Effective date: November 24th, 2022

Privacy notice

iGenius (hereinafter referred to as ‘we’, ‘our’, ‘us’), as the Data Controller of the processing described hereinafter, takes privacy and personal data protection extremely seriously.
This document has therefore been produced to provide you, also to comply with Section 13 of the General Data Protection Regulation ("GDPR"), with information on the purpose and means used to process your Personal Data which are collected when browsing on our website ( - hereinafter referred to as the “Website”), using services reserved for registered users, communicating with our operators or using our live chat system (hereinafter jointly referred to as “Crystal Services”). Please note that, unless otherwise defined herein, all the capitalized words shall have the same meaning provided by Article 4 GDPR.

We may collect information about you when:

  • You request information about our services using the contact form;
  • You browse our website or use services reserved for registered users;
  • You communicate via live chat.

In particular, we need to process the personal data that you provide when registering or requesting a service. With your consent, we can also use other information you freely provide when registering or related to the methods you use to communicate with us (hereinafter jointly referred to as “Data”).

This Privacy Notice (along with our General Terms and Conditions applicable to related services, our Data Processing Agreement, and our Cookie Policy) sets out the basis on which your Data will be processed.

1. Which Personal Data will we use?

i. Browsing data

When you visit our Website may collect, in accordance with applicable laws and where required with your consent, information relating to the devices you use and the networks you are connected to when using our services. This may include the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, and information about your visit, including the URL clickstream. We collect this information using tracking technologies, including cookies (for further information, please refer to our Cookie Policy).

Including cookies (for further information please refer to our Cookie Policy). We may also use third-party tools to process analytics information on our Services.

ii. Data collected when using Crystal Services

To create an account on Crystal Services or use our product demo, you/your employer must provide your full name, email, employer, and role. When you use Crystal Services, we will process the Data needed to guarantee your full enjoyment of these services, including, for example, log-in data, pages visited, your requests, your communications, and other additional information that you may freely provide during the usage of Crystal Services. We may also process audio (which may contain your voice) if you use our speech recognition features.

An Important Note: This Privacy Policy does not apply to any personal information that our customers may process using Crystal Services as data controllers (“Customer Data”). Our customers’ respective privacy policies govern the collection and use of Customer Data. Our processing of Customer Data is governed by the contracts we have in place with our customers and not otherwise provided for by the Data Processing Agreement or this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

2. For what purposes will we use your Data, and based on which legal requirements?

We will use your Data with the use of electronic systems:

  1. To allow you to browse the Website and use the Crystal Services. Your Data will be used to provide you with the services requested and, more generally, to comply with all related contractual and administrative obligations.
  2. To meet legal obligations or comply with any orders from legal authorities.
  3. To meet our legitimate interest to anonymize, aggregate, and use Data related to your usage of the Crystal platform for the Crystal Services product enhancement.

Providing your Data is optional, but refusal to do so, in part or full, may prevent us from correctly meeting your specific requests.

With your consent, we can also use your Data for the following purposes:

  1. sending you by email newsletters information about products and services provided by us (also about products or services different from those which you purchased), offers and promotions, and for carrying out market research.
  2. studying your preferences and the methods you use to communicate with us. In particular, to gain a better understanding of your tastes and interests in our products and services, we may examine, occasionally using automated systems, the information provided when you register on the Website, your use of Crystal Services, and your interest in communications and newsletters which we send you. In any case, these profiling activities are not capable of producing legal effects in your regard or of having significant effects on you as an individual.

The provision of Crystal Services and/or the handling of information that you request will not in any way be affected by whether you give consent as set out at points cd and e) above in Section 2.

In light of the above, the so-called “lawful basis of processing,” as per Regulation EU No. 679/2016 (General Data Protection Regulation or “GDPR”), specifically for the purpose as per Point 2. a) above, the lawful basis is answering your requests also for contractual or pre-contractual purposes (Article 6.1.b of the GDPR).

3. How long will we keep your Data?

Your Data will only be processed for the period of time strictly necessary to fulfill the purposes for which they were collected about the regulations in force.

In any case, for the purposes of marketing and/or profiling (as per points c) and d) of Section 2 above), Data regarding the details of your purchases will not be processed for a period exceeding 12 months. In the same way, the information regarding your communications with us will not be retained for a period exceeding 12 months.

4. Who will we share your Data with?

So that the activities related to the Website function properly, your personal data indicated above may be accessed by employee staff, as well as by non-employee personnel appointed by us that need to process the personal data to carry out their duties (for example, digital function, administration, and customer service).

Your Data may be shared, also for administrative purposes, with our subsidiary, parent, and partner companies to deliver the Crystal Services requested, with third-party service providers involved in activities carried out by us (e.g., IT services). These parties will be Data Processors (e.g.: iGenius S.p.A.).

We or any of our assets, including the Website, may be sold, or other transactions may occur in which your personal data is one of the business assets of the transaction. In such cases, your personal data may be transferred, either as part of the transaction or during any due diligence process.

Lastly, we may share information with government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings to comply with a legal obligation when we believe in good faith that the law requires it or where this is necessary for us or for third parties to protect our or their rights, property, safety or security.

5. Where and how do we retain your personal data?

Your Data may be transferred to or accessed by entities worldwide, including iGenius-affiliated companies, to perform processing activities such as those described in this Privacy Policy concerning your use of our products and services. iGenius complies with laws on the transfer of Data between countries to help ensure your Data is protected, wherever it may be.

The iGenius entity that controls your Data may differ depending on your Company headquarters.

Data relating to individuals in the European Economic Area, the United Kingdom, and Switzerland is controlled by iGenius S.p.A. in Italy. iGenius's international transfer of Data collected in the European Economic Area, the United Kingdom, and Switzerland takes place in compliance with appropriate guarantees for the protection of your Data and, in particular, the Standard Contractual Clauses.

Your Data is mainly processed electronically and in some cases, also in paper format.

6. How can you modify your preferences or withdraw your consent?

You can check, modify, or withdraw your consent with regard to the purposes set out in letters (d) and (e) in Section 2 above at any time. You just need to modify your settings in the Cookie Management widget.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

You may stop or restrict the placement of tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. See our Cookie Policy for more information. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

7. Which rights can you exercise?

You may have the right under applicable law to access your Data and, if necessary, have it amended, deleted, or restricted. You may also ask us to provide some types of Data to you, or another organization nominated by you, in a structured and machine-readable format.

You can object to the processing of your Data in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement), at any time either through the opt-out link at the bottom of our marketing e-mails, (in case of marketing, or by contacting us at the contact details indicated below).

These rights can be limited – for example, where we need your Data (i) to comply with the law or (ii) to the interest of iGenius will prevail, or (iii) where providing your information would reveal Data about another person.

You also have a right to complain to an EU data protection authority where you live, work, or where you believe a breach may have occurred.

For more details or any privacy questions, please contact us by email at (at this address, you can reach out to our DPO, too, in accordance with Article 27 of Regulation (EU) 2016/679).

iGenius Inc. has appointed iGenius S.p.A., with a registered office in Via Principe Amedeo, 5, 20121 Milan, Italy, as its representative in the European Union.

8. How can you modify your preferences or withdraw your consent?


9. Children’s Privacy

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we become aware that a child has provided us with personal information violating applicable law, we will delete any personal information we have collected unless we have a legal obligation to keep it and terminate the child’s account as applicable.

10. Changes to this privacy notice

This privacy notice may be amended or updated, in full or in part, as a result of changes to the applicable law. We will keep you informed as required under applicable law of any substantial changes that affect how your Data is processed.In any case, we invite you to periodically consult the updated privacy notice published on the Website.