Personal Data processed for the following purposes and using the following services:

• • Analytics

    • Fathom Analytics

      Personal Data: Usage Data

  • Backup saving and management

    • Backup on Dropbox and Backup on Google Drive

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Building and running Gem X

    • WordPress (self-hosted)

      Personal Data: Data communicated while using the service; password; payment info; username

  • Collection of privacy-related preferences

    • iubenda Privacy Controls and Cookie Solution

      Personal Data: IP address; Trackers

  • Contacting the User

    • Contact form

      Personal Data: address; company name; email address; first name; last name; phone number

    • Mailing list or newsletter

      Personal Data: email address; first name; last name

    • Phone contact

      Personal Data: phone number

  • Content commenting

    • Comment system managed directly

      Personal Data: first name; last name; username

  • Data transfer outside of the UK

    • Data transfer abroad based on consent (UK), Data transfer abroad based on standard contractual clauses (UK) and Data transfers according to a UK adequacy regulation

      Personal Data: various types of Data

  • Data transfer outside the EU

    • Data transfer abroad based on consent, Data transfer abroad based on standard contractual clauses and Data transfer to countries that guarantee European standards

      Personal Data: various types of Data

  • Displaying content from external platforms

    • Font Awesome, Google Fonts, Google Maps widget and Instagram widget

      Personal Data: Trackers; Usage Data

    • Vimeo video

      Personal Data: Cookies; Usage Data

  • Handling payments

    • Stripe and PayPal

      Personal Data: various types of Data as specified in the privacy policy of the service

    • Apple Pay and Android Pay

      Personal Data: email address; first name; last name; various types of Data as specified in the privacy policy of the service

  • Handling productivity related activity

    • Google Workspace

      Personal Data: email address; first name; last name

    • Google Sheets

      Personal Data: email address; first name; last name; physical address; username

    • Basecamp

      Personal Data: Usage Data

    • Google Docs

      Personal Data: Data communicated while using the service

  • Hosting and backend infrastructure

    • Google Cloud

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Infrastructure monitoring

    • Uptime Robot

      Personal Data: various types of Data as specified in the privacy policy of the service

  • Interaction with external social networks and platforms

    • PayPal button and widgets

      Personal Data: Cookies; Usage Data

  • Managing contacts and sending messages

    • Mailchimp

      Personal Data: email address; first name; last name; phone number; physical address

    • Brevo email

      Personal Data: email address; Trackers; Usage Data

  • Managing web conferencing and online telephony

    • Zoom

      Personal Data: contact details; first name; geography/region; last name

  • Registration and authentication provided directly by Gem X

    • Direct registration

      Personal Data: city; company name; country; email address; field of activity; first name; last name; password; phone number; profession; username; various types of Data

  • Spam and bots protection

    • Google reCAPTCHA

      Personal Data: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data

    • Cloudflare Bot Management

      Personal Data: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code

  • Traffic optimization and distribution

    • Cloudflare

      Personal Data: Cookies; various types of Data as specified in the privacy policy of the service

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• • Selling goods and services online

    The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
    The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Gem X depends on the payment system used.

  • The Service is not directed to children under the age of 13

    Users declare themselves to be adult according to their applicable legislation. Minors may use Gem X only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use Gem X.

  • Transfer of Data outside of Switzerland based on standard data protection clauses

    If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland, if such transfer is carried out according to standard data protection clauses previously approved, established or recognized by the Federal Data Protection and Information Commissioner.
    This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by Swiss law. For further information, Users are requested to contact the Owner through the contact details provided in this document.

  • We do not collect personal data about Colorado consumers below the age of 13

    We do not knowingly collect personal data of Colorado consumers who are below the age of 13 nor do we sell or process their data for targeted advertising purposes.

  • We do not collect personal data about Connecticut consumers below the age of 13

    We do not knowingly collect personal data of Connecticut consumers who are below the age of 13 nor do we sell or process their data for targeted advertising purposes.

  • We do not collect personal data about Utah consumers below the age of 13

    We do not knowingly collect personal data of Utah consumers who are below the age of 13 nor do we sell or process their data for targeted advertising purposes.

  • We do not collect personal data about Virginia consumers below the age of 13

    We do not knowingly collect personal data of Virginia consumers who are below the age of 13 nor do we sell their data or process them for targeted advertising purposes.

  • We do not collect personal information about California consumers below the age of 16

    We do not knowingly collect personal information of consumers who are below the age of 16 nor do we sell or share it.

  • Transfer of Data outside of Switzerland to third countries that guarantee an adequate level of data protection

    If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland to a destination country, or international organization guaranteeing an adequate level of protection of the Data according to a decision of the Swiss Federal Council.

  • Transfer of personal information outside of Brazil based on contracts and other legal means

    We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.

    To do so, we may use one of the following legal means:

    • specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
    • standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
    • global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
    • seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.

  • Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD

    We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
    The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:

    • the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
    • the nature of the personal information subject to the transfer;
    • the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
    • the adoption of suitable security measures;
    • the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
    • any other pertinent circumstance related to the relevant transfer.

Contact information

• • Owner and Data Controller

    Gem X LLC
    1251 Avenue of the Americas
    NY, NY 10020
    United States
    +1 (917) 816-7177

    Owner contact email: members@gemx.club