Purpose

The DPA governs Genesis processing of personal data on behalf of customers where Genesis acts as a processor or service provider.

Role model

• Publisher is controller or business for its end-user relationship and context sent to Genesis.
• Genesis is processor or service provider for publisher-provided request context and hashed identifiers where applicable.
• Genesis may act as controller or business for account administration, advertiser relationships, billing, security, fraud prevention, and platform operations.

Processing instructions

• Provide offer retrieval and matching.
• Record events and signals.
• Generate analytics and exports.
• Support billing, payouts, policy enforcement, security, and support.

Security measures

• TLS in transit and encryption at rest for sensitive stores.
• API key hashing, RBAC, audit logging, and rate limits.
• Network isolation, incident response, and access reviews.

Requests and deletion

Genesis assists with access, deletion, correction, and opt-out requests where technically feasible and legally required. Requests may require publisher-provided hashed identifiers.

Subprocessors and transfers

The DPA links to the current subprocessor list, transfer terms, and role classification notes; /subprocessors is linked from privacy, terms, and the footer for procurement review.

Contact

DPA and data-processing questions can be sent to legal@thegenesis.com. Data-rights requests use privacy@thegenesis.com.