Last Updated: 3.12.2025

This Privacy Policy explains how GEM Global Equities Management S.A. (“Company”, “we”, “us”, or “our”) collects, uses, stores, and protects personal information in accordance with the Bahamas Data Protection (Privacy of Personal Information) Act, 2003 (“DPA”). By accessing www.gem.bs or any associated pages (the “Site”), you acknowledge that you have read and understood this Policy.

Our Site is primarily informational; however, certain personal data may be collected automatically or voluntarily when you interact with us. This Policy outlines how such information is handled.

1. Information We Collect

Because our Site is informational, the personal data we collect is limited. Depending on how you interact with the Site, we may collect:

1.1. Information You Provide Voluntarily

You may provide personal information when interacting with the Site, including:

• Full name, email address, phone number, or company details when completing a contact form
• Information included in messages, inquiries, or requests submitted to us
• Any other information you choose to disclose voluntarily

We do not request or process sensitive categories of data (e.g., health, biometric, financial account data).

1.2. Automatically Collected Information (Cookies & Similar Technologies)

When you visit the Site, certain technical data is collected to ensure proper functioning and security:

• IP address and general geolocation
• Browser type, version, and device type
• Operating system
• Pages viewed, links clicked, date and time of access
• Access duration and browsing behavior
• Referring website (if applicable)

This information is collected through cookies and similar technologies (see Section 7).

2. Purpose of Processing

We process personal data only for lawful, explicit, and legitimate purposes, including:

• Responding to inquiries submitted through the Site
• Providing information about our services upon request
• Operating, maintaining, and improving the Site’s functionality
• Conducting analytics to understand visitor behavior and enhance user experience
• Detecting, preventing, and investigating security incidents or misuse
• Complying with legal and regulatory requirements applicable to financial and corporate entities in The Bahamas

We do not conduct automated decision-making or profiling.

3. Legal Basis for Processing

In accordance with the DPA, our legal bases include:

• Consent — for optional cookies or when you choose to submit information via a form
• Legitimate interests — improving the website, ensuring security, responding to user queries
• Compliance with legal obligations — where regulatory or statutory reporting is required

4. How We Share Personal Information

We may disclose limited personal data to the following parties:

4.1. Service Providers

Trusted third parties engaged to support Site operations, such as:

• Website hosting companies
• IT support and maintenance providers
• Analytics and performance monitoring tools (aggregated data only)

These parties operate under written agreements requiring confidentiality and compliance with data protection standards.

4.2. Legal or Regulatory Authorities

We may disclose information if required to:

• Comply with Bahamian laws, court orders, or regulatory obligations
• Cooperate with supervisory bodies (e.g., Securities Commission of The Bahamas)

4.3. Corporate Transactions

If GEM undergoes a merger, restructuring, or acquisition, personal data may be transferred under legally compliant safeguards.

5. International Transfers

If personal data is transferred outside The Bahamas (e.g., to cloud providers or analytics tools), we ensure that:

• adequate safeguards are in place, and
• the receiving parties provide comparable protection as required under the DPA.

6. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is legally required.

7. Cookies and Tracking Technologies

7.1. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help provide functionality, security, and improved user experience.

7.2. Types of Cookies Used

Our Site may use the following categories:

1. Strictly Necessary Cookies
   Essential for core site functionality, security, and performance.
2. Performance / Analytics Cookies
   Collect anonymous data on how visitors use the Site, helping us optimize content and navigation.
3. Functional Cookies
   Enable enhanced features such as remembering user preferences or settings.

No advertising or tracking cookies are used.

7.3. Why We Use Cookies

Cookies help us:

• Understand how visitors interact with the Site
• Improve information layout and usability
• Ensure secure and stable operation
• Analyze traffic patterns without identifying individual users

7.4. Managing Cookies

You can control or disable cookies through your browser settings. However, disabling essential cookies may affect site functionality

8. Data Security

We implement reasonable administrative, technical, and physical safeguards to protect personal data from:

• unauthorized access
• alteration or deletion
• accidental loss
• misuse or disclosure

These measures include encryption, secure servers, access controls, and monitoring for security breaches.

However, no online transmission is entirely risk-free, and users provide information at their own discretion.

9. External Links

The Site may contain links to external third-party websites.

We are not responsible for the content, security, or privacy practices of third-party sites and encourage users to review their respective privacy policies.

10. Your Rights Under Bahamian Law

Under the DPA, you have the right to:

• Request access to your personal data
• Request correction of inaccurate information
• Request deletion where legally permissible
• Withdraw consent (for processing based solely on consent)
• Object to processing on legitimate grounds.

Rights requests may be submitted to the addresses below.

Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

info@gem.bs