Privacy policy

GEM4ME Privacy Policy

(Last Updated: March 2020)

This Privacy Policy (“Policy”) applies to users of the 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 give 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:

  • “you” or “user” refer to users of the Platform
  • “data” refers to data you provide while registration and use of the Platform with us and other users

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

  • “processing” refers to the actions we take with your data, including collection and storage among other actions which refer to processing under applicable law.

Who are we? 

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

As a data controller, we are ready to:

  • give you information on data we store about you
  • respond to your questions related to the Policy 

among other actions set forth in this Policy.


What data do we process?

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

  • You register with the Platform, namely phone number and geo position. Such data is necessary to use the Platform. You provide other data to us voluntarily and at your discretion only. 
  • You synchronize your phone book, including phone numbers and names, with the Platform. You provide such data voluntarily and at your discretion only. 

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

  • You use the Platform.

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

  • your connection status 
  • whether you've received and read messages
  • data on calls you've made or received and if you are currently on a call
  • content you've accessed and accounts you've interacted with
  • websites you've linked to via the Platform
  • services you use via the Platform
  • from which device you've accessed the Platform

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. 

  • You address your queries to the Platform's customer service. In your queries, you can share data, including your messages and other users’ data. 
  • Third parties provide information about you.

We process the following data:

  • Data about you that other users provide to us after registration through synchronization of phone book, etc.
  • Data related to you from service providers, such data cover payment information on transactions you've made, for example, non-activated functionality of the Platform or data on technical errors related to your use of the Platform 
  • You provide data otherwise.

We collect other data from you that 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, or 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 ethnicity, origin, biometric data, health data, political, religious or philosophical beliefs, union memberships, genetics, 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 own discretion, you become solely responsible for the outcome of such disclosure.

Billing information

We do not collect or 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 that 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 for us to 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 login status and viewing preferences from earlier use of the Platform for later use.

The cookies we use cover: 

  • Session Cookies , which remember your activity on the Platform during the session
  • Preference Cookies , which remember your preferences in the Platform and various settings
  • Security Cookies , which we use for security purposes

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

Doing this can limit certain functionalities of the Platform.

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

Why do we use your data?

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

We use your data to:

  • make the Platform available for you, including, to:
    • register you with the Platform, create your account, and manage your registered account
    • communicate with you and respond to your queries 
    • give you information about your account and respond to your requests on personal data
    • notify you about your contacts who already use the Platform 
  • improve the Platform, including, to:
    • better understand users’ behavior and trends
    • detect potential outages and technical issues 
  • enhance security and safety of the Platform and your data, including to: 
    • prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, and to protect our trademarks
    • send the Platform related notifications 

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

  • restore access to your Platform account
  • respond to your queries
  • communicate on the Platform support–related matters

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

  • Remarketing services 

Google (Google LLC) provides 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

  • host and run the Platform

Google (Google LLC) hosts the data and provides infrastructure that enables the Platform to run. Google provides services used outside the EU in compliance with the GDPR as a participant of the Privacy Shield Framework:

  • comply with our obligations set by law

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:

  • required by law, e.g., for accounting and tax records
  • any violation or abuse has occurred to you or to other users at your fault for as long as is necessary to defend rights and legitimate interests
  • a dispute between us and the user takes place
  • we were summoned and/or subpoenaed not to erase the data at the state body’s request or a court order

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 the law. 

We will keep certain, non-personal data of yours pertaining to your use of the Platform, including your communication with customer service, for statistical 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 by law. 

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

  • We the persons involved in or in charge of the Platform operation and our subsidiaries have access to your data in the scope necessary for providing you with access to the Platform. New owners can access your data if we merge with or are acquired by a business, or are involved in a transaction with a similar financial effect
  • Service providers that process payment, provide customer support, mailing services, hosting and storage and other services can access your data in connection to the Platform, Internet connection, and other network providers for delivery of the data you share via the Platform
  • Other users can see your:
    • Platform account data, e.g., nickname, profile picture. You can control access to other data through your account settings. Additional data can become available if you use certain functionalities of the Platform
    • Data that you share voluntarily, including by sending messages and content
    • State bodies who are authorized to access your data by law

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 be used to identify you, with third parties for statistical 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

  • Right of access

You can receive:

  • information whether your personal data has been retained
  • duplicates of such personal data. 

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. 

  • Right to rectification

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.

  • Right to erasure

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

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

  • Right to object

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.

  • Right to restriction of processing of your Personal Data

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

  • Right to personal data portability

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.

Namely, the Platform provides you with access to Market Space. Processing of your personal data is governed under its own Privacy Policy. You accept it by registering with the Platform.

How do 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, as well as unauthorized disclosure or access. 

We take reasonable measures possible, including application of encryption, and we are required by law to maintain 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 can be transferred abroad if necessary to provide you with access to the Platform and Platform-related services.

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. 

Namely, you can access Market Space via the Platform. To allow you to use Market Space we transfer some of your personal data, e.g., registration data, technical data, to Marketspace Solutions OÜ, which operates Market Space.

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

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 inform users about amendments to the Policy?

We can amend or update our Policy. We notify you about 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. 

To ensure that you agree to our Policy, we recommend that you review it regularly or from 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.