Welcome! Thanks for visiting Gemini, a digital asset platform. Use of the words “Gemini,” “we,” “us,” or “our” refer to any or all Gemini entities and their affiliates. This Privacy Policy explains what Personal Information (as defined below) we collect, why we collect it, how we use and disclose it, your choices, any rights you may have, and how you can contact us about our privacy practices. By continuing to use Gemini, you agree to this Privacy Policy. If you do not wish your Personal Information collected, used, or disclosed as described below, or if you are under the age of 18, you should stop accessing our Services. This Privacy Policy does not apply to third party websites, products, or services, even if we provide links to them or they link to us.
Your privacy matters to us so whether you are new to Gemini or a long-time customer, please do take the time to get to know and familiarize yourself with our policies and practices. If you are a job applicant, please refer to our separate . Feel free to print and keep a copy of this Privacy Policy, but please understand that we reserve the right to change any of our policies and practices at any time at our sole discretion. But don’t worry, you can always find the latest version of this Privacy Policy here on this page.
STATE LAW PRIVACY NOTICE
As a financial institution under the Gramm-Leach-Bliley Act (“GLBA”), Gemini’s privacy practices are subject to federal law and therefore are exempt from many state privacy laws. For those states with laws that do apply to Gemini’s practices, please see our state-focused privacy disclosures about when we may process your personal data and your corresponding rights, in our .
ENTITIES YOU ARE ENGAGING WITH
This table below describes which Gemini entity or entities you are engaging with, which determines the means and purposes of processing your Personal Information. If you are a customer based in the European Economic Area, please stop reading and go to , which will identify the Gemini entities you are engaging with and how they use your Personal Information.
| Your Place of Residency | Services Provided | Your Gemini Entity | Contact Address |
|---|
Anywhere but EEA, UK, Australia, Singapore | -Fiat services
-Digital Asset services | Gemini Trust Company, LLC NY Entity No: 5002896; (d/b/a Gemini Exchange, LLC in AZ, CA, DE, FL, ID, IL, KS, KY, MA, MI, MN, NC, ND, NM, OH, OR, SD, UT, and VA; d/b/a Gemini Exchange in AK and WA) | 600 Third Avenue, 2nd Floor New York, NY 10016 |
United States | -Exchange | Gemini Moonbase, LLC | 600 Third Avenue, 2nd Floor New York, NY 10016 |
United States | -Credit Card | Gemini Constellation LLC | 600 Third Avenue, 2nd Floor New York, NY 10016 |
United States | -Digital Assets portfolio management services | Bitria, Inc. | 600 Third Avenue, 2nd Floor, New York, NY 10016 |
UK | -E-money services | Gemini Payments UK, Ltd Company No: 11497305 FCA Register No: 900988 | 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX |
UK | -Digital Asset services | Gemini Intergalactic UK, Ltd Company No: 12471710 FCA Register No: 921817 | 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX |
European Economic Area (EEA) | -E-money services | Gemini Payments Europe, Limited Company No: 669681 CBI Reference No: C432664 | 70 Sir John Rogerson’s Quay, Dublin 2, Ireland |
European Economic Area (EEA) | -Digital Asset Services | Gemini Intergalactic Europe, Limited Company No: 698251 CBI Reference No: C453651 (until your account is transferred to Gemini Intergalactic EU, Ltd) | 70 Sir John Rogerson’s Quay, Dublin 2, Ireland |
European Economic Area (EEA) | -Digital Asset Services | Gemini Intergalactic EU, Ltd | 171, Old Bakery Street, Valletta, Malta |
European Economic Area (EEA) | -Investment Services | Gemini Intergalactic EU Artemis, Ltd | 171, Old Bakery Street, Valletta, Malta |
Singapore | | Gemini Artemis, Pte. Ltd. | 7 Straits View, #08-06, Marina One East Tower, Singapore 018936 |
Singapore | -Digital Asset Services | Gemini Digital Payments Singapore, Pte. Ltd. | 7 Straits View, #08-06, Marina One East Tower, Singapore 018936 |
Singapore | -OTC Derivatives | Gemini Voyager, Pte. Ltd. | 7 Straits View, #08-06, Marina One East Tower, Singapore 018936 |
Australia | -Digital Asset Services | Gemini Intergalactic Australia, Pty Ltd | 7 Straits View, #08-06, Marina One East Tower, Singapore 018936 |
Depending on what Gemini products and services you use, we may provide you with an additional consumer privacy notice detailing how we will collect, use, and share your Personal Information for that product or service (each a “Gemini Consumer Privacy Notice”). In the event of any conflict between this Privacy Policy and any Gemini Consumer Privacy Notice, the Gemini Consumer Privacy Notice will control. If you are a retail Gemini customer or a Gemini Credit Card customer, please find your Gemini Consumer Privacy Notice .
1. Personal Information We Collect
Personal information typically means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that relates to, describes, is reasonably capable of being associated with or could reasonably be linked to an identified or reasonably identifiable individual. For the purposes of this Privacy Policy, only the definition of personal information from the applicable law of your legal residence will apply to you and be deemed your “Personal Information.”
A. Personal Information we collect from you
We may collect the following categories of Personal Information directly from you:
Identification Information, such asname, email, date of birth, phone number, postal address, and/or government-issued identity documents;
Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;
Financial Information, such asbank account information, routing number, or other financial account information;
Correspondence, such asinformation that you provide to us in correspondence, including account opening and customer support;
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information, such asimages and video collected for identity verification, audio recordings left on answering machines;
Biometric Information, such as scans of your face geometry extracted from identity documents;
Professional or Employment-related Information, such asjob title, source of wealth;
Institutional Information, such asfor institutional customers, we may collect additional information, including: institution’s legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government, and proof of legal existence (which may include articles of incorporation, certificate of formation, business license, trust instrument, or other comparable legal document);
Sensitive Personal Information, such as government-issued identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number) and financial account information.
Preferences, such as settings and preferences you select in the Gemini app;
Communications, such as survey responses, information provided to our Customer Support team, including communications with interfaces such as chatbots; and
Referral information, such as your contacts’ phone or email addresses if you choose to invite those contacts to Gemini.
B. Personal Information we collect automatically
We may collect the following categories of Personal Information automatically through your use of our services:
Online Identifiers, such asIP address; domain name, geographic location;
Device Information, such ashardware, operating system, browser, screen size; and
Usage Data, such assystem activity, internal and external information related to Gemini pages that you visit, clickstream information, keystrokes, mouse movements, form field entries, recordings of chat sessions or your use of and inputs to other AI-supported tools, and other use and overall engagement with our Services.a
Session Replay Information, such as information about your interaction with our sites and with our mobile and webforms (such as IP address, time of session, and other session details), including the use of session replay technology.
Our automatic collection of Personal Information may involve the use of Cookies and other tracking technologies, described in greater detail below.
C. Personal Information we collect from third parties
We may collect and/or verify the following categories of Personal Information about you from Third Parties:
Identification Information, such asname, email, phone number, postal address;
Financial Information, such asbank account information, routing number. When you use third party services (for example, when you connect your Gemini account to your bank account) or websites that are linked through our Services, the providers of those services or products may receive information that Gemini, you, or others share with them. Those third party services are not governed by this Privacy Policy, and their own terms and privacy policies will apply to those products and services;
Blockchain Data, such as timestamps of transactions, IP addresses, transaction IDs, transaction accounts and wallet addresses.
Credit and Fraud Information, such as credit investigation, credit eligibility, identity or account verification, fraud detection, or as may otherwise be required by applicable law;
Sensitive Personal Information, such as government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number) and financial account information and
Additional Information, as permitted by law or required to comply with legal obligations, which may include criminal records or alleged criminal activity, or information about any person or corporation with whom you have had, currently have, or may have a financial relationship.
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. Please note that some information is required to support our legal obligations and account set up, and if you choose not to provide us with this Personal Information, you may not be able to access Gemini’s services.
D. Combination of Personal information
Please note that we may combine Personal Information that we receive from various sources. For example, we may combine Personal Information that we receive from third parties with Personal Information we already have about you. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.
Please also note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Privacy Policy.
2. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information
The Personal Information we collect and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve Gemini. The below explains how we use your personal information and our legal basis for each data use:
Perform our contract with you
Provide you with our services. We use your Personal Information to provide you with our services pursuant to the terms of our User Agreement. For example, in order to facilitate fiat transfers into and out of your account, we need to know your financial information.
Provide you with customer support. We process your Personal Information anytime that you reach out to our Customer Support team, such as when there are issues arising from your account. We may use AI third party support services to provide you with streamlined customer support. We may use anonymized Personal Information to train AI models for internal use only.
To send Service communications. We use your Personal Information to send you administrative or account-related communications about our Services. This may include security updates or account-related information through email, telephone, or in-product notification. You may not opt-out of receiving critical service communications sent for legal or security purposes.
Protect the security and integrity of our services. We use your Personal Information to further our security-first mentality. Maintaining the security of your account and the Exchange requires us to process your Personal Information, including information about your device and your activity on the Exchange, and other relevant information.
Comply with our legal obligations
To verify your identity. We process your Personal Information to properly identify or verify your identity to fulfill our obligations under the anti-money laundering laws (“AML”) or sanctions laws/regulations of numerous jurisdictions and, as such, we may use an image of an identity document that you provide to help us verify that you are the true owner of the identity document and that the document does not show signs of fraud. All such information is securely maintained and is only disclosed where permitted by law.
To comply with legal and regulatory requirements. We may process your Personal Information where we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, governmental, and other legal requests, court orders, or for disclosure to tax authorities.
Use based on legitimate interests
Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
Optimize and enhance our services. We use your Personal Information to understand how our products and services are being used to help us improve our Services and develop new products.
Market our products to you. We may send you information, newsletters, marketing materials and other customized content and targeted offers from us, and on behalf of, our marketing partners and affiliates. You may use tools that we provide to opt out of these communications from us at any time.
To provide you with Promotions. We may use your information to provide promotions, including sweepstakes offers or other incentives and rewards for using our Services.
To protect the security and integrity of our services and systems. Beyond the performance of our contract with you, we may use and analyze your information to protect the security and integrity of our services and systems. This may include logging suspicious behavior and investigations of violations to our Terms.
To preserve and share information with law enforcement, civil litigants, and other issuers of legal requests. We may preserve and share information as a result of requests from third parties such as civil litigants, law enforcement and other government authorities in the course of fraud investigations. Information may also be shared when we seek to protect ourselves in the course of litigation or other disputes, and to respond to Customer requests or communications for litigation and settlement purposes.
For research and development. We engage in user testing to understand the customer experience using our Services and the trading that you engage in to conduct and support research and development related to our Services.
Use based on your consent
To enable device-based settings. We collect information that you allow us to receive through the device-based settings you engage (such as location, language) which we use to provide the features or services described when you enable these settings.
To provide marketing communications to you. With your consent, we send targeted marketing communications through email, mobile, SMS, in-app, or push notification. You may also see ads for our Services when you visit other websites.
Use to protect your or others’ vital interests
To preserve and share information with law enforcement, civil litigants, and other issuers of legal requests. We may preserve and share information with law enforcement and other government authorities in circumstances where someone’s vital interests require protection (e.g., emergencies).
3. How We Share Your Personal Information
We will not share your Personal Information with third parties, except as described below:
Service Providers. We may share your Personal Information with third party service providers for business or commercial purposes. Your Personal Information may be shared so that they can provide us with services, including identity verification, fraud detection and prevention, credit verification (including pre-screening for credit offers), security threat detection, payment processing, customer support, data analytics, Information Technology, advertising, marketing, data processing, network infrastructure, storage, transaction monitoring, and tax reporting. We share your Personal Information with these service providers only so that they can provide us with services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose. Our third party service providers are subject to strict confidentiality obligations.
Affiliates. We may share your Personal Information with our affiliates, for the purposes outlined above, and as it is necessary to provide you with our services.
Business Partners. We may share your Personal Information to other companies with whom we partner to provide services or other offerings to you and carry out other related activities.
Analytics Partners. We may share your Personal Information to our partners that assist us in performing analytics and help us measure the effectiveness of our services’ content and our marketing and advertising efforts. Please see our section on Cookies and other Tracking Technologies for more information.
Marketing and Advertising Partners. We may share your Personal Information to third parties for marketing and advertising purposes, including social media platforms, third party advertising networks, and other parties that assist us in serving and optimizing our advertisements. Please see Section 4 on Cookies and other Tracking Technologies for more information.
Legal Obligations. We may be required or in good faith and in our sole discretion as we believe is necessary, to share your Personal Information with law enforcement, government agencies, regulators or third parties to comply with legal or regulatory requirements.
Corporate transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
Consent. We may share or disclose your Personal Information with your consent.
Other business or commercial purposes. We may share or disclose your Personal Information for other business or commercial purposes as permitted by law.
If we decide to modify the purposes for which your Personal Information is collected, used, or shared, or our practices relating to your Personal Information, we will amend this Privacy Policy as described below.
4. Cookies and other Tracking Technologies
When you access Gemini, we make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Gemini. We use Cookies to help us recognize you as a customer, collect information about your use of Gemini to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure compliance with our Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) program (“BSA/AML Program”), (ii) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities, and (iii) assess and improve our services and advertising campaigns.
Third party tracking technologies are not controlled by us, and statements regarding our practices do not apply to these third parties or their use of information. We make no representations regarding the policies or practices of such third parties. You may be able to opt out of the practices of some of these third parties if they are members of the Network Advertising Initiative (“NAI”) by visiting http://www.networkadvertising.org/choices or if they participate in the Digital Advertising Alliance (“DAA”) by visiting http://www.aboutads.info/choices. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.
You also can learn more about Cookies by visiting , which includes additional useful information on Cookies and how to block Cookies on different types of browsers and mobile devices.
Our use of Google Analytics and Advertising technologies: Our website uses technology provided by Google to facilitate advertising and reporting. We implement Google Analytics Cookies to collect personal information about you when you visit our website for purposes of remarketing, impression reporting, and demographic and interest reporting. These Cookies count traffic visits to our website and traffic sources so we can measure and improve our Services. This information includes identifiers and data about the pages you visit, and can be combined with other data related to you collected through Google’s advertising cookie or other third party technology. You can opt-out of the use of this technology through the Google Analytics , Google Ad Settings, Ad Settings for mobile apps, or the NAI’s consumer opt-out.
We use first party and third party Cookies for marketing purposes. These advertising cookies allow us to serve personalized advertising on our Services or to serve advertising on other third party sites that may be of interest to you. You may see advertising from us on the internet after you visit our Services. The information collected and shared during this process is anonymized and does not contain details or other personal information that can be used to directly identify you.
You may opt out of Cookies on your device at any time by going to our or opting out at the account level on your page. Some strictly necessary Cookies, such as those used for security purposes and to detect fraud on your account, are essential for the performance of our Services and therefore cannot be switched off.
5. Direct Marketing
Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may opt-out of such marketing communications at any time by visiting the Exchange tab of your page. You may also opt-out of such communications by following the directions provided in any marketing communication. If you opt out of marketing communications, please note that we may still send you necessary information about transactions or our business relationship. It is our policy to not provide your Personal Information to third parties for their own direct marketing purposes without your consent.
6. Children’s Personal Information
Gemini is not intended for children under the age of 18 and we do not knowingly collect Personal Information of children under the age of 18. If we learn that we have collected any Personal Information from a child under the age of 18, we will promptly delete it from our systems.
7. Your Privacy Rights and Choices
Depending on where you live, you may be able to exercise certain privacy rights related to your personal information. For any of your privacy rights and choices, please see You may submit a request via privacy@gemini.com. If any of the rights listed below are not provided by law for your operating entity or jurisdiction, Gemini may exercise its discretion in providing you with these rights.
Please note that in order to maintain your privacy and security, we may take steps to verify your identity prior to complying with your request. If we are unable to verify your identity, we may decline your request.
Your Right to Lodge a complaint:
If you reside in the EEA or Switzerland, you have the right to lodge a complaint about our practices with respect to your personal information with the supervisory authority of your country or state. For e-money activities, the relevant data protection authority is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, +353 017650100 / + 353 1800437737, email: . For crypto activities, the relevant data protection authority is the Malta Office of the Information and Data Protection Commissioner (IDPC), Floor 2, Airways House, High Street, Sliema, SLM 1549, Malta, +356 2328 7100, email: .
If you are located in the UK and you believe that we have not adequately resolved any such issues, you have the right to contact the Information Commissioner’s Office . You may also contact our Data Protection Officer in relation to the processing of your personal data by emailing .
If you reside in Australia, you may lodge a complaint about our practices with respect to your personal information with the Office of the Australian Information Commissioner. For more information on how to do so, please see the Supplemental Notice for Australia.
If you reside in the Philippines, you may lodge a complaint about our practices with respect to your personal information with the National Privacy Commission, email: .
If you reside in Brazil, and you are not satisfied with our response, or how we process your personal information, you can make a complaint to ANPD through .
8. Information Security
We take reasonable measures, including administrative, technical, and physical safeguards, to protect your Personal Information from loss, theft, or misuse, and from unauthorized access, disclosure, alteration, and destruction. Nevertheless, no security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect Gemini and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take may include encryption of the Gemini website communications with SSL; required two-factor authentication for all sessions; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Where it is lawful and practical, we allow you to interact with Gemini without identifying yourself or by using a pseudonym. For example, you may browse our public website without providing personal details. However, as a regulated financial institution, Gemini is required by law to verify the identity of all customers who use our services. We collect personal information to satisfy Know Your Customer (KYC) requirements and to fulfill obligations under anti-money laundering and counter-terrorism financing (AML/CTF) laws, as well as sanctions regulations and other financial services regulatory requirements.
Although cryptocurrency transactions on public blockchains are pseudonymous in nature, they are not truly anonymous. When you transact through Gemini, we link your verified identity to your blockchain addresses and transaction history on our platform to support our compliance obligations and help ensure the security and integrity of our services.
9. Retention
We retain your Personal Information for as long as is reasonably necessary to provide services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account with us, we will continue to retain your Personal Information as necessary to comply with our legal and regulatory obligations, including for fraud monitoring, detection and prevention; and for our tax, accounting, and financial reporting obligations.
10. International Transfers
Gemini is a global business. As a result, Personal Information may be stored and processed in any country where we have operations, Affiliates, third party partners or where we engage service providers. Gemini, its Affiliates, third party partners, or service providers may transfer, store, and process your Personal Information throughout the world, including Ireland, the UK, Malta, Singapore, Australia, and the US.
If you are located in the European Economic Area (“EEA”), the UK or Switzerland, and are provided services by Gemini Payments UK, Ltd, Gemini Intergalactic UK, Ltd, or Gemini Payments Europe, Ltd,we ensure that the transfer of your Personal Information is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.
We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate international transfers of Personal Information to third countries, including from Gemini’s European operations to Gemini Trust Company, LLC in the United States.
Additionally, we may rely on adequacy decisions from the European Commission where available. In certain instances, we may rely on certain exemptions for sharing personal information (such as with law enforcement outside of the EEA) in emergency situations, pursuant to Article 49(1)(f) of the GDPR.
For UK personal data, adequacy decisions are issued by the UK Secretary of State under the Data Protection Act 2018. Where no adequacy decision applies, we implement safeguards recognised under UK law, such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses.
For further information regarding your specific rights, please see the section titled Jurisdiction Specific Disclosures. If you have any questions regarding international data transfers, please contact (dpo@gemini.com).
11. Updates To this Privacy Policy
We may change this Privacy Policy from time to time to reflect changes to our privacy practices, enhance user experience, or comply with relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy. If we change the Privacy Policy in a material way, we will provide appropriate notice to you. Such notice may be provided via a temporary banner on our Site, an email sent to users for whom we have an email address, or by temporarily noting “UPDATED” next to the Privacy Policy link on the footer of our Site. Your continued use of Gemini after our posting of changes to this Privacy Policy means that you understand and agree to such changes.
12. Contact Us
If you have questions or concerns regarding this policy or our processing of your Personal Information, please feel free to email us at: ; or write to us at: Gemini Trust Company, LLC and Gemini Moonbase, LLC, 600 Third Avenue, 2nd Floor, New York, NY 10016 or Gemini Payments UK, Ltd or Gemini Intergalactic UK, Ltd, 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX.
13. Jurisdiction Specific Disclosures
