Thank you for installing Gener8. We aim to empower you to have more control of your advertising experience. Gener8 Ads Limited respects your privacy and is committed to protecting your personal information. This notice will inform you how we look after your personal information and tell you about your privacy rights and how the law protects you.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and processes your personal information, including any information you may provide to us, when you visit our website and when you contact us.
It is important that you read this notice so that you are fully aware of how and why we are using your information.
Gener8 Ads Limited (referred to as we, us or our in this notice) is the controller and responsible for your personal information.
If you have any questions about this notice, including any requests to exercise your legal rights, please contact us:
Legal entity: Gener8 Ads Limited
Email address: [email protected]
Postal address: Gener8 Ads, 70 Wilson street, London, EC2A 2DB
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to your information
It is important that the personal information we hold about you is accurate and current. Please update your account if your personal information changes.
The information we collect about you
Personal information means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:
- Identity Information includes first name(s), maiden name, last name, username or similar identifier, year of birth, gender and income range.
- Contact Information includes email address and geographical location.
- Technical Information includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to utilise our services.
- Marketing and Communications Information includes your preferences in receiving targeted advertising (Ads), information about Ads you have seen, where you saw them and time you saw them.
Inaccurate or incomplete information
Our services are free to use and if you use them, you will generate tokens which you can chose to exchange for cash, products or make a donation to charity.
Our technology will target Ads depending on the information you provide in your account settings. There is no obligation to provide any information, but you will see more Ads that are relevant to your interests if your information is complete and accurate.
You can update your information at any time in your account settings.
How is your personal information collected?
We use different methods to collect information from and about you including through:
- Direct interactions. You may give us your Identity, Contact Information and Marketing and Communications Information by updating your account settings. You can change this information at any time. This includes personal information you provide when you:
- Automated technologies or interactions. As you interact with our service, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may obtain Technical Information from the following parties:
- analytics providers;
- search information providers.
How we use your personal information
We will only use your personal information when the law allows us to or where you have otherwise provided specific consent.
Set out below is a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Type of information
Lawful basis for processing including basis of legitimate interest
To register you as a user and so you can login to your profile.
To send you relevant information about Gener8.
(b) Contact; and
(c) Marketing and Communications.
Performance of a contract with you.
To deliver our services to you, including:
(d) Transaction; and
(e) Marketing and Communications.
(a) Performance of a contract with you; and
(b) Necessary for our legitimate interests.
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
(b) Contact; and
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud); and
(b) Necessary to comply with a legal obligation.
To use data analytics to improve our website.
Necessary for our legitimate interests (to keep our services updated and relevant and to develop our business).
To make suggestions and recommendations to you about goods and services that may be of interest to you.
(c) Technical; and
(d) Marketing and Communications.
(a) Performance of a contract with you; and
(b) Necessary for our legitimate interests (to develop our services and grow our business).
Your data is anonymised
All information you provide to us is anonymised. We give each user profile a randomly generated alpha-numeric tag which we use as an identifier. We then aggregate this anonymised data and approach our advertising partners with the anonymised statistics. It is this anonymised data which generates the Ads you see. If we use trusted partners to support us with ad sales they will only have access to anonymised data.
You can stop using our services at any time by uninstalling Gener8.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Disclosures of your personal information
We may share your personal information with the parties set out below for the purposes set out in the table above.
- Trusted partners, acting as processors, who enable us to provide you with relevant advertising experiences.
- Professional advisers acting as processors or joint controllers including solicitors, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of our processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
All of our service providers are based inside the European Economic Area (EEA), so their processing of your personal information will not involve a transfer of information outside the EEA.
If this changes and it becomes necessary or desirable to transfer your personal information out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe; or
- Where we use providers based in the US, we may transfer information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
If you delete your account profile, most of your personal information will automatically be irretrievably erased.
However, by law we have to keep certain basic information about you (including Contact, Identity, Financial and Transaction Information) for six years after you delete your account for regulatory and tax purposes.
Your legal rights
You have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following situations: (a) if you want us to establish accuracy of the information; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform our services to you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please update your account preferences.
You will not have to pay a fee to access your personal information or to exercise any of your other rights.
Time limit to respond
We respond to all legitimate requests as soon as possible and endeavour to do so within one month.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of contract means processing your information where it is necessary for the performance of our services.
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.