What Information We Collect; the Purpose of Collection and Use
Gemini’s platform may collect your IP address and this information will be used by Gemini Advisory for security purposes.
Information We Collect Directly from You (Contact Information)
When you contact us via our Website or sign up to receive our newsletters or Product information on the Website, we collect the contact information you provide, via browser forms or online request forms or via email, which may include: name, e-mail address, name of your organization and phone number. We do not collect any contact information from you when you use the Website unless you provide us with the contact information voluntarily.
This contact information is used by our sales, support and Product teams to contact our visitors, customers and distributors for the purpose of providing the requested information, support, or Products.
Information We Collect from Cookies
Information We Collect for Analytics Services
Like most organizations, we rely on automatic data collection technology, such as Google Analytics and Jetpack when you visit our Website, or license, access or use our Products online. These technology services may collect information on our behalf such as your IP Address, geolocation information, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and other data. This information is collected automatically and anonymized. The third parties we currently work with include the following (click on the links to view these organizations’ privacy policies and find out more about what data they hold about you, what they do with it, and how to opt-out from certain data collection). Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.
In an ongoing effort to better understand our users and the Website, we might analyze your information in aggregate form to operate, maintain, manage, and improve the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Products and the Website to current and prospective business partners and to other third parties for other lawful purposes.
Our Disclosure of Personal Information to Third Parties
Gemini Advisory will not disclose your personal information except as specifically described in this section.
Onward Transfer to Third Parties
WE DO NOT SELL OR RENT YOUR PERSONAL INFORMATION TO THIRD PARTIES. WE DO NOT SHARE YOUR INFORMATION TO SOCIAL NETWORKS OR OTHER PUBLIC OR SEMI-PUBLIC PLACES.
Disclosure to Public Authorities
We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Data Retention Period
Gemini retains Customer Data for the life of the subscription, and up to thirty days thereafter. After this time, data is deleted but may persist in back-ups for up to six months.
We may disclose non-personal information to any third party for any reason in our sole discretion.
Right of Access; Marketing Opt-Out
Accessing and Updating Personal Information
When you use Gemini Advisory services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. All requests, accompanied by proof of identification, should be sent to privacy [at] geminiadvisory [dot] io
Opt-Out for Direct Marketing; Email Management
You may opt out at any time from the use of your personal information for direct marketing purposes by contacting us at [email protected]. Please allow us a reasonable time to process your request. You may manage your receipt of marketing and non-transactional communications by clicking on the “Manage Email Preferences” link located on the bottom of any Gemini Advisory marketing email and following the instructions found on the page to which the link takes you. You cannot opt out of receiving transactional e-mails related to their account or purchase orders inquiries and requests.
Retention of Personal Information
Openness & Data Access
Depending on where you reside (for example, the European Union), you may have several rights regarding Personal Information:
You have the right to request an accounting of all personal information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
You have the right to request that we change any personal information that pertains to you.
You have the right to request that we delete any personal information that pertains to you.
To request an accounting of your personal information, a change to your personal information, or deletion of your personal information, contact privacy [at] geminiadvisory [dot] io.
How We Use the Information
Data Integrity and Quality
Quality of Internet Information
The information we deliver to our clients and customers (that is the aggregated, analyzed and indexed information from public sources), is only as accurate as the original source material itself. Thus, we cannot remove information from a public website, blog, posting, filing or other source, and if the underlying information is erroneous, our index of that information will merely reflect what was posted. Therefore, before you act on any information we may provide to you from public sources, you should undertake reasonable steps to validate the accuracy of the information, not merely its existence. We accept no responsibility to validate the accuracy of information posted by others online, nor does Recorded Future have any ability to do so.
How We Protect Your Information
We take commercially reasonable steps to protect the personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. We monitor for and try to prevent security breaches. If you have any questions regarding which measures and techniques we use, feel free to contact us. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Important Notice to Non-U.S. Residents
Our servers are located in the U.S. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the U.S.
California Privacy Rights
Under California law, specific disclosures are required, and California residents have additional rights regarding their personal information. Please review this section to learn more.
The following details the categories of Personal Information that we collect and have collected over the past twelve (12) months: contact information, including full name and email address; information you submitted for purposes of accessing or using the Products; location information and Internet, including geolocation data; and customer service information.
Under the California Consumer Protection Act of 2018 (“CCPA”), a California consumer has the following special rights:
right to request that the business disclose what personal information it collects, uses, discloses, and sells;
right to request the deletion of their personal information collected by the business; and
the right, at any time, to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information (“right to opt-out”).
Over the past twelve (12) months, we have disclosed the following categories of Personal Information to service providers or other parties for business purposes: contact information, including full name and email address; information you submitted for purposes of accessing or using the Products.
Based on our understanding of the term “sell” under the CCPA, we do not sell your Personal Information.
For any of the above-mentioned rights, you may designate an authorized agent to make a request on your behalf. In the request, you or your authorized agent must provide including information sufficient for us to confirm the identity of an authorized agent. We are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfil your request.
To exercise their rights and request copies of the data collected about them in the past 12 months, that their personal information collected by Gemini Advisory be deleted or to exercise their right of opt out, California residents may make a request at [email protected]. Such request must include sufficient information to allow us to verify that you are the person about whom we have collected personal information and describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Opt-Out Requests may be cancelled by making an Opt-In Request.
We will work to respond to your valid request within 45 days of receipt. We will not charge you a fee for making a valid request unless your valid request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your valid request warrants a fee, we will notify you of the fee and explain that decision before completing your request
We will use the information you provide to make your CCPA rights requests to verify your identity, identify the personal information we may hold about you and act upon your request. We strongly recommend that you submit the email that you used when you registered with the Services. After you submit a CCPA rights requests using one of our forms, you will be required to verify access to the email address you submitted. You will receive an email with a follow-up link to complete your email verification process. You are required to verify your email in order for us to proceed with your CCPA rights requests. Please check your spam or junk folder in case you can’t see the verification email in your inbox. If you are a California resident and have any questions regarding your CCPA rights under this Privacy Notice, please contact us at [email protected].
Right to be free from discrimination. You may exercise any of the above rights without fear of being discriminated against. We are permitted to provide a different price or rate to you if the difference is directly related to the value provided to you by your data.
California Customers may request further information about our compliance with California’s privacy law, and may request to review and request changes to their personal information collected and stored by Gemini Advisory by e-mailing[email protected] or contacting us as stated below.
Shine The Light Law California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes or to find out more about your opt-out rights, please contact us at:
California Do Not Track Disclosure Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.
Gemini Advisory also agrees to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
We will respond to requests within a reasonable timeframe. We retain and use your information as necessary to comply with our legal obligations, contractual statute of limitations, resolution of disputes, and enforcement of our agreements. Please note that we may not be able to delete all of your data upon request depending on the reasons above and the nature of your interactions.