Gemini Privacy Policy (Archived – 2016-06-21)

Last Modified: August 10, 2015

Introduction

Welcome! Thanks for visiting our online platform (“Gemini”), provided by Gemini Trust Company, LLC. By visiting Gemini, you are agreeing to this privacy policy (“Privacy Policy”) so please read it carefully. This Privacy Policy explains what information we collect, why we collect it and how we treat your information.

Your privacy matters to us so whether you are new to Gemini or a long-time user, please do take the time to get to know and familiarize yourself with our practices.

 

I. Information We Collect

Verification Information – Information that you provide during a completed, incomplete or abandoned registration. This may include:

Individual – Your full legal name, date of birth, home address, social security number, a valid email address and phone number. We may also ask for other information that helps prove your identity and address, such as a driver’s license, occupation, or utility bill.

Institution – Institution’s legal name, employer identification number (EIN), full legal name, valid email address and phone number of a legal representative(s), address of principal place of business, proof of legal existence (e.g., state certified articles of incorporation/certificate of formation, current government-issued business license, or trust instrument) and name of beneficial owners and executive management.

Device Information – Information that is automatically collected about your device (such as hardware, operating system, browser, etc.).

Location Information – Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us.

Log Information – Information that is generated by your use of Gemini that is automatically collected and stored in our server logs. This may include device-specific information, location information, system activity and any internal and external Gemini pages that you visit.

Account Information – Information that is generated by your account activity including trading activity, deposits, withdrawals, and order history.

Correspondence – Information that you provide to us in correspondence, including opening an account and with respect to ongoing customer support.

In addition, we make use of the accepted practice of placing Cookies (a tiny data file) on your device to help us recognize you. If you do not consent to the placing of Cookies on your device, please do not use our services.

 

II. How We Use Information We Collect

The information collected and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve Gemini.

We may share information with trusted and contracted service providers that help us operate our platform, systems and detect fraud and security threats. In addition, we may be compelled to share information with law enforcement, government officials and regulators.

For example, we may use your information to:

  1. provide you with our service, including customer support for our service;
  2. optimize and enhance our service, for all users or for you specifically;
  3. conduct anti-fraud and identity verification checks (you authorize us to share your information with our third-party providers who may also conduct their own searches of publicly available information about you);
  4. monitor the usage of our service, and conduct automated and manual security checks of our service; and
  5. create aggregated and anonymized reporting data about our service.

If we propose to sell or buy any business or assets, we may disclose your information in an anonymized form to the prospective buyer or seller of such business or assets. In the event of a merger, acquisition or asset sale of Gemini, we will give you notice if, and before, your information is transferred in a non-anonymized form or becomes subject to a different privacy policy.

We do not sell information to third-parties for the purposes of marketing.

Be aware that bitcoin, ether and other digital assets are not necessary truly anonymous. Generally, anyone can see the balance and transaction history of any public digital asset address. We, and any others who can match your public digital asset address to other information about you, may be able to identify you from a block chain transaction. This is because, in some circumstances, information published in the blockchain (such as your digital asset and IP address) can be correlated with information that we and others may have. This may be the case even if we, or they, were not involved in the transaction. Furthermore, by using data analysis techniques on a given block chain, it may be possible to identify other information about you. As part of our security, anti-fraud and/or identity verification checks, we may conduct such analysis to collect and process such information about you.

 

III. Information Security

We take your privacy very seriously and work hard to protect Gemini and you from unauthorized access to or unauthorized alteration, disclosure or destruction of information we collect and store. In particular we encrypt our online platform with SSL; we require two-factor authentication for all sessions; we review information collection, storage and processing practices; and we restrict access to your information on a need to know basis to Gemini employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

 

IV. Questions

If you have questions or concerns, please feel free to email us at privacy@gemini.com. Please note that whenever you send a message, you will be providing us with your email address, your name if you choose to do so and any information you choose to include in the text of your message. In some cases, other information may be required in order for us to be helpful and address your query or concern.

This Privacy Policy only covers Gemini. Websites linked to and/or from this website are not covered by this Privacy Policy.

 

V. Submissions

We cannot agree to obligations of confidentiality or non-disclosure with regard to information you submit via this website or to one of our email addresses. By submitting information or materials to Gemini, its principals, employees, attorneys and/or agents, you or anyone acting on your behalf, agree that any such information or materials will not be considered confidential or proprietary.

 

VI. Changes

We reserve the right to change this Privacy Policy from time to time to meet our changing needs, but don’t worry, you can always find the latest version (as well as archived older versions) here. Your use of Gemini after any changes have been posted will constitute your agreement to our modified Privacy Policy.