Thank you for using Genwords’s websites and services that link to this Privacy Policy, including genwords.com (the “Sites”). GCloud LLC (“Genwords,” “we,” “us,” and/or “our”) operates these Sites to provide our users (“you” and “your”) with tools and information about Genwords and our services.
Genwords sources and matches the world’s top freelancers (“Freelancers”) in a variety of fields with clients who need the Freelancer’s skills and expertise (“Clients”). Genwords also operates tools across our Sites that support Freelancers and Clients. Our tools, sourcing and matching service, and other offerings, such as matching Clients with groups of Talent or providing outcomes-based deliverables, are referred as the “Services” for this policy.
Genwords screens Freelancers with skills in areas such as marketing, sales, design and product to curate a proprietary network of highly skilled Freelancers (the “Network”). We call Freelancers in the Network “Talent”.
Genwords values your privacy rights, and we take our responsibilities and obligations about your privacy rights seriously. We want you to know that Genwords is not in the business of selling your information. This privacy policy (“Privacy Policy”) explains our data practices in depth, so that you know how and why we collect and use your information in compliance with applicable data regulations.
This Privacy Policy explains how we collect, retain, and use information, including personal data (“Personal Data”), about Freelancers, Talents, Clients, potential Clients, Site visitors, vendors, blog readers, and job applicants, and others in accordance with applicable data protection laws and regulations as described below.
The information we receive and how we use it varies based on our relationship with you. The sections below explain our data practices based on our different relationships with users. Use these links to quickly navigate to the section relevant to you:
We collect information from applicants and during our screening process we need to evaluate your qualifications such as your language skills, personality, domain-specific knowledge, competence, professionalism, and technical skills. If we admit you as a Talent, we may also collect this information throughout your time in the Network. We may ask you to provide information about yourself, which could include your:
During the screening process or your time as a Talent, we may also record your audio and video calls with us or with Clients to help document your skills or to be used for our quality assurance or training purposes. Genwords provides Talent and our internal team members the use of a genwords.com email address. Genwords stores and processes information sent to and from all genwords.com email addresses.
Based on your potential role as a Talent, we may request a background check that will collect additional data about you through a third-party service provider. If applicable to you, your express written consent to the collection of such additional data by the third-party service provider will be solicited at such time, pursuant to applicable laws.
If we select you to be a Talent, we may use some of your Personal Data to enable you to create a profile for us to display within the Services, which may be viewed by Clients seeking Talent. We may also display some of your information on public sections of genwords.com, marketing materials, and presentations to showcase your skill sets or to demonstrate the value in the Network.
If you become a Talent, Clients you engage with may provide us information about your performance.
We may collect information, such as your name, contact information, address, work experience, and education from publicly available sources, third-party data providers, or services. This includes sources such as professional job boards or social media websites, like LinkedIn. We use this information to supplement the information that you provide us or to assess if you may be a good fit for the Network.
When you interact with Genwords through the Site or services, we may automatically collect certain information. Please read the “Site Visitors” section below for more information.
We use your Personal Data to process your request to become a Talent and administer our contracts with you and your engagements if you become a member of the Network.
We also may use your Personal Data for certain business interests deemed legitimate under applicable law, including:
We may also ask for your consent to use your Personal Data for a purpose that is not listed on this Privacy Policy, and we will use your Personal Data for that purpose to the extent that you freely provide your informed consent.
We may monitor, record, and transcribe audio or video calls with you during the application process or your time as a Talent. Consenting is voluntary, and you may withdraw your consent at any time. These recordings allow Genwords team members to review applications to the Network, to better review your suitability for a Client engagement, or for internal quality assurance and training purposes. Additionally, we may provide your interviews with Clients for specific engagements to Client stakeholders to review the call.
We may collect your voice, image, in-meeting messages, and any other Personal Data you choose to share during such calls. In addition, other participants in a video conference may be able to view your display name, email address and profile picture. Any third-party software we use for these audio or video calls may also collect and use your Personal Data. Please review the terms of any third-party site for their specific privacy practices.
For individuals in the EU and the UK, please see the EU and UK Individuals section below for information on our legitimate interests and your rights. For individuals that reside in California, please see the California section below for information on your rights.
We collect Personal Data from Clients and Prospective Clients (collectively “Clients”) when a Client visits our Sites and begins to use our Services as well as through requests from a Client to engage our Talent. This information may include, among other kinds of data:
Genwords provides Talent and our internal team members the use of a genwords.com email address. Genwords stores and processes information sent to and from all genwords.com email addresses.
We may collect additional information about you and your company from publicly available or from third-party databases or services that provide information about business contacts and companies (including individuals’ names, job titles, business contact information, and company information).
When you interact with Genwords through the Site or Services, we automatically collect certain information. Please read the “Site Visitors” section below for more information.
Genwords uses the Personal Data you provide consistent with this Privacy Policy. If you provide Personal Data for a certain reason, if we use the Personal Data, we will do so in connection with the reason for which you provided it. If you provide Personal Data in order to obtain access to the Services, we will use your Personal Data through our performance of our contract with you to provide you with access to such Services, maintain your account, contact you regarding your use of the Services and/or the Sites or to notify you of important changes to the Services and/or the Sites, and to monitor your use of such Services.
We may use your contact details to tell you about Services, upcoming events, and other promotions that we believe you will be interested in. If we do so, each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications. You cannot opt out of some administrative communications that are reasonably necessary to the Services, such as billing or Service notifications, as those are not considered marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish for us to delete your contact information from our mailing lists, please contact us at info@genwords.com or at our mailing address in the Contacting Genwords section below.
Where required by applicable law, we will only send you marketing information by email if you consented to our use of your Personal Data for such communications.
We may use your Personal Data for the certain business interests deemed legitimate under applicable law, including:
We may also ask for your consent to use your Personal Data for a purpose that is not listed on this Privacy Policy, and we will use your Personal Data for that purpose to the extent that you freely provide your informed consent.
We may monitor, record, and transcribe audio or video calls with you during your time as a Client. Consenting is voluntary, and you may withdraw it at any time. These actions allow multiple Genwords team members to review your requirements for sourcing or matching Talent, specifics about a particular engagement, or for internal quality assurance and training purposes. Additionally, your interviews with Talent for specific engagements may be recorded for internal purposes and, upon request, provided to you to review the call.
For individuals in the EU and the UK, please see the “EU and UK Individuals” section below for information on our legitimate interests and your rights. For individuals that reside in California, please see the California section below for information on your rights.
We may request a credit check through a third-party service prior to providing a Client our Service, which will collect additional data about the Client.
When you apply for a position with Genwords, you will provide Personal Data in your application, resume, cover letter, or in other formats. While you may decide what information to include, for instance most applications include your:
If we invite you to undertake further assessments in connection with your application and you participate in such assessments, we will collect the additional Personal Data that you provide to us as part of that process. If you do not provide us with certain information when requested, it may impact our ability to assess your suitability for a role with us or we may not be able to offer you a position with Genwords. With your prior consent, we may record your audio or video interview(s) to better evaluate your candidacy and for training purposes. Your consent is voluntary, and you may withdraw your consent at any time, including during the interview. If you withdraw your consent or do not consent, it will not impact your candidacy.
Throughout the recruitment process, we may create Personal Data in connection with the assessment of your application, such as through your interviewer’s evaluation of your suitability for the role(s) that you applied for.
If your application is successful, we may collect further Personal Data about you in connection with conducting reference and background checks where required and permitted by applicable law, including, if applicable to you, special categories of Personal Data, which we will solicit your consent to collect at the time. We may also collect copies of relevant identification documents from you, such as your passport or driving license, proof of address, a copy of your work permit, a photograph, and a copy of your signature through your executed acceptance.
Please see the “Region Specific Information” section below for information on your rights in relation to the Personal Data we hold about you.
When you interact with Genwords through our Site in relation to your application, we automatically collect certain information. Please read the “Site Visitors” section below for more information.
We have a legitimate interest in:
If you are engaged to work for Genwords, your Personal Data will be used as part of your team member record under our team member privacy policies and may be shared with third-party service providers assisting us in completing our obligations to you, such as payroll providers.
When you interact with Genwords through the Site or the Services, we and service providers acting on our behalf will automatically collect information about you through cookies and other technologies. Please review the genwords.com Cookie Policy or relevant cookie policy for one of our other websites to learn more about how we use cookies and other technologies on the specific Site you are using.
As a Site Visitor, our servers record information (“log data”), including information that your browser automatically sends whenever you visit the Site. This log data includes your Internet Protocol (“IP”) address from which we understand the country you are connecting from at the time you visit the Site, browser type and settings, and the date and time of your request.
We use this automatically collected data for our legitimate interests in maintaining the safe operation of our Site, maintaining our legal obligations and our legitimate interest in learning how Site visitors interact with our Site to improve your use of the Site.
Genwords offers and maintains a variety of software for Freelancers and Clients to use, including:
When you use Genwords software, we collect account level data, including your name, email, and password, to facilitate your access, storage of historical data, and operation of software. If you create an account by using credentials from a third-party service or sign-in services such as your Google account, these services will authenticate your identity and provide you with the option to share certain Personal Data, such as name and email address(es), with us. Use of account level data is necessary to perform a contract with us in relation to your use of the software or it is in our legitimate interest to respond to your requests and ensure we provide our Services in the best way that we can.
When you use Genwords software, we may collect usage statistics for analytics and to support and troubleshoot the software to provide a better user experience. We have a legitimate interest in conducting usage statistics to ensure our software is working as intended and to make improvements to our Services. We use service providers to assist in authentication of users and cloud hosting the storage and retrieval of screenshots.
Genwords’s software includes online components and cookies that are required for full functionality. For more information about the Sites cookie usage please see each software’s cookie policy.
We may collect Personal Data from you when you attend one of our events, for instance at business conferences and trade shows. The data we collect includes information that you voluntarily give to us directly or through granting access to your Personal Data through the event, such as contact details on a business card. We will use this information to develop a potential business relationship with you including marketing our Services to you consistent with the purpose for which you gave the information.
Where required by applicable law, we will ask your consent before or when sending you marketing information by email. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us at info@genwords.com or by mail at the address in the Contacting Genwords section below.
Genwords is not in the business of selling your information. We consider information about you and our interactions to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties, as explained below:
As we develop our business, we might acquire businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Genwords, like many businesses, hires third parties to perform certain business-related functions. These third parties include website analytics companies, providers of digital advertising services, our hosting and cloud computing service providers, providers of customer relationship management software, marketing and sales software solutions, providers of billing and processing payments functions and providers of background check services. When we engage another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Pursuant to our instructions, these parties may access, process, or store Personal Data in the course of performing their duties to us and solely in order to perform the services we hired them to provide.
If you enter financial information into one of the Sites to process a payment, Stripe, our payment processor, will receive the information you enter and process the payment in accordance with Stripe’s Privacy Policy.
Genwords may disclose your Personal Data if required to do so by law, for example, as part of our compliance with sanctions about specific regions and specifically designated individuals, or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Genwords, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.
Our policy is to keep your Personal Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. If you elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
You may be able to exercise certain rights and access certain information depending on your location. Please review the following sections for more details. You can reach out to info@genwords.com with questions about your information.
This section applies solely to individuals in the United Kingdom and European Union, provided however that reference to the EU also includes certain non-EU countries including, where applicable, Switzerland and the European Economic Area countries of Iceland, Liechtenstein, and Norway. Our Privacy Policy describes why and how Genwords collects, uses, and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing (please see “Your Rights” section below).
Genwords is the data controller for processing your Personal Data. The data controller is responsible for deciding how Personal Data about you is used. Please contact us with any questions at info@genwords.com or at the address provided in the Contacting Genwords section below, which also provides the contact details of our representative in the EU and the UK for purposes of the General Data Protection Regulation and the United Kingdom’s Data Protection Act 2018.
Subject to applicable EU and UK law and where possible, you have the following rights in relation to your Personal Data:
You may exercise your rights by contacting us as indicated under the “Contacting Genwords” section below.
“Legitimate interests” means our interests in conducting and managing our organization and delivering the best Services to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you outweighs our interests unless we have your consent or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see the “Your Rights” section above.
Genwords is based in the United States. When you apply as a Freelancer, use our Services as a Client, or otherwise use our Sites, your Personal Data will be transmitted to servers in the United States as necessary to provide you with the Services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy, and your Personal Data may be transmitted to our service providers supporting our business operations (described above). The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. Where we transfer your Personal Data across the border of the European Economic Area or United Kingdom, we will take steps to ensure that your Personal Data receives an adequate level of protection where it is processed and your rights continue to be protected.
Our Privacy Policy describes above why and how Genwords collects, uses, and stores your Personal Data, the lawful basis on which your Personal Data is processed, and what your rights and our obligations are in relation to such processing.
If you are a California resident, you, or a person verifiably authorized to act on your behalf, have certain rights under the California Consumer Privacy Act and its successor legislation, the California Privacy Rights Act, collectively the “CCPA.” For the purpose of this section, certain words, including “sale,” “share,” “business purpose,” and “personal information” have the meanings defined in the CCPA. For the purpose of this Privacy Policy, we use “Personal Data” to cover “personal information” as defined in the CCPA.
We update our Privacy Policy based on our current practices. As required by the CCPA, the information in this section is relevant for the last twelve-month time period. During that time, we collected the categories of Personal Data listed in the relevant section above (i.e., Freelancers, Clients, Job Applicants, or Site Visitors) from the sources listed in those sections (i.e., from you, third parties, or automatically). During the last twelve-month period, we have not sold Personal Data.
During the last twelve-month period, we disclosed for business purposes the following categories of Personal Data:
For information about who we may share or disclose your Personal Data to, please review the relevant information in the above Freelancers, Clients, Job Applicants, or Site Visitors sections.
Your rights under the CCPA include the following, which you may execute by contacting us at privacy@genwords.com where possible and allowed by law:
If you would like to exercise your rights or have questions about your rights or information, please contact us at info@genwords.com or at the post addresses included in the Contacting Genwords section below.
You can use the Sites without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.
This Privacy Policy does not apply to any Personal Data collected by Genwords other than Personal Data collected through the Sites, Services, events, third parties or as otherwise stated in this Privacy Policy. This Privacy Policy shall not apply to any unsolicited information you provide to Genwords through this Site or through any other means (without prejudice to your rights under the applicable law). This includes, but is not limited to, information posted to any public areas of the Sites, such as forums (collectively, “Public Areas”), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Genwords shall be free to reproduce, use, disclose, distribute, and exploit such Unsolicited Information without limitation or attribution.
Genwords does not knowingly collect Personal Data from children under the age of 16. If you are under the age of 16, please do not submit any Personal Data through the Sites. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on these Sites without their permission. If you have reason to believe that a child under the age of 16 provided Personal Data to Genwords through this Sites, please contact us, and we will endeavor to delete that information from our databases.
The Sites may contain links to other websites not operated or controlled by Genwords (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or review the Third-Party Sites. We suggest contacting those sites directly for information on their privacy practices and policies.
Genwords takes reasonable and appropriate steps to protect the Personal Data provided via the Sites or the services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.
Your access to and use of genwords.com is subject to our Website Terms & Conditions. Your access to and use of other Sites may be subject to different terms and conditions. Please review those Sites for more information.
The Sites and our business may change from time to time. As a result, at times it may be necessary for Genwords to make changes to this Privacy Policy. Genwords reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice, unless otherwise required by the applicable law. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Site after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy, without prejudice to your rights under the applicable law.
Please contact us if you have any questions about Genwords’s Privacy Policy, the information practices of the Sites, or if you have questions about your rights.
We have a team responsible for overseeing questions regarding this Privacy Policy. You may contact the Genwords Privacy Team as follows: by email at info@genwords.com, or by mail at:
GCloud LLC
16192 Coastal Highway
Lewes, Delaware 19958
USA
