GEM4ME Privacy Policy

(Last Updated: August 2019)

This Privacy Policy (“Policy”) applies to users of GEM4ME platform (“Platform”) operated by GEM4ME CUSTODIAN SERVICES LTD ("us", "we", or "our") on data exchange related matters. 

You accept the Policy upon registration with the Platform. Without accepting it in full users cannot use the Platform. By accepting it you confirm that you gave your informed, unambiguous and specific consent freely for processing of your data as defined hereof, including your personal data.

This Policy is based on the principles set forth in the Regulation (EU) 2016/679 dd. April 27, 2016 (General Data Protection Regulation) coming into force as of May 25, 2018 (“GDPR”).

In this Policy:

Data or combination thereof can constitute your personal data if it can identify you as a person.

Who we are? 

In respect to your personal data we are a data controller. As a data controller we determine the purposes and means of processing personal data. We shoulder responsibility for it under applicable law. 

As a data controller, we are ready to:

among other actions set forth in this Policy.


What data we process?

We collect the data about you ourselves or through third parties when:

If you permit the Platform to synchronize with your phone book you can see who also uses the Platform. 

We process the data on your activity via the Platform which covers: 


We process data on the device through which you access to the Platform, e.g. device ID, operating system, your browser, browser or operating system language, wireless network and your mobile carrier, IP address. 

We process the following data:

We collect other data from you which is not specifically listed above. 

We need the data so that you are able to use the Platform. Without the data the use of the Platform or its certain function can be limited or impossible. 

Ordinarily we do not keep your messages, calls and content shared via the Platform. Such data is automatically deleted after their delivery. If the data is not delivered within up to 2 weeks it is also deleted automatically.

You keep this data on the device though which you use the Platform. The only information we keep about the messages is status and time of delivery.

We do not collect sensitive data on your ethical origin, biometric data, health data, political, religious or philosophical beliefs, union memberships, genetic, health or sex life among other sensitive personal data.

If you disclose your personal or sensitive data to public through the Platform voluntarily and at your choice you become solely responsible for the outcome of such disclosure.

Billing information

We do not collect and otherwise process your billing information, e.g. credit card, name, address, expiration date and security code. You send such data to a responsible third-party service provider through the Platform interface. 

We only process information about your transactions to provide you with functionality of the Platform which activates when we receive payment confirmation from the payment provider.


Cookies are text files placed on your computer. Cookies are sent to your browser from a website and stored on your device. 

By registering with the Platform you consent that we can collect data on your use of the Platform through cookies.

We use cookies to enhance your experience in using the Platform, e.g. by remembering your log-in status and viewing preferences from earlier use of the Platform for later use.

The cookies we use cover: 

You can adjust your browser settings to prevent receiving cookies or to provide notification whenever a cookie is sent to you. 

If you do this certain functionality of the Platform can be limited.

You can also adjust your cookies preferences for Google remarketing services through

Why we use your data?

The data we collect from you let you use the Platform and helps our mission in creating best experiences for you from using the Platform.

We use your data to:

We can notify you via your phone number or email, including, to:

You can disable this at any time via your account settings. In this case you will be unable to use such features.

Google (Google LLC) serve advertising services based on your interaction with the Platform by using cookies and data related to your use of the Platform. You can opt-out the services through

Google (Google LLC) host the data and provide infrastructure which enable the Platform to run. Google provides services using outside the EU in compliance with the GDPR as a participant of the Privacy Shield Framework:

Retention of personal data

We keep your data as long as it is necessary for the relevant purposes of their processing. 

We can process your personal data after processing purpose is achieved if:

If you delete your Platform account we will delete your personal data quickly and permanently. Personal data and payment data cannot be deleted if it is necessary to comply with law. 

We will keep your certain non-personal data on your use of the Platform, including your communication with customer service, for statistics purposes so that we can understand how the Platform is used and can be improved.

For more information about data retention terms in relation to specific personal data, please contact us at

Who can access to your data?

We do not share your data with third parties unless set forth hereof and under law. 

To perform our obligations set hereof and in other Platform-related documents the following parties can access your data:

If we share your personal data with our subsidiaries and third parties we guarantee an adequate level of protection, including by entering into standard data protection clauses adopted by the European Commission.

We do not provide your personal data to third parties without your consent.

We share your non-personal data which cannot identify you with third parties for statistics purposes, e.g. for third-party providers who provide us data on our targeted audience, our users’ behavior.

What rights do you have in respect to your personal data?

Under the General Data Protection Regulation (GDPR) you can exercise certain rights in respect to your data. You can exercise them by contacting us via

You can receive:

If the request affects the rights and freedoms of other users or is manifestly unfounded or excessive we can charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. 

You must provide to us your correct, accurate and up-to-date personal data. If it is inaccurate or incomplete you must change such data via the Platform account. Otherwise, we can ban your Platform account.

You can delete your personal data by withdrawing your consent in respect to the requested scope.  

Removal of certain data can result in impossibility to use the Platform in full or in part. 

When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR you can object to this processing. If you object we will no longer process your personal data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims. 

You can always lodge a complaint at a supervisory authority.

You can obtain restriction for processing of your personal data under article 18 of the GDPR.

You can receive your personal data in a structured, commonly used and machine-readable format and transmit it to another controller as set forth in article 20 of the GDPR. 

What happens to your data on third-party websites or apps?

The Platform contains links to third-party websites or services. The Policy does not apply to such websites and services and we are not responsible for their privacy practices. 

To learn how your data is processed though such websites and services please read their privacy policies.

How we protect your data?

We use technical and organizational measures to protect your personal and non-personal data against accidental or unlawful destruction, alteration or loss, unauthorized disclosure or access. 

We take reasonable measures possible, including application of encryption, and required by law to keep confidentiality and secrecy of your data, to keep it safe and prevent unauthorized access and maintain data security.  

Do we transfer your data abroad?

By registering with the Platform you consent that your data is transferred abroad if necessary to provide you with access to the Platform. 

In this case your data is treated securely and in accordance with this Policy using an adequate level of protection as set forth in GDPR. Such measures cover EU standard contractual clauses and EU Commission adequacy decisions, including application of the Privacy Shield Framework by our processors. 

As we operate internationally and provide access to the Platform users worldwide your account data, e.g. nickname among other data which you make available to other users, can become available to users outside your state. 

Who must consent to personal data processing? 

The minimum age to create the Platform account is 13. The Platform will not knowingly collect personal data from children under this age. 

If certain countries apply a higher age of consent for the collection of personal data we require parental consent before registration of the Platform account and collection of their personal data. 

If you are a parent or guardian and you are aware that your child provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent we take steps to remove that information from the Platform.

How do you know on amendments to the Policy?

We can amend or update our Policy. We notify you on such amendments by posting the “Last Modified” date in the document. Your continued use of the Platform confirms your acceptance of new Policy as amended. 

If you do not agree to our Policy regularly time to time.

Contact Us

If you still have questions about our privacy policy, please feel free to send us an email to, or a request to the requisites  “contact us” section.