Privacy Policy

This webpage explains our privacy and security commitments in plain language.

• The network of GENUS websites and resources, including but not limited to our websites and digital learning resources www.genus.earth together with activity websites for national and regional events which may use or integrate with some of the aforementioned websites, as well as GENUS feedback forums (collectively, the Site) are owned and operated by GENUS Ltd and/or its subsidiaries and/or licensors (collectively we or us).
• Each product or resource, together with challenge websites for national and regional events which may use or integrate with the Site, is owned and operated by GENUS (collectively, ‘GENUS’ or ‘us’ or ‘we’).
• References to the Site in this Privacy Policy includes all products and resources that we produce and /or distribute.
• GENUS is committed to protecting the safety and security of our registered users, including students, teachers, school administrators and at-home home users and parents (collectively, Registrants) and we are sensitive to our Registrant’s concerns about the safety of the personal information provided to us. Please read this Privacy Policy carefully in order to understand how any personal information collected by us is used.
• As a global company, our Privacy Policy has been developed in accordance with a range of legislation which applies to us. In addition, we have developed our privacy framework to assist our customers that are schools, districts and education bodies to comply with privacy legislation and regulations applicable to them and the way they manage personal information.
• Collectively, this legislation includes, without limitation:

• The Australian Privacy Act 1988
• The New Zealand Privacy Act 1993
• The United Kingdom Data Protection Act 2018 
• The United States Children’s Online Privacy Protection Act (“COPPA”) and Rule
  as administered by the Federal Trade Commission
• The United States Family Educational Rights and Privacy Act (“FERPA”)
• The Alberta Freedom of Information and Protection of Privacy Act
• The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”)
• The Freedom of Information and Protection of Privacy Act (British Columbia) (“FIPPA”)
• The Personal Information International Disclosure Protection Act (Nova Scotia) (“PIIDPA”)
• The Municipal Freedom of Information and Protection of Privacy Act, Ontario (“MFIPPA”)
• The Student Online Personal Information Protection Act, California (“SOPIPA”)
• The EU General Data Protection Regulation (Regulation 2016/679)(“GDPR”)
• The UK General Data Protection Regulation (“UK GDPR”)
• The South African Protection of Personal Information Act (‘POPI Act’).

What personal information we collect

• We collect the following categories of personal information:
• As a customer, prospective customer, or user of our Site, we may collect information such as your name, age, contact information including phone number and email address, school name, class year and country or state of residence or school.
• We may also collect details of other interactions that you have with us, together with any other information that you choose to provide us with, for example, through your interactions with our customer and technical support teams.
• We do not however collect any unnecessary personal information from Registrants (for instance, information about religious beliefs).
• It is impractical in most circumstances for you to remain anonymous, and we may not be able to interact with you, provide access to the Site, or answer your enquiry if we are not able to identify you or collect your personal information.
• In the case of school/educational institution customers (School Customer), we seek consent from the School Customer to be provided with Registrant information for and on behalf of that student or teacher.
• In the case of individual / home subscriptions (At-Home Customers) we seek consent from the At-Home Customer at the time of purchasing and registering the product to use the information collected. Where the At-Home Customer is a minor, we ask that permission be sought by that student’s parent / legal guardian.
• Registrants who do not give this consent (or do not have this consent provided on their behalf) cannot provide us with their personal information and cannot use the Site. You can however withdraw your consent at any time.

What we will do with your information

• The information collected from Registrants, customers or prospective customers may be used for the following purposes
• to provide access to our products and services;
• to manage prospective purchases, purchased subscriptions and payments including to provide quotes or offers for, and updates about, our products and services;
• to send a confirmation notice to the Registrant of the registration; to administer and manage accounts, including password resetting, responding to questions raised by Registrants, to contact the Registrant about any problems with the Registrant’s account or conduct on the Site;
• to send out a GENUS newsletter or emails about the Site including information about current events, changes, improvements, upgrades, new product development and rules of the Site;
• to publish the names of winners and high performers on the Site or in the GENUS newsletter and to provide results data for each Registrant or school class;
• to send prizes or certificates for participation and performance on the Site;
• for administrative, planning, product or service development, staff training, quality control and research purposes relating to our products and services;
• for marketing purposes, but only where we have express or implied consent to contact someone or we are otherwise permitted by law to do so. Registrants may also opt out at any time by following the specific opt out instructions within the communications that we send.
• Leaderboards: GENUS strives to provide a highly engaging Site for students. Given students have indicated their strong preference for their name to be shown publicly on our Sites in recognition of their achievements, we allow this – but we do not allow full names (i.e. First Name and Surname) to be shown publicly. In addition, all administrative user access to any Site permits the partial (to initials only) or full anonymising (by use of a pseudonym) of names, where preferred by the user. If you have any questions about the Hall of Fame and managing the information that is disclosed, please contact us.
• Access to, and use of customer feedback forums, such as GENUS feedback, is designed for use by parents, teachers and other contributors who are not legally minors.

What we will not do with your personal information

• GENUS will keep your personal information confidential and not sell or disclose your information to advertisers or any external third parties, unless:
• we believe, in good faith, that we are required to share your information with a third party such as a regulator or court in order to comply with law, regulation, legal process, court order or subpoena;
• to enforce our Terms & Conditions or the terms of the licence granted to access and use the Site;
• the disclosure is to a third party that acts on our behalf, powers certain aspects of our Sites or processes data on our behalf, such as a distributor of our products and services, the licensor or owner of a product or resource that we distribute, or to a contracted service provider;
• in connection with any transaction involving our companies or assets, where another party acquires ownership or operation of the Site, in which case that successor organization will be subject to the obligations in this Privacy Policy and any contractual representations we have entered into; or
• to protect the safety and security of our Registrants and our Site.
• If third parties act on our behalf, we require them to hold, use and disclose your personal information in accordance with this Privacy Policy, applicable privacy obligations and our contractual obligations.
• Generally we will only use your information within GENUS, however, sometimes we provide data on results to government education departments, peak bodies managing or representing schools, or schools themselves, especially in the case of School Customers, who use the features of our products (such as performance reporting tools) for educational / teaching purposes. We will require these third parties to comply strictly with our instructions, use the information only for legitimate educational interests and not for any commercial purposes.
• We do not sell data to advertisers (whether personal, anonymous or aggregated). We do not use data to engage in targeted advertising to children and we do not create or build personal profiles of students other than for the purpose of supporting authorized educational/school purposes or as otherwise specifically authorized by a parent/student or school/educational institution customer.

How we collect and process your information

• We may collect your personal information in a number of ways, including:
• directly from you (unless it is unreasonable or impracticable to do so);
• from our school / educational institution customers (e.g. teachers or school administrators that purchase access to our Site for their students and teachers); or
• from third parties such as our distributors (resellers and sales agents).
• In order to register for GENUS resources, students registering individually and not part of a school, must give their consent at the time of registration to provide us with their personal information such as their name, age and email address.
• Alternatively, parents registering on behalf of their child(ren), must give their consent at the time of registration to provide us with information about them and their child(ren).
• Teachers or administrators registering for their class or school must give their consent at the time of registration to provide us with their own name, class name, school name and their email address, as well as the names of their students.
• We also ask for Registrants’ consent to use any personal information collected in accordance with this Privacy Policy at the time of login to our Site. If a Registrant does not wish to provide us with their consent, they cannot agree to the Site Terms and Conditions and must not use the Site.

How long we hold your information

• We retain the personal information that we collect from and about our Registrants for as long as it is needed to provide access to the Site or to manage that Registrant’s account. We take reasonable steps to delete the personal information we collect if your registration to use our Site lapses and you (or if you are under 13 or legally a minor in your relevant location, a parent or guardian may request on your behalf) opt out of receiving further communications from us, or if you ask us to delete your information. We may however retain and use personal information as necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements, and we may retain and use anonymous and aggregated information for performance reporting, benchmarking and analytic purposes and for product and service improvement.
• Registrants can request that their personal information be deleted by contacting the GENUS Data Protection and Privacy Officers as set out below:
  

Updating and accessing your personal information

• Registrants have a right to request a copy of the personal information we hold about them, and Registrants can also update their personal information at any time, in each case by contacting GENUS.
• If you wish to receive a copy of this information or to update or correct information held about you, please address your request to the Privacy and Data Protection Officers. We will endeavour to deal with your request promptly.

Keeping your personal information secure

• GENUS is committed to information security. We will use all reasonable endeavours to keep the personal information we collect and use in a secure environment, and we have implemented appropriate technical, administrative and physical security measures that are designed to protect personal information from unauthorised access, disclosure, use and modification. These measures include the encryption of personal information and the implementation of organisational measures, such as our incident response plan. As part of our privacy compliance processes we review these security procedures to consider appropriate new technology and methods and engage independent third parties to review and audit aspects of our information security.
• We use Microsoft Azure and Amazon Web Services for data hosting and storage. Both providers are recognised for their leading approaches to data security. 
• Further information regarding Microsoft Azure privacy and security practices, including the latest updates and compliance information, at news.microsoft.com/security2015 and www.microsoft.com/en-us/trustcenter/security/azure-security.
• Further information regarding Amazon Web Services privacy and security practices, including the latest updates and compliance information, can be found at aws.amazon.com/compliance/data-privacy-faq and aws.amazon.com/security
• We provide our personnel with training about data security and privacy, and we require all our employees and contractors to comply with this Privacy Policy and their obligations of confidentiality. We will take appropriate actions to address breaches by employees and contractors of the obligations imposed by this Privacy Policy.

Data transfers, storage and processing globally

• Registrants’ personal information is uploaded to and stored on servers that are maintained by third party providers, Microsoft Azure and Amazon Web Services, at locations in the United States, Europe and Australia. For further information about where personal information is hosted please see our Data Privacy and Security FAQs.
• As we operate globally, we may on occasion allow your personal information to be accessed in countries other than your own location. We may do this where data is accessed:
• by companies within the GENUS Group
• by our sales, operational or global customer support teams (primarily located in Australia); or
• by one of our licensors (who owns, develops and hosts a particular product) or distributors (sales agents or resellers) who requires the information to set up, service or manage a customer account;
• where a copy is sent to the Registrant itself at their request.
• By consenting to the collection and use of their personal information, Registrants’ consent to their personal information being transferred and stored in this manner.
• In the APAC region, we may record, with your express consent, customer service calls for quality and staff training purposes. If, with your consent, we record a customer service telephone call, that recording will be stored in data centres located in Australia and deleted when no longer required.

Anonymous or aggregated information

• In addition to personal information and results data, GENUS also collects anonymous information about Registrants and the activities of Registrants on the Site. Anonymous information is information that is not linked to the name or identity of a user. This information is used for educational performance reporting and analytics and to assist us in enhancing the learning resources. The information remains anonymous at all times.
• GENUS utilises third-party providers to power certain elements of the Company’s online marketing and advertising. These service providers collect data about your activities that does not personally or directly identify you when you visit our website or the websites and online services where we display advertisements (i.e. publishers). This information may include the content you view, the date and time that you view this content, the products you purchase, or your location information associated with your IP address. We use the information we and these third party service providers collect to serve you more relevant advertisements regarding GENUS resources (referred to as “retargeting”). We collect information about where you saw the ads and what ads you clicked on. This is data that does not personally or directly identify you. We do not engage in this type of marketing or advertising to students or children.
• When agreeing to the Term and Conditions, Registrants grant us the right to use this anonymous information for our own purposes, such as the preparation of statistical reports or to improve and change the content of our products.

Cookies & Third Party Technologies Policy

This section explains how GENUS use cookies and third party technologies on our websites (Websites) and in online products and services the we own, operate and/or distribute. It explains what these technologies are and why we use them, and how to contact us with any questions concerning our use of cookies or third party technologies.

What are cookies?

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies perform various tasks, including remembering your preferences, and are an important part of improving your experience of our Websites and Services.
There are three main types of cookies:

• Session cookies:  specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don’t have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;
• Persistent cookies:  record information about your preferences and are stored in your browser cache or mobile device; and
• Third party cookies:  placed by someone other than us which may gather data across multiple websites or sessions.

We use cookies and third party technologies for several reasons, including:

• for technical reasons in order for our Websites and Services to operate;
• to store user preferences and other information to save you time, or tell the web server that you have returned to a specific page;
• to enable functionality and personalisation to provide an improved user experience;
• to track and target the interests of our users (such as parents and/or school teachers and administrators), to help us understand how our Websites are being used or how effective our marketing campaigns are, or to help us customise our Websites for you to deliver customized content and promotions to customers or users whose behaviour indicates that they are interested in a particular subject area;
• third party cookies through our Websites and Services for advertising, analytics and other purposes. This is described in more detail below.

We do not use cookies or third party providers to engage in behavioural targeting of advertisements to students. We do not use third party cookies in those parts of our Services that are used and accessed by students.

What cookies do we use?

We use the following cookies:

• Essential website cookies. These are cookies that are required for the operation of our Website, Services and the use of their features. The information collected relates to the operation of our Website and Services (e.g. website scripting language and security tokens) and enables us to provide you with the service you have requested. In most cases these are session cookies and are deleted when you close your browser. Some may persist for up to 48 hrs to improve the experience for users that log back into the Services within a short period of logging out.
• Analytical / performance cookies. These cookies collect information on how users use our Website, for example which pages you visit most often, whether you receive any error messages and how you arrived at our website. Information collected by these cookies is used to improve your use of our Website and Services. These cookies expire after a period of inactivity.
• Functionality cookies. These cookies are used to enhance the functionality of our Websites and Services, to improve your user experience and to make your visits more tailored and enjoyable, by remembering the choices you have made when interacting with our websites and online products. In most cases these cookies are persistent cookies and remain stored, in order to recall your preferences, until you clear your cache.
• Advertising cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. In most cases these cookies expire within 90 days.

Additional information about third party cookies

Some of the third party cookies we use on our Website include:

• Cookies to monitor web traffic and analysis services. We use Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. All the information these cookies collect is aggregated and therefore anonymous. You can find more information about Google Analytics at the following links:  Marketing Platform Google and  Safeguarding your data. You can opt out here.
• Cookies that allow the provision of enhanced functionality and personalisation, such as videos. We use services like Intercom to power some of these features on our Website and in our Services.
• Cookies used for advertising and marketing purposes to promote our Services, including Google AdWords, LinkedIn and Facebook.

Other third party technologies

In addition to cookies, we use some other third technologies:

• Hubspot, Stripe, Google Analytics, Intercom: We sometimes contract third-party service providers, vendors, SDKs or plug ins to assist us in better understanding our site visitors and app users. These service providers, such as Salesforce and Zoho, are not permitted to use the information collected on our behalf except to help support the internal operations of our business.

IP Addresses

Additionally, when visitors request pages from our Websites and Services, Genus' servers log the visitor’s internet protocol address (“IP address”). Your IP address, browser type, browser language, and the date and time of your query, enable us to better understand and improve the usability, performance and effectiveness of our websites for purposes of system administration, to infer a visitor’s geographic location, to track the use of our websites, and to identify a visitor when GENUS feels it is necessary to enforce compliance with our policies.

How can I manage cookies?

Most internet browsers are set up by default to accept cookies. However if you want to refuse or delete them please refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Internet Explorer, Google Chrome, Mozilla Firefox and Safari). Keep in mind that each browser has a different procedure for managing and configuring cookies. However, if you use your browser settings to block all cookies (including necessary cookies) you may not be able to access all or parts of our Website and Services and some functionality may be restricted.

You can also find information about disabling or clearing cookies on most websites, including Facebook, LinkedIn, YouTube and Twitter.

You can find more information about cookies, including how to disable them at  www.allaboutcookies.org.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit  www.aboutads.info/choices.

You may opt out by clicking here or if located in the European Union, by clicking here. Please note this does not opt you out of being served advertising. You may continue to receive generic advertisements.

Revision of Privacy Policy

GENUS reserves the right to change, modify, or revise this Privacy Policy in order to comply with any applicable laws, to reflect changes in our processes or for any other reason at any time. Material changes in our Privacy Policy will be communicated to Registered Users and customers, but we also encourage our Registrants to check the Privacy Policy periodically to read about any changes, modifications, or revisions. Registrants may wish to check it each time they submit personal information. You will be deemed to have consented to such variation by your continued use of the Site following any changes being made.

Contact Us

• All requests to access, update and delete personal information as well as questions and concerns about your personal information and this Privacy Policy should be directed to the GENUS Data Protection and Privacy Officers (details below) or Privacy Officer, 
• GENUS Data Protection and Privacy Officers:
• If you are not satisfied with the response you receive, you may have the right to contact the regulator responsible for privacy in your home country.

More privacy information

• For more information on privacy legislation and guidelines in your local jurisdiction please contact your relevant local authorities.
• Australia: privacy.gov.au
• Canada: priv.gc.ca/en
• European Union: ec.europa.eu/justice_home/fsj/privacy
• India: mit.gov.in/default.aspx
• New Zealand: privacy.org.nz
• Singapore: mica.gov.sg
• United Kingdom: ico.org.uk
• USA: ftc.gov
• South Africa: popia.co.za

Special information for users across Canada

• GENUS is committed to providing access to our resources through an environment that is compliant with all national and provincial privacy requirements applicable to us, and those requirements that apply to our School Customers across Canada.
• This Privacy Policy has been developed with the standards required to be compliant with the Alberta Freedom of Information and Protection of Privacy Act, the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Information International Disclosure Protection Act (Nova Scotia) (“PIIDPA”), the Freedom of Information and Protection of Privacy Act (British Columbia) (“FIPPA”) and the Municipal Freedom of Information and Protection of Privacy Act, Ontario (“MFIPPA”).
• We sometimes transfer school information to others, including to affiliated entities or unrelated companies (“service providers”), that carry out certain functions on our behalf such as order fulfillment, accounts receivable and data processing. Student names or other personally identifiable information, however, remains in Canada. In those cases where we do need to use the services of a third party, we require them not to use or disclose the information for any purpose other than as directed by Genus.
• We take all reasonable contractual or other measures to protect your personal information while processed or handled by these service providers. If the information is located outside Canada it will be subject to legal requirements in those foreign countries applicable to our service providers, however the information they have will not be personal in nature.

Special Information for users in the European Union and the United Kingdom

• GENUS welcomes the EU GDPR and UK GDPR as essential regulations to affirm our commitment to data protection across the European Union and the United Kingdom. We are committed to ensuring:
• Personal data is processed fairly, lawfully and in a transparent manner
• Personal data is collected and processed only for specified and lawful purposes
• Processed data is adequate, relevant and not excessive
• Processed data is accurate and, where necessary, kept up to date
• Personal data is not kept longer than necessary
• Personal data is processed in accordance with an individual’s rights
• Personal data is kept secure
• Personal data is not transferred to countries outside of the EU or the UK without adequate protection
• The information below should be read in addition to our Privacy Policy, and outlines specific information relevant to certain aspects of our GDPR compliance. Genus is registered with the Independent Commissioners Office, registration reference no: Z2188515. A copy of this certificate can be downloaded here. Genus Earth Pty Ltd is a company registered in England and Wales with company registration no. 05919214 and is a trading company within the GENUS Group.
• Lawfulness of processing: Genus collects personal information in a number of contexts and for a number of purposes. Please refer to the “What personal information we collect”, “What we will do with your information” and “How we collect and process your information” sections of the Privacy Policy. Our processing activities are based either on consent or legitimate interests pursued by GENUS and our school and district customers in delivering learning resources for use by schools, teachers, parents and students which are designed to improve learning outcomes and inspire a love of learning.
• Is personal information transferred outside of the European Union or the United Kingdom? Yes, personal information in relation to Registered Users and customers located in the EU or the UK may be transferred outside of the EU or UK in 2 main situations:
• User data may be uploaded to and stored on our servers located in the USA or Australia. For further information about where personal information is hosted please see our Data Privacy and Security FAQs
• Additional information about Microsoft’s compliance with the EU GDPR is available here.
• Additional information about Amazon Web Services’ compliance with the EU GDPR is available here.
• In most instances, personal data about our EU and UK based customers is collected, accessed and managed by our sales, operational and customer support teams in the United Kingdom. Very occasionally however, such information may be shared with our employees in one of our offices outside of the UK e.g. to respond to an urgent customer support query outside of normal hours or for internal reporting processes. Our main offices outside of the EU are located in Calgary, Canada and Sydney, Australia. To ensure appropriate safeguards exist in relation to such transfers, GENUS has implemented standard contractual clauses to cover the transfer of data relevant to EU and UK registrants to other companies within the Genus that are not located in the EU.
• We stay up to date with regulatory developments in the EU and the UK to ensure that appropriate and compliant safeguards are in place for the transfer of any personal information outside of the EU or UK.
• For further information, please contact the GENUS Data Protection and Privacy Officer, whose details are brent@genus.earth.
  

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