Last Updated: March 30, 2020
This Policy does not apply to third parties that we do not own or control, or to individuals that GemCrowd does not employ or manage.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to GEMCROWD.COM, INC., 650 South Hill Street, Suite 917, Los Angeles, CA 90014.
For the purpose of the GDPR, the Company is the Data Controller.
- Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Account means a unique account created for You to access our Service or parts of our Service.
- Website refers to GEMCROWD.COM, accessible from https://gemcrowd.com
- Service refers to the Website.
- Country refers to: California, United States
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
For the purpose of the GDPR, Service Providers are considered Data Processors.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Facebook Fan Page is a public profile named GemCrowd specifically created by the Company on the Facebook social network, accessible from https://www.facebook.com/GemCrowd/
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
- Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
- Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
- Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
- Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.
INFORMATION THAT WE COLLECT
- Any Information you provide to us in conjunction with using or purchasing our services or products, or any Information you provide to us thereafter, including name, address, zip code, area code, country, telephone number, email address, birthdate, gender, IP address, browser information, cookies, payment information (e.g., financial institution, credit /debit card number, credit/debit card security code, credit/debit card expiration date, checking account number, checking routing number), and billing address.
- Information you provide to us, our employees, our agents, our contractors, or our sub-contractors related to your use of our Platforms. For quality and training purposes, as well as compliance purposes, we may monitor or record any conversations with you or anyone acting on your behalf.
- Information you enter on forums or other public areas of the Platforms, or transmitted to other users of the Platforms or third parties.
- Information obtained about past and contemplated future transactions with us.
- Information we receive from third parties about you.
- Demographic and interest data collected through Google Analytics or a similar analytics system.
WE COLLECT INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:
Information You Give Us. This includes:
- The personal data you provide when you register to use our website, including your name, postal address, email address, telephone number, username, password and demographic information (such as your gender);
- the personal data that may be contained in any video, comment or other submission you upload or post to the website;
- the personal data you provide in connection with our rewards program and other promotions we run on the website;
- the personal data you provide when you report a problem with our website or when we provide you with customer support;
- the personal data you provide when you make a purchase thorough our website; and
- the personal data you provide when you correspond with us by phone, email or otherwise.
Information from Social Networking Websites.
Our website includes interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our website, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information Automatically Collected.
We automatically log information about you and your computer or mobile device when you access our website. For example, when visiting our website, we log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our website. We collect this information about you using cookies.
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:
If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.
HOW WE USE THE INFORMATION
- To provide you with services through our Platforms.
- To improve our Platforms and services.
- To display relevant advertisements and recommendations.
- To not display irrelevant advertisements and recommendations.
- To contact you regarding billing information, customer service issues, to send alerts, to solicit reviews, to send promotional and informational messages.
- To measure traffic and usage trends on our Platforms, including webpages you visit, add-ons you use, and other information that assists us in improving our Platforms.
- For any other purpose for which you provide consent.
PURPOSES OF PROCESSING
- What is personal data?
We collect information about you in a range of forms, including personal data. As used in this Policy, “personal data” is as defined in the General Data Protection Regulation, this includes any information which, either alone or in combination with other information we process about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
- Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to our Platforms. If you registered with us, you will have been asked to tick to agree to provide this information in order to access our services, purchase our products, or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this Policy, please do not use our Platforms.
USING YOUR PERSONAL DATA
We may use your personal data as follows:
- to operate, maintain, and improve our website, products, and services;
- to manage your account, including to communicate with you regarding your account, if you have an account on our website;
- to operate and administer our rewards program and other promotions you participate in on our website;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing e-mails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- to process payments you make via our website;
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others;
- for analysis and study services; and
- as described in the “Sharing of your Personal Data” section below.
Detailed Information on the Processing of Your Personal Data
- Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
- We may use third-party Service providers to monitor and analyze the use of our Service.
- Google Analytics
- Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
- For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
- Firebase is an analytics service provided by Google Inc.
- We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
- For more information on what type of information Firebase collects, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
- We may use Service providers to show advertisements to You to help support and maintain Our Service.
- Google AdSense DoubleClick Cookie
- You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/
- AdMob by Google
- AdMob by Google is provided by Google Inc.
- You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
- Bing Ads
- Bing Ads is an advertising service provided by Microsoft Inc.
- You can opt-out from Bing Ads by following the instructions on Bing Ads Opt-out page: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
- We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
- We may use Email Marketing Service Providers to manage and send emails to You.
- Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
- Google Ads (AdWords)
- Google Ads (AdWords) remarketing service is provided by Google Inc.
- You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
- Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
- For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
- Bing Ads Remarketing
- Bing Ads remarketing service is provided by Microsoft Inc.
- You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
- Twitter remarketing service is provided by Twitter Inc.
- You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
- Facebook remarketing service is provided by Facebook Inc.
- You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
- To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
- Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
- For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
- We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
- Apple Store In-App Payments
- Google Play In-App Payments
- When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.
Usage, Performance and Miscellaneous
- We may use third-party Service Providers to provide better improvement of our Service.
- Invisible reCAPTCHA
- We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.
- The reCAPTCHA service may collect information from You and from Your Device for security purposes.
- Google Places
- Google Places is a service that returns information about places using HTTP requests. It is operated by Google.
- Google Places service may collect information from You and from Your Device for security purposes.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page (https://www.facebook.com/GemCrowd/), the Company and the operator of the social network Facebook are Joint Controllers.
The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php
We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.
Your Rights under the CCPA
- The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
- The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our “Do Not Sell My Personal Information” section or web page.
The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email or call us or visit our “Do Not Sell My Personal Information” section or web page.
The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law.
If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:
- From Our “Cookie Consent” notice banner
- Or from Our “CCPA Opt-out” notice banner
- Or from Our “Do Not Sell My Personal Information” notice banner
- Or from Our “Do Not Sell My Personal Information” link
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.
You must be 18 years old to use of Platforms. Our Platforms are not intended for children and therefore do not knowingly collect Information from children under the age of 13 years. If we become aware that a child under 13 years of age has provided us with Information, we shall take immediate steps to delete such Information.
If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable.
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13.
If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
Your California Privacy Rights (California Business and Professions Code Section 22581)
California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.
To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
DISCLOSURE OF THE INFORMATION
We may share, sell, rent, or trade your Information to the following third parties and for the following purposes:
- Members of our corporate family (parents, subsidiaries, related and affiliated companies).
- Employees, contractors, subcontractors.
- Businesses that sell items through our Platform.
- To third parties to market their products or services to you.
- Vendors that provide services to us.
- Financial institutions that provide us with capital.
- Payment network request.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- Any potential investors, buyers, or other successor in the event of a merger, divestiture, restructuring, or other sale or transfer of assets, whether as a going concern or as part of bankruptcy or similar proceeding, in which personal information about our customers is among the assets transferred.
- To enforce or apply our Terms and Use or and other agreements with us, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
SHARING YOUR PERSONAL DATA
We may share your personal data as follows:
- Third Parties Designated by You. We may share your personal data with third parties where you have provided your consent to do so.
- Our Third Party Service Providers. We may share your personal data with our third party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
- Third Party Sites
Our website may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them.
USER GENERATED CONTENT
You may share personal data with us when you submit user generated content to our website, including via our rewards program, forums, message boards and blogs on our website. Please note that any information you post or disclose on our website will become public information, and will be available to other users of our website and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on our website. Such personal data and other information will not be private or confidential once it is published on our website.
If you provide feedback to us, we may use and disclose such feedback on our website, provided we do not associate such feedback with your personal data. If you have provided your consent to do so, we may post your first and last name along with your feedback on our website. We will collect any information contained in such feedback and will treat the personal data in it in accordance with this Policy.
COMMUNICATIONS FROM US
By agreeing to this Policy, you give us consent to contact you at the mailing address, telephone (cellular or landline) number, text/SMS number, email address, or fax number that you provide during the sign-up process or that you provide to use thereafter. Any such communications may be transactional, informational, or promotional in nature.
None of the aforementioned communications are a condition for using our Platforms (unless confirmation or deliver is required). If you wish to stop receiving any communications from us, please contact us at [email protected] and let us know the type of communication you wish to stop receiving and the appropriate telephone number, email address, or other contact method to designate as restricted.
COOKIES AND OTHER TRACKING TOOLS
We and our designated third parties (including advertisers) may use several tracking tools, such as cookies, to collect usage and demographic data about you over time through our Platforms. Your browser may store cookies or other information on your computer in a small file.
We and our designated third parties (including advertisers) may also use software technology such as GIFs (e.g., web beacons or web bugs). These are placed in the code of a webpage or an email newsletter. When you access a partner site within our Platform, we may track your activity on that site.
We may use technologies to help determine your physical location, such IP address mapping, Wi-Fi, GPS signals, cell tower positioning, and other technologies to improve and personalize your experience.
We do not control third party tracking technologies or how they may be used. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
WHAT ARE COOKIES?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our website.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our website; and (2) third party cookies, which are served by service providers on our website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
COOKIES WE USE
Our Platforms use the following types of cookies for the purposes set out below:
|Type of cookie||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our website and to enable you to use some of its features. For example, they allow you to log in to secure areas of our website and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our website to remember choices you make when you use our website, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our website which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our website and how users use our website. The information gathered does not identify any individual visitor. It includes the number of visitors to our website, the websites that referred them to our website, the pages they visited on our website, what time of day they visited our website, whether they have visited our website before, and other similar information. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookiesYou can find out more about how Google protects your data here: https://policies.google.com/privacy.You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB|
|Targeted and advertising cookies||These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites.You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.|
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.|
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our website. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our website.
We may use other companies to serve third-party advertisements when you visit and use the website. These companies may collect and use click stream information, browser type, time and date, subject of advertisements clicked or scrolled over during your visits to the website and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use tracking technologies to collect this information. Other companies’ use of their tracking technologies is subject to their own privacy policies.
DO NOT TRACK NOTIFICATIONS
While some web browsers may have a “Do Not Track” feature, we do not alter our behavior or change our services based upon receiving a “Do Not Track” request. Such a feature is the responsibility of the browser.
The security of the Information is important to us, which is why we take measures to reasonably protect it. We limit access to Information we received to those third parties who we believe have a legitimate business or legal purpose to access such information. We maintain physical, electronic, and procedural safeguards to keep Information safe. We also require companies and individuals working with and for us to protect such Information, and that they agree to use it only for limited and designated purposes.
Please be aware that transmission of information over the internet is not completely secure, no security measures are perfect or impenetrable. We cannot guarantee the security of your Information and are not responsible for circumvention of any privacy settings or security measures contained on the Platforms. Additionally, we cannot control the actions of other users of the Platforms with whom you may choose to share your Information. Any transmission of Information is at your own risk.
We seek to use reasonable organizational, technical and administrative measures to protect personal data within our organization. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
MERGER OR ACQUISITION
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we shall notify you with a prominent notice on our website of any change in ownership or uses of your Information, as well as any choices you may have regarding your Information.
CONSENT TO INTERNATIONAL TRANSFER
Information we collect may be transferred, stored, or processed in any country in which we or our corporate family, third party service providers, or agents maintain facilities. By using our services, you consent to any such transfer, storage, and processing of information.
Your information, including personal data that we collect from you, may be transferred to, stored at and processed by us outside the country in which you reside, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accepting this Policy, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
We will retain your Information as long as we have a legitimate business purpose to do so. If you have any questions about your account with us or want us to no longer use your Information, contact us at [email protected] We will make commercially reasonable efforts to honor your request, to the extent that it does not interfere with our use of your Information to comply with our legal and business obligations, resolve disputes, and enforce any agreements.
We will only retain your personal data as long reasonably required for you to use our Platforms until you close your account/cancel your subscription unless a longer retention period is required or permitted by law (for example for regulatory purposes).
To opt out of tracking tools and online behavioral advertising, click here. This means that we will no longer use Information collected from your online activity collected by us to improve our ability to advertise towards you. To be clear, this does not mean that you will no longer receive any advertising from us or third parties; rather it means that any advertisements from us will not be based on your particular interests. Additionally, we may still collect Information for other purposes consistent with this Policy.
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; (iv) any new processing of your personal data that we may carry out beyond the original purpose; or (v) the transfer of your personal data outside the EEA. Please note that your use of some of the website may be ineffective upon opt-out.
- Access. You may access the information we hold about you at any time via your profile/account or by contacting us directly.
- Amend. You can also contact us to update or correct any inaccuracies in your personal data.
- Move. Your personal data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
CALIFORNIA PRIVACY RIGHTS
California Civil Code § 1978.83 permits users of our Platforms, who are California residents, to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]
We are committed to resolve any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us through the information listed on our website. We will reply to your complaint as soon as we can and in any event, within 30 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.
If you are in the European Union, you can choose to lodge a complaint with your local Data Protection Authority (DPA). The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
CHANGES TO THIS POLICY
We reserve the right to modify this Policy at any time and without prior notice. If we decide to change our Policy, we will conspicuously post a link to the updated Policy in places on our Website that we deem appropriate so that you are aware of what Information we collect, how we use it, and under what circumstances, if any, we disclose it. By continuing to use our Platforms, you consent to any such changes.
- By email: [email protected]
- By visiting this page on our website: https://gemcrowd.com/privacy-policy/
- By phone number: 1.702.799.9855