GSX Solutions Privacy

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.

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.

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.

• Process your purchase orders and deliver the products, services and support or carry out the transactions you have requested;
• Better understand our customers and online users, including profiling based on interests and interactions with our site;
• Diagnose problems with our websites, products and services, and to administer our websites;
• Contact you, and provide you with information about your transaction status including order confirmations, billing or payment, expiration of your maintenance fee, specific GSX programs in which you have chosen to participate, products, and services available from GSX, events, promotional offers and surveys;
• Facilitate your use of our website, including GSX newsgroups and blogs;
• Customize, analyze and improve our products and services (including the content and advertisements on our website to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you;
• Personalize content, create personal profile areas, view protected content and implement your preferences;
• Meet our contractual obligations and enforce our conditions of sale, website terms and separate contracts with you;
• Prevent fraud, software piracy, and other prohibited or illegal activities;
• Protect the security or integrity of our customers as well as GSX; or
• Perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.

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:

• Your consent, for example where we have obtained your consent to process your Personal Information for certain activities (such as the use of cookies for online tracking and analysis). You are free to withdraw your consent at any time by contacting privacy@gsx.com. If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew it. Where applicable, we may ask for your consent to processing at the point where you provide your Personal Information.
• For compliance with a contractual obligation. We will advise you upon collection whether the provision of your Personal Information is mandatory and of the possible consequences if you do not provide us with your Personal Information.
• For compliance with GSX’ legal obligations where other laws require the processing of your personal information (for example, taxation and anti-money laundering laws).
• GSX’ (and its Business Partners’) legitimate interests which include the provision of this website and/or relevant products and services, and/or the carrying out of marketing and profiling activities, provided always that our legitimate interests are not outweighed by any prejudice or harm your rights and freedoms.

If you have any questions or need more information concerning the legal basis on which we collect your Personal Information, please contact us at privacy@gsx.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 privacy@gsx.com.

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:

• Access:you have the right to request information about how we process your Personal Information and to obtain a copy of that Personal Information.
• Rectification:you have the right to request the rectification of inaccurate Personal Information about you and for any incomplete Personal Information about you to be completed.
• Objection:you have the right to object to the processing of your Personal Information, which is based on our legitimate interests (as described above).
• Erasure:you have the right to request the erasure of your Personal Information (subject to certain conditions).
• Automated decision-making:you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
• Restriction:you have the right to ask us to restrict our processing of your Personal Information, so that we no longer process that information until the restriction is lifted.
• Portability:you have the right to receive your Personal Information, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organization in certain circumstances.

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 privacy@gsx.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 privacy@gsx.com 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:

• Using encryption when collecting or transferring sensitive information, such as credit card details;
• Having in place technical and organizational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and services;
• Limiting physical access to our premises;
• Limiting access to the information we collect about you;
• Ensuring that we and our Business Partners have appropriate security safeguards to keep Personal Information secure; and
• Where required by law, destroying or de-identifying Personal Information.

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.

GSX works with advertising and personalization Business Partners to use cookies, and Internet browsing to help us display personalized content and appropriate advertising during your visits to mobile applications, gsx.com and other websites. Cookies placed by these Business Partners also assist us with measuring the performance of our advertising campaigns and with identifying the pages you view, the links and ads you click on, other actions you take on those web pages, and the site from which you came before arriving at a web page. These cookies can be effective whether you are on gsx.com or another website. If you opt out of receiving targeted display advertising, the data associated with these cookies will not be used.

ome 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.

Our website includes social media features, including Facebook “Like” button and Twitter “Follow” button, or the LinkedIn or YouTube “Connect” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing them

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.

If you would like to contact us for any reason regarding our privacy practices, please email us at privacy@gsx.com or write to us at the following address:

GSX Sarl
Boulevard Helvetique, 36
1207 Geneva, Switzerland

Effective Date: May 14, 2018

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.