Privacy Policy
1. Infrastructure and Global Jurisdiction
This Privacy Policy establishes the data governance framework for Genius Energy, a resilience and off-grid intelligence platform operated by Genius Marketing FZ (“The Publisher,” “We,” or “Us”). The Publisher is incorporated in and legally anchored to Dubai Internet City (TECOM Group), United Arab Emirates, and our operations are governed by the laws of the UAE.
Our U.S. mailing address in Dover, Delaware, is a registered mail-forwarding address used solely to receive legal and administrative correspondence. It does not change our place of incorporation or governing jurisdiction, which remain the United Arab Emirates.
To deliver intelligence on energy freedom and grid vulnerability, our digital infrastructure spans international borders. By using our platform, accessing our guides, or subscribing to our alerts, you acknowledge and authorize the routing, processing, and storage of your data between the UAE and our infrastructure providers located in the United States, including our newsletter and email platforms (Ghost(Pro), Mailgun, and Beehiiv), subject to the safeguards described in Section 6.
2. Data Acquisition: The Minimalist Approach
We collect only the telemetry necessary to deliver our grid-independence briefings, operate our messaging programs, and maintain platform security.
2.1 Essential Credentials
To receive our intelligence, we collect your email address. For urgent alerts regarding grid instability or time-sensitive recommendations, we may collect your mobile phone number (optional). We do not require real names or physical addresses for standard access.
2.2 Consent Records
To document lawful consent for our email and SMS programs, we log the timestamp of your submission, the IP address from which it was submitted, the URL of the form used, and the state of each consent checkbox at the moment of submission. These records are maintained for regulatory compliance only.
2.3 Interaction Telemetry
We monitor how you navigate our platform to keep our content relevant. We log timestamps and the topics you engage with (e.g., solar battery configurations vs. independent water filtration), as well as email open and click events.
2.4 Technical Footprints
To defend our infrastructure against synthetic traffic and botnets, we capture system-level data including your IP address, ISP, and device architecture.
2.5 Interest Signals (Derived Internally)
To tailor resilience strategies and relevant partner hardware offers, we may derive inferences about your interests based exclusively on your own on-site behavior and engagement with our content. We do not cross-reference your email or other personal data with external commercial identity graphs, data brokers, or third-party profile-enrichment services to append demographic or professional data to your record. All interest signals are derived solely from your direct interactions with our platform.
3. How We Use Your Data
We process personal data to: deliver our briefings, guides, and alerts; send email and, where you opt in, SMS messages; perform analytics and improve our content; present relevant partner hardware offers within our own communications; maintain security and prevent fraud; and meet legal and compliance obligations.
4. Data Dissemination and SMS Privacy Doctrine
We operate under a strict “No-Sale” doctrine. We do not sell your personal data for monetary compensation, and we do not share it for cross-context behavioral advertising. External data flows occur exclusively under these conditions:
- Delivery Custodians: Our newsletter, email, and dispatch infrastructure providers — Ghost(Pro) (publishing and membership), Mailgun (email delivery for our Ghost platform), and Beehiiv Inc. (newsletter distribution) — process outbound communications and host related data in the United States. They act solely as processors under our instructions, are bound by contractual confidentiality obligations, and are strictly prohibited from exploiting your data for their own purposes.
- Affiliate “Pass-Through” Model: We curate offers for backup generators, solar systems, and survival gear. Your contact data is NEVER transferred to these vendors by us. A data exchange only occurs if you consciously click a link and land on the vendor’s external domain, at which point you become subject to their independent privacy practices.
- Regulatory Authorities: We may disclose records only if formally ordered by UAE Courts, TECOM Group regulatory authorities, or recognized international law enforcement pursuant to valid legal process.
Ironclad SMS Non-Sharing Mandate: SMS opt-in consent and mobile numbers are never sold, rented, leased, or shared with any third parties, affiliates, or partners for their own marketing or promotional purposes. Your mobile communication data is used solely to operate the SMS program you requested.
5. Cookies & Tracking
We use cookies and similar technologies for essential functionality, performance and security, and to measure engagement with our content. You can control cookies through your browser settings and, where applicable, our cookie banner; disabling some cookies may affect functionality.
6. International Data Transfers
Because we are incorporated in the UAE and rely on infrastructure providers located in the United States, your personal data may be transferred to, stored in, and processed in jurisdictions outside your country of residence, including the UAE and the United States, which may maintain different data-protection statutes. Where required by applicable law, such transfers are carried out under appropriate safeguards — including, for transfers subject to the GDPR, the European Commission’s Standard Contractual Clauses, and for transfers subject to the UAE PDPL, contractual and technical measures designed to ensure an adequate level of protection.
7. Data Retention
We retain personal data only as long as necessary for the purposes in this Policy, except where a longer period is required by law:
- Newsletter subscriber data: for the duration of the subscription plus 12 months after unsubscription.
- SMS opt-in records: for a minimum of four (4) years from the date of consent.
- SMS opt-out and revocation records: for a minimum of ten (10) years.
- Telemetry and technical data: individual records purged after 90 days; aggregated data retained thereafter.
8. Your Privacy Rights
8.1 California Residents (CCPA/CPRA)
California residents have the right to know, delete, and correct personal information; to opt out of the sale or sharing of personal information; to limit the use of sensitive personal information; and to be free from discrimination for exercising these rights. Genius Energy does not sell your personal data for monetary compensation, nor do we share it for cross-context behavioral advertising. Do Not Sell or Share: To submit a request, email us with the subject line “Do Not Sell Request.” We will respond within forty-five (45) days, and you will not be discriminated against for exercising this right.
8.2 UAE PDPL
In accordance with UAE Federal Decree-Law No. 45 of 2021 (PDPL), subscribers have the right to access their data; correct inaccurate profile data; execute the “Right to be Forgotten” by demanding erasure of their records; restrict processing for specific promotional categories; object to processing; and withdraw consent at any time without affecting prior lawful processing.
8.3 EU / EEA Residents (GDPR)
Where we accept subscribers in the EU/EEA, you have the rights of access, rectification, erasure, restriction, portability, and objection. We process newsletter and SMS data based on consent (Art. 6(1)(a)); compliance recordkeeping based on legal obligation (Art. 6(1)(c)); and security and integrity based on legitimate interests (Art. 6(1)(f)). You may withdraw consent at any time and lodge a complaint with your local supervisory authority.
9. Communications Consent (TCPA & CAN-SPAM)
9.1 Email (CAN-SPAM)
Every briefing dispatched by Genius Energy identifies the sender accurately, uses non-deceptive subject lines, contains a single-click unsubscribe mechanism (processed within 10 business days), and includes our physical mailing address.
9.2 SMS Alerts (TCPA)
By providing your mobile phone number and opting in via a non-pre-ticked checkbox, you provide your prior express written consent under the Telephone Consumer Protection Act (TCPA) to receive recurring automated marketing and informational text messages, including messages sent via an Automatic Telephone Dialing System (ATDS), from Genius Energy. Providing your phone number is not a condition of purchasing any goods or services. Alert frequency may vary. Standard message and data rates may apply. Reply STOP, QUIT, or UNSUBSCRIBE to cancel; reply HELP for support. T-Mobile and all other wireless carriers are not liable for delayed or undelivered messages.
10. Age Restrictions and Minors
Our content addresses infrastructure vulnerabilities, financial preparations, and physical resilience strategies and is engineered exclusively for adults (18 years and older). We do not knowingly collect data from minors and will execute immediate purging routines if such data is discovered.
11. Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect your data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
12. Changes to This Policy
We may revise this Policy from time to time. Updates will be indicated by the date at the top of this document. Continued engagement with our platform after an update constitutes acceptance of the revised Policy.
13. Corporate Registration and Legal Correspondence
Genius Energy operates under the legal framework of the United Arab Emirates. All formal compliance requests, privacy inquiries, and legal notices may be routed to our registered U.S. mailing address (for correspondence only):
Genius Marketing 1151 Walker Rd Ste 100, PMB 827, Dover, DE 19904, USA