Privacy statement

This Privacy Statement (hereinafter, the Policy) governs the processing of personal data of users of Geomotiv products and services.

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We attach great importance to the protection of your personal data, so take a moment to find out more about our Privacy Policy and contact us if you have any questions.

Scope

This Policy shall govern any interaction between Geomotiv and users related to personal data when you:

• use our websites –  geomotiv.com, theemployerofrecord.com, talenavita.com and georlearn.com.
• use applications deployed by us.
• reach us via any of our services or interact with us in any other form.

This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the services. Thus, if you integrate any third-party applications with our services, we will not be able to control how such applications process your personal data.

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Please be aware that this Policy also does not apply to the application we are developing and deploying on behalf of other companies as an IT service provider. In this case the processing of your personal data will be governed by privacy statements of our clients acting as data controllers. 

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Please do not use the Services if you do not agree with the provisions and scope hereof.

Who determines the purposes and means of personal data collection?

The purposes and means of how your personal data is collected in these services are determined by the following legal entity:

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Geomotiv Holdings LLC

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700 N. Fairfax suite 614, Alexandria VA, 22314 USA

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email: privacy@geomotiv.com

Personal Data We Collect

Personal data is any information that could enable direct or indirect identification of a person (e.g., their name, passport details, online identifier, etc.).

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In accordance herewith, personal data may be collected both directly and indirectly.

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(1) Personal data are collected directly when you provide them voluntarily (e.g. when registering in the Services). 

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(2) Indirect collection of personal data may occur automatically when accessing the Services. For example such a personal data collecting will occur when we receive your personal data from third parties (e.g. our analytics partners) or via cookies. 

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The personal information we collect varies based on your interactions with our apps, website, and services. The categories of data we may gather include:

• Contact Information – for example, your name, email address, phone number, and mailing address.
• Account Information – login credentials, account settings, and other details required to manage your user account.
• Payment Information – bank account information in order to pay for products and/or services within our services.
• Service Usage Data – your interactions with our apps and website, including navigation patterns, feature usage, and session activity.
• Customer Support Data – details shared when you reach out for support, such as your messages and any relevant information needed to address your inquiries.

Data Processing, Storage and Protection

“Processing” is understood as at least one of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.

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When it comes to application processing purposes as well as respective legal bases, we process your personal data as follows.

• Delivering our services – to provide, operate, and maintain our apps and services, including processing transactions, managing user accounts, and delivering updates or notifications.

We are relying on the performance of a contract with you to process your personal data in such a manner (e.g., our Terms of Service). We store your personal data processed for this purpose as long as you have any active services with us. In the case of transaction and payment data it will be stored up to 10 calendar years depending on the applicable jurisdiction. 

• Customer support – to answer your customer support-related requests and enquiries as well as to resolve technical issues.

We are relying on our legitimate interest to provide you necessary customer support to process your personal data in such a manner (e.g., our Terms of Service). We store your personal data processed for this purpose for 3 calendar years after the moment of our latest interactions. 

• Keeping you informed – to send you our newsletters as well as blog updates if you are subscribed to it.

We are relying on our consent to process your personal data in such a manner. You can withdraw this consent at any time. We store your personal data processed for this purpose until you withdraw your consent.

• Marketing and advertising – to send communications and to display advertisements in our services. Additionally, we may use your information to personalize our services.

We are relying on our consent to process your personal data in such a manner. You can withdraw this consent at any time. We store your personal data processed for this purpose until you withdraw your consent. For more detailed retention periods regarding installed cookies we kindly refer you to our Cookie Policy.

• Compliance with laws – to comply with applicable legal, regulatory, or contractual obligations, including responding to lawful requests and enforcing our Terms of Service.

We are relying on our legal obligations to process your personal data in such a manner. We store your personal data processed for this purpose as long as we are obliged by applicable laws.

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Subject to data anonymisation, your personal data may be used by Geomotiv for any other purposes. This allows us to both strictly respect the data protection rights of our users, and not to lose the value of the user experience that they have shared within the Services.

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We do not not use any other automated decision-making tools in personal data processing. Automated decision-making tools primarily include those systems that process your personal data without human intervention to make decisions that may have potential legal consequences for you.

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Your personal data will be stored on the servers of our counterparties that we are using for operating our Services. 

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Employees of Geomotiv shall also take all necessary organisational, legal and technical measures available to us for protection of your personal data. Users of the Services shall also be responsible to the maximum possible extent for the provision of accurate account details, keeping passwords and any other information required for authorisation confidential and its protection from unauthorised access by third parties. 

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Any personal data collected and processed hereunder shall be properly protected unless:

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(1) you consent to their disclosure;

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(2) such personal data are anonymised;

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(3) such personal data are subject to disclosure under the applicable law.

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We will do our best to keep your personal data protected. However, despite any possible measures taken on our part, we cannot guarantee full protection of the Services against information security risks.

Transfer and Disclosure

A number of third parties may have access to your personal data - processors, services of which we use in order to constantly improve our Services, as well as provide you with the opportunity to use all its functionality.

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For the list of our current processors we kindly refer you to our List of Processors.

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To ensure the provision of our services, your personal data may also be transferred to a legal entity created after reorganisation of Geomotiv should it be necessary.

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Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of Geomotiv and third parties or for other substantial public interest purposes.

Children's Personal Data

To the extent to which it is not prohibited by the applicable law, we do not authorise the use of our Services by individuals who have not reached the age of full legal capacity in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.

Sale of Personal Data

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), “sell” and “sale” refer to the transfer, disclosure, or making available of a consumer’s personal information to a third party for valuable consideration. This does not necessarily involve a direct monetary exchange but may include other forms of benefit.

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We do not sell personal information in the traditional sense. However, we may allow Service Providers to process personal information for business purposes such as advertising, marketing, and analytics, which may be considered a “sale” under CCPA/CPRA.

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In the past twelve (12) months, we may have sold the following categories of personal information:

• Identifiers.
• Personal information categories listed under the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
• Commercial information.
• Internet or other similar network activity.

The categories listed above align with CCPA/CPRA definitions. This does not mean that all types of personal information within these categories were sold, but rather that some data within these categories may have been shared in exchange for value.

User Rights

The rights of users related to the collection and processing of personal data shall be determined in accordance with the applicable law.

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Your rights with respect to the collection and processing of personal data may be determined in accordance with General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC).

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In accordance with GDPR you may access, change and/or make additions to, delete, restrict processing and migration of, object to or withdraw your consent to the processing of your personal data as well as and to lodge a complaint to the supervisory authority.

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If you are a California resident, your rights to the collection and processing of personal data may be determined in accordance with California Consumer Privacy Act (CCPA).

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In accordance with CCPA you may have the right to know, right to delete, right to opt-out of sales, right to non-discrimination. 

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To exercise any of your rights above and any other rights guaranteed to you by applicable law and if you have any related questions, write to: privacy@geomotiv.com. For issues related to your personal data please contact: Geomotiv.

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Geomotiv reserves the right to verify your identity before exercising any rights at your request. In case we are not able to exercise any of your rights or provide any information, we will also explain the reasons to you.

Final Provisions

This Policy may be amended and (or) modified at any time of the Services operation. In this case, a notice with information about the changes accompanied by the new version of the Policy and date of its adoption will be published in the Services. The User of the Services must read and acknowledge the new version hereof.

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The Policy is an agreement between us and the User about the use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby canceled.

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If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.

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Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.