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GENESYS PRIVACY POLICY

Date last revised: September 2024

Genesys Cloud Services, Inc. (“Genesys”) processes Personal Data (defined below)
on behalf of our customers all around the world. Some of these customers
transfer Personal Data to Genesys from the European Economic Area (EEA). To that
end, Genesys complies with the Data Protection Framework Framework, and its
extensions, as further explained below, as set forth by the U.S. Department of
Commerce regarding the collection, use, and retention of personal information
transferred from the EEA to the United States.

This EU Privacy Notice sets forth the practices that Genesys follows for such
information.

Definitions Used:

Agent: any third-party data processor that processes Personal Data provided by
Genesys on its behalf and under its instructions.

Data Controller: the natural or legal person, public authority, agency or other
body which, alone or jointly with others, determines the purposes and means of
the processing of personal data; where the purposes and means of such processing
are determined by Union or Member State law, the controller or the specific
criteria for its nomination may be provided for by Union or Member State law.

Data Processor: a natural or legal person, public authority, agency or other
body which processes personal data on behalf of the controller.

Data Protection Laws: means the EU GDPR, UK GDPR, Swiss Data Federal Data
Protection Act and other regional applicable regulations in the European
Economic Area, as well as United States’ state laws appliacable to the company
when conducting business and processing Personal Data.

Personal Data: any information or set of information that identifies or could be
used to identify (together with other information) a living individual. Personal
Data does not include information that is anonymized or aggregated.

Sensitive Personal Data: any Personal Data that reveals race, ethnic origin,
political opinions, religious or philosophical beliefs, trade union membership,
information that concerns health or sex life, and information about criminal or
administrative proceedings and sanctions. In this Privacy Notice, all references
to Personal Data include Sensitive Personal Data.

Data Protection Framework Principles: the Data Protection Framework principles
agreed to between the U.S. Department of Commerce and the European Commission
concerning the transfer of Personal Data from the E.U. to the U.S.


HOW CAN I FIND OUT MORE INFORMATION ON DATA PROTECTION FRAMEWORK?

To learn more about the Data Protection Framework, and to view our
certification, please visit https://www.dataprivacyframework.gov/ .


HOW DOES GENESYS ENSURE COMPLIANCE WITH DATA PROTECTION FRAMEWORK?

Genesys complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the
UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Genesys has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union and the United
Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. 
Likewise, Genesys has certified to the U.S. Department of Commerce that it
adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF
Principles) with regard to the processing of personal data received from
Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between
the terms in this privacy policy and the EU-U.S. DPF Principles and/or the
Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the
Data Privacy Framework (DPF) Program, and to view our certification, please
visit https://www.dataprivacyframework.gov/

The DPF Principles enable Genesys to satisfy requirements in the EEA pertaining
to protecting Personal Data that is transferred out of those jurisdictions.
Genesys has certified that it adheres to the principles of notice, choice, and
accountability for onward transfer, security, data integrity and purpose
limitation, access, and recourse, enforcement, and liability. For Personal Data
transferred from the EEA, in the event that there is any conflict between this
Privacy Notice and the Data Protection Framework Principles, the Data Protection
Framework Principles shall govern.


DOES GENESYS MAINTAIN A DATA PROTECTION OFFICER?

Genesys maintains a Data Protection Officer as a key contact for questions and
complaints regarding Personal Data. Please contact us
at DataPrivacy@genesys.com with any questions or concerns you may have about
this Privacy Notice or our use of your Personal Data.


WHAT PERSONAL DATA DOES GENESYS COLLECT, HOW WILL IT BE HANDLED, AND HOW WILL IT
BE USED AND DISCLOSED?

Genesys is a Data Processor on behalf of its customers who procure Genesys
products and services. Our products and services facilitate our customers to
place, record, log, and otherwise manage contacts, telephone calls, and other
types of electronic communications which may generate Personal Data (e.g. time
of call, call status, parties to a call, call recordings, and others). Some of
our products and services enable our customers to transmit information necessary
to manage a call center and contacts in which agents at that call center
communicate (e.g. first name, last name, address, email address, telephone
number, SMS number, Internet screen name, and others).

Following the principles of the EU-U.S. DPF and the UK Extension to the EU-U.S.
DPF and Swiss-U.S. DPF Principles, Genesys only processes Personal Data
collected through our products and services at the behest of our customers. We
will not sell or otherwise transfer the Personal Data to any third party unless
(1) otherwise agreed to by our customers when they transfer information to us,
such as to provide needed information to our Agents, resellers, partners and
contractors who may provide products or services (e.g. our data center
provider); (2) in connection with the sale of all or substantially all of the
assets of a business division of Genesys, a line of Genesys’ business or
Genesys’ entire business or merger with another company; (3) to payment
processing vendors as necessary for processing credit card transactions or
support transactions; or (4) for compliance with possible legal or governmental
disclosure requirements.

It should be understood that in some rare cases it may be necessary to disclose
Personal Data in response to lawful requests by public authorities, including to
meet national security or law enforcement requirements.


HOW CAN YOU RESTRICT THE USE OR DISCLOSURE OF YOUR INFORMATION?

If Genesys is processing your Personal Data on behalf of one of our customers,
you may opt out of any disclosure of your Personal Data to any third party that
is not our Agent or the use of that data for a purpose other than the purpose
for which it was originally collected from, or subsequently authorized by, you.
We will not disclose Sensitive Personal Data to a third party that is not our
Agent or use Sensitive Personal Data for a purpose other than the purpose for
which it was originally collected from, or subsequently authorized by, you
unless we have received your affirmative and explicit consent to do so (i.e.,
opt-in consent). The above is aligned with the EU-U.S. DPF and the UK Extension
to the EU-U.S. DPF and the Swiss-U.S. DPF Principles.

For additional information regarding how you may restrict the use or disclosure
of your Personal Data, please contact us at DataPrivacy@genesys.com.


HOW CAN YOU ACCESS OR CORRECT INFORMATION HELD ABOUT YOU?

You have the right to obtain a confirmation from Genesys of whether we maintain
Personal Data relating to you. Upon request, we will provide you with access to
the Personal Data that we hold about you within a reasonable time period. We
will also enable you to correct, amend or delete Personal Data related to you in
our possession and control that is inaccurate or incomplete. Your right to
access your Personal Data may be restricted in exceptional circumstances,
including, but not limited to, when the burden or expense of providing this
access would be disproportionate to the risks to your privacy in the case in
question, or where the rights of persons other than you would be violated by the
provision of such access. If we determine that your access should be restricted
in a particular instance, we will provide you with an explanation of our
determination and respond to any inquiries you may have.

For information regarding how you may request to access, correct, amend, or
delete your Personal Data please contact us at DataPrivacy@genesys.com.


HOW WILL YOUR INFORMATION BE PROTECTED?

Genesys is committed to protecting the Personal Data entrusted to us. We have
implemented reasonable and appropriate physical, electronic and administrative
procedures to safeguard and secure this information from loss, misuse,
unauthorized access or disclosure, alteration and destruction.

We will take special care to ensure the security of Sensitive Personal Data. We
will use and disclose Personal Data only in ways that are compatible with and
relevant to the purposes for which such information was collected or authorized
by you.

To the extent necessary for this purpose, we will take reasonable steps to
ensure that Personal Data remains accurate, complete, current and reliable for
its intended use.

Unfortunately, no data transmitted over or accessible through the Internet can
be guaranteed to be completely secure. As a result, while Genesys utilizes
industry standard security technologies and procedures intended to protect all
Personal Data, we cannot ensure or warrant that Personal Data will be completely
secure from misappropriation by hackers or from other nefarious or criminal
activities, or in the event of a failure of computer hardware, software, or a
telecommunications network. We will notify you in the event we become aware of a
security breach involving your personally identifiable information (as defined
by the applicable state and federal laws) stored by or for us. By disclosing
your email address to us for any reason, you expressly consent to receive
electronic notice from us in the event of such a security breach.


WHAT STEPS WILL GENESYS TAKE BEFORE TRANSFERRING YOUR INFORMATION TO THIRD
PARTIES?

Genesys is potentially liable in cases of onward transfers of Personal Data to
third parties. We will obtain written assurances from our Agents that they will
safeguard Personal Data in accordance with this Privacy Notice.

Appropriate assurances may include:

 * we will require our Agent to enter into a contract with us that requires the
   Agent to provide at least the same level of protection as is required by the
   Data Protection Framework Principles;
 * in certain circumstances, our Agent may be subject to the Data Protection
   Laws;
 * our Agent may be established in a country that is subject to a finding of
   adequacy by the European Commission as per Data Protection Laws; or
 * our Agent may have their own Data Protection Framework certification.

Please note that all along the process described above, Genesys will firmly and
consistently comply with the Principles of the EU-U.S. DPF and the UK Extension
to the EU-U.S. DPF and the Swiss-U.S. DPF Principles.


HOW ARE COMPLAINTS AND DISPUTES RESOLVED?

Your complaint may be resolved by Genesys internally. We will investigate the
matter and attempt to resolve the issue quickly. In any case, our commitment is
to respond within 10 days and resolve the complaint within 45 days. We also
agree to participate in independent dispute resolution of your complaints
through the EU data protection authorities (DPAs). We will cooperate with the
DPAs in the investigation and resolution of complaints brought under the Data
Protection Framework and we agree to comply with any advice given by the DPAs
where the DPAs take the view that the organization needs to take specific action
to comply with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the
Swiss-U.S. DPF. Under certain conditions, it is possible for individuals to
invoke binding arbitration before the panel.


HOW WILL GENESYS ENSURE COMPLIANCE WITH THIS NOTICE?

Genesys will conduct compliance audits of our privacy practices to verify
compliance with this Privacy Notice.

Any Genesys employee that we determine has acted in violation of this Privacy
Notice will be subject to disciplinary action up to and including termination of
employment.

Any questions or concerns regarding our use or disclosure of Personal Data
should be addressed to the Genesys DPO at DataPrivacy@genesys.com.

We will investigate and attempt to resolve any complaints and disputes regarding
the use and disclosure of Personal Data in accordance with the provisions of
this Privacy Notice.


CHANGES TO THIS PRIVACY NOTICE

It is our policy to post any changes we make to our Privacy Notice on this
website. If we make material changes to how we treat the Personal Data that
falls within the scope of our Privacy Notice, we will notify you by email to the
email address specified in your account or through a notice on this website.

The date the Privacy Notice was last revised is identified at the top of the
page.


WHO SHOULD YOU CONTACT IF YOU HAVE ANY QUESTIONS CONCERNING THIS PRIVACY NOTICE?

You may contact our Data Protection Officer at DataPrivacy@genesys.com. We
encourage you to contact our DPO to inform us of any complaints or disputes you
may have regarding the use of your Personal Data or to request access to your
Personal Data.

Lastly, in compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S.
DPF and the Swiss-U.S. DPF, Genesys commits to cooperate and comply with the
advice of the panel established by the EU data protection authorities (DPAs) and
the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data
Protection and Information Commissioner (FDPIC) with regard to unresolved
complaints concerning our handling of personal data received in reliance on the
EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

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