Guided Equity Management, Inc. d/b/a Gemifi (“Company”, “Gemifi” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website https://www.gemifi.co/ or with respect to our software offerings and/or platforms that are accessible through our website (collectively, our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. If you're a resident of California or Nevada or visiting us from the European Economic Area ("EEA"), you should read this policy and the applicable sections below for residents of California and Nevada and visitors from the UK and EEA.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. We use your personal data to provide and improve our platform. By using the platform, you agree to the collection and use of information in accordance with this privacy policy. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see “Changes to Our Privacy Policy” below). Any changes to this Privacy Policy will be effective immediately on posting the updated Privacy Policy unless otherwise stated or as required by applicable law (for example, notice and opt-in or opt-out consent may be required). Your continued use of this Website after we make changes is deemed to be acceptance of those changes to the fullest extent permitted by applicable law, so please check the policy periodically for updates.
1. Scope of Gemifi Privacy Policy
This Privacy Policy applies to all aspects of our Website as well as to information we may collect offline. This Website may link to or incorporate websites or content hosted and served by others over which we have no control, such as third-party websites, online properties, platforms, social media, or systems, which are each governed by the privacy policy and business practices of the third party. You understand and agree that Gemifi is not responsible for the security, privacy, or business practices of any third party.
This policy applies to information we collect
● On this Website and all associated Gemifi software and web apps.
● In email, text, and other electronic messages between you and this Website.
● When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
● Us offline or through any other means, including on any other website operated by the Company or any third party; or
● Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
2. Your Information
2.1 Information We Collect About You and How We Collect It. We collect several types of information from and about users of our Website, including information:
● By which you may be personally identified, such as name, e-mail address, postal address, telephone number, payment information, and any other identifier by which you may be contacted online or offline, including IP addresses and cookie identifiers (collectively, “personal information”); and/or
● About your internet connection, the equipment you use to access our Website, and usage details.
We collect this information:
● Directly from you when you provide it to us.
● Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
● From third parties, for example, our business partners.
2.2 Information you provide. The information we collect on or through our Website may include:
● Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use or creating an account on our Website, purchasing our products, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
● Details of transactions you carry out through our Website and of the fulfillment of your orders, in which event you may be required to provide financial information before placing an order through our Website.
● Records and copies of your correspondence (including email addresses), if you contact us.
● Your responses to surveys that we might ask you to complete for research purposes.
● Any other information, content or documents you upload to the Website.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although take measures to ensure the security of our Website, and any information we collect, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
2.3 Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
● Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
● Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Email here contact@gemifi.co for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
● Estimate our Website usage statistics and usage patterns.
● Store information about your preferences, allowing us to customize our Website according to your individual interests.
● Improve the services we provide to our users.
● Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
● Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
● Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information” below.
● Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
2.4 Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. 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. We require all third-party service providers to meet our security standards through contractual obligations, including NDAs and Data Processing Addendums. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
3. How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
● To present our Website and its contents to you.
● To provide you with information, products, or services that you request from us.
● To fulfill any other purpose for which you provide it.
● To provide you with notices about your account, including expiration and renewal notices.
● To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
● To notify you about changes to our Website or any products or services we offer or provide though it.
● To use data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
● 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.
● To contact you with respect to items, products or services that are germane to the products and services that the Company might provide you.
● To allow you to participate in interactive features on our Website.
● In any other way we may describe when you provide the information.
● For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at contact@gemifi.co. For more information, see “Choices About How We Use and Disclose Your Information” below.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. We are not selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your personal information and data to any persons or entities.
4. Retention and Transfer of Information
4.1 Retention of Your Personal Information and Data
The Company will retain your personal information and data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal information and data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain your usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our platform, or we are legally obligated to retain this data for longer time periods.
4.2 Transfer of your Personal Data
Your personal information and data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that your personal information and data is treated securely and in accordance with this privacy policy and no transfer of your personal information and data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
4.3 International Users
By using the Website, users understand and agree that the Company will transfer data to the United States and other global jurisdictions. By choosing to visit the Website, utilize the services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Delaware, United States and the adjudication of any disputes arising in connection with the Company or the Website will be in accordance with the Terms & Conditions which can be found at https://www.gemifi.co/terms.
Notwithstanding the foregoing, if you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to processing of your data globally. By providing your personal information, you consent to any transfer and processing in accordance with this Privacy Policy.
The General Data Protection Act (GDPR) provides protections and outlines specific requirements for companies with respect to the processing of Personal Data from the European Union. The Company may develop and implement appropriate policies, processes and controls to achieve GDPR compliance. The Company may also offer European Union Model Clauses, sometimes referred to as the Standard Contractual Clauses, to meet the adequacy and security requirements for our customers that operate in the European Union. If you are an enterprise customer and would like to request a copy of our standard data processing addendum, incorporating the model clauses, please email us at: contact@gemifi.co.
5. Security of your Personal Data
The security of your personal information and data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information and data, we cannot guarantee its absolute security. Any natural or legal person who processes the data on behalf of the Company may have access to your personal information or data. These third-party vendors collect, store, use, process and transfer information about your activity on our platform in accordance with their privacy policies.
6. Disclosure of Your Information
6.1 Information We May Disclose. Some content or applications, including advertisements, on the Website may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy:
● To our subsidiaries and affiliates.
● To contractors, service providers, and other third parties we use to support our business and who may be bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
● To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
● To third parties to market their products or services to you if you have these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
● To fulfill the purpose for which you provide it.
● For any other purpose disclosed by us when you provide the information.
● With your consent.
We may also disclose your personal information:
● To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
● To enforce or apply our Terms of Use which can be found at https://www.gemifi.co/terms and other agreements, including for billing and collection purposes.
● If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6.2 Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
● Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
● Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). You can also always opt-out by sending us an email with your request to contact@gemifi.co.
● Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or by sending us an email stating your request to contact@gemifi.co. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
● Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email with your request to contact@gemifi.co.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.
California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” below for more information.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: contact@gemifi.co. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
7. State Privacy Rights
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia, you may have certain rights in relation to the personal information we collect from you. However, these rights are not absolute, and we may decline your request as permitted by law. These rights include:
● Right to know whether or not we are processing your personal data;
● Right to access your personal data;
● Right to correct inaccuracies in your personal data;
● Right to request the deletion of your personal data;
● Right to obtain a copy of the personal data you previously shared with us;
● Right to non-discrimination for exercising your rights; and
● Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).
Depending on the state you live in, you may also have the following rights:
● Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota);
● Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland);
● Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon);
● Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota);
● Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California); and
● Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida).
To exercise these rights, please contact us at: contact@gemifi.co.
If you are a California resident, you have the right to request that the Company discloses the specific personal information and categories we have collected about you. To request this information, please contact us at: contact@gemifi.co. You can also request to have your personal information deleted that has been collected about you. To submit a deletion request, please contact us at: contact@gemifi.co.
8. Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Multi-factor authentication is required for remote access to production systems. We employ data leakage prevention mechanisms to prevent unauthorized data exfiltration, and perform daily automated backups of all customer data with geographic redundancy to protect against data loss. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using industry-standard AES-256 encryption and TLS/SSL protocols. We maintain business continuity and disaster recovery plans that are tested annually to ensure service availability.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. In the event of a data breach affecting your personal information, we will notify affected users in accordance with applicable law and our internal incident response procedures.
9. Changes to Our Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
10. Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at: contact@gemifi.co.