Privacy Policy

When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information.

Effective March 1, 2020

Gems (“https://gems.lifology.com,” “we,” “us” or “our”) respects your privacy. This Privacy Policy Statement (“Privacy Policy”) describes the ways we collect information from and about you, and what we do with the information, so that you may decide whether or not to provide information to us. By accessing our website, or purchasing our services, you agree to this Privacy Policy in addition to any other agreements we might have with you. In the event that such agreements contain terms that conflict with this Privacy Policy, the terms of those agreements will prevail.

In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at privacy@lifology.com.

INFORMATION WE COLLECTS

We want you to understand the types of information we collect as you use our services.

We collect information to provide better services to all our users — from figuring out basic stuff like which language you speak, to more complex things like which labor market information you’ll find most useful, the people who matter most to you online, or which lifeware videos you might like. The information Gems collects, and how that information is used, depends on how you use our services and how you manage your privacy controls.

When you’re not signed in to a Gems Account, we store the information we collect with unique identifiers tied to the device you’re using. This helps us do things like maintain your language preferences while using the platform.

When you’re signed in, we also collect information that we store with your Gems Account, which we treat as personal information.


Things you create or provide to us

When you create a Gems Account, you provide us with personal information for App functionality and Account management. Gems may collect the following information (“Personal Information”) and you hereby explicitly consent to the following:

  • Account Opening Information and Account Information: Self-declared User’s details like Parent’s name, Child’s Name, Parent’s Email ID, Parent’s Contact Number, Child’s Gender, Child’s School Name, Child’s Grade, Child’s Stream.
  • User’s Image: We require access to your mobile device camera to take a photo or photos in your device, for uploading your profile photo. Profile Photo would be only used to display it in the Dashboard & Profile screen.

We also collect the content you create, upload, or receive from others when using our services. This includes things like assessment responses, reports based on various assessments you take, photos you save, rating you give after coaching session and other information you save in the platform.

Information we collect as you use our services

We collect information about the apps, browsers, and devices you use to access Gems services, which helps us provide features like automatic product updates. We automatically collect certain information such as when you visit, how much time you spend on the platform, videos you watch, articles you read, purchase activity and use or navigate the sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our sites and other technical information. This information is primarily needed to maintain the security and operation of our sites, and for our internal analytics and reporting purposes.

We use the Firebase service from Google LLC. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) in order to derive application behavioral analytics. We use that information to see how users interact with our website and app.

Firebase is part of the Google Cloud Platform and offers numerous services for developers. A list can be found here: https://firebase.google.com/terms/. Some Firebase services process personal data. In most cases, the personal data is limited to so-called “instance IDs”, which are provided with a time stamp. These “Instance IDs” assigned by Firebase are unique and thus allow the linking of different events or processes. This data does not represent personally identifiable information for us, nor do we make any efforts to personalize it subsequently. We process these aggregated data to analyze and optimize usage behavior, for example by evaluating crash reports.

CHILDREN’S PRIVACY

Gems do not knowingly collect personal data from children under the age of 13. If you are under 18, please be sure to read this section of our Privacy Policy with your parent(s) or legal guardian(s) and ask questions about things you do not understand.

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this section, “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

A school may sign up a child for online websites subject to COPPA and then under the provisions of COPPA, the school transfers such consent to Gems through agreements with schools. This section seeks to provide the relevant notifications under COPPA, including:

  • The types of information we may collect from children.
  • How we use the information we collect.
  • Our practices for disclosing that information.
  • Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
  • All operators that collect or maintain information from children through this website and other marketing programmes.

This section only applies to children under the age of 13 and supplements the other provisions of this privacy policy. Only the other provisions of this privacy policy apply to teens and adults.

INFORMATION WE COLLECT FROM CHILDREN

Children can access many parts of the Service and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Service.

We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary. 

WHY WE COLLECTS DATA

We use the information we collect from all our services for the following purposes:

  • To provide better services – We use your information to deliver our services, like we use unique identifiers stored in cookies on your device to help us authenticate you as the person who should have access to your Gems Account.
  • To maintain and improve our services – We use your information to ensure our services are working as intended, example, we continuously monitor our systems to look for problems. And if we find something wrong with a specific feature, reviewing activity information collected before the problem started allows us to fix things more quickly.

Also we use your information to make improvements to our services. For example, we use cookies to analyze how people interact with our services and that analysis can help us build better products.

  • To develop new services – We use the information we collect in existing services to help us develop new ones.
  • To provide personalized services, including articles and videos – We use the information we collect to customize our services for you, including providing recommendations and personalized contents.
  • Measure performance – We use data for analytics and measurement to understand how our services are used.  We analyze the data for better user experience and service optimization.
  • To communicate with you – We use information we collect, like your email address, to interact with you directly. We may send you a notification if we detect suspicious activity, like an attempt to sign in to your Gems Account from an unusual location. Or we may let you know about the purchase you did, upcoming events and appointments or new features added to our services. Also if you contact us, we’ll keep a record of your request in order to help solve any issues you might be facing.
  • To send you marketing and promotional communications – We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
  • To request Feedback – We may use your information to request feedback and to contact you about your use of our Sites and coaching you take.

HOW WE COLLECT INFORMATION FROM YOU

We collect information from you when you submit it to us, for example, when you request product, services, or information from us, register for an account, register to participate in an event on our social media or website, participate in public forums on the website, or respond to our customer surveys.

We may also:

  • Automatically collect usage, analytics, viewing, logs, metrics and other device and technical data when you access our sites or use the service as an end user. For example, when you access our sites or log into the Gems, our servers will automatically record certain information about your device and browser, and we may collect usage, clickstream, event data, crash data, and other technical data. We, our advertising partners and our service providers may also use technologies such as cookies, beacons, tags, Local Storage Objects (LSOs) (such as HTML5 and Flash LSOs) and scripts to collect this information. Please consult our “Cookie Policy” for further information.
  • Obtain information about you from our resellers or other third-party partners, for example, if you purchase access to the Gems through one of these partners;
  • Acquire information from public sources or from third-party sources, such as our advertising and market research partners, including to update or enhance the other information collected about you. Local law may require that you authorize the third party to share your information with us before we can acquire it; and
  • Automatically acquire information when you reply to or interact with an email/link we send, such as to track your engagement with our messages or when your replies to our messages contain additional email addresses.

HOW WE USE INFORMATION

We may use the information collected to:

  • Process your purchase and requests and respond to your questions and concerns; for example, if you inquire about our services or submit an application to Gems, we may use your data to respond to and process these requests;
  • Provide you with products and services, and personalize your experience; for example, we may use information on your prior activities or job function to tailor the features and content on the Gems services or platform, or we may use technical data to remember your preferences;
  • Communicate with you about your account or payments, and provide you with product-related communications, such as information about new features and policy updates;
  • Operate, maintain, analyze, develop, update and improve our platform, Gems.lifology.com, and other products and services we offer. For example, we may administer and track users’ activities on our platform and Gems to determine how to improve our content and features, or we may analyze trends and gather demographic information about our user base to better tailor our marketing efforts;
  • Detect, investigate and prevent activities that may violate our policies, including our Acceptable Use Policy, or applicable laws (such as fraud detection and prevention) or that may threaten the security, integrity or availability of our or another party’s products, systems and services;
  • Send you news, updates, promotions, product information, event announcements, and other marketing communications.
  • Provide you with and target advertising based on your activity and interests, both on our own platform and applications and on third-party sites and applications;
  • Act pursuant to your consent for a specific purpose not listed in this policy. For example, with your consent, we may post your testimonial along with your name on our platform. If you wish to update or delete your testimonial, please contact us as explained below; and
  • Perform the activities described in our Cookie Policy.

SHARING YOUR INFORMATION

When we shares your information

We do not share your personal information with companies, organizations, or individuals outside Gems except in the following cases:

  • With your consent – We’ll share your personal information including assessment reports and any data we derived from it, outside to Gems when we have your consent. We’ll ask for your explicit consent to share any sensitive personal information.
  • With domain administrators – If you’re registered under a school or school group, your domain administrator, who manage your school or school account will have access to view your assessment report. They can have the permissions to
  • View your assessment report
  • View statistics regarding to your Gems account interactions.
  • Change your Gems account password
  • Suspend or terminate your account access
  • Restrict your ability to delete or edit your information or your privacy settings
  • For external processing – We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
  • For legal reasons – We will share personal information outside of Gems if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to:
  • Meet any applicable law, regulation, legal process, or enforceable governmental request.
  • We share information about the number and type of requests we receive from governments in our Transparency Report.
  • Enforce applicable Terms of Service, including investigation of potential violations.
  • Detect, prevent, or otherwise address fraud, security, or technical issues.
  • Protect against harm to the rights, property or safety of Gems, our users, or the public as required or permitted by law.

We may share non-personally identifiable information publicly and with our partners — like publishers, advertisers, developers, or rights holders.

If Gems is involved in a merger, acquisition, or sale of assets, we’ll continue to ensure the confidentiality of your personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

KEEPING YOUR INFORMATION SECURE

We built with strong security features that continuously protect your information. The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you. And if we do detect something risky that we think you should know about, we’ll notify you and help guide you through steps to stay better protected.

We work hard to protect you from unauthorized access, alteration, disclosure, or destruction of information we hold, including:

  • We use encryption to keep your data private while in transit
  • We offer a range of security features, like Safe Browsing and Security Checkup to help you protect your account.
  • We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems
  • We restrict access to personal information to our employees, contractors, and partners who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

HOW LONG DO WE KEEP YOUR INFORMATION?

How long we keep the personal information we collect depends on the type of information, the purpose for which it is used, how sensitive it is, and similar factors. In general, we will retain your personal information for the length of time reasonably needed to fulfill the purposes outlined in this privacy policy (including for as long as need to provide you or our customer with products and services), unless a longer retention period is required or permitted by law. We will also retain and use your information for as long as necessary to resolve disputes and/or enforce our rights and agreements. Anonymous and aggregated information may be stored indefinitely.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY

We maintain servers around the world and your information may be processed on servers located inside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks relating to the transfer of data, such as the EU-US and Swiss-US Privacy Shield Frameworks.

In particular, Gems complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States and has certified its compliance with it. As such, Gems is committed to subjecting all personal information received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Gems is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Gems is subject to the regulatory enforcement powers of the U.S. FTC.

In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

DATA SECURITY AND INTEGRITY

Gems is concerned about the security of your data. We have implemented technical and organizational security measures that are designed to help protect your information from unauthorized access, disclosure, use and modification. From time-to-time, we review our security procedures to consider appropriate new technologies and methods.

Please be aware, though, that despite our efforts, no security measures are perfect or impenetrable. We cannot ensure, and do not warrant or guarantee, that the information you transmit to Gems will remain secure, nor do we guarantee that this information will not be accessed, disclosed, altered, destroyed or used in an unauthorized manner.

If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on the site or Gems if a security breach occurs. Depending on where you live, you may have a legal right to receive a notice of a security breach in writing. If you have any questions about the security of your personal information, please contact us as indicated in the ‘Contact Us’ section.

USE COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

THIRD PARTY SITES, SERVICES AND APPLICATIONS

  • In General: We are not responsible for the practices employed by websites, applications, or services linked to or from the Gems.lifology.com or platform, including the information or content contained there. Please remember that your browsing and interaction on any third-party website, service or application, including those that have a link or advertisement on our Site, are subject to that third party’s own rules, policies, and practices, and not our privacy policy.
  • Partner Pages: Some of our partner pages may have the look and feel of being on Gems.lifology.com; however some information collected on those pages may be collected by, or sent to, our partners. Information collected by, or sent to, our partners is subject to their respective privacy policies.
  • Social Media and Commenting Features: Our platform may include social media and commenting features provided by third parties. These features may collect your IP address and which page you are visiting on our website, and may set a cookie to allow the feature to function properly. Your interactions with these features are governed by the privacy policy of the organization providing it.
  • Notice to students who registered through schools/School groups to Gems.lifology.com: The Gems.lifology.com are primarily intended for use by Schools/ School groups. Where the Gems are made available to you through school/school group, that organization is responsible for administering the accounts over which it has control. If this is the case, please direct your data privacy questions and requests to your administrator. We are not responsible for the privacy or security practices of your administrator’s organization, which may be different than this policy.

WE HANDLE YOUR SOCIAL LOGINS

Our Sites offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. 

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps. 

YOUR CHOICES AND DATA CONTROL

You can limit the information you provide to Gems. You can also limit the communications that Gems sends to you. To opt-out of marketing emails, you can visit our website and communicate your choice to the relevant privacy contact. Alternatively, you may opt-out of receiving future marketing emails by clicking “unsubscribe” at the bottom of marketing emails we send you.

Please note that even if you opt-out of receiving marketing material, we may still need to contact you with important Transactional Information about your account or your products. For example, even if you opt-out of marketing emails, we will still send you a confirmation when you purchase something from us as well as to provide communications related to our products.

You can manage cookie preferences and opt-out of having cookies and other similar collection technologies used by adjusting the settings on your browser or interface, commonly known as “Do Not Track” settings. All browsers and interfaces are different, so visit the “help” section of your browser or interface to learn about cookie preferences and other privacy settings that may be available. You can manage how your mobile device and mobile browser share location information with Gems, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings. In general, Gems complies and requests that all of its service providers comply with your “Do Not Track” settings you select using your internet browser(s).

Gems complies with applicable law regarding your ability to access, correct, and delete your personal information. If you have an online account, you may be able to log into your account to access and update certain information you provided to us. For personal information that is not linked to an online account, for assisting in opting-out of communications, or if you need assistance updating or deleting your personal information, please contact us via email at privacy@lifology.com. You can also write to us at the address in the Contact Us section. If you send us a letter, please provide your name, address, email address, and detailed information about the change you would like to make.

FOR EU RESIDENTS:

The General Data Protection Regulation (“GDPR”), particularly Articles 15 to 21, affords an EU resident, a number of rights as a data subject.  If you are an EU resident, Gems encourages you to read and learn about those rights on your own.  However, the following will help you to begin to understand those rights afforded to EU residents. 

The Right to Access: This allows you to request from Gems information about your personal information, including what data Gems has and how and why it is being processed.

The Right to Rectification: In the event that some or all of the personal information that Gems has concerning you is inaccurate, this gives you the right to have those inaccuracies rectified.

The Right to Erasure: In some cases, you may have the right to request that Gems erase your personal information that it has in its possession.

The Right to Restriction of Processing: This gives you the right, in some circumstances, to have Gems process your personal information only with your consent.

The Right to Object to Processing: Where Gems is processing your personal information on the ground of its legitimate interests, or to carry out tasks in the public interest or to exercise official authority, you have a right to object to the processing on grounds relating to your particular situation. In cases where you object to Gems’s processing of your personal data for direct marketing purposes, the processing will cease.

The Right to Data Portability: This allows you to request from Gems a copy of your personal information that it has on file and to transfer that information to someone else without any interference from Gems.  In some cases, you may be able to request that Gems transfer your Personal Information directly to a third party on your behalf.

In addition, to the extent that Gems processes any of your personal information on the basis of your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing that was based on your consent before its withdrawal.

If you are a natural person residing in the EU and at any time you believe Gems has violated one of your rights listed above, or if you believe Gems is in violation of one or more of the provisions of the GDPR, you have the right to lodge a complaint with a Data Protection Authority. 

ACCESSING AND CORRECTING YOUR CHILD’S PERSONAL INFORMATION

At any time, you may review your child’s personal information maintained by us, require us to correct or delete your child’s personal information, and/or refuse to permit us from further collecting or using your child’s information.

You can review, change, or delete your child’s personal information by:

  • Logging into your child’s account and visiting his or her account profile page.
  • Sending us an email at privacy@lifology.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
  • Contacting your child’s school.

CHANGES TO THIS POLICY

From time-to-time, we may change this privacy policy to accommodate changes to our products, services and, new technologies or industry practices, updated regulatory requirements, or for other purposes. We will provide notice to you (as described below) if these changes are material.

Notices may be by email to the last email address you provided us, by posting notice of such change on our site or the Gems.lifology.com, or by other communication channels. We always indicate the date the last changes were published and we offer access to archived versions for your review. We reserve the right to determine the form and means of providing notifications to you, consistent with applicable law.

CONTACT US

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@lifology.com