Genoo
Genoo is a United States based marketing automation and lead generation platform that tracks visitor behaviour with cookies. Deploying it on a European website triggers consent and data transfer obligations under the GDPR and the ePrivacy Directive.
What does Genoo do?
What Genoo is
Genoo is a marketing automation and lead generation platform that marketing teams use to run campaigns by email, publish landing pages, and track how visitors interact with a website. It loads from third party servers and follows individual visitors across sessions, so it has direct privacy implications for any European site that deploys it.
What data and cookies Genoo collects
Once active, Genoo places tracking cookies in the browser and records page views, form submissions, message engagement, and click behaviour. It builds a persistent profile tied to a unique identifier and links anonymous browsing to a contact record once a form is completed, which means the information it handles qualifies as personal data under the GDPR.
GDPR and ePrivacy implications
Storing or reading cookies on a user device is governed by Article 5(3) of the ePrivacy Directive, which requires prior consent for anything that is not strictly necessary. Genoo cookies serve marketing and analytics purposes, so they fall within that obligation, and the profiling it performs also triggers GDPR transparency and lawful basis duties for the site operator acting as controller.
Consent requirements
Genoo must not load before the visitor has given freely given, specific, informed, and unambiguous consent for marketing cookies. The script should stay blocked by default and only be released once the user accepts the relevant category in your consent banner. Pre ticked boxes, implied consent from continued browsing, or firing the tag on page load are not valid under European rules.
Data transfers outside the EU
Genoo is operated from the United States, so deploying it sends personal data to a third country. Such transfers need a valid mechanism, typically the EU US Data Privacy Framework where the vendor is certified, or Standard Contractual Clauses supported by a transfer impact assessment. Your privacy policy must disclose the transfer and the safeguard you rely on.
Genoo and the GDPR
Genoo is classified as “Marketing”. On a site that targets European visitors, it must only load after the visitor consents, and it must be listed in your cookie policy.
- Legal basis
- Consent under Article 6(1)(a) GDPR and Article 5(3) ePrivacy for cookie storage
- Risk level
- high
- Applicable regulations
- GDPR, ePrivacy Directive, EU US Data Privacy Framework
Impact assessment (DPIA)
Genoo performs behavioural profiling and links anonymous browsing to identified contacts, so a data protection impact assessment is recommended where it drives large scale marketing tracking. Assess the volume of profiles, the sensitivity of inferred interests, and the United States transfer before deployment.
Sample text for your banner
We use Genoo to run our marketing campaigns and to understand how you interact with our content. These cookies are only set if you accept marketing cookies.
What Genoo sets and contacts
- Tracking method
- Tracking cookies and pixels with server side lead capture
- Server location
- United States
- Data transferred outside the EU
- Personal data is processed on servers in the United States. Transfers rely on the EU US Data Privacy Framework where the vendor is certified or on Standard Contractual Clauses with a transfer impact assessment.
Cookies set (3)
| Name | Type | Duration | Purpose |
|---|---|---|---|
| genoo_uid | Tracking | 1 year | Stores a unique visitor identifier used to recognise the same person across sessions and link browsing to a lead profile |
| genoo_session | Functional | Session | Maintains the visitor session while interacting with Genoo forms and tracked pages |
| genoo_camp | Marketing | 6 months | Records the marketing campaign and source attributed to the visitor for lead nurturing |
Third-party domains contacted (2)
genoo.comapp.genoo.com
Frequently asked questions about Genoo
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What cookies does Genoo set?
Genoo sets tracking cookies that store a unique visitor identifier and support its marketing automation, including a long lived identifier cookie, a session cookie, and a campaign attribution cookie. They record page views, form activity, and engagement so the platform can build a lead profile.
Do I need consent to use Genoo?
Yes. Genoo cookies are used for marketing and analytics rather than strictly necessary purposes, so under Article 5(3) of the ePrivacy Directive you must obtain prior consent before the script loads.
What is the legal basis for processing with Genoo?
Cookie storage relies on consent under the ePrivacy Directive, and the subsequent profiling relies on consent under Article 6(1)(a) of the GDPR. Legitimate interest is generally not appropriate for cross session marketing tracking.
Does Genoo transfer data to the United States?
Yes. Genoo is operated from the United States, so personal data leaves the EEA. You need a valid transfer tool such as the EU US Data Privacy Framework or Standard Contractual Clauses, and you must disclose the transfer in your privacy policy.
Is a DPIA needed for Genoo?
A data protection impact assessment is recommended when Genoo drives large scale behavioural tracking or profiling. Document the data collected, the United States transfer, and the measures that reduce the risk to visitors.
How do I implement Genoo in a compliant way?
Block the Genoo script by default, load it only after marketing consent through a consent management platform, sign a data processing agreement with the vendor, and list its cookies in your cookie policy. Test that no Genoo cookie is set before consent is given.
Are there alternatives to Genoo?
Yes. Marketing automation tools hosted in the EU or privacy focused analytics platforms can reduce transfer exposure. Any alternative that sets marketing cookies still requires consent, so the core compliance steps stay the same.
How do I update my cookie policy for Genoo?
Add each Genoo cookie with its name, purpose, and duration, state that data is transferred to the United States, and name the safeguard you rely on. Keep the list updated whenever Genoo changes its tracking technology.
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