GENGURU PRIVACY POLICY
This Privacy Policy (hereinafter the “Privacy Policy”) explains how GenGuru (hereinafter also “we”, “our”, or “us”) collects, uses, and protects your personal data in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679) (hereinafter the “GDPR”) and other applicable data protection laws. This Privacy Policy applies to users who interact with our genealogy platform (hereinafter the “Platform”), which connects people seeking genealogy-related services (hereinafter the “Clients”) with independent experts offering such services (hereinafter the “Experts”).
By using the Platform, you consent to the practices and activities outlined in this Privacy Policy. If you do not agree with any provision of this Privacy Policy, please discontinue use of the Platform.
1. DATA CONTROLLER INFORMATION
The Platform is currently operating in an experimental, non-commercial phase. The purpose of this phase is to assess market potential, evaluate the feasibility of future commercial activities, and contribute to the genealogical community by facilitating genealogy research. GenGuru is not yet a registered legal entity, and during this phase, the Platform’s founders, Asad Khabibullin and Anton Kheistver, serve as data controllers under GDPR. They determine the purposes and means of processing your personal data. Once GenGuru transitions into a registered legal entity, the legal entity will assume the role of data controller.
2. WHAT KIND OF PERSONAL DATA WE COLLECT
We collect and process the following personal data:
Personal Information You Provide:
- Account Registration Data: Your name, email address, postal address, place of residence, and any other information requested by GenGuru when creating a Client and Expert account on the Platform.
- Profile Data of an Expert: This includes such information as qualifications, expertise, experience, languages, portfolio, services offered, and any other data requested by GenGuru or added by you from time to time. This data may be published and displayed by GenGuru to Clients and other Experts and publicly to any non-registered users of the Platform.
- Communications: Messages you send to us, including feedback or requests for customer support, and communication you send to other Platform users.
Usage Data Collected Automatically, which may include log data (e.g., IP address, browser type, operating system, access times, and referring URLs), as well as cookies and similar technologies (e.g., information collected via cookies to enhance user experience and gather usage statistics). Users can manage cookie preferences through their browser settings.
Data From Third-Party Services (e.g., Google, when you register with your Google account) integrated with the Platform when applicable.
3. LEGAL BASIS FOR PROCESSING PERSONAL DATA
We rely on the following legal bases for processing your personal data:
Contractual Necessity: Processing is required to provide you with the Platform, e.g., to create and manage our account, enable communications between Clients and Experts, as well as exercise our own rights and obligations in accordance with our Standard Terms.
Legitimate Interests: We may process your data for our legitimate interests, such as improving the Platform and developing new services, provided such interests do not override your rights and freedoms.
Consent: We process certain data based on your consent, particularly for marketing communications or non-essential cookies. You may withdraw your consent at any time by contacting us or managing your settings.
Legal Obligation: We may process personal data to comply with our legal obligations.
4. HOW WE USE YOUR DATA
We use your personal data for the following purposes:
Provision of the Platform: E.g., to create and manage your account, enable communication between Clients and Experts, and allow Experts to display their profiles.
Platform Improvement: To monitor Platform usage, analyze trends, and enhance security and functionality.
Marketing: With your explicit consent, we may send newsletters or promotional materials related to GenGuru. You can unsubscribe at any time.
Legal: E.g., to comply with legal obligations, resolve disputes, enforce our rights from Standard Terms and other agreements, and protect the integrity of the Platform.
5. SHARING YOUR DATA
We only share your personal data in specific circumstances and in accordance with the GDPR requirements:
With Other Users of the Platform: If you are a Client, your name may be visible to Experts and other users of the Platform. If you are an Expert, your profile information, including your name, qualifications and services, and any other information indicated in the Expert’s profile, may be publicly visible to Clients and other users of the Platform.
Service Providers and Personnel: We keep your personal data confidential but disclose it to our personnel, service providers or subcontractors if it is reasonably necessary for the purposes indicated in this Privacy Policy. Activities by our service providers include website hosting, website analytics, email services, and IT support.
Business Transfers: In the event of a merger, acquisition, sale or transfer of GenGuru’s assets, your data may be transferred as part of the respective transaction.
Legal Obligations: We may disclose your personal data if required to do so by law or to fulfil our rights and obligations, e.g., in response to requests from public authorities or as a part of legal proceedings.
Enforcement: We may disclose your personal data to third parties to enforce the terms of any agreements, investigate potential breaches or protect the rights of GenGuru, our partners and users.
6. INTERNATIONAL DATA TRANSFERS
We will process your data in accordance with the GDPR requirements. The Platform is accessible worldwide, and your data may be transferred to countries outside the European Economic Area (EEA). Where such international transfers occur, we will ensure that adequate safeguards are in place, such as Standard Contractual Clauses (SCCs), Adequacy Decisions, and/or any additional safeguards. You have the right to obtain more details about the international transfers of your data by contacting us.
7. YOUR RIGHTS
We respect your rights under applicable data protection laws. You may (as applicable):
- Request access to your personal data and information related to our use and processing of your personal data;
- Request the correction of your personal data;
- Request deletion of your personal data;
- Request that we limit our use of your personal data;
- Request your personal data in a structured, commonly used format and transfer it to another data controller;
- Object to the processing of your personal data;
- Withdraw your consent to our use of your personal data at any time when we rely on your consent to use or process that personal data.
Right to Lodge a Complaint: If you believe that we are not processing your personal data in accordance with the legal requirements, you have the right to lodge a complaint with a Data Protection Supervisory Authority.
8. DATA SECURITY
We employ appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. However, no data transmission or storage system is completely secure, and we cannot guarantee the absolute security of your personal data.
9. DATA RETENTION
We retain your personal data only for as long as necessary for the purposes for which it was collected or as required by law, after which it will be securely deleted or anonymized.
10. CHILDREN’S PRIVACY
The Platform is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided personal information to GenGuru, please get in touch with us immediately. We will take steps to remove such information.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. GenGuru will notify you of any changes by posting the updated Privacy Policy here. Your continued use of the Platform after such changes will be deemed as your acceptance of the updated Privacy Policy.
12. OUR CONTACT DETAILS
For questions or requests regarding this Privacy Policy, your rights, or any data privacy concerns, you can contact us via hello@genguru.co and/or the following address:
GenGuru
c/o Impressumservice Dein-Impressum
Stettiner Straße 41
35410 Hungen, Germany