Our Contact Details
GEMUL is a company incorporated and acting under the laws of Estonia with a registry code 14786273.
Our registered Address is at: Roosikrantsi tn 2-1068, Kesklinna linnaosa,Tallinn, Harju maakond, 10119,
Estonia Our contact Email address is: firstname.lastname@example.org
Categories of Personal Information We Collect Include
contact details (phone number, email, residence address)
date of birth electronic identifiers (IP address, browser and operating system information, device fingerprint)
identity documents details (such as driver license, passport)
information on transactions you make on our platform
information on sources of funds
other information you could provide us upon a request
How We Get the Personal Information and Why We Have it
Most of the personal information we process is provided to us directly by you for one of the following purposes:
to enable you open account and operate on
if you contact us, to reply and process your requests
to analyze the use of our Website GEMUL
to comply with regulatory requirements such as (tax, prevention of money laundering and fraud, accounting)
to prevent fraud within providing our services
to provide you with information about products and promotions that may be of interest to you, from ourselves
for market research e.g. surveying our Users’ needs and opinions on issues, such as our performance, etc.
We may also receive some information from publicly available sources or from our contractors (for instance, information on sanctions lists).
We use a browser feature known as a “cookie”, which assigns a unique identification to your computer. Cookies are typically stored on your computer’s hard drive.
Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyse trends, and administer the Platform.
How You can Manage Cookies
You can change your cookie preferences at any time by:
Alternatively, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
Find out how to manage cookies on popular browsers:
Microsoft Internet Explorer
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
Who We Share Personal Information
We may share your Personal Information with:
affiliates, agents and representatives;
financial institutions and payment service providers;
customer communications platforms;
contractors providing software for identification purposes or services on checking against sanctions list;
law enforcement or regulatory agencies, as may be required by law.
International Data Transfer
Our contractors and affiliates may be situated at different locations (including countries located outside the EU. In these cases we may transfer your Personal Information only in the following cases:
if the country where we transfer your Personal Information to provides the adequate level of personal data protection (based on the relevant decision of European Commission);
if we take appropriate safeguards to ensure that your rights as data subject are protected;
if any derogations for specific situations apply (for instance, if is such transfer is necessary for the establishment, exercise or defence of legal claims or for important reason of public interest).
Lawful Bases of Processing
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
Your consent. You are able to remove your consent at any time. You can do this by contacting us at email@example.com
We have a contractual obligation
We have a legal obligation
We have a vital interest
We need it to perform a public task
We have a legitimate interest (for instance, for fraud prevention purposes)
Your Data Protection Rights
Under data protection law, you have rights including:
Your right of access -You have the right to ask us for copies of your personal information.
Your right to rectification -You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure -You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing -You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing -You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability -You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
There may be a minimal charge for providing you additional copies of your Personal Information to cover administrative costs.
Please contact us at firstname.lastname@example.org if you wish to make a request. Where possible, you will be able to exercise your rights in your account profile page yourself.
If you make a request, we have one month to respond to you.
We may request you to confirm your identity by providing identification documentation and/or other methods prior to assisting you in exercising any of your rights. If you refuse to prove your identity, we may decline to take actions in respect of your data, save restricting processing, until we can ensure that such actions are the true wish of the data subject.
In cases when we will not be able to fulfill your requests due to legal obligations or overriding legitimate interests, we will inform you accordingly.
Automated Decision Making
We may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services. Through this automated processing, we carry out an analysis of your identification, transactional and behavioural patterns.
Please note that such processing is necessary to provide you with our services.
If you feel that this processing might be detrimental to you, we can provide you with further information about this automated processing by contacting us on email@example.com
We have implemented technical and organisational measures (TOMs) to ensure security of our platform.
Where you have consented to, or we are obliged to pass on Personal Information to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, we will request that the same levels of technical and organisational security measures from our contractors.
TOMs which we have implemented will be continuously reviewed to be in line with legal and technical developments.
How we store your personal information
Your information is securely stored within our data centers located within the European Union.
We keep your personal data no longer as needed for the purposes indicated in this Policy. As a rule, we will have to store your data for 5 years upon closure of your account within our platform.
We will dispose your information once we do not have any obligation to provide you with a service you requested, nor an obligation to hold personal data for regulatory or legal purpose.
Our Data Protection Officer
Data Protection Officer (DPO) is a person compliance with data protection laws.
Our DPO can be reached at firstname.lastname@example.org
How to complain
If you have questions or concerns about our data protection practices, or wish to exercise your rights under the GDPR please contact us at: email@example.com
If we consider that your rights may be affected by any such changes, we will request you to confirm your consideration and acceptance prior to continue our relationship with you.