Privacy Policy

This Privacy Policy ("Policy") describes how GEMtrust DAO ("GEMtrust DAO," "we," "us," or "our") may collect, use, and disclose information about participants and visitors to the Site and Services. Please read this Policy carefully and contact us with questions at office@gemdicom.com.

0. Applicability of This Policy

This Policy applies to our Services, which include the website and associated services provided in connection with Gem DiCom (collectively, the "Site" and "Services"). IF YOU DO NOT AGREE WITH THIS POLICY, DO NOT ACCESS OR USE THE SITE OR SERVICE.


1. Information We Collect

1.1 Personal Information: We collect personal information necessary for your participation in Gem DiCom. This may include your name, contact details, identification documents required for KYC/AML compliance, and transaction-related information.

1.2 Usage Data: We collect data on your interactions with our Services, such as transaction history and participation-related activities.

1.3 Technical Information: We may collect technical information such as IP addresses, browser type, and operating system for security and analytical purposes.


2. How We Use Information

2.1 Service Provision: To manage your accounts, process transactions, and provide participant support.

2.2 Security: To implement security measures, prevent fraud, and ensure the integrity of our systems and data.

2.3 Compliance: To adhere to legal and regulatory requirements.

2.4 Communication: To send essential updates or respond to inquiries related to your participation in Gem DiCom.

2.5 Marketing: We may use your contact details to send institutional communications relating to Gem DiCom, including material updates, governance notices, or service-related information. Participants may opt out of non-essential communications by contacting us at office@gemdicom.com.


3. How We Share & Disclose Information

3.1 With Your Consent: We may share personal information with third parties for their marketing purposes, but only with a Participant's explicit written consent, and provided that such data cannot reasonably be used to identify any individual Participant.

3.2 To Comply with Our Legal Obligations: We may share your information to cooperate with regulatory or government investigations; when required by a subpoena, court order, or similar legal procedure; if we reasonably believe it necessary to prevent harm to another person; to report illegal activity; or to investigate violations of our Terms of Participation or other applicable policies.

3.3 With Service Providers: We may share your information with third-party service providers engaged to assist with compliance, custody, technology, and operational services. These service providers are contractually bound to use such data exclusively for the services they provide to GEMtrust DAO.

3.4 During a Change to Our Business: In the event of a merger, acquisition, or sale of assets, Participant information may be transferred subject to confidentiality arrangements consistent with this Policy.

3.5 Aggregated or De-identified Data: We may share aggregated and/or anonymized data with others for their own uses.


4. Data Security Measures

4.1 GEMtrust DAO utilizes institutional-grade security protocols to protect Participant data from unauthorized access, disclosure, alteration, or destruction. This includes measures such as data encryption, secure server infrastructure, and regular security audits.

4.2 Participants are solely responsible for maintaining the security of their own access credentials and account information. GEMtrust DAO is not liable for any losses arising from a Participant's failure to maintain appropriate security measures.

4.3 Our partners, including those responsible for the institutional custody of underlying gemstone assets, are contractually required to adhere to strict confidentiality and data security standards.


5. Transparency and User/Participant Control

5.1 Participants have the right to access and control their personal data held by GEMtrust DAO. Participants may request information about stored data, correct inaccuracies, or request deletion of their data where legally and operationally permissible.

5.2 GEMtrust DAO is committed to transparency regarding its data policies, regularly reviewing and updating these to reflect changes in our processes or applicable laws.


6. Compliance with Laws and Regulations

6.1 GEMtrust DAO adheres to all applicable data protection laws and regulations in the jurisdictions in which it operates, including internationally recognized standards for data protection and privacy.

6.2 GEMtrust DAO has implemented measures to restrict participation in Gem DiCom from jurisdictions where such participation may be prohibited or subject to enhanced regulatory requirements.


7. Confidentiality

All parties engaged with GEMtrust DAO agree to maintain the confidentiality of proprietary information, financial details, and operational methods disclosed in connection with their participation in Gem DiCom, except where disclosure is required by applicable law or regulation. This confidentiality obligation survives the termination of any participation arrangement or agreement.


8. Online Tracking Opt-out Guide

8.1 The Site may utilize standard tracking technologies, including cookies, to collect information about Participant interactions with the Site for security and analytical purposes. Participants can manage their tracking preferences using the settings provided by their browser or through applicable third-party opt-out tools.

8.2 You can manage your preferences using the methods provided by your browser or through third-party tools.


9. Privacy Practices

GEMtrust DAO does not sell personal information for monetary or other consideration. We may utilize third-party analytics tools for operational improvement purposes. Participants can find opt-out instructions in the 'Online Tracking Opt-Out Guide' section of this Policy.


10. Privacy Rights

Participants may have the following rights in relation to their personal data, subject to applicable law:


  • Right of Access: To request confirmation of whether GEMtrust DAO holds personal data and to receive a copy of such data.
  • Right to Erasure: To request deletion of personal data where no longer necessary or where consent has been withdrawn.
  • Right to Data Portability: To receive personal data in a structured, commonly used format.
  • Right to Withdraw Consent: To withdraw consent at any time where processing is based on consent.

    • To exercise any of the above rights, please contact GEMtrust DAO at office@gemdicom.com. GEMtrust DAO will respond within the timeframe required by applicable law.


    11. How to Submit a Request

    To submit a request relating to personal data held by GEMtrust DAO, including requests for access, rectification, or deletion, please contact us at office@gemdicom.com. All requests will be assessed and responded to in accordance with applicable data protection law.


    12. Identity Verification

    GEMtrust DAO will request identity verification before providing a substantive response to any data-related request. This measure is implemented to protect Participant data from unauthorized access or disclosure.


    13. Authorized Agents

    Participants may designate an authorized agent to submit data-related requests on their behalf, provided that such agent holds prior written authorization confirming their authority to act. GEMtrust DAO reserves the right to verify the authorization directly with the Participant.


    14. Updates to This Policy

    GEMtrust DAO reserves the right to update this Policy at any time. Any changes will be reflected in the "Last Updated" date at the top of this page. Participants are encouraged to review this Policy periodically. In the event of material changes, GEMtrust DAO will endeavour to provide advance notice via email or through the Services.