Privacy Policy

Who we are

Suggested text: Our website address is: https://genereko.com.

This Privacy Policy describes how GENEREKO POWER SYSTEMS., and our subsidiaries and affiliated companies (collectively, “GENEREKO”, “our”, “we”, or “us”) collect, use, and disclose personal information about you and provides information regarding your rights. Personal information is sometimes also referred to as personal data, personally identifiable information or other like terms to mean any information that directly or indirectly identifies you or is reasonably capable of being associated with you or your household. This Privacy Policy applies to personal information we collect online and offline, and applies in the following situations:

• Websites: Your use of this or other GENEREKO websites that post or link to this Privacy Policy;
• Products and Services: Your interactions with GENEREKO in relation to our products and/or services that refer to or link to this Privacy Policy;
• Business Partners and Suppliers: Your interactions with us if you visit our facilities or otherwise communicate with us in your role as a representative of a vendor, supplier, service provider or an entity conducting business with us; and
• Digital Tools: Your use of the variety of digital tools (including apps) offered by GENEREKO in connection with our diagnostics and repair services for commercial vehicles and equipment, such as Guidanz®, INSITE™, INLINE™, QuickServe® Online, etc.

We may provide different or additional notices of our privacy practices with respect to other personal information collection practices not within the scope of this Privacy Policy, in which case this Privacy Policy will not apply. For example, if you are applying for a job on our websites, the Notice for Job Applicants applies to our personal information handling practices, instead of this Privacy Policy.

Source and Type of Personal Information We Collect

You may visit our website without providing any information about yourself. However, for GENEREKO to provide certain web-based services to you or to permit you to enter certain sections of our website, we require you to provide some personal information relative to the type of interaction or service. For example, we may collect your personal information directly from you when you register a product, submit a query, purchase an item, apply for a job, participate in a survey, conduct business dealings with us. We may also collect your personal information from other parties, such as our service providers, contractors, processors, and others.

The personal information we collect may include:

• Your identifiers, such as your name, company name, job title, email address, phone number, mailing address, Internet Protocol address, unique personal identifier, and other similar identifiers;
• Your business relationship with us, such as whether you are a customer, business partner, vendor, service provider, or supplier;
• Commercial information, such as your purchase history, payment and invoicing history, financial information, interest in our particular products or services, warranty information, service history, product or service interest, VIN number of engines/generators that you have purchased, and identification of your dealer and/or service centers;
• Your enrollment in any of our programs, such as newsletter, sign up for emails, participate in a survey, or other similar services that we offer;
• Your online or offline interactions with us, such as your “likes” and feedback via social media sites, interactions with our call centers;
• Your use of commercial vehicles or equipment containing activated telematics devices that transmit information to GENEREKO in relation to the proper functioning and maintenance of the vehicle/equipment on which it is installed, such as vehicle or equipment identifiers, fault codes and similar functioning information, applicable dates and times, precise geolocation data (for evaluating road conditions and similar factors impacting performance), and braking and speed information. To learn more, see our Telematics Data Protection Notice for GENERATORS;

We and others that control collection of personal information use tracking technologies, such as cookies and web beacons, to collect information about you. For more information about cookies and how to disable them, see our Cookie Website Notice and Disclosure Statement.

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

Purposes and Use of Personal Information

GENEREKO may use the categories of personal information identified above for the following purposes:

• To manage and support your interactions with us, such as answering your questions about our products or services, processing orders or returns, enrolling you in programs at your request, or similar activities that respond to your request or relate to our business activities;
• To manage and improve the quality of our products, services, websites, social media interactions and our offerings;
• To manage and improve the services that we provide in connection with our telematics business;
• To support and enhance our customer relationships, such as by gathering information and interacting with you in relation to other products and services that may be of interest, based on your preferences;
• To conduct business dealings with our partners and service providers;
• To send you technical notices, security alerts, and support and administrative messages;
• To monitor and analyze trends, usage, and activities in connection with our services;
• To detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of GENEREKO and others;
• To debug to identify and repair errors in our services;
• To comply and fulfill applicable legal, compliance, financial, export and regulatory obligations; and
• To carry out any other purpose described to you at the time the personal information is collected.

Disclosure of Personal Information

We disclose personal information in the following circumstances or as otherwise described in this policy:

• Our Service Providers, Contractors and Processors: We may disclose your personal information to our services providers, contractors and processors, such as those who assist us with our websites; IT security; data centers or cloud services; communications services; social media; those that partner with us in relation to our products and services such as dealers, distributors, service centers and telematics partners; and those that assist us with other types of services. GENEREKO evaluates those service providers, contractors and processors in advance to ensure that they are capable of upholding a similar level of protection for the data and also requires them to enter into a written agreement confirming their understanding that they are expressly prohibited from using the personal information for any unrelated purposes or from selling or sharing the information.
• Sale of Personal Information to Third Parties: We do not sell your personal information to third parties.
• Sharing of Personal Information for Targeted Advertising: We do not share your personal information with third parties for targeted advertising.
• Legal Disclosures: We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may also disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of GENEREKO, our users, the public, or others.
• Disclosure to Advisors and Lawyers: We may disclose personal information to our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• Disclosure of Personal Information During Change of Ownership: We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Among Our Family of Affiliated Companies and Others: Personal information is disclosed between and among GENEREKO and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership. When personal information is disclosed to our group companies or third-party partners assisting us, we require them (as well as any of their subcontractors) to uphold a substantially equivalent level of protection for that personal information.
• With Your Consent: We disclose personal information with your consent or at your direction.
• Disclosing Non-Personal Information: We may disclose aggregated or de-identified information that cannot reasonably be used to identify you.
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Legal Basis for Processing Personal Information

The legal basis for processing personal information varies in accordance with the purpose(s) for collection.  This may include:

• Consent, such as managing our services, or responding to website user inquiries;
• Performance of a contract, such as managing your access to your customer or supplier account, processing and tracking service requests and orders;
• Fulfill business or legal obligations such as when processing is required by law, such as retention of purchase or service invoices); or
• Our legitimate interests, such as improvement of our products, services or website; prevent misuse or fraud; secure our website or other GENEREKO software or property, or tailor our communications.

Retention of Personal Information

We store your personal information as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purpose, including to meet our legal, regulatory or other compliance obligations. You can find more details about our personal information retention by contacting office@genereko.com.

Safeguarding Your Information

GENEREKO has put in place appropriate physical, electronic, and managerial practices to help safeguard and secure the information we collect online from loss, misuse, unauthorized access, alteration, destruction, or theft. This includes appropriate safeguards for customers making purchases through our sites, as well as those who enroll in our programs. The safeguards that we have adopted are commensurate with the sensitivity of the information and are updated as warranted to address evolving security risks.

Children

This website is not intended for or directed at children under the age of 13. In addition, we do not knowingly collect personal information from children under 13. If we learn that we mistakenly collected any information from anyone under the age of 13 or the cutoff age in the relevant country where the child resides, we will purge it immediately, except as required by law.

Cross-Border Transfers of Personal Information

As a global organization, GENEREKO transfers and stores some of the personal information we collect outside of its country of origin.  This may include transfers to third parties assisting us in other countries as well as cloud storage of the data.  If you live outside of the United States, you should be aware that the data privacy laws that apply to personal information differ from country to country, and do not always offer a consistent level of protection to that offered in your country.  Nevertheless, GENEREKO has adopted measures that are designed to ensure that cross-border transfers of personal data take place in accordance with applicable data protection laws and requirements. The measures include assessments of the data importer as well as applicable host country laws to ensure that the recipient is capable of upholding an adequate level of protection for the data and entering into appropriate written agreements with the data importer confirming that commitment. GENEREKO relies on the E.U. Standard Contractual Clauses or an equivalent data transfer mechanism for those transfers and has also put in place similar mechanisms for transfers between our group companies.

Links to Other Websites

Our website may contain links to other websites that are not owned or operated by GENEREKO. You should carefully review the privacy policies and practices of other websites, as we cannot control and are not responsible for privacy policies or practices of third-party websites that are not ours.

Accuracy of Personal Information

GENEREKO take reasonable steps to ensure that your personal information on file with us is accurate and up-to-date. We also encourage individuals who have entrusted their data to us to keep it current (such as if you change your email address, address or phone number), and to keep your contact preferences up-to-date (such as in relation to our products or services and the frequency of contacts), so that we have your correct information on file and so that we can personalize our service to your expectations and needs.

Rights of Individuals with Disabilities

GENEREKO provides multiple ways to communicate with us in order to provide assistance to individuals with disabilities and to allow each individual to communicate effectively.

Upholding and Fulfilling Individual Rights

In accordance with applicable laws, GENEREKO has processes in place to uphold the rights of individuals in relation to the personal information collected about them. This includes, for example, the right to know about the data we hold about you or to obtain a copy, and the limited rights to amend your data, request erasure, or object to the processing of your data. Finally, we offer individuals the right to withdraw consent from our marketing and commercial programs and offerings at any time.

To do so, or to exercise any of these other rights, you may contact us by emailing us at office@genereko.com or writing to us at GENEREKO POWER SISTEMS,Pipera Boulevard, no. 200A – Bucharest (RO). GENEREKO may request additional verification from you as well as more descriptive information relating to your interactions with the company, in order to process and respond to your request without providing personal information to an unauthorized person.

Please see below for country- or region-specific sections for additional rights that may apply to you based on your location.

Disclosure for Individuals in Europe

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal information (this is called “personal data” under the privacy laws of these countries and regions), and this section applies to you. GENEREKO is the controller of your personal data. Our contact details can be found in the Contact Us section.

Data Subject Requests

Subject to certain limitations, you have the following rights:

• The right to be informed: you have the right to obtain clear, transparent and easily understandable information about how we use your personal data, and your rights;
• The right of access: you have the right to access the personal data that GEBEREKO holds about you;
• The right of rectification: you have the right to have your personal data rectified if it is incorrect or outdated and / or completed if it is incomplete;
• The right to erasure / right to be forgotten: you have the right to have your personal data erased or deleted. Please note this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data;
• The right to restriction of processing: you have the right to object to, or request that we restrict, certain processing;
• The right to object to direct marketing: you can unsubscribe or opt out of our direct marketing communication at any time. You are able to do so by clicking on the “unsubscribe” link in any email or communication we send you. You are also able to request to receive non-personalized communications about our products and services;
• The right to withdraw consent at any time for data processing based on consent: You can withdraw your consent to our processing of your data when such processing is based on consent; and
• The right to data portability: you have the right to move, copy or transfer data from our database to another. This only applies to data that you have provided, where processing is based on a contract or your consent, and the processing is carried out by automated means.

Please contact us at office@genereko.com to exercise these rights or if you have any questions or complaints regarding the processing of your personal data.

Sensitive Personal Information

Under data privacy laws, certain types of personal information are considered “sensitive” personal information or data and require additional data privacy rights and obligations. GENEREKO collects precise geolocation and financial information, which may be considered sensitive personal information under privacy laws. Where required by law, we will obtain your consent before processing your sensitive personal information. We will also only use your sensitive personal information for limited purposes, such as to perform the services or provide the goods or services you expected; to prevent, detect, and investigate security incidents; to resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions; or to verify or maintain the quality or safety of our products, services, or devices.

Changes to This Privacy Policy

As we continue to provide additional services and as the privacy laws and regulations evolve, it may be necessary to revise or update our Privacy Policy. If we decide to change our policy, we will post those changes on our Homepage, so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we would like to use personal information in a manner that is different and not reasonably inferable from that stated in our policies at the time it was collected, we will notify users in advance and seek their consent if legally required.

Contact Us

If you have questions about GENEREKO’ Privacy Policy or believe that your information has been mismanaged, you can contact us by emailing us at office@genereko.com, or writing to us at GENEREKO Pipera Boulevard, no. 200A – Bucharest (RO). GENEREKOhas put in place a dispute resolution process for any privacy or security-related disputes, and does not retaliate against any individual who contacts us with a dispute that they believe to be legitimate. Individuals who believe that their dispute has not been resolved to their satisfaction by the company also have the right to file claims with the relevant oversight agencies for data protection.

Digital Tools Data Protection Notice

Purpose of Collection: Our digital tools include online tools and apps which are designed to assist customers with service events relating to vehicles and equipment. We understand the inconvenience and time drain associated with downtime and maintenance and strive to minimize the inconvenience via these tools. Among other things, the tools assist you in rapidly locating nearby repair service (or bringing the service to you), streamlining the diagnostic process to identify the cause of the fault or malfunction, and getting you back in business as quickly as possible.

Personal Information Collected: The specific data elements collected via GENEREKO’ digital tools vary based upon the tool and specific customer needs. They include, but are not limited to, your name and contact details, information relating to the commercial vehicle or equipment at issue, location data (in relation to locating a nearby repair center or bringing the service to you), diagnostic evaluations pertaining to the fault codes or repairs including the root cause and potential factors impacting the malfunction, payment information for any repairs or subscriptions to those services, and customer feedback via surveys (if applicable).

Processing of Information Collected: GENEREKO processes the data collected in relation to the particular digital tool or app in which you enroll and in relation to your particular needs. This includes, conducting necessary diagnostics on your commercial vehicle or equipment, fulfilling your repair and service requests, providing information to you about nearby service locations, scheduling appointments, and coming to your location to provide the diagnostics and repairs. The data may also be used for surrounding purposes such as product and quality improvement, customer feedback and support, and surrounding regulatory, legal and compliance purposes.

Other Information: Please refer to the other sections of this Privacy Policy for additional information on GENEREKO’ practices pertaining to its digital tools (and other) personal data such as in relation to security, cross-border transfers, specific information for certain regions, individual rights, data retention, and any disputes.

Individuals with questions or concerns about the collection of personal data by GENEREKO in relation to our digital tools can also contact us at office@genereko.com for further assistance.

E.U. – U.S. Privacy Shield Website Privacy Notice

This website Privacy Shield Notice is intended to inform you about GENEREKO’ adherence to, and compliance with, the E.U.-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce.

Scope: GENEREKO has certified to and confirmed its adherence to the E.U.-U.S. Privacy Shield framework for its human resource and customer personal information pertaining to residents of the European Union (E.U.), European Economic Area (E.E.A.). However, in light of the judgment of the Court of Justice of the European Union in Case C-311/18 (“Schrems II”), GENEREKO discontinued its reliance on the Privacy Shield framework as a legal basis for transfers of personal data. GENEREKO nevertheless continues to remain certified to that framework as part of the company’s overall commitment to ensuring compliant and responsible data protection practices in the countries where we operate.

Privacy Shield principles that GENEREKO upholds in connection with its Privacy Certification are: Notice; Choice (Consent); Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website at https://www.privacyshield.gov/list.

Conflicts: If there are any conflicts between the terms of the Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles, as modified by the EU Court of Justice’s Schrems II decision, shall govern.

Disputes: In compliance with the Privacy Shield principles, GENEREKO has committed to cooperate with the E.U. Supervisory Authorities with regard to unresolved Privacy Shield complaints concerning the company’s human resource or customer personal information. Individuals who believe their personal information has been mismanaged by GENEREKO in relation to the company’s Privacy Shield commitments have the right to contact the E.U. Supervisory Authorities for more information or to file a complaint, and can do so without charge. E.U./E.E.A. individuals with inquiries or complaints regarding the Privacy Shield policies or practices should first contact GENEREKO at:

Email: office@genereko.com
Address: Pipera Boulevard, no. 200A – Bucharest (RO)

Barring any unforeseen circumstances, GENEREKO will respond to the individual submitting the grievance within forty-five (45) days of receipt.

Regulatory Oversight and Enforcement: In connection with its Privacy Shield certification, GENEREKO is subject to investigatory and enforcement authority of the U.S. Federal Trade Commission and the relevant European Supervisory Authorities.

Right to Binding Arbitration: Under limited circumstances and in accordance with the Privacy Shield framework, E.U./E.E.A. individuals can also seek binding arbitration before a Privacy Shield Panel.

Rights of Individuals to Access Their Data: E.U./E.E.A. individuals have the right to access personal information about them, and to limit use and disclosure of their personal information. In certain situations, such as where the data is incorrect or was collected inappropriately, the individuals also have the right to request amendment or erasure of their data. GENEREKO committed to respect and uphold those rights. Should you wish to exercise those rights, you may contact us by writing to us at Pipera Boulevard, no. 200A – Bucharest (RO), or emailing us at: office@genereko.com Please note that there are certain limitations on these rights, as described in the Privacy Shield framework.

Law Enforcement Requests: GENEREKO may be required to disclose personal information in response to lawful requests by public authorities, including compliance with national security or law enforcement requirements. In doing so and to the extent permitted relative to the particular situation, GENEREKO takes reasonable steps to balance the rights of the individuals with those of the requesting agencies.

Updates: This Policy may be updated from time to time, such as in relation to modifications to the Privacy Shield framework, regulatory expectations, or changes within GENEREKO. These changes will not adversely impact the Privacy Shield protections that have been put in place by GENEREKO.