Introduction

Gemini Group respects the privacy of its customers and visitors to its website, and is committed to protecting the privacy of the Personal Data (defined below) that you share with us.

This Privacy Policy explains how we handle the personal information that you provide to us on websites controlled by Gemini Group (including its subsidiaries and affiliates) which link to this Privacy Policy (referred to as “Gemini Group Websites“). The EU General Data Protection Regulation (“GDPR”) is in force from 25 May 2018. The GDPR amends and updates the rights you have in relation to your Personal Data. The GDPR also regulates what companies that process your Personal Data are permitted to do with it. This Privacy Policy provides you with information relating to the processing of your Personal Data. It also explains how you may exercise your data protection rights under the GDPR.

This Privacy Policy does not apply to personal information collected from you offline, to Gemini Group Websites that do not link to this Privacy Policy, or to third party websites to which Gemini Group Websites may link. Your use of Gemini Group Websites, which link to this Privacy Policy is subject to this Privacy Policy and the Terms of Use.

Please read this Privacy Policy before using Gemini Group Websites or submitting personal information to us.

What is Personal Data?

“Personal Data” is any information that identifies you or from which you could be identified, in particular by reference to an identifier such as a name, an identification number, location data, an online identified or one or more factors specific to the physical, psychological, genetic, mental, economic or social identity.  Personal Data includes subsets of special categories of  information that reveal information about your health, among other things.

Why does Gemini Group process your Personal Data?

Gemini Group processes your Personal Data:

• to perform a contract with you, such as where you sign up or register for our services or download and use one of our mobile apps;
• to comply with local EU laws.
• to fulfil its legitimate business interest in doing so, such as for direct marketing or for research purposes or to defend Gemini Group;
• where you have consented to the processing of your Personal Data.

Who does Wollerau Pharma Limited share your Personal Data with?

Gemini Group may share your Personal Data with its affiliate companies within its corporate group. Gemini Groupmay also share your Personal Data with vendors with whom Gemini Group contracts to carry out business activities for Gemini Group. If Gemini Group provides your Personal Data to vendors to assist us with our business activities, it is Gemini Group's practice to require those vendors to keep your Personal Data confidential and to use your Personal Data only to perform functions for Gemini Group.

Gemini Group reserves the right to disclose your Personal Data to respond to authorized information requests from government authorities, to address national security situations, or when otherwise required by law.

Does Gemini Grouptransfer your Personal Data outside of Europe?

We may need to transfer your Personal Data outside of the European Economic Area (“EEA”) to third countries which do not offer the same level of protection as required by the EEA. In order to safeguard your Personal Data we will only make such transfers on the basis of: (i) a decision of the European Commission that permits this; or (ii) EU-approved Standard Contractual Clauses. Please note, Gemini Group and all subsidiaries and related entities have entered into intragroup data transfer agreements based on the EU Standard Contractual  Clauses to transfer your Personal Data from the EEA to third countries, which includes the United States. To access or receive a copy of our intragroup data transfer agreement, please contact our EU data protection officer (details below).

How long does Gemini Group store your Personal Data for?

Your Personal Data will be stored for as long as it is needed to provide you with: (i) the Gemini Group service or product that you have requested; and/or (ii) access to the Gemini Group Websites. Alternatively, your Personal Data will also be stored for as long as we require it to respond to your queries and concerns or in accordance with any legal requirements, including those in relation to product or medical device safety. For further information please contact your local customer care or our EU data protection officer using the details below.

What Gemini Group does to keep Personal Data secure?

It is Gemini Groups's practice to secure each web page that collects personal information; however, the confidentiality of personal information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. Gemini Group cannot guarantee that unauthorized third parties will not gain access to your personal information; therefore, when submitting personal information to our website, you must weigh both the benefits and the risks. In addition, our website covered by this Privacy Policy will display a warning whenever you link to a website that is not controlled by Gemini Group or subject to a Gemini Group privacy policy; you should check the privacy policies of such third party websites before submitting personal information.

What rights do you have in relation to your Personal Data?

You may have the following rights in relation to your Personal Data:

• The right to rectify, or erase any wrong or incomplete Personal Data that Gemini Group holds about you;
• The right to access the Personal Data that Gemini Group holds about you;​
• The right, in some cases, to object to the processing of your Personal Data where we process it on the basis of our legitimate business interests;
• The right not to be subject to automated decision making intended to evaluate certain personal aspects relating to you, such as analytics based on conduct. Please refer to the cookies section of this Privacy Policy for more information on how to exercise this right if it is indicated that cookies are being used;
• Where you have provided your Personal Data to us with your consent or as part of a contract, the right to the portability of that Personal Data to another person or, if it's technically feasible for us to do so, to another company;​
• The right to lodge a complaint with your local data protection supervisory authority or to receive compensation for any damage you suffer; and
• The right to withdraw your consent to Gemini Group's processing of your Personal Data without detriment, where you have provided consent for Gemini Group to process your Personal Data.

We may ask you for additional information to confirm your identity and for security purposes, before responding to any request you submit.

Where you have been asked to consent to the processing of your Personal Data, we will provide you with an opportunity to withdraw your consent.  There may be several methods by which you can withdraw consent, such as by contacting us directly or by deleting any Gemini Group mobile app from your smartphone.  In each case you will be given information about how to withdraw consent. Any withdrawal of consent will not affect the lawfulness of the processing based on your consent before the withdrawal.  Please also note that where you withdraw consent, Gemini Group will only stop processing your Personal Data that relates to the withdrawal of consent.

Gemini Group may still need to process Personal Data where:

• we are required to do so by law;​
• we have a legitimate business interest to do so, such as in connection with the sale or transfer of our product lines or divisions;
• necessary to respond to authorized information requests from government authorities;
• necessary to address national security situations; or
• otherwise required by law to which we are subject.

Why do Gemini Group Websites use “cookies” and other tracking technologies?

Gemini Group may use “cookies” to collect other information during an individual's visit to the Gemini Group Websites, such as the particular site areas visited and the services utilized through our website. We collect this information to better tailor our site and our products to your interests and needs. Cookies may also be used to help speed up your future activities on our site. For example, a site can recognize that you have provided Personal Data to use and refrain from requesting the same information a second time. Most browsers are initially set to accept a cookie. Cookies may be disabled by the individual visitor, although refusal of cookies at the site may result in an inability to visit certain areas of the site or to receive personalized information when visiting the site.

In addition, we are constantly trying to improve how we promote our websites. To help us do this, we may measure the effectiveness of our web presence by determining when you accessed the Gemini Group Websites, and what you clicked on within our site. Site measurement statistics may be used to personalize your website experience, as well as to evaluate – anonymously and on an aggregated basis – statistics about usage of the website. Information about your computer, such as your IP address (a number assigned to your computer whenever you surf the Internet), the type of Internet browser you are using and the type of operating system you are using may also be collected and linked to your Personal Data. This is to ensure that the Gemini Group Websites presents the best web experience for visitors, and that they are effective information resources.

Some of the pages an individual visits may also collect information through the use of pixel tags (also called clear gifs) that may be shared with third parties which directly support Gemini Group's promotional activities and website development. For example, website usage information about visitors to the Gemini Group Websites may be shared with our third party advertising agency in order to better target Internet banner advertisements on the Gemini Group Websites. The information collected through the use of these pixel tags is not, however, personally identifiable, although it could be linked to an individual's Personal Data.

For more details about the cookies used on the Gemini Group Websites, please click here to see our Cookie Policy.  

What choices do I have about Gemini Group's use of cookies and other tracking technologies?

The specific choices you receive about Gemini Group's use of cookies and other tracking technologies vary by website.

On some Gemini Group Websites, you will be asked to consent to the use cookies and/or other tracking technologies on that website. Cookies that are necessary to the operation of the site will continue to function regardless of whether you have provided consent. Other types of cookies and tracking technologies will be turned off until you provide consent. As a result, the functionality of the site may be reduced until you choose to provide consent.

On some Gemini Group Websites, you may be provided with preference questions or boxes allowing you to indicate that you do not want that website to use cookies or other tracking technologies that are not necessary to the operation of the site. If you choose to exercise this opt-out option, the functionality of the site may be reduced as a result.   Some Internet browsers allow you to limit or disable the use of cookies and other tracking technologies. Please refer to the information provided by your Internet browser for instructions on how to do so (generally found under a “Help” menu).

Do I have to provide my Personal Data to Gemini Group?

The provision of Personal Data to Gemini Group is required to fulfil the terms of a contract you have with Gemini Group, to provide you with a product or service you have requested or to comply with local laws, such as those relating to product or medical device safety. Any failure to provide such Personal Data will mean that Gemini Group cannot provide you with the product or service you have requested.

Who can I contact?

To exercise any of your rights in connection with your Personal Data or if you have any questions or concerns as to the processing of your Personal Data, please contact our Information Security Officer at:
3 Wimpole Street| Marylebone | London | W1G 9SQ| United Kingdom.
E-mail: info@geminitradegroup.com
You can expect to receive confirmation that we have received your request within 3 days, and fulfilment of the request within 1 month. There is no charge for providing information; however, repeated requests for the same information may incur a fee.