

For marketing-related communications such as emails and phone calls, Genio will (i) only provide you with such information after you have opted in, if legally required, and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related communications. You can also opt out of marketing-related communications at any time by updating that preference on your Account Profile. 

Processing to ensure compliance. Genio and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the UK, European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Genio is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Genio’s websites or other delivery channels controlled by Genio. This could include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to Genio’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match. Any such use of your Personal Data is based on the permission to process Personal Data in order to comply with statutory obligations (Article 6(1) lit. c GDPR) and Genio ‘s legitimate interest (Article 6(1) lit. f GDPR) or under the equivalent articles under other national laws, when applicable.

Furthermore, you acknowledge that information required to track your data protection and privacy choices for processing your Personal Data, or for receipt of marketing materials (that is to say, depending on the country in which Genio operates and whether you have expressly consented to or opted out of receiving marketing materials) may be exchanged among members of Genio affiliates when necessary to ensure compliance.

Processing based on Genio’s legitimate interest. Genio can use your Personal Data based on its legitimate interest (Article 6(1), lit. f GDPR) or the equivalent article under other national laws, when applicable, as follows:

  • Fraud and Legal Claims. If required, Genio will use your Personal Data for the purposes of preventing or prosecuting criminal activities such as fraud and to assert or defend against legal claims.
  • Questionnaires and surveys. With prior agreement, Genio could invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any data that can be used to identify you. If you nonetheless enter such data in a questionnaire or survey, Genio will use this Personal Data to improve its products and services.
  • Contract Performance. If as the Account Manager, you purchase or intend to purchase goods or services from Genio on behalf of a corporate customer or otherwise be the nominated contact person for the business relationship between a corporate customer (a “Customer Contact”) and Genio, Genio will use your Personal Data for this purpose. This includes, for the avoidance of doubt, such steps which are required for establishing the relevant business relationship. In case that an existing Customer Contact informs Genio that you are their replacement, Genio will, from the point in time of such notification, consider you to be the relevant Customer Contact for the respective customer until you object as further set out below.
  • Creation of anonymized data sets. Genio will anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.
  • Personalised Content. If you opt-in to receive marketing communications such as and including newsletters, brochures or white papers from Genio, Genio will collect and store details of how you interact with such content to help create, develop, operate, deliver and improve our communications with you. This information is aggregated and used to help Genio provide more useful information and to understand what is of most interest to you.
  • Recordings for quality improvement purposes. In case of telephone calls or chat sessions, Genio will record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions to improve the quality of Genio’s services.
  • To keep you up-to-date or request feedback. Within an existing business relationship between you and Genio, Genio might inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars and events) which are similar or relate to such products and services you have already purchased or used from Genio. Furthermore, if you attend a webinar, seminar or event of Genio, download or view whitepapers, newsletters, videos, software free trials, or purchase products or services from Genio, Genio might contact you for feedback regarding the improvement of the relevant material, product or service.

Right to object. You can object to Genio’s use of your Personal Data as set forth in this section at any time by updating that preference. In this case, Genio will carefully review your objection and cease further use of the relevant information unless Genio has a compelling legitimate ground for continued use of the information and such ground overrides your objection, or if Genio requires the information for the establishment, exercise or defence of legal claims.

Processing under applicable national laws. If the applicable national law allows Genio to do so, Genio will use information about you, some of which is Personal Data, for the following business purposes:

  • to plan and host events
  • to host online forums or webinars
  • for marketing purposes such as to keep you updated on Genio’s latest products and services and upcoming events
  • to help Genio create, develop, operate, deliver and improve Genio services, products, content and advertising and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Genio
  • to provide more personalised information to you
  • for loss prevention
  • for account and network security purposes
  • for internal purposes such as auditing, analysis, and research to improve Genio’s products or services
  • to verify your identity and determine appropriate services
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • debugging to identify and repair errors that impair existing intended functionality
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Genio.

C. Processing based on consent

In the following cases, Genio will process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6(1) lit. a GDPR) or the equivalent article under other national laws, when applicable. Each below section about a processing operation of Personal Data is linked to one consent statement. If you re-open this Privacy Statement after you initially grant one or more consents, you will see the full Privacy Statement and not just information on the consents you granted.

News about Genio’s Products and Services. Subject to a respective provision and your consent, Genio may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with Genio (prior purchases, participation in webinars, seminars, or events or the use of (web) services - further details on this topic can be found in the Cookie Statement displayed on the relevant Genio website) in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about Genio’s software and services (including marketing-related newsletters) as well as events of Genio and in order to display relevant content on Genio’s applications and websites. 

Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by selecting “unsubscribe”. In case of withdrawal, Genio will not process Personal Data subject to this consent any longer unless legally required to do so. In case Genio is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by Genio up to the point in time of your withdrawal. Furthermore, if your use of any Genio offering requires your prior consent, Genio will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for CoachPro to use your profile under the Genio Identity Authentication Service for multiple Genio offerings), offer or event to you after your revocation.

D. Cookies and similar tools

Information gathered by cookies or similar technologies, and any use of such information, is further described in Genio Cookie Policy. You can exercise your cookie preferences as outlined in Genio Cookie Policy by visiting the “Cookie Preferences” link in the bottom footer of the www.mygenio.co.uk  homepage.

E. Additional Country-Specific Provisions

Where Genio is subject to U.S. privacy requirements, the following also applies:

Do Not Track. Your browser may allow you to set a “Do not track” preference. Unless otherwise stated, our sites do not honour “Do not track” requests. However, you may elect not to accept cookies by changing the designated settings on your web browser or, where available, by referring to our Cookie Statement. Cookies are small text files placed on your computer while visiting certain sites on the Internet used to identify your computer. Please note that if you do not accept cookies, you may not be able to use certain functions and features of our site. This site does not allow third parties to gather information about you over time and across sites.

By clicking “Accept All Cookies”, you agree to the storing of cookies on your device to enhance site navigation, analyze site usage, and assist in our marketing efforts. View our Privacy Policy for more information.