GINIIS Privacy Policy

Scope and Consent

You accept this Privacy Policy when you sign up for, access, or use our products, services, content, features, technologies or functions offered on our website and mobile application (collectively “GINIIS Services”). This Privacy Policy applies US law and is intended to govern the use of GINIIS Services by our users unless otherwise agreed through service contract. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective as of the published effective date. We will notify allour registered users whenever this policy will change.By continuing to access or use the services provided by GINIIS after those changes become effective, you agreeto be bound by the revised Privacy Policy.

Information we collect automatically: When you use GINIIS Services, we collect information sent to us by your computer, mobile phone or other access device. The information sent to us includes, but is not limited to, the following: data about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and fromthe sites, referral URL, ad data, and standard web log data and other information. We also collect anonymous information through our use of cookies and web beacons.

GINIIS software application will store information about schools and students andwill not share personal identified information (“PII”) with any thirdparty.GINIIS does not and will not store the passwords to any accounts. GINIIS can,however,use information to run statistical data, without sharing or disclosing PIIand publish, sell, and share such statistical data to or with a third party. GINIIS reserves the right to run ads on its website and in the application and send unsolicited messages to the users as available. This privacy policy is subject to changes and updates. Any change or update made will be disclosed.

GINIIS secures all data shared on our servers and has security measures to protect such data against loss, misuse, unauthorized access, unauthorized disclosure, manipulation, or destruction. We reserve the right to use data, with or without PII, for internal training.

In addition, if you use GINIIS Financial Management services, we may collect the following types of information:Contact information, such as your name, address, phone, email and other similar information, financial information, such as the full bank account numbers and/or credit or debit card numbers that you link to your GINIIS account or give us when you use GINIIS Services, detailed personal information such as your date of birth or national ID number.

Authentication and Fraud Detection: Tohelp protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with GINIIS Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

Using Your Mobile Device: We may offer you the ability to connect with GINIIS Services using a mobile device, either through a mobile application or via a mobile optimized website. The provisions of this Privacy Policy apply to all such mobile access and use of mobile devices.When you download or use our mobile application, or access one of our mobile optimized sites, we may receive information about your location and your mobile device, including a unique identifier for your device. We mayuse this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting's menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacture of your device.

We donot collect or save conversations used in “GINIIS Chat”. We reserve the right to block or not process any conversation deemed suspicious. Retention time for the conversation or messages is limited to 24 hours, after which the messages are erased automatically, with no recovery option.

GINIIS records log data and cookie information for interacting with our services including but not limited to when you visit our website, sign into our services, or use our mobile application. We use log data for analysis, to provide technical support for troubleshooting, statistics, quality assurance, to monitor system security. When you use GINIIS, cookies can be stored on your device. Cookies are little pieces of information that can help identify your browser and that can store informationsuch asapplication settings. GINIIS uses cookies to track usage, to improve ease-of-use and the overall user experience, and to manage advertising inventories.

We may use your PII to:

We may contact you via electronic means or postal mail to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through or questionnaires, or asotherwise necessary to service your account. Additionally, we may contact you to offer promotions and inform you about GINIIS Services. Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with youor your school. To reach you as efficiently as possible, we may contact you via phone, and may use autodialed or prerecorded calls and text messages as described in our User Agreement/Contract. Where applicable and permitted by law, you may decline to receive certain communications.

Marketing: We do not sell or rent your PIIto third parties for their marketing purposes without your explicit consent. We may combine your personal information with information we collect from other companies and use it to improve and personalize GINIIS Services, content, and advertising. If you do not wish to receive marketing communications from us or participate in our ad-customization programs, simply indicate your preference by logging into your account and going to the Notifications sectionand updating your preferences, or by following the directions that may be provided within the communication or advertisement.We respect your communication preferences. If you no longer wish to receive notifications via our application, you can adjust your preferences by visiting the settings page of the application.

Most Internet browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting acookie from the websites you visit. However, some Services may not function properly if you disable cookies.

GINIIS can delete user-accounts if they remain inactive during a school year and notify school authorities. GINIIS implements several mechanisms to prevent unauthorized access to accounts, or other data.

To access GINIIS, you use the one-time verification codewhich GINIIS provides to prevent unauthorized access. User-accounts are protected by passwords. You should choose a secure password and ensure its confidentiality to prevent unauthorized access to your account. GINIIS does not store any passwords as it logs you in via Google’s OAuth2 authentication mechanism

Like any other personal information, GINIIS will not share participants’ e-mail addresses or phone numbers with third parties. GINIIS will not send any e-mail communication to participants’ e-mail addresses or phone numbers without your consent.

Calendar Integration: You must connect GINIIS with your calendar to make the scheduling process work.In either case, the connection between GINIIS and your calendar can be deleted at any time.GINIIS respects your personal information. We will not share your personal meetings or who you meet with other users or thirdparties.If you connected GINIIS with your Calendar, we may share your Free\Busy availability over requested periods. This information sharing is for your benefit, allowing your GINIIS contacts to invite you at times you are comfortablewith. Unlike calendar sharing in other systems, other users will not be exposed to your full calendar.

Communications between you and GINIIS: If you send GINIIS a message, this message can be stored to process it, to compile statistical information, to improve our services and support or to get in touch with you.The GINIIS databases are located on Amazon Web Services (AWS) as per their policy (https://aws.amazon.com/privacy/) and for chat “Moziki”are located on Google’s Compute Engineservers and are secured as per their policy (https://developers.google.com/cloud/terms/).Google is enrolled in the U.S. Department of Commerce Safe Harbor Program and will remain enrolled in this program or another replacement program (or will adopt a compliance solution which achieves compliance with the terms of Article 25 of Directive 95/46/EC) throughout the Term.

Please note that by becoming a user, you have given us your express and informed consent to transfer the data that you provide to us for storage, to our servers at Google.GINIIS LMS is

Sharing personal information: GINIISuses personal information according to the Terms of Service and this Privacy Policy. GINIIS may share personal information with other companies or individuals only in the following limited circumstances: (i) GINIIS has your explicit consent to do so; (ii) GINIIS acts in good faith under a legal obligation to share the data; (iii) GINIIS needs to access or share the data to protect the security of the service or of other users’ data; (iv) GINIIS needs to access or share the data to protect GINIIS’s rights and property or to enforce the Terms of Service.

To help secure your personal information, access to your data on GINIIS is password-protected. To protect any data,you store on the servers used by GINIIS, GINIIS also regularly audits its system for possible vulnerabilities and attacks. However, since the online network is not a 100% secured environment, we cannot ensure or warrant the security of any information you transmit to GINIIS. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. We strongly advise you not to communicate any confidential information through any electronic means

If you have any questions, comments or concerns regarding this Privacy Policy, please contact GINIIS. In your inquiry please include the following information: identification details, the name of the company (if relevant), your contact information, your concerns indetails.