Privacy Policy


Your privacy is very important to us. GEM, LLC and its related companies (collectively, (“The“Company” or “We” or “Our”)) wants to make your experience on the Internet as enjoyable and rewarding as possible, and we want you to use the Internet’s vast array of information,tools, and opportunities with complete confidence.

We have created this Privacy Policy to demonstrate our firm commitment to privacy and security. This Privacy Policy describes how our company collects information from all end users of the website located at (the “Site” or the “Services”), including those who access our Services. This Privacy Policy also describes how our company collects information from those that visit our site (“Visitors”), from those who apply to GEM’s Investor Network (“Applicants”), and/or those who purchase our subscription Services (“Members”), what we do with the information we collect, and the choices Visitors, Applicants, and Members have concerning the collection and use of such information. We request that you read this Privacy Policy carefully.

How Your Personal Information Is Collected and UsedIntroduction

GEM collects information in different ways from its Visitors who access the various parts of our Services. We use this information primarily to provide a customized experience as you use our Services, and also to collect, transfer, manipulate, store, and disclose for purposes of measuring and improving our Services and to send you information about our Services or to advertise additional services to you. From time to time, we may notify you about new products, announcements, upgrades and updates. You may opt-out of these promotional mailings by clicking on the “Unsubscribe” link at the bottom of any e-mails we send to you.

We use your personal information for the purpose of providing you with the Services, contacting you to deliver certain Services or information you have requested, verifying your authority to enter our Site, improving the content, and general administration of the Site and our Services, providing you with notices regarding Services that you have purchased or may wish to purchase in the future, and for targeted marketing purposes. Social networking websites and APIs on the Site that are operated independently from GEM may collect your personally identifiable information and their collection and use of such information is subject to the terms of their privacy policies, including, without limitation, LinkedIn’s Privacy Policy, etc. Be mindful, if you decide to use your other social media logins to connect to the Site (e.g., LinkedIn, Facebook, Twitter, etc.), then those other social media services may send us your registration or profile information about you from that service and other information that you may authorize from your privacy settings on that social media service.


You may be asked to provide certain personal information when you apply for and/or sign up for our Services such as name, address, telephone number, billing information (such as a credit card number), birth date, and the type of personal computer being used to access the Services.

The personal information collected during the registration process is used to manage your account and to collect such information from you to send periodic e-mails. This information is not shared with third parties, unless specifically stated otherwise or in special circumstances.

Personal information may be collected by Gem when you use our Site and/or Services. Such personal information may include: name, address, email address, date of birth, telephone & fax numbers, payment information and other personal information that you upload or enter into the Site and/or the Services. We may also hold other details from your social networking user profiles (e.g., LinkedIn, Facebook, Twitter, etc.), if you have provided those user identities to us, including, without limitation, your usernames, passwords, birth date, friends, personal interests, gender, education and occupation. Information, which you add to your online public identities, is accessible on the World Wide Web, which is a public domain. You use the Services and post content at your own risk. Other people may view your online public identity and use it (for example, by tagging you, adding you, or including you in a group). You should be aware that if you cancel your Facebook account, “unfollow” on Twitter or delete the Site from your LinkedIn Apps or you cancel your Application and/or Membership or make private information, which you have previously made public on any social networking system, some information may remain on public cache databases, including ours. If you become aware of any information, which you wish to remove, please notify Gem at with the subject line “Remove” and we will take all reasonable steps to remove it. We may be obligated to disclose your personal information in very special circumstances such as when we are required to do so by law or in other special cases, as described below.

We may provide your personal information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our Services to you. For example, we may provide your personal information to a credit card processing company like Stripe or Paypal to process your payment.

In instances where we and a partner jointly promote our Services, we may provide the partner certain personal information, such as the name, e-mail address, age, and username of persons who subscribed to the Services as a result of the joint promotion for the sole purpose of allowing us and the partner to assess the results of the promotion. However, in this instance, personal information may not be used by the partner for any other purpose. We may also generate non- identifying and aggregate profiles from personal information Applicants and/or Members provided during registration. As explained in more detail below, we may use this aggregated and non-identifying information to sell advertisements that appear on the Services.

Our Company Partners and Sponsors Some products and services may be offered to you in conjunction with an affiliate, independent contractor seller or non-affiliated partner using publicly available information. In some instances, to provide you with some of these products and services, the partner may need to collect and maintain personal information. In these instances, you will be notified before any such data is collected or transferred and may decide not to use that particular service or feature.

Additionally, our partners may have advertisements or co-branded Web Pages that are cosponsored by an affiliate, independent contractor seller, or non-affiliated partner. Our company may share non-identifying and aggregate information (except as described above), but not personal information, with such partners in order to administer the co-branded products or services offered.

Online Advertisements

Gem may display our online advertisements. In those cases we share aggregated and non- identifying information about you collected through the registration process as well as through online surveys and promotions with these advertisers.

Additionally, in some instances, we use this aggregated and non-identifying information to deliver tailored advertisements or joint ventures. For instance, an advertiser or joint venture company tells us the audience they want to reach and provides us an advertisement tailored to the audience. Based upon the aggregated and non-identifying information we have collected, we may then display or send the advertisement to the intended audience. We do not share personal information about any of its Members with these advertisers or joint venture companies.

Responses to Email Inquiries

When you send email inquiries to our company from your e-mail accounts, the return email address is used to answer the email inquiry we receive. Our company does not use the return email address for any other purpose and does not share the return email address with any third party. We do not collect e-mail addresses when you send us a communication through our online Contact form.

We may periodically conduct both business and individual customer surveys. We encourage you to participate in these surveys because they provide us with important information that helps us to improve the types of products and services we offer and how we provide them to you. Your personal information and responses will remain strictly confidential, even if the survey is conducted by a third party. Participation in our customer surveys is voluntary.

We may take the information we receive from individuals responding to our Customer Surveys and combine (or aggregate) it with the responses of other Applicants and/or Members we may have, to create broader, generic responses to the survey questions (such as gender, age, residence, hobbies, education, employment, industry sector, or other demographic information).

We then use the aggregated information to improve the quality of our services to you, and to develop new services and products. This aggregated, non-personally identifying information may be shared with third parties.

Special Cases

It is GEM’s policy not to use or share the personal information about you in ways unrelated to the ones described above without also providing you an opportunity to opt out or otherwise prohibit such unrelated uses.

However, we may disclose personal information about you, or information regarding your use of the Services or websites accessible through our Services, for any reason if, in our sole discretion, we believe that it is reasonable to do so, including: credit agencies, collection agencies, merchant database agencies, law enforcement, or to satisfy laws, such as the Electronic Communications Privacy Act, the Child Online Privacy Act, regulations, or governmental or legal requests for such information; to disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Terms and Conditions, or other user policies; to operate the Services properly; or to protect our company and our Visitors, All Applicants, All Members, and Extended Members.

We will not sell or rent your personal information to any company or organization except we may transfer your Application, Memberships and User Profiles to a successor entity upon a merger,consolidation or other corporate reorganization in which GEM participates or to a purchaser of all or substantially all of GEM’s assets to which this Site and the Services relate.

How you can access and correct your personal information or remove material you no longer wish to be accessible via the Site If you wish to access and correct any personal information that we hold about you, or remove any material you have placed on the Site or which is accessible on the Site via any other of your online identities, please contact us at with the subject line,“Personal Information” or “Remove Material” and we will respond to your request as soon as possible, generally within 72 hours. You can access and correct some of the information we hold about you directly on the Site (for example, your profiles and identities information) through the dashboard when you join the Site as an investor, judge or entrepreneur.

What security measures we use

Some of your user information and data you upload to certain Services, such as Social Media Analytics Platforms are password-protected for your privacy and security. We take other reasonable steps to secure your personal information, and to protect it from misuse, loss, unauthorized access or modification. Although we take reasonable steps to protect your personal information, the Internet is inherently insecure and we cannot guarantee that the Site or your information is secure (‘hacker-proof’). When your personal information is no longer required by us, we destroy or permanently de-identify the information.

“Cookies” and How Our Company Uses Them

A “cookie” is a small data file that can be placed on your hard drive when you visit certain websites. We may use cookies to collect, store, and sometimes track information for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. This may include your server address, domain name, date and time you visited the site, pages viewed and the information downloaded and other aggregate data through our use of cookies. If you prefer not to receive cookies, you can adjust your browser to disable or to warn you when cookies are used. By disabling cookies, you will not be able to participate in some of the services offered by us.

We may use a cookie to save your settings and to provide customizable and personalized services. These cookies do not enable third parties to access any of your customer information.

Facebook, Twitter, LinkedIn, advertisers, other social media websites, and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

The GEM Do Not Track Policy

We do not track our Visitors or Subscribers over time and/or across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (DNT) signals.

However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, you can modify the preferences on your browser to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. Please consult your browser for instructions on how to change the preferences to “Do Not Track.”

GEM’s Commitment to Children’s Privacy

Protecting children’s privacy is especially important to us. Therefore we restrict the Site to persons twenty one years or older.


The Site is not aimed at children under 13 years old and we will not collect, use, provide or process in any other form any personal information of children under the age of 13 deliberately.

We therefore also ask you, if you are under 13 years old, please do not send us your personal information (for example, your name, address and email address).

GEMs Commitment to Data Security

Services and websites we sponsor have security measures in place to protect the loss, misuse, and alteration of the information under our control. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining this information.

Where to Direct Questions About GEMs’ Privacy Policy

If you have any questions about this Privacy Policy or the practices described herein, you may contact us by sending an e-mail to with the subject line,

“Question About Privacy.”

Revisions to This Policy

We reserve the right to revise, amend, or modify this policy, our Terms and Conditions of this agreement, and our other policies and agreements at any time and in any manner, by updating this posting.

Last updated: January 21st, 2016


Back to Top