Privacy Policy

1. Introduction

At THEHOLD Inc. (“Genesys AI”, “our”, “us” or “we”), we value your privacy and are committed to being fair, accountable, and transparent in how we handle your personal information. This Privacy Policy outlines how we collect and use your personal information when you use our websites, products, applications, and other Genesys AI services (our “Service”). It also describes your privacy rights.

This Privacy Policy does not apply to data that we process on behalf of our enterprise customers or thelist.app, such as information managed through our API. Our processing of such data is governed by the terms and agreements established with each customer. If you wish to exercise your rights with respect to personal information processed under those agreements, please contact the company on whose behalf we are processing such data. They maintain control over your information and are responsible for addressing any requests.

2. Collection of your personal information

2.1 Personal information you provide

Account Data: When an account is required to access the Service, we will collect your name, contact information, account credentials, and, where payment is required, Payment Data (described below). If you register or log into our Service using another service, that service will send your information to us. We do not share your personal information in any form when you use existing third-party credentials to access the Service.

Payment Data:Where payment is required to access the Service, we may collect payment information (such as payment card information) directly from you and details regarding your transactions with us.

With the exception of our recruitment activities, we do not aim to collect sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric data, criminal background, or trade union membership) and ask that you do not provide us with any such information.

Contact and Communications Data:If you communicate with us, we will collect contact information such as your name, email address, any other contact details you voluntarily choose to provide us, and any additional information you provide in your communications with us.

2.2 Personal information we collect when you use Genesys AI

Applicant Data: If you apply for a job or role with Genesys AI, we will collect your personal information such as your contact details, resume/CV, education and work history, visa status, and other information obtained during interviews (including interview recordings and screenshots, where permissible). You also may choose to provide your gender, ethnicity, veteran status, disability status, and links to your website, blog, portfolio, LinkedIn or other public profiles.

When you use or interact with thelist.app, Genesys AI or our Service, we collect certain information from or about you. This may include:

Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, X, YouTube and LinkedIn. When you interact with our social media pages, we collect personal information that you choose to provide to us, such as your contact details (collectively, “Social Data”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.

User Content: We collect personal information that is included in user prompts or inputs (like the text, photos, images, file uploads, and other materials you submit to Genesys AI) (“Input”) and the outputs generated by Genesys AI (“Output”) (together, “User Content”). If you include personal information in Inputs you provide to Genesys AI, this information may be reproduced in the Output. Please do not share any personal information (including any sensitive information) in your Input to Genesys AI.

We use this information to provide Genesys AI’s functionality to you, to improve your user experience, and to further train and improve our models.

2.3 Personal information we collect automatically

Device Data: Technical information such as your IP address, device type, country from which you access, browser type and version, browser plug-in types and versions, and operating system.

We may collect this information through our Service or through other methods of web analysis. We use Google Analytics, a web analytics service provided by Google LLC, to help us understand how users interact with our Service. Google Analytics collects information such as how often you visit the Service, what pages you visit, and what other sites you visited prior to arriving. We use this information to improve our Service. Google Analytics collects only the IP address assigned to you on the date you visit, rather than your name or other identifying information. We do not combine the information collected through Google Analytics with personally identifiable information.

Feedback Data: We may collect your suggestions, recommendations, or other feedback relating to Genesys AI. This might arise if, for example, you report that Genesys AI returned inaccurate information or rate an Output using the thumbs-up/thumbs-down icons. If you provide such feedback, we may collect it even if you have opted out of our use of your information to train our models.

Google’s ability to use and share information collected by Google Analytics about your visits is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits by disabling cookies in your browser settings.

Interaction Data: We also receive certain information about your use of Genesys AI, such as the frequency and duration of interactions, the number and length of sessions, response times, and how often you use Genesys AI over time. This may also include other usage data, such as information about the features you engage with, the sequence of actions, and types of tasks performed.

2.4 Personal information from other sources

Publicly Available Data: We collect a variety of information that is publicly available on the internet to train and develop the models that power our Service. In some instances, this information may include personal information (for example, information about politicians, celebrities, published authors or other public figures) and sensitive information (for example, political opinions, religious or philosophical beliefs, or information concerning sexual orientation, among others).

For job applicants, we may receive personal information about you from our affiliated companies and third parties, such as recruitment agencies, social media platforms, and individuals who refer you. This information may include:

Mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs, and custom profiles.
Resumes, reference information, and background check information.

Usage Data:Information about your use of the Service, pages you view, date and time of your visit, duration of visits, browsing history, search history, traffic data, standard server log information, and other communication data.

3. How we use your personal information

Inferred Location Data: Your country-level, state-level, and city-level location based on your IP address.

We use your personal information for the following purposes:

To process payments: We may process payment data in relation to access to certain features of our Service.

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

4. Sharing of your personal information

We do not share your personal information with third parties, other than as follows:

Public Posts: We collect public posts shared on social media, which includes the content of public posts, the date shared, and engagement data such as the number of followers associated with the account as well as the number of views, likes, reposts, shares, and replies.

With our contracted vendors, service providers and consultants: To assist in providing the Service to you or performing business operations, we provide your personal information to vendors and service providers including providers of hosting services, cloud services, web analytics providers, content delivery services, support and safety monitoring services, and payment and transaction providers and other technology service providers.

Internet Search Data: In responding to search queries, some aspects of the Service may include the ability to conduct a real-time web search of public results from the internet. In some instances, this data may include personal information.

We may also create and share anonymized, aggregated, and de-identified usage data with our related companies and third parties to help us perform analysis and make improvements. Save as expressly detailed above, we do not share, sell, or rent any of your personal information to any third party and will not do so without updating this Privacy Policy, notifying you, or, where necessary, obtaining your consent.

Licensed Datasets: Datasets we license from third-party businesses.

Please note that any personal information or other information you choose to submit in communities, forums, blogs, or chat rooms on our websites may be read, collected, and used by others who visit these forums or pages.

5. Marketing

We do not collect and use your personal information for marketing purposes and do not share your personal information with third parties for the purpose of marketing.

6. Security of your personal information

Genesys AI takes reasonable precautions to safeguard your personal information, including through use of appropriate organizational and technical measures to help safeguard your personal information against accidental or unlawful destruction, loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no security measure or modality of data transmission over the internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites and online accounts after your sessions.

To provide and maintain our Service: We use your personal information to provide and maintain our Service (including to provide Output in response to Input).

7. Retention of your personal information

To provide support and assistance: We use your personal information to troubleshoot and diagnose problems, and provide customer care and support services.

We retain your personal information for no longer than is necessary for the purposes set out in this Privacy Policy. The specific retention periods we apply are as follows:

To develop and improve our Service: We use your personal information for research and development purposes, to analyze trends, and to identify future opportunities for the development, promotion, and improvement of our Service. For example, we process Publicly Available Data and User Content to train and improve the models that power our Service.

AI model training and automated processing: Genesys AI is powered by machine learning models that may be improved using data from your interactions with the Service, including your inputs and feedback, unless you have opted out (see Section 10). Outputs are generated by AI and may not always be accurate. We do not use your data to make automated decisions with legal or significant effects on you.

With our related companies: We may disclose personal information to our related companies to the extent such sharing is necessary to fulfill a request you have submitted via our Service or for customer management, customer support, technical operations, or the purposes described above.

To ensure security and integrity: We process your information to protect the security of the Service and our systems, and to detect and prevent fraud, unauthorized use, unlawful activity, and other misuses of our Service.

To comply with legal obligations: To (i) comply with laws or to respond to lawful requests and legal process, (ii) protect the rights and property of Genesys AI and our agents, customers, and others, including to enforce our agreements, policies, and terms of service, or (iii) in an emergency, to protect the personal safety of Genesys AI, its customers, or any person.

To comply with legal obligations: We process your personal information when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws.

In connection with business transfers: In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. If required by applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third party.

To process job applications: We process your personal information if you apply for a job or role with Genesys AI, to evaluate your application and make hiring decisions, communicate with you about current and future career opportunities, manage and improve our recruiting and hiring processes, and conduct reference and background checks where required or permitted by applicable law.

For other legitimate business purposes: We may use your personal information for other purposes such as data analysis, developing new products, identifying usage trends, and operating and expanding our business activities.

Data Type	Retention Period	Basis
Account data	Duration of account + 3 years	Contractual / Legitimate interests
Conversation / prompt data	2 years from last interaction	Service improvement / Legitimate interests
Feedback data	3 years	Service improvement / Legitimate interests
Payment data	7 years	Legal obligation (financial records)
Job applicant data (unsuccessful)	1 year	Legitimate interests
Security / log data	90 days rolling	Security / Fraud prevention

Notwithstanding the periods above, we may retain your personal information for longer where:

We have a legal obligation to do so (e.g., if we receive a court order);
It is necessary to deal with and resolve requests and complaints;
It is necessary to protect the safety, security, and integrity of our business and the Service; or
It is necessary for litigation or regulatory matters.

8. Links to other websites and social media features

Our Service may contain hyperlinks to websites or plugins of social media platforms that are not operated by us. These hyperlinks and plugins are provided for your reference and convenience only. This Privacy Policy only applies to the personal information that we collect or which we receive as detailed in this Privacy Policy, and we cannot be responsible for personal information about you that is collected and stored by third parties.

Third-party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third-party websites or their terms and conditions or policies.

9. Children’s privacy

Our Service is not directed at children or minors under the age of 18 and we do not knowingly collect any personal information from them. While we have taken measures to limit undesirable training data and outputs, Genesys AI could produce output that is not appropriate for all ages. If you are a child under the age of 18, please do not attempt to register for or otherwise use our Service.

If we learn that we have inadvertently obtained personal information about a child under the age of 18 via our Service, or from any other source, then we will delete that information as soon as possible. Please contact us at privacy@thegenesys.ai if you are aware that we may have inadvertently collected personal information from a child under the age of 18.

10. Additional information for individuals located in Europe

If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland (collectively, “Europe”) the following disclosures apply:

Data controller

THEHOLD Inc. Corp. is the controller of your personal information as described in this Privacy Policy, unless otherwise specified.

Legal basis

When we process your personal information, we will only do so in the following situations:

Contract: Where we need it to perform a contract with you, including where necessary to provide you our Service under our consumer Terms of Service.

Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override our interests. Our legitimate interests include:

Protecting our Service from abuse, fraud, or other misuses;
Maintaining and improving our Service, including to train and improve the models that power our Service;
Research and development, including developing new products and features;
Ensuring the safety and security of our Service;
Detecting, preventing, and enforcing violations of our terms including misuse of services, fraud, abuse, and other trust and safety protocols;
Processing job applications and managing, improving, and safeguarding our recruiting and hiring processes;
Protecting our rights and the rights of others.
Consent: Where you have given us your consent. When we process personal information based on your consent, it will be expressly indicated to you at the point and time of collection. You have the right to withdraw your consent at any time.

Legal obligation: From time to time, we may also need to process personal information to comply with a legal obligation, if it is necessary to protect the vital interests of you or others, or if it is necessary for a task carried out in the public interest.

International transfers

By using our Service, you understand and acknowledge that your personal information will be used, stored and/or accessed by us in the United States and disclosed to our service providers in other jurisdictions. We maintain primary data centers in the United States. We take steps designed to ensure that the personal information we collect under this Privacy Policy is processed as described in this Policy and according to applicable law.

When we provide any personal information about you to any non-UK and non-EEA third party, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy. These measures may include ensuring that there is an adequacy decision by the relevant authority, or having in place standard contractual clauses approved by the UK Government or European Commission. Further details are available upon request by contacting privacy@thegenesys.ai.

Your rights

You may access, correct, update or request deletion of your personal information, subject to certain exceptions.

Please note that we cannot guarantee the factual accuracy of Output from our models. If Output contains factually inaccurate personal information relating to you, you can submit a correction request to privacy@thegenesys.ai, though due to the technical complexity of our models it may not always be possible for us to fulfil such requests.

You can object to processing of your personal information when our processing is based on our legitimate interests, ask us to restrict processing of your personal information, or request portability of your personal information in a readable and standardised format.

You may opt out of our use of your information to train our models by contacting us at privacy@thegenesys.ai.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a supervisory authority about our collection and use of your personal information. Contact details for supervisory authorities in the EEA and the UK are available from your local supervisory authority. Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.

If you have a Genesys AI account, some of these rights may be exercised through your account. You can also exercise your rights by contacting us at privacy@thegenesys.ai. We will consider all such requests and provide our response in accordance with applicable data protection laws. Please note that your personal information may be exempt from such requests in certain circumstances. If an exception applies, we will inform you when responding to your request. We may request information necessary to confirm your identity before responding.

11. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. If we make any changes, we will post an amended version and change the “Last Updated” date above. Where appropriate, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided. Please review this Privacy Policy periodically.

If you use the Service after any changes to the Privacy Policy have been posted, that means you agree to all the changes.

12. How to contact us

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact us at:

Email: privacy@thegenesys.ai
By mail:Attn: Privacy TeamTHEHOLD Inc.6 Saint Johns LaneNew York, NY 10013United States

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