Data retention policy
We retain Personal Information for as long as you have an open account with us and for 3 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.
Data archiving and removal policy
We retain Personal Information for as long as you have an open account with us and for 3 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.
Data storage policy
We currently use datacenter facilities located exclusively in the United States. Your information will be stored and processed in the United States or other countries where we decide to maintain datacenter facilities in the future. Regardless of what country you reside or supply information from, you authorize us to use, process and store your information in the United States and any other country where we operate, which may have different rules, regulations and protections regarding privacy than those in your jurisdiction.
When transferring data from the European Union, the European Economic Area, and Switzerland, Gem Software relies upon a variety of legal mechanisms, including contracts with our users. Gem Software complies with the EU-U.S. and Swiss–U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area, and Switzerland to the United States. You can find Gem Software’s Privacy Shield certification https://www.privacyshield.gov/list. You can also learn more about Privacy Shield at https://www.privacyshield.gov.
Gem Software is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance — free of charge to you. We ask that you first submit any such complaints directly to us via privacyshield@gem.com. If you aren't satisfied with our response, please contact JAMS at https://www.jamsadr.com/eu-us-privacy-shield. In the event your concern still isn't addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.
Gem Software is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Gem Software complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU and Switzerland, including the onward transfer liability provisions.
Within the scope of our authorization to do so, and in accordance with our commitments under the Privacy Shield, Gem Software will provide individuals access to Personal Information about them. Gem Software also will take reasonable steps to enable individuals to correct, amend, or delete Personal Information that is demonstrated to be inaccurate. App/service has sub-processors
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Guidelines for sub-processors