PRIVACY POLICY

Last updated: August 2022

Please read the following privacy policy carefully and consider that by visiting and using gem-wheel.com, or any other website owned or operated by École de gemmologie de Montréal Inc. (the "Website"), you ("you" or the "user") are accepting and consenting to the practices described in this privacy policy for the collection, use and disclosure of your Personal Information.

École de gemmologie de Montréal Inc. ("GEMWHEEL" or "we") undertakes to treat your personal information confidentially in accordance with this privacy policy (the "Policy") and applicable Canadian laws with respect to data protection in the private sector, such as the Personal Information Protection and Electronic Documents Act and the Act Respecting the Protection of Personal Information in the Private Sector (Quebec), as well as all substantially similar laws governing the collection, use and disclosure of personal information in the rest of Canada. We will work with the appropriate regulatory authorities, including local data protection authorities, to try to resolve any complaints or disputes related to the transfer of personal data that we cannot resolve directly with the individuals concerned.

For the purposes hereof, "Personal Information" means information about an identifiable individual.

1. What information is collected?

Users may provide Personal Information through various means on the Website, including by accessing the Website, completing the various forms available, subscribing to our newsletter, submitting an application, or otherwise providing us with Personal Information. 

Personal Information, such as username, address, e-mail address, and financial and banking information, may be collected from you voluntarily. Users do not need to submit this information to use the Website. 

In general, when you browse our Website and view its content, you remain anonymous. However, when you register to access certain parts of our Website, list an item for sale or make a purchase, we ask you to provide us with some information, which is generally limited to your e-mail address, financial and banking information and other basic information such as your name.

2. Why do we collect Personal Information?

We collect, use or disclose certain Personal Information to enable us to undertake, manage, maintain and develop our business and operations, particularly to:

1. operate the Website, to facilitate navigation of the Website, and to enable you to access and use the Website;

1. process and evaluate customer and user inquiries and requests;

1. establish, maintain and manage our relationship with you so that we can provide our services to you;

1. allow us to review the services we provide to you so that we can understand your preferences and needs and work to improve our services;

1. send you marketing, advertising, promotional and other information that may be of interest to you, provided that you may unsubscribe or opt-out of receiving these communications in your settings when you access your account;

1. protect us against error, fraud, theft, and damage to our property and assets; and

1. enable us to comply with applicable laws or regulatory processes.

We expressly acknowledge that we will not use your Personal Information for any other purpose without your consent. Further, we will only collect Personal Information to the extent necessary for the purposes identified above.

3. How do we use and disclose your Personal Information?

Your Personal Information may be used and disclosed as follows:

1. We may use and disclose your Personal Information for any other purposes described in this Policy or for which we have obtained your consent to use and disclose your Personal Information.

1. We may use or disclose your Personal Information without your knowledge or consent where permitted or required by applicable laws or regulations.

We may also disclose non-personal information (for example, aggregated and anonymized customer data) publicly and to our partners or other third parties. In addition, Personal Information may be used and disclosed to the extent that Gemwheel may deem reasonably necessary to enforce the terms of any agreement between you and Gemwheel, or to protect the rights, property, or safety of any person or entity, or as required by law, in particular, in response to a request from the competent governmental authorities.

4. With whom do we share your Personal Information?

We share your Personal Information with our employees, contract staff, advisors and other parties who require such information to help us establish, maintain and manage our relationship with you, including third parties who provide services to us or on our behalf, third parties who collaborate on the services we provide to you, and third parties whose services we use in order to provide our services. We may also share Personal Information in transactions, including in connection with merger negotiations, asset sales, financings or acquisitions. Anonymized Personal Information may be shared for statistical analysis.

5. How long do we keep your Personal Information?

We do not retain your Personal Information beyond the time permitted by law and we delete Personal Information when it is no longer needed for the purposes described in this Policy.

6. How may I review the information collected?

In accordance with applicable privacy laws, you have the following rights with respect to your Personal Information: 

• Right of access: You may ask whether we hold Personal Information about you and, if so, request a copy of that information. There may be a charge for transcribing, reproducing or transmitting such information.

• Right of rectification: If Personal Information about you is inaccurate, incomplete or equivocal, or if its collection, communication or retention is not in compliance with or authorized by the Act respecting the protection of personal information in the private sector, C.Q.L.R., c. P-39.1 (the "Act"), you may demand that it be rectified.

If you wish to review, access or correct your Personal Information, please send us a written request to info@gem-wheel.com . 

7. How may I manage or delete my information?

You may update or delete your Personal Information at any time by logging into the Website and making the necessary changes to your account.  If you submit Personal Information to the Website and then determine that you do not want Gemwheel to use, collect or disclose that information for any purpose permitted or required by the applicable laws in force, you should contact info@gem-wheel.com. You understand and acknowledge, however, that some of your Personal Information must be provided to Gemwheel in order for you to use the platform and that removal of such information may limit your access to or use of the Website.

8. How may I withdraw my consent?

You may withdraw your consent to the retention of your Personal Information at any time by sending a written request to info@gem-wheel.com . Upon receipt of your notice for withdrawal of your consent, we will stop retaining your Personal Information within a reasonable time frame, which will vary depending on the Personal Information we have collected and the purpose for which we have collected it. Please note that we will send you an email confirmation upon receipt of your request. Please note that if you choose to withdraw your consent, your experience using the Website and browsing our Website may no longer be optimal and you may no longer have access to all of our services offered through our Website.

9. How do I file a complaint?

You may file a complaint regarding the collection, use, destruction, retention or protection of your Personal Information to info@gem-wheel.com . Please note that we will respond to your complaint within 30 business days.

10. How do we secure your Personal Information?

Your personal information is stored on servers located in Quebec. We continually implement and update security measures to help protect your personal information from unauthorized access, destruction or alteration. However, no method of transmission over the Internet and no method of storage of electronic information is 100% secure. As a result, we cannot guarantee the security of the data transmitted to us or the security of the personal information we store.

In addition, your Personal Information may be transferred to and stored on other servers located outside of your jurisdiction, where privacy laws may not provide similar or adequate protection to your jurisdiction.  By agreeing to this Privacy Policy, you consent to such transfer.

11. What information is collected about the Website’s visitors?

Our server may collect information about your visit, including the IP address and domain used to access our Website, the type and version of your web browser, the website from which you came to our Website, the page you entered and exited, all pages of the Website viewed by the IP address, and the country from which you access the Website. We use this information to track activity on our Website (number of visits, average time spent, pages viewed) and to strategically increase our visibility on the Internet.

12. What about links to other Websites?

Our Website may contain "links" to a wide variety of other websites. Gemwheel is not responsible for their privacy policies or for the manner in which those websites handle information collected about their users. We strongly recommend that you review the privacy policies of such websites.

13. Update of the Policy

If we decide to change this Policy, we will make every effort to post those changes on this page so that our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Your continued use of the Website following the implementation of such changes constitutes your acceptance of this Policy as amended. 

Please send any notices or requests regarding this Policy to the following email address: info@gem-wheel.com .

6. Eligibility

The Website and the services offered on it are not intended for persons under the age of 18. If Gemwheel becomes aware that Personal Information about individuals under the age of 18 has been inadvertently collected, it will promptly delete such information.

7. Privacy Officer

Gemwheel is the Privacy Officer and is responsible for compliance with and implementation of the Act. You may contact the Privacy Officer at the contact information listed below: 

phone: 515-889-8589

E-mail address: info@gem-wheel.com