This Privacy Statement describes the privacy practices of GSX group of companies in relation to our customers, websites, products, online services and online user information ("Privacy Statement") and applies to GSX Sàrl and its worldwide subsidiaries ("GSX," "we" or "our"). This Privacy Statement also does not apply to the websites of our Business Partners (as defined below) or to any other third parties, even if their websites are linked to our website. We recommend you review the privacy statements of the other parties with which you interact.
This Privacy Statement governs Personal Information we collect from our customers and from our website and other online visitors ("you" or "your"), as well as information we automatically collect from your online visits.
For the purposes of this Privacy Statement, "Business Partner" means any subcontractor, vendor or other entity with whom we have an ongoing business relationship to provide products, services or information.
By using the GSX websites, products or online services, you consent to the collection and use of the Personal Information as described here.
We may ask you to provide Personal Information when you:
"Personal Information" means information that may directly or indirectly identify you. Personal Information we collect may include your name, email address, home address, contact telephone numbers, Internet Protocol ("IP") address, location data, user IDs and passwords, or payment information (e.g., credit card number, billing information). It may also include work information such as job title, industry, and other business or company information. We may also collect demographic information, such as your age, gender, interests, and preferences. We may ask for your national identity number and other data to process your credit or financing request.
In order to offer you a more consistent and personalized experience in your interactions with GSX, information collected through one source may be combined with information GSX obtains through public sources. We may also supplement the information we collect with information obtained from other parties, including our Business Partners and other third parties to create customized profiles about you.
We may automatically collect behavioral and usage information about your visits to our websites, including the pages you view, the links and advertisements you click, search terms you enter, and other actions you take in connection with GSX websites and services. We may also collect certain information from the browser you use to come to our website, such as your IP address, device identifier, location data browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our website and the URL to which you browse away from our site if you click on a link on our site.
We may obtain information about you from third party sources such as public databases, our Business Partners, joint marketing partners, social media platforms, and from other third parties. Examples of the information we may receive from other sources include: page-view information from some business partners with which we operate co-branded services or joint offerings, and credit history information. We may use the information to better understand you to enhance our ability to provide relevant marketing, products and services to you and to help prevent and detect fraud.
Our legal basis for collecting and using your Personal Information as described in this Privacy Statement will depend on the Personal Information concerned and the specific context in which we collect it. In general, we collect and process your Personal Information on one or more of the following bases:
If you have any questions or need more information concerning the legal basis on which we collect your Personal Information, please contact us at email@example.com.
We will retain your Personal Information as necessary in connection with the purposes described in this Privacy Statement, for as long as your account is active, and in accordance with GSX' retention policies and applicable law.
GSX may transfer your Personal Information to other companies within the GSX group and/or to Business Partners, if required for the purposes described in this Privacy Statement. This may involve the transfer of your Personal Information to countries outside your home country or region, including outside the European Economic Area if that is your region, which may have a different level of data protection from your home country. Such countries may include, without limitation, the United States and other countries in which GSX or its subsidiaries, affiliates or Business Partners are active. In order to provide adequate protection for the transfer of your Personal Information, we have in place contractual arrangements (as appropriate) with our subsidiaries, affiliates and Business Partners in respect of such transfers. We will take all reasonable technical and organizational measures to safeguard Personal Information we transfer.
We may share your Personal Information with GSX subsidiaries or Business Partners for the purposes described in this Privacy Statement, including (without limitation) to carry out transactions you request, or to make our business (or that of our subsidiaries) more responsive to your needs. Our subsidiaries and/or Business Partners may contact you with information about GSX, and GSX-branded products, services or offers. We will only share your Personal Information with GSX subsidiaries and Business Partners who agree to protect your Personal Information and use it solely for the purposes specified by GSX.
In addition, GSX may share your Personal Information with participants in our sales and marketing chain, including but not limited to retailers, resellers, distributors, integrators, order fulfillers and some sale agents and channel partners, for the limited purposes of selling, marketing or providing support for GSX products and services.
We may disclose your Personal Information for any purpose with your consent.
We may also disclose your Personal Information in connection with law enforcement, fraud prevention or other legal action; as required by law or regulation; if GSX (or a part of GSX) is sold or merges with another company or if we sell a GSX website, product or business unit or all or a substantial portion of our assets are acquired by another company; or if GSX reasonably believes it is necessary to protect GSX, its customers or the public.
Except as described above, we will not disclose your Personal Information to third parties for their own marketing purposes without your consent.
GSX wants to help you keep your Personal Information accurate. To view or edit your Personal Information please contact us at firstname.lastname@example.org.
Where the processing of your Personal Information is subject to EU data protection laws, you have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law:
In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Information infringes applicable data protection law.
If you have any questions about the type of Personal Information we hold about you or if you wish to request deletion or correction of Personal Information we hold about you, or exercise any other data subject right, please send a written request to email@example.com or to the postal address provided at the bottom of this Privacy Statement. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.
You may choose to receive or not receive marketing communications from GSX by indicating your preferences. You can click "unsubscribe" in any marketing email communications or newsletters about our products and services or you can email us at firstname.lastname@example.org to opt-out of allowing us to create a customized profile about you.
Any marketing by GSX, or any third parties on behalf of GSX, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences.
Please allow up to 8 business days for your email preferences to take effect. As some promotions, such as direct mail catalogs, are developed in advance, you may sometimes receive marketing communications after we receive your preference request. If you opt out of receiving marketing communications, we may still communicate with you in connection with transactions you request and/or service related matters.
GSX takes all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorized access, modification or disclosure. The ways we do this include:
We encourage you to keep any passwords you use confidential and to be careful to avoid "phishing" scams where someone may send you an email that appears to be from GSX asking for your personal information. However, despite our efforts, no security controls are 100% effective and GSX cannot ensure or warrant the security of your Personal Information.
Cookies allow you to take advantage of some of GSX' essential features. If you choose to decline cookies, you may not be able to sign in or use other interactive features of GSX websites and services that depend on cookies.
Some marketing you receive may be personalized based on your visits to gsx.com and your browsing history. In addition, when you click on some links in email marketing, our email service provider may place a cookie on your browser. This type of cookie would be linked to your email address or IP address and used to gather information about the products and services you view on gsx.com. Information gathered may be used to personalize and customize future email marketing messages you receive. You may opt out of this use by clicking on the unsubscribe link provided in every personalized email marketing message you receive.
GSX or its Business Partners may use web beacons on our websites, in our email messages, in our advertisements on other websites, or in our advertisements in others' email messages. Similarly, third parties whose content or advertisements appear at gsx.com, or whose email of our email campaigns, by counting the number of individuals who open or act upon an email message, determining when an email message is opened and determining how many times an email message is forwarded. Subject to local laws, messages gsx.com sends to our users, may also place web beacons in their advertisements or email messages for the purposes of measuring the effectiveness of the content, advertisements or email messages.
We may allow some of our Business Partners to compile individual or aggregated statistics from the use of web beacons on gsx.com by GSX, its agents or others, to determine the effectiveness of online marketing and to develop statistics on how often clicking on an advertisement results in a purchase or other action on the advertiser's site. No Personal Information about you is shared with Business Partners for this research.
You can make some web beacons unusable by rejecting cookies in your web browser.
When you visit our websites or view one of our email messages, we may use pixel tags, tracking links and/or similar technology to note some of the pages you visit on our websites. We may also use pixel tags to determine what types of email your browser supports. We may use the information collected through web beacons, pixel tags, tracking links and similar technology in combination with your Personal Information to personalize your experience on gsx.com and to provide you with more useful and relevant advertisements.
Please be aware that GSX provides links to other websites, which if you click on them may collect Personal Information about you. The information practices of those third-party websites linked to gsx.com are not covered by this Privacy Statement.
We will occasionally update this Privacy Statement. If we make changes to this Privacy Statement or make any material changes to how we use your Personal Information, we will revise this Privacy Statement to reflect such changes. We encourage you to periodically review this Privacy Statement to be informed of how we are using and protecting your Personal Information.
If you would like to contact us for any reason regarding our privacy practices, please email us at email@example.com or write to us at the following address:
Boulevard Helvetique, 36
1207 Geneva, Switzerland
Effective Date: May 14, 2018