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Privacy Policy

Last updated: December 23, 2024

Welcome! Thanks for visiting Gemini, a digital asset platform. Use of the words “Gemini,” “we,” “us,” or “our” refer to any or all Gemini entities and their affiliates. This Privacy Policy explains what Personal Information (as defined below) we collect, why we collect it, how we use and disclose it, your choices, any rights you may have, and how you can contact us about our privacy practices. By continuing to use Gemini, you agree to this Privacy Policy. If you do not wish your Personal Information collected, used, or disclosed as described below, or if you are under the age of 18, you should stop accessing our Services. This Privacy Policy does not apply to third party websites, products, or services, even if we provide links to them or they link to us.

Your privacy matters to us so whether you are new to Gemini or a long-time customer, please do take the time to get to know and familiarize yourself with our policies and practices. If you are a job applicant, please refer to our separate Applicant Privacy Statement. Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time in our sole discretion. But don’t worry, you can always find the latest version of this Privacy Policy here on this page.

STATE LAW PRIVACY NOTICE 
As a financial institution under the Gramm-Leach-Bliley Act (“GLBA”), Gemini’s privacy practices are subject to federal law and therefore are exempt from many state privacy laws. For those states with laws that do apply to Gemini’s practices, please see our state-focused privacy disclosures about when we may process your personal data and your corresponding rights, in our State Law Privacy Notice.

ENTITIES YOU ARE ENGAGING WITH
This table below describes which Gemini entity or entities you are engaging with, which determines the means and purposes of processing your Personal Information. If you are a customer based in the European Economic Area, please stop reading and go to this Privacy Policy, which will identify the Gemini entities you are engaging with and how they use your Personal Information.
Your Place of ResidencyServices Provided Your Gemini EntityContact Address

Anywhere outside of EEA and UK

-Fiat services

-Digital Asset services

Gemini Trust Company, LLC NY Entity No: 5002896

(d/b/a Gemini Exchange, LLC in AZ, CA, DE, FL, ID, IL, KS, KY, MA, MI, MN, NC, ND, NM, OH, OR, SD, UT, and VA; d/b/a Gemini Exchange in AK and WA)

600 Third Avenue, 2nd Floor New York, NY 10016

UK

-E-money services

Gemini Payments UK, Ltd Company No: 11497305 FCA Register No: 900988

Suite 1, 7th Floor, 50 Broadway, London SW1H 0BL

UK

-Digital Asset services

Gemini Intergalactic UK, Ltd Company No: 12471710 FCA Register No: 921817

Suite 1, 7th Floor, 50 Broadway, London SW1H 0BL

European Economic Area (EEA)

-E-money services

Gemini Payments Europe Limited Company No: 669681 CBI Reference No: C432664

70 Sir John Rogerson’s Quay, Dublin 2, Ireland

European Economic Area (EEA)

-Digital Asset services

Gemini Intergalactic Europe Limited Company No: 698251 CBI Reference No: C453651

70 Sir John Rogerson’s Quay, Dublin 2, Ireland

United States

-Credit Card

Gemini Constellation LLC

600 Third Avenue, 2nd Floor New York, NY 10016

United States

-Exchange

Gemini Moonbase, LLC

600 Third Avenue, 2nd Floor New York, NY 10016

Any Jurisdiction in which Gemini Derivatives is Available

-Gemini Derivatives

Gemini Artemis Pte. Ltd.

18 Robinson #17-01, 18 Robinson Road, Singapore 048547

Depending on what Gemini products and services you use, we may provide you with an additional consumer privacy notice detailing how we will collect, use, and share your Personal Information for that product or service (each a “Gemini Consumer Privacy Notice”). In the event of any conflict between this Privacy Policy and any Gemini Consumer Privacy Notice, the Gemini Consumer Privacy Notice will control. If you are a retail Gemini customer or a Gemini Credit Card customer, please find your Gemini Consumer Privacy Notice here. 

1. Personal Information We Collect

Personal information typically means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that relates to, describes, is reasonably capable of being associated with or could reasonably be linked to an identified or reasonably identifiable individual. For the purposes of this Privacy Policy, only the definition of personal information from the applicable law of your legal residence will apply to you and be deemed your “Personal Information.”
A. Personal Information we collect from you
We may collect the following categories of Personal Information directly from you:
  • Identification Information, such as name, email, date of birth, phone number, postal address, and/or government-issued identity documents;
  • Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;
  • Financial Information, such as bank account information, routing number, or other financial account information;
  • Correspondence, such as information that you provide to us in correspondence, including account opening and customer support;
  • Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information, such as images and video collected for identity verification, audio recordings left on answering machines;
  • Biometric Information, such as scans of your face geometry extracted from identity documents;
  • Professional or Employment-related Information, such as job title, source of wealth;
  • Institutional Information, such as for institutional customers, we may collect additional information, including: institution’s legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government, and proof of legal existence (which may include articles of incorporation, certificate of formation, business license, trust instrument, or other comparable legal document); and
  • Sensitive Personal Information, such as government-issued identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number) and financial account information.
  • Preferences, such as settings and preferences you select in the Gemini app.
  • Communications, such as survey responses, information provided to our Customer Support team, including communications with interfaces such as chatbots.
  • Referral information, such as your contacts’ phone or email addresses if you choose to invite those contacts to Gemini.

B. Personal Information we collect automatically
We may collect the following categories of Personal Information automatically through your use of our services:
  • Online Identifiers, such as IP address; domain name, geographic location;
  • Device Information, such as hardware, operating system, browser, screen size; and
  • Usage Data, such as system activity, internal and external information related to Gemini pages that you visit, clickstream information, keystrokes, mouse movements, form field entries, recordings of chat sessions or your use of and inputs to other AI-supported tools, and other use and overall engagement with our Services.
Our automatic collection of Personal Information may involve the use of Cookies and other tracking technologies, described in greater detail below.

C. Personal Information we collect from third parties
We may collect and/or verify the following categories of Personal Information about you from Third Parties:
  • Identification Information, such as name, email, phone number, postal address;  
  • Financial Information, such as bank account information, routing number. When you use third party services (for example, when you connect your Gemini account to your bank account) or websites that are linked through our Services, the providers of those services or products may receive information that Gemini, you, or others share with them. Those third party services are not governed by this Privacy Policy, and their own terms and privacy policies will apply to those products and services;
  • Transaction Information, such as public blockchain data (bitcoin, ether, and other Digital Assets are not truly anonymous). We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you; 
  • Credit and Fraud Information, such as credit investigation, credit eligibility, identity or account verification, fraud detection, or as may otherwise be required by applicable law;
  • Sensitive Personal Information, such as government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number) and financial account information and
  • Additional Information, as permitted by law or required  to comply with legal obligations, which may include criminal records or alleged criminal activity, or information about any person or corporation with whom you have had, currently have, or may have a financial relationship. 
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned.

D. Combination of Personal information
Please note that we may combine Personal Information that we receive from various sources. For example, we may combine Personal Information that we receive from third parties with Personal Information we already have about you. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.
Please also note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Privacy Policy.


2. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information

The Personal Information we collect 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 use your Personal Information to:
  • Provide you with our services. We use your Personal Information to provide you with our services pursuant to the terms of our User Agreement. For example, in order to facilitate fiat transfers into and out of your account, we need to know your financial information. 
  • Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations. For example, we have identity verification requirements to fulfill our obligations under the anti-money laundering laws of numerous jurisdictions and, as such, we may use an image of an identity document that you provide to help us verify that you are the true owner of the identity document and that the document does not show signs of fraud.
  • Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
  • Protect the security and integrity of our services. We use your Personal Information to further our security-first mentality. Maintaining the security of your account and the Exchange requires us to process your Personal Information, including information about your device and your activity on the Exchange, and other relevant information. 
  • Provide you with customer support. We process your Personal Information anytime that you reach out to our Customer Support team, such as when there are issues arising from your account.  We may use AI third party support services to provide you with streamlined customer support.  We may use anonymized Personal Information to train AI models for internal use only.
  • Optimize and enhance our services. We use your Personal Information to understand how our products and services are being used to help us improve our Services and develop new products. 
  • Market our products to you. We may send you information, newsletters, marketing materials and other customized content and targeted offers from us, and on behalf of, our marketing partners and affiliates. You may use tools that we provide to opt out of these communications from us at any time.
  • With your consent. We may use your Personal Information for additional purposes with  your consent.
  • Other business purposes. We may use your Personal Information for additional purposes in the operation of our business, that would be reasonably expected based on context, and as permitted by law or required  to comply with our legal obligations.


3. How We Share Your Personal Information

We will not share your Personal Information with third parties, except as described below:
  1. Service Providers. We may share your Personal Information with third party service providers for business or commercial purposes. Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, credit verification (including pre-screening for credit offers), security threat detection, payment processing, customer support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your Personal Information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose. Our third party service providers are subject to strict confidentiality obligations.
  2. Affiliates. We may share your Personal Information with our affiliates, for the purposes outlined above, and as it is necessary to provide you with our services. 
  3. Business Partners. We may share your Personal Information to other companies with whom we partner to provide services or other offerings to you and carry out other related activities.
  4. Analytics Partners. We may share your Personal Information to our partners that assist us in performing analytics and help us measure the effectiveness of our services’ content and our marketing and advertising efforts. Please see our section on Cookies and other Tracking Technologies for more information.
  5. Marketing and Advertising Partners. We may share your Personal Information to third parties for marketing and advertising purposes, including social media platforms, third party advertising networks, and other parties that assist us in serving and optimizing our advertisements.  Please see Section 4 on Cookies and other Tracking Technologies for more information.
  6. Legal Obligations. We may be required or in good faith and in our sole discretion as we believe is necessary, to share your Personal Information with law enforcement, government agencies, regulators or third parties to comply with legal or regulatory requirements.
  7. Corporate transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
  8. Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations. 
  9. Consent. We may share or disclose your Personal Information with your consent. 
  10. Other business or commercial purposes. We may share or disclose your Personal Information for other business or commercial purposes as permitted by law. 

If we decide to modify the purposes for which your Personal Information is collected, used, or shared, or our practices relating to your Personal Information, we will amend this Privacy Policy as described below.


4. Cookies and other Tracking Technologies 

When you access Gemini, we make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Gemini. We use Cookies to help us recognize you as a customer, collect information about your use of Gemini to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure compliance with our Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) program (“BSA/AML Program”), (ii) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities, and (iii) assess and improve our services and advertising campaigns. 

Third party tracking technologies are not controlled by us, and statements regarding our practices do not apply to these third parties or their use of information. We make no representations regarding the policies or practices of such third parties. You may be able to opt out of the practices of some of these third parties if they are members of the Network Advertising Initiative (“NAI”) by visiting http://www.networkadvertising.org/choices or if they participate in the Digital Advertising Alliance (“DAA”) by visiting http://www.aboutads.info/choices. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.

You also can learn more about Cookies by visiting https://www.allaboutcookies.org, which includes additional useful information on Cookies and how to block Cookies on different types of browsers and mobile devices. 

Our use of Google Analytics and Advertising technologies: Our website uses technology provided by Google to facilitate advertising and reporting. We implement Google Analytics Cookies to collect personal information about you when you visit our website for purposes of remarketing, impression reporting, and demographic and interest reporting. These Cookies count traffic visits to our website and traffic sources so we can measure and improve our Services. This information includes identifiers and data about the pages you visit, and can be combined with other data related to you collected through Google’s advertising cookie or other third party technology.  You can opt-out of the use of this technology through the Google Analytics opt-out browser add on, Google Ad Settings, Ad Settings for mobile apps, or the NAI’s consumer opt-out.

We use first party and third party Cookies for marketing purposes. These advertising cookies allow us to serve personalized advertising on our Services or to serve advertising on other third party sites that may be of interest to you. You may see advertising from us on the internet after you visit our Services. The information collected and shared during this process is anonymized and does not contain details or other personal information that can be used to directly identify you. 

You may opt out of Cookies on your device at any time by going to our homepage or opting out at the account level on your Account Settings page. Some strictly necessary Cookies, such as those used for security purposes and to detect fraud on your account, are essential for the performance of our Services and therefore cannot be switched off.


5. Direct Marketing

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may opt-out of such marketing communications at any time by visiting the Exchange tab of your Account Settings page. You may also opt-out of such communications by following the directions provided in any marketing communication. If you opt out of marketing communications, please note that we may still send you necessary information about transactions or our business relationship. It is our policy to not provide your Personal Information to  third parties for their own direct marketing purposes without your consent. 


6. Children’s Personal Information

Gemini is not intended for children under the age of 18 and we do not knowingly collect Personal Information of children under the age of 18. If we learn that we have collected any Personal Information from a child under the age of 18, we will promptly delete it from our systems.


7. Information Security

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your Personal Information from loss, theft, or misuse, and from unauthorized access, disclosure, alteration, and destruction. Nevertheless, no security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Gemini and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take may include encryption of the Gemini website communications with SSL; required two-factor authentication for all sessions; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our 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.


8. Retention

We retain your Personal Information for as long as is reasonably necessary to provide services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account with us, we will continue to retain your Personal Information as necessary to comply with our legal and regulatory obligations, including for fraud monitoring, detection and prevention; and for our tax, accounting, and financial reporting obligations. 


9. International Transfers

Gemini is a global business. As a result, Personal Information may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Information that we maintain about you to recipients in countries other than the country in which the Personal Information was originally collected. Those other countries may have data protection or privacy rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Information remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

If you are located in the European Economic Area (“EEA”), the UK or Switzerland, and are provided services by Gemini Payments UK, Ltd and Gemini Intergalactic UK, Ltd, we comply with applicable law to provide an adequate level of data protection for the transfer of your Personal Information to the US or other third countries. Gemini enters into the appropriate data processing agreements and, if required, standard contractual clauses for the transfer of data which have been approved by the applicable data protection regulatory authority. 

10.  Information For Persons Subject To UK Data Protection Laws

If you are located in the UK and are provided services by Gemini Payments UK, Ltd, and Gemini Intergalactic UK, Ltd, we adhere to relevant UK data protection laws and provide individuals with the following additional information. For purposes of this section, “personal data” has the meaning provided in the General Data Protection Regulation (EU) 2016/679 as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“GDPR”). 

Lawful bases for processing 
We process personal data subject to GDPR on one or more of the following legal bases:
  • Legal Obligation: to conduct anti-fraud and identity verification and authentication checks and to fulfill our retention obligations; 
  • Contractual Obligation: to satisfy our obligations to you under our User Agreement, including to provide you with our services and customer support services, and to optimize and enhance Gemini;
  • Legitimate Interest: to monitor the usage of Gemini, conduct automated and manual security checks of our service, to protect our rights; and
  • Consent: to market Gemini and our services to you. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn. 
Privacy rights
UK Residents have the following rights under applicable data protection laws, subject to certain exceptions provided under the law, with respect to their personal data:
  • Rights to Access and Rectification. You may submit a request that Gemini disclose the personal data that we process about you and correct any inaccurate personal data.
  • Right to Erasure. You may submit a request that Gemini delete the personal data that we have about you. 
  • Right to Restriction of Processing and Right to Object. You have the right to restrict or object to our processing of your personal data under certain circumstances.
  • Right to Data Portability. You have the right to receive the personal data you have provided to us in an electronic format and to transmit that Personal Information to another data controller.
When handling requests to exercise your privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request. 
Automated decision-making 
We may engage in automated decision-making for purposes of fraud detection and prevention. When we do, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, including the right to obtain human intervention, to express your point of view and to contest the decision.


11. Updates To this Privacy Policy 

We may change this Privacy Policy from time to time to reflect changes to our privacy practices, enhance user experience, or comply with relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy. If we change the Privacy Policy in a material way, we will provide appropriate notice to you. Such notice may be provided via a temporary banner on our Site, an email sent to users for whom we have an email address, or by temporarily noting “UPDATED” next to the Privacy Policy link on the footer of our Site. Your continued use of Gemini after our posting of changes to this Privacy Policy means that you understand and agree to such changes. 


12. Contact Us

If you have questions or concerns regarding this policy or our processing of your Personal Information, please feel free to email us at: privacy@gemini.com; or write to us at: Gemini Trust Company, LLC, 600 Third Avenue, 2nd Floor, New York, NY 10016 or Gemini Payments UK, Ltd or Gemini Intergalactic UK, Ltd, 1 Poultry Office 02-102, London, United Kingdom EC2R 8EJ.
If you are located in the UK and you believe that we have not adequately resolved any such issues, you have the right to contact the Information Commissioner’s Office here. You may also contact our Data Protection Officer in relation to the processing of your personal data by emailing DPO@gemini.com.

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