Our website or Services are not directed to persons under the age of 18. We do not knowingly collect Personal Information from anyone under the age of 18 nor knowingly allow such persons to register for the Website or Services. If we learn that we have collected the information from a minor under the age of 18, we will delete that information as soon as possible. If a parent or guardian becomes aware that their child has provided us with Personal Information without the parent’s consent, they should contact us at firstname.lastname@example.org.
What information do we collect and for what purpose?
We gather various types of Personal Information from our customers and website visitors, including, but not limited to, the following types of data:
Information You Provide to Us
When you create a new account to use the Services, we will solicit your consent to connect your email account to your new Gem account (using the OAuth authentication method), thereby providing us with access to your email account, including but not limited to email, contacts, and calendar. Gem accesses and stores a limited subset of data from your account, including name and email address, to provide you with our Services.
For users authenticating via Google accounts; Gem Software’s use of information received, and Gem Software's transfer of information to any other app, from Google APIs will adhere to Google's Limited Use Requirements.
We receive and store any information that you provide to us during your use the Services. For example, through your account settings, sending emails and InMail, creating lists of contacts, inputting contact information, requests for support through customer care, and otherwise using the Services, we may collect Personal Information such as your name, email address, location, phone number, payment information, and third-party account credentials (for example, your log-in credentials for Google Mail or other third party sites). Certain information may be required to register with us or to take advantage of some of our features.
In addition, we collect Personal Information you submit to us, for example by completing a form on our website or participating in a Gem event. In that case, we may communicate with you, for example by calling you at the phone number you provide or emailing you about your use of the Services. If you do not want to receive communications from us but believe we have your Personal Information, please indicate your preference by sending an email to email@example.com.
Information Collected Automatically
In connection with your use of the Services, we may also collect information created or provided by you, or that we otherwise receive, in connection therewith. For example, if your contacts send messages to you, we may collect and maintain the message data, which may include Personal Information.
What is our legal basis for processing in the EU?
Providing your Personal Information may be a requirement necessary to enable your use of the Services, including for the performance of certain services and functionalities, such as replying to and managing requests for information, questions, communication or feedback. In these circumstances, refusal to provide your Personal Information means that we cannot provide the requested services. However, providing your Personal Information for survey, marketing and other profiling purposes is optional; refusal to provide your Personal Information for these purposes will not have any impact on your use of the Services
Where we process your information on the basis of legitimate interests as described in the table above, you have the right to object to, and seek restriction of, this processing.
Information We Share
In certain circumstances we work with third parties to help us provide our Services and this can require us to share your information with these third parties.
We share your information with the following different categories of third-party service providers:
Compliance with our legal obligations and protecting our rights.
Data storage and transfer
For example, we currently use datacenter facilities located in the United States. Countries which are outside the EEA, Switzerland or United Kingdom may not offer the same level of data protection as in your home country, for example there is currently no adequacy decision in respect of the United States. Where the European Commission has recognized a country as providing an adequate level of data protection, Gem may rely on the Commission’s adequacy decision, as applicable, to transfer data.
When transferring data to vendors outside the EEA, Switzerland or the UK, Gem Software relies upon a variety of legal mechanisms including. Standard Contractual Clauses. For a copy of the Standard Contractual Clauses, please contact firstname.lastname@example.org.
In certain limited circumstances, we may use derogations, such as the contractual necessity derogation, where appropriate to process personal data, when there are no other data transfer mechanisms applicable. For example, where the transfer of information is necessary to provide our Services as set out in the Terms of Service.
Your data rights
You can contact Gem to exercise your rights by emailing email@example.com.
We retain Personal Information for as long as you have an open account with us and for 7 years after you close your account. In some cases we retain Personal Information for longer, if doing so is necessary to comply with any legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify any individual personally.
An example of the retention period that applies to certain types of data that we collect is set out below:
How should you contact Gem?
Our main office address is 1 Post Street, 18th Floor, San Francisco, CA 94104, USA.
Last Modified: July 15, 2022