The
Ginicoe Corporation has a rich tradition of bringing confidentiality,
availability, and integrity of personal data to our members around the world,
and our sites and applications are created to connect our members with the best
that we have to offer on the platforms and devices our members prefer.
Although
this Privacy Policy is not a binding contract and does not create any legal
rights, it does serve as an expression of the Company’s commitment to
protecting private personal information.
Our
privacy policy is designed to provide transparency into our privacy practices
and principles, in a format that our members can navigate, read and understand.
We are dedicated to treating your personal information with care and respect.
Privacy
Policy
Last
Modified: May 1, 2019
This
privacy policy describes the treatment of information provided or collected on
the sites where this privacy policy is posted. It also explains the treatment
of information provided or collected on applications we make available on
third-party sites or platforms if disclosed to you in connection with use of
the application. We follow this privacy policy in accordance with local law in
the places where we operate.
1. Types of Information We Collect
2. How We Collect Your Information
3. Use of Your Information by The
GiniCoe Family of Companies
4. Sharing Your Information with
Other Companies
5. Your Controls and Choices
6. Children’s Privacy
7. Data Security and Integrity
8. Data Transfers, Storage and
Processing Globally
9. Changes to this Privacy Policy
10. Comments and Questions
1.
Types of Information We Collect
We
collect three basic types of information - personal information, anonymous information, and biometric facial
recognition (BFR) information - and we may use personal, anonymous, and BFR information to create a
fourth type of information, aggregate information. We collect the following
categories of information:
· Registry event information you provide
when you create an account, including your first name and surname, credit
and/or debit cards, facial image, your phone (or mobile) number, driver’s
license number, country of residence, gender, height, weight, color of hair,
style of hair, handedness, color of eyes, distinguishing facial tattoos,
distinguishing facial piercings, date of birth and age, your self-identified
race, email address, username and password.
· If you choose not to provide personally
identifiable information (PII) we may not be able to provide you with requested
products, services, or information.
· Transaction information you provide when
you purchase or return a product or service from us or our affiliate merchants,
card issuers, health care, government benefit agencies, educational services,
or similar points of interaction whether on our sites or through our
applications, including your postal address, telephone number and payment
information.
· Information you provide in public forums
on our sites and applications.
· Information sent either one-to-one or
within a limited group using our message, chat, email, post or similar
functionality, where we are permitted by law to collect this information
· Information you provide to us when you
use our sites and applications, our applications on third-party sites or
platforms such as social networking sites, or link your profile on a
third-party site or platform with your enrollment account.
· Location information when you visit our
sites or use our applications, including location information either provided
by a mobile device interacting with one of our sites or applications, or
associated with your IP address, where we are permitted by law to process this
information.
· Usage, viewing and technical data,
including your device identifier or IP address, when you visit our sites, use
our applications on third-party sites or platforms or open emails we send
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2.
How We Collect Your Information
· Ginicoe supports The Customer Online
Notification for Stopping Edge-provider Network Transgressions (CONSENT) Act
for subscribers to proactively OPT-IN not opt-out. Put another way, upon registration and
enrollment, you are OUT of ALL third party interactions outside of our General
Business Purpose, until YOU change your profile
· We collect information you provide to us
when you request products, services or information from us or our affiliate
merchants, card issuers, health care, government benefit agencies, educational,
or similar points of interaction vendors, register with us, participate in
public forums or other activities on our sites and applications, respond to
customer surveys, or otherwise interact with us or our affiliate merchants,
card issuers, or government benefit agencies, educational, or similar points of
interaction vendors. Please keep in mind that when you provide information to
us on a third-party site or platform (for example, via our applications), the
information you provide may be separately collected by the third-party site or
platform. The information we collect is covered by this privacy policy and the
information the third-party site or platform collects is subject to the
third-party site or platform’s privacy practices. Privacy choices you have made
on the third-party site or platform will NOT apply to our use of the
information we have collected directly through our applications.
· We may connect information collected
automatically with information we already have about you in order to accurately
identify you as a enrollee or registered member. If we are able to identify you
as a Ginicoe member, we may for example, link your information and activity on
our website to your activity with an affiliate, partner, or merchant, card
issuers, government benefit agencies, educational or similar points of
interaction vendor. This allows us to
provide you with a personalized experience regardless of the omni-channels that
you select to interact with us – online, affiliate merchants, mobile,
telephone, postal mail, fax, or brick-n-mortar physical merchants, etc.
· We collect information through
technology, such as cookies, Flash cookies and Web beacons, including when you
visit our sites and applications or use our applications on third-party sites
or platforms. This information may also include the pages you visit on our
site, which web address you came from, the type of browser/device/hardware you
are using, purchasing information and checkout process search terms and
IP-based geographic location. Please visit Online Tracking and Advertising for
further information, including Do Not Track and how to disable cookies.
· We acquire information from other
trusted sources to update or supplement the information you provided or we
collected automatically. We may also connect collected information with
information we already have about you in order to identify and authenticate you
as a new enrollee or existing Ginicoe member in good standing. If we are able
to identify you as a Ginicoe member, for example, link your activity on our
website to your activity in an affiliated merchant’s store, card issuers,
government benefit agencies, educational, or similar points of interaction
vendor. This allows us to provide you with personalized experience regardless
of how you interact with us – online, mobile, SMS Messages, affiliated
merchants, etc. Local law may require that you authorize the third party to
share your information with us before we can acquire it.
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3.
Use of Your Information by The Ginicoe Family of Companies
A
member of The GiniCoe Family of Companies, which includes many different
brands, will be the data provider for your information. The relevant data
provider(s) can be determined here. Other members of The Ginicoe Family of
Companies may have access to your information where they perform services on
behalf of the data provider(s) (as a data processor) and, unless prohibited
under applicable law, for use on their own behalf (as a data provider) for the
following purposes:
· Provide you with the products and
services you request
· Communicate with you about your account
or transactions with us and send you information about features on our sites
and applications or changes to our policies
· Consistent with local law and choices
and controls that may be available to you:
· Send you offers and promotions for our
products and services or third-party products and services.
· Personalize content and experiences on
our sites and applications.
· Provide you with advertising based on
your activity on our sites and applications and on third-party sites and
applications. To learn more about how we use your information for
personalization and tracking, please visit Online Tracking and Advertising.
· Optimize or improve our products,
services and operations
· Detect, investigate and prevent
activities that may violate our policies or be illegal
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4.
Sharing Your Information with Other Companies
We
will NOT SHARE your personal information outside The GiniCoe Family of
Companies except in limited circumstances, including:
· When you allow us to share your personal
information with another company, such as:
· Electing to share your personal
information with carefully selected companies so that they can send you offers
and promotions about their products and services
· Directing us to share your personal
information (PII) with third-party sites or platforms, such as merchants, card
issuers, government benefit agencies, educational, or similar points of
interaction vendors or social networking sites.
Please
note that once we share your personal information with another company, the
information received by the other company becomes subject to the other
company’s privacy practices.
· When we cooperate with financial
institutions to offer co-branded products or services to you, such as our
co-branded Ginicoe Dynamic Scoring™ ; however, we will do so only if permitted
by applicable law and, in these cases, the financial institutions are
prohibited from using your personal information for purposes other than those
related to the co-branded products or services.
· When companies perform services on our
behalf, like perform data scrapping, data crawling, data spiders, internet
service providers, and customer service; however, these companies are
prohibited from using your personal information for purposes other than those
requested by us or required by law.
· When we share personal information with
third parties in connection with the sale of a business, to enforce our Terms
of Use or rules, to ensure the safety and security of our members and third
parties, to protect our rights and property and the rights and property of our
members and third parties, to comply with legal process or in other cases if we
believe in good faith that disclosure is required by law.
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5.
Your Controls and Choices
As
a member, we provide you the ability to exercise certain controls and choices
regarding our collection, use and sharing of your information. In accordance
with local law, your controls and choices may include:
· You may create, read, update and delete
(CRUD) your enrollment account and profile.
· You may change your choices for
subscriptions, payment methods, and pricing plans.
· You may opt-in or opt-out of having your
facial image displayed on our website or public jumbo-tron located in Times
Square, New York in the upcoming future.
· You may choose whether to receive from
us offers and promotions for our products and services, or products and
services that we think may be of interest to you
· You may choose whether we share your
personal information with other companies so they can send you offers and
promotions about their products and services
· You may choose whether to receive
targeted advertising from many ad networks, data exchanges, marketing analytics
and other service providers here
· You may request access to the personal
information we hold about you and that we amend or delete it and we request
third parties with whom we have shared the information do the same
You
may exercise your controls and choices, or request access to your personal
information, by visiting Privacy Settings, or by contacting Member Services, or
following instructions provided in communications sent to you. Please be aware
that, if you do not allow us to collect personal information from you, we may
not be able to deliver certain products and services to you, and some of our
services may not be able to take account of your interests and preferences. If
you have questions regarding the specific personal information about you that
we process or retain, please contact Member Services.
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6.
Children’s Privacy
We
recognize the need to provide further privacy protections with respect to
personal information we may collect from children on our sites and applications.
Some of the features on our sites and applications are age-gated so that they
are not available for use by children, and we do not knowingly collect personal
information from children in connection with those features. When we intend to
collect personal information from children, we take additional steps to protect
children’s privacy, including:
· Notifying parents or caregivers about
our information practices with regard to children, including the types of
personal information we may collect from children, the BFR image of the child,
and the uses to which we may put that information, and whether and with whom we
may share that information
· In accordance with applicable law,
obtaining consent from parents for the collection of personal information from
their children, or for sending information about our products and services
directly to their children
· Limiting our collection of personal
information from children to the least privilege that is reasonably necessary
to participate in an online activity
· Giving parents access or the ability to
request access to personal information we have collected from their children
and the ability to request that the personal information be changed or deleted
For
additional information about our practices in the United States and Latin
America regarding children’s personal information, please read our Children’s
Online Privacy Policy.
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7.
Data Security and Integrity
The
security, confidentiality, integrity, and availability of your information are
extremely important to us. We have implemented technical, administrative and
physical security measures that are designed to protect member’s information
from unauthorized access, disclosure, use and modification. From time to time,
we review our security procedures and policies to consider appropriate new
technologies, processes, people or methodologies. Please be aware though that,
despite our best efforts, no security measures are perfect or impenetrable.
Additionally, we ask that you, the member, remain vigilant is protecting your
security as a Ginicoe Member.
“Phishing”
is a scam designed to steal your personal information. If you receive an e-mail
that looks like it is from us asking you for your personal information, do not
respond. We will never request your
password, user name, credit card information, facial image or other personally
identifiable information (PII) by way of an e-mail or SMS text message.
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8.
Data Transfers, Storage and Processing Globally
We
operate globally and may transfer your personal information to individual
companies of The Ginicoe Family of Companies or third parties in locations
around the world for the purposes described in this privacy policy. Wherever
your personal information is transferred, stored or processed by us, we will
take reasonable steps to safeguard the privacy of your personal information.
Additionally, when using or disclosing personal information transferred from
the European Union, we abide by the Safe Harbor Principles as set forth by the
U.S. Department of Commerce, use standard contract clauses approved by the European
Commission, adopt other means under European Union law for ensuring adequate
safeguards, or obtain your consent. We also apply the substantive requirements
of the Safe Harbor Principles when transferring personal information from
Australia.
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9.
Changes to this Privacy Policy
From
time to time, we may change this privacy policy to accommodate new
technologies, industry practices, regulatory requirements or for other
purposes. We will provide notice to you if these changes are material and,
where required by applicable law, we will obtain your consent.
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10.
Comments and Questions
If
you have a comment or question about this privacy policy, please contact Member
Services. Our sites and applications may contain links to other sites not owned
or controlled by us and we are not responsible for the privacy practices of
those sites. We encourage you to be aware when you leave our sites or
applications and to read the privacy policies of other sites that may collect
your personal information.
Notice
to California Residents: If you are a California resident, California Civil
Code Section 1798.83 permits you to request information regarding the
disclosure of your personal information by certain members of The Ginicoe
Family of Companies to third parties for the third parties’ direct marketing
purposes. With respect to these entities, this privacy policy applies only to
their activities within the State of California. To make such a request, please
send an email to caprivacy[at]ginicoe.com or write us:
CA
Privacy Rights
P.O.
Box 12521
East
Cleveland, Ohio
44112-9998
In
your request, please specify the member of The Ginicoe Family of companies to
which your request pertains. If no member is specified, we will treat your
request as pertaining to Ginicoe basic low product.
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Definitions
Aggregate
Information. Aggregate information means information about groups or categories
of members, which does not identify and cannot reasonably be used to identify
an individual member.
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Anonymous
Information. Anonymous information means information that does not directly or
indirectly identify, and cannot reasonably be used to identify, an individual
member.
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Application.
Application means a program or service operated by us (or on our behalf) that
may be displayed on various online, mobile or other platforms and environments,
including those operated by third parties, which permits us to interact
directly with our members.
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Children.
Children means individuals who we have identified are not of legal age to
consent to the collection and processing of their personal information. In the
United States and Latin America, the term “children” refers to individuals
under 13 years of age.
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Data
Provider. The data provider is the subsidiary or affiliated entity of The
Ginicoe Corporation that is responsible for the personal information collected
from sites and applications, as follows:
· Authorized United States Photography
Shops
· United States Postal Service
usimageupload[at]ginicoe.com
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Data
Processor. A data processor is a person or entity that processes personal
information on behalf of a data provider (or data providers) and is permitted
to perform data processing only as directed by the data provider(s).
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IP
Address. An IP address is associated with the access point through which you
enter the Internet, and is typically controlled by your Internet Service
Provider (ISP), your company, or your university. We may use IP addresses to
collect information regarding the frequency with which our members visit
various parts of our sites and applications, and we may combine IP addresses
with personal information.
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Member.
Member means a subsidiary or affiliated entity that is part of The Ginicoe
Family of Companies.
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Notice.
Notice may be by email to you at the last email address you provided us, by
posting notice of such changes on our sites and applications, or by other
means, consistent with applicable law.
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Parents.
Parents means a parent or legal guardian.
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Personal
information. Personal information means information that identifies (whether
directly or indirectly) a particular individual, such as the individual’s name,
postal address, email address and telephone number. When anonymous information
is directly or indirectly associated with personal information, this anonymous
information also is treated as personal information.
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Public
Forums. Our sites and applications may offer message boards, conversation
pages, blogs, chat rooms, social community environments, profile pages, and
other forums that do not have a restricted audience. If you provide personal
information when you use any of these features, that personal information may
be publicly posted and otherwise disclosed without limitation as to its use by
us or by a third party. To request removal of your personal information from a
public forum on one of our sites or applications, please opt-out or contact
Member Services.
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The
Ginicoe Family of Companies. The Ginicoe Family of Companies refers to The
Ginicoe Corporation and its subsidiary and affiliated entities, which offer
their products and services under various brand names. These companies engage
in a number of businesses, including credit and/or debit card processing,
financial products delivery, biometric processing, data aggregation and
processing, and interactive services. The Ginicoe Company brands include, among
others, the following:
· Premium product with all features + Plus,
Standard, & Essential
· digital POI + standard & Essential
· physical brick–n–mortar POI + essential
· basic product with basic features; FREE
enrollment
Ginicoe
supports S.2639: Customer Online
Notification for Stopping Edge-provider Network Transgressions (CONSENT) Act
for subscribers to proactively OPT-IN not opt-out.
We
also comply with 47 U.S.C section 230 Communications Decency Act (CDA)
protection for immunity for a neutral public forum. In effect, we are not “a publisher or content
provider”. We are a Tech Company.