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Our Privacy Policy was posted on 11th JULY 2018 and last updated on 18th JULY 2018 and is produced in accordance with the European Union General Data Protection Regulation (GDPR) 2016/679 and Italian law on personal data protection.

 

The data processor and legal responsible is:

GEM Foundation -- Via Ferrata 1 -- 27100 Pavia, Italy (Tax Code: 96059180180).

 

At the GEM Foundation, we know that you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our privacy policy. By accessing GEM Foundation website properties ("Websites"), or using any of the services provided through the Website you are accepting the practices outlined in this Privacy Policy.

 

Our Websites follow all legal requirements to protect your privacy. Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information.

 

This Privacy Policy does not apply to content you post or otherwise make available to other users or the public via the website. You acknowledge that any Website display name (if you have one) may be displayed to other users when you post content. Any content that you submit to the Website may be widely redistributed through the Internet and other media channels.

 

This policy does not apply to the practices of third parties that GEM does not own or control, or to individuals that GEM does not employ or manage.

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Types of Data Collected

 

• Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to: Email address, Name, Address, State, Province, ZIP/Postal code, City, Cookies and Usage Data.

 

We may use your Personal Data to contact you with newsletters or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

 

• Usage Data

We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

 

• Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

 

Cookies are files with small amounts of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

 

Examples of Cookies we use: session cookies (we use these cookies to operate our Service) and preference cookies (we use these cookies to remember your preferences and various settings).

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Use of Data​

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We use the collected data for various purposes:

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• To provide and maintain our Service

• To notify you about changes to our Service

• To allow you to participate in interactive features of our Service when you choose to do so

• To provide customer support

• To gather analysis or valuable information so that we can improve our Service

• To monitor the usage of our Service

• To detect, prevent and address technical issues

 

To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

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Retention of Data

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We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

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Transfer Of Data​

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Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

 

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

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Security Of Data

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The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

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Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)​

 

If you are from the European Union, GEM Foundation legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

 

GEM Foundation may process your Personal Data because:

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• We need to perform a contract with you

• You have given us permission to do so

• The processing is in our legitimate interests and it's not overridden by your rights

• To comply with the law or in response to valid requests by public authorities

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Your Data Protection Rights Under General Data Protection Regulation (GDPR)

 

If you are a resident of the European Union, you have certain data protection rights. GEM Foundation aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

 

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

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In certain circumstances, you have the following data protection rights:

 

• The right to access, update or to delete the information we have on you.

• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object. You have the right to object to our processing of your Personal Data.

• The right of restriction. You have the right to request that we restrict the processing of your personal information.

• The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format.

• The right to withdraw consent. You also have the right to withdraw your consent at any time where GEM Foundation relied on your consent to process your personal information.

 

Please note that we may ask you to verify your identity before responding to such requests.

 

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Union.

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External Service Providers​

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We may employ or embed third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

 

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

 

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

• Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

 

• Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

 

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

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For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

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http://www.google.com/intl/en/policies/privacy/.

 

• Wix web services and tools

Wix is a service by Wix.com, Inc. that provides hosting and tools to create and manage websites. Wix uses the data collected to track and monitor the use of our Service. For information on how Wix handles our website visitors' data please review sections 8, 12, and 13 of Wix's Privacy Policy available here https://www.wix.com/about/privacy.

 

In accordance with the GDPR, site visitors have the right to access their data or "be forgotten" (to be permanently deleted from your databases). Wix has developed the two main tools to assist you in becoming GDPR compliant:

 

Right to access (click here for instructions:

https://support.wix.com/en/article/getting-a-copy-of-your-customers-data

 

Right to be forgotten (click here for instructions:

https://support.wix.com/en/article/permanently-deleting-your-customers-data

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Children's Privacy​

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Our Service does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

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Changes To This Privacy Policy

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We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

 

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

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Contact Us

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If you have any questions about this Privacy Policy, please contact us by using the contact information we provided on our Contact page.