Legal

Genero includes Genero Media Pty Ltd and its subsidiaries, Genero Media UK Limited, Genero Media SG Pte Ltd, Genero Media US Inc and Genero Brasil Plataforma De Midia - Sociedade LTDA.

We at Genero are committed to protecting and respecting your privacy. This privacy policy explains how, why and when we process your personal data, as well as information about your rights in relation to the personal data that we hold about you.

The way you choose to interact with Genero will change the types of personal data we may collect about you.

The personal data that we may collect from you includes:

• Your full name
• Your personal email and/or business email
• The identity of your employer / business
• The website address of your employer / business
• Your telephone number
• Your country, state, city and postal/zip code
• Your photograph for your Genero profile and release forms if applicable
• Your address and signature (in relevant agreements)
• Your browsing data across our websites
• IP address and IP geolocation

We collect information in the below ways:

• When you register with the Genero Platform, we ask you to provide your name, a business or personal email address and a country of origin.
• If you wish to be a ranked Creator, we also collect your city and state/province.
• If you are a performer who has been retained by a Genero Creator and are required to complete a Digital Release Form for your participation in a client video, we may also collect your address and signature in digital or hard-copy format.
• If you are the parent or guardian of a performer who is under the age of 18, we may also collect your address and signature in a digital or hard-copy format, as you will be required to execute the Digital Release Form on behalf of any minor in your care.
• If you subscribe to any of our marketing communications or service updates.
• If you browse our websites we may collect information about the pages you view, the device you use and other information regarding your interactions with our website. For more information about how we use cookies on our website and your options in relation to them, please see our Cookie Policy.

We use the personal data we collect for the following purposes:

• To provide our services to both Creators and Clients;
• To maintain and improve our services;
• To measure performance;
• To communicate with you.

You have the right to access any personal information that Genero processes about you and to request information about:

• What personal data we hold about you;
• The categories of personal data concerned;
• The purposes for which it is processed;
• The recipients to whom the personal data has/will be disclosed;
• How long we intend to store your personal data for;
• If we did not collect the data directly from you, information about the source; and
• If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

You also have the right to request erasure of your personal data or to restrict processing (where applicable, for example if we have collected your data because you were commissioned on a brief or you completed a talent release form, our own contractual requirements to retain that data may extend beyond the date of completion of that brief) in accordance with the data protection laws as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use. Genero reserves the right to determine the method of data portability in order to ensure that if you request it, we will be able to get your data to you in a manner which is mutually convenient for all parties.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

We may need to share or disclose your personal data for the purposes specified in this notice or where there is a legal requirement. All processors acting on our behalf only process your data in accordance with instructions from us and are contractually bound to comply fully with data protection laws and to maintain appropriate confidentiality and security measures. Genero may use the following processors to host your data or provide other infrastructure that helps with the delivery of our services.

Genero takes reasonable measures and precautions to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place including encryption by way of Secure Socket Layer (SSL) protection.

Transfers Outside the EU

Genero utilises some products or services (or parts of them) that may be hosted/stored outside the European Economic Area ("EEA").

Therefore, when you use the Genero Platform or otherwise visit the Genero website, any personal data you submit may be stored on servers which are hosted in the United States and routed through or accessed by our other offices (including Australia, Singapore, United Kingdom, United States, Netherlands and Brazil) or our third party service providers as noted above in the ‘Sharing and Disclosing Your Personal Information’ section. Where this is the case, we will take steps to ensure that those providers use appropriate protections for your information and are contractually bound to comply with the relevant data protection laws.

Genero may also transfer personal data outside of the EU for the below purposes:

• For the facilitation of contracts between Genero, Creators and Clients for the production of media / advertising materials, including but not limited to videos and images. The data may be transferred to any of our offices (including Australia, Singapore, United Kingdom, United States, Netherlands and Brazil) and to our server hosts in the United States.

Where we transfer personal information for the above reasons, we ensure that only authorised staff have access to data and we utilise SSL encryption for the display of any data.

Legitimate Interests

We occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.

We use the legitimate interests’ legal basis for processing your name, email address and country of origin (city and state/province locations are collected for ranked Creators as well) and have identified that our interests are contractual, because we need to properly identify all parties involved in order to facilitate the production of media / advertising materials, including but not limited to videos and images.

You are not obligated to provide your personal information to Genero, however, as this information is required for us to provide you with our services, we will not be able to offer any of our services without some or all of this information (as required).

Genero retains personal information for only as long as is necessary for the purposes set out in this notice. We have a retention policy in place to help us to meet these obligations.

We partner with third-parties (defined in the processors table above) to capture how you use and interact with our website, including through behavioural metrics, heatmaps, and session replay, etc., to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, advertising, etc.

Genero may contact you with information concerning new briefs on the platform, new services that we may provide and other information and offers related to Genero that we believe may be of interest to you. Our processing of your information for this purpose is based on our legitimate interest, or on your consent, or as otherwise permitted according to applicable laws. You may opt out of receiving these communications at any time by using any of the following opt-out/unsubscribe options:

• visit the Settings on your account to change your preferences;
• follow the ‘unsubscribe’ link included in all such communications; or
• contact our Data Protection Team directly at DPT@genero.com.

Please note however that Creators and Clients with accounts on the Genero Platform cannot opt out of transactional or service-related communications (e.g., account verification, invoicing and billing confirmations and reminders, changes/updates to features of the Platform, technical and security notices, etc.).

If you have any questions regarding how Genero handles your personal data or you would like to raise a complaint, you may contact our Data Protection Team at any time using the following details.

Genero Media Pty Ltd

Data Protection Team

PO Box 59, Elwood, Victoria, 3184, Australia

DPT@genero.com

You also have the right to lodge a complaint with the relevant supervisory authority.

Office of the Australian Information Commissioner - https://www.oaic.gov.au/

Information Commissioner’s Office, UK https://ico.org.uk/

Personal Data Protection Commission, Singapore https://www.pdpc.gov.sg/

Autoridade Nacionalde Proteçãode Dados, Brasil https://www.gov.br/anpd/pt-br

Federal Trade Commission, USA https://www.ftc.gov/

Autoriteit Persoonsgegevens, Netherlands https://autoriteitpersoonsgegevens.nl/