Our visitors' privacy is important to us, and we recognize the need to provide additional privacy protection for children on the GEMS Sites permitting such visitors. Our privacy practices are guided by the United States' Children's Online Privacy Protection Act of 1998, as well as data privacy laws in the United States and other applicable countries. Younger visitors should always check with their parents or guardians before entering information on any website or mobile application and we encourage families to discuss their household guidelines regarding the online sharing of personal information.
In general, we collect three types of information:
We take reasonable precautions against the unauthorized access to or loss of your information, always with the goal of keeping our security up to date as cyber threats change. Despite such precautions, there is always a chance of unauthorized access to or loss of your information. If you think a third party has accessed your information, please contact us immediately as instructed below.
In general, the information we collect may be used to respond to your requests; enable you to take advantage of GEMS Sites features and services; measure analytics; and manage and improve the services available on the GEMS Sites. We may use your information in these ways when and where it is consistent with legal requirements to do so.
Depending upon the circumstances, we may share collected information with (a) law enforcement or others as needed to protect or defend our rights and the rights of others; (b) third parties we hire to handle certain activities; (c) advertisers or third parties with whom we may partner to provide you additional content, products or services; (d) in the event of a corporate transaction; and (e) otherwise with your consent.
Third parties may collect and disclose certain identifiers, like IP address or cookie information, solely for the support of the internal operations of the GEMS Sites, such as providing content or allowing features to run on the GEMS Sites, serving contextual advertising, and using analytics and other tools to improve the quality and performance of the GEMS Sites.
Some of these third parties, such as advertising networks that serve targeted advertising on websites and online services intended for older audiences, or analytics service providers that analyze the performance of the GEMS Sites may use their own unique identifiers, and their use of these technologies is within their control and not ours. These companies may use the information they collect from you consistent with their own privacy policies, which we encourage you to review.
You have the right to access, update and correct factual inaccuracies in any personally identifiable information we collect about you.
You can stop the delivery of commercial e-mail messages from the GEMS Sites by following the instructions in emails you receive.
You may have choices about the use of your information by third parties wishing to deliver certain targeted advertising to you.
Parents and guardians can review any personally identifiable information collected about their children and request that such information be deleted and/or that no further information be collected.
The GEMS Sites are made available by the GEMS. If you have any questions about our information handling practices, including our practices with respect to children's personal information, please contact us at:
GEMS The Education Partners
70 W 40th St, FL 6
New York, NY 10018
We may request or collect certain information when you visit the GEMS Sites. However, visitors are required to share only the information that is reasonably necessary to participate in the particular activity.
A. Registration Information: The information required to register varies by Site, but may include: (a) birth date; (b) gender; (c) country; (d) state; (e) zip code; (f) user name and password; (g) wireless telephone number; (h) email address; and (i) other profile information such as avatar preferences, communications preferences, and interests. If the Site either is directed to children under 13 or has actual knowledge that a user is under 13 years old, the child may be asked to provide his or her parent's or guardian's email address. For certain countries, child visitors or their parents/guardians will receive an activation email and must follow the procedures or otherwise agree to the terms within the activation email within a certain time period to activate the account; accounts not activated within that time period will be deleted.
Registration information is used to enable visitors to log into their accounts across different devices and platforms.
B. Computer Information Collected by Us: When visitors come to a Site, we may automatically collect certain information from their computers or mobile devices, such as the type of computer or mobile operating system (e.g., Windows or Mac OS), the visitor's IP address, the web browser (e.g., Internet Explorer, Safari, Chrome and Firefox), UDID (for certain mobile devices), information about the websites visited before and after visiting the Site, the web pages and advertisements viewed and links clicked on within the GEMS Sites, interactions with e-mail messages sent by a Site (e.g., links clicked on and whether the messages were opened or forwarded), information collected through the use of unique identifiers such as cookies (see below), application metrics, debug information, information regarding the Internet service provider, and other standard server log information ("Computer Information").
We may use Tracking Technologies to help tailor our content, allow users to move between certain GEMS Sites without logging into each Site, enable the internal functioning of the GEMS Sites, understand Site and internet usage, improve or customize the content, offerings or advertisements on this Site, personalize your experience on the Site (for example, to recognize you by name when you return to the Site), understand your interactions with email messages originating from the GEMS Sites, save your password, save your video player settings, enable you to use shopping carts, help us offer you products, programs or services that may be of interest to you, maintain and administer the GEMS Sites. These Tracking Technologies collect "click stream" data and additional other information regarding your visits to the GEMS Sites (such as your visits to specific webpages, use of features, purchasing history or preferences), may collect such other information across multiple sessions on the GEMS Sites and may also collect your IP address or some other identifier unique to the device you use to access the site ("Identifier"). An Identifier may be automatically assigned to any device you use to access the GEMS Sites.
By visiting a Site, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to set and access Cookies on your device and track your activities and your use of a Site through these Tracking Technologies and Identifiers and that we may use Tracking Technologies in the emails we send to you.
Our Third Party Advertising Service Providers (as defined in Section C) do not have access to Tracking Technologies set by the GEMS Sites except to the extent necessary to provide services to the Site. The Third Party Advertising Service Providers, as well as advertisers, may themselves set and access their own Tracking Technologies on your Device if you choose to have Tracking Technologies enabled in your browser (or, for Flash cookies, if you have not removed them) and/or they may otherwise have access to other information about you.
You have a number of options with respect to the Tracking Technologies set by the GEMS Sites:
Please note that deleting, rejecting, disabling or turning off Tracking Technologies through the above options will not remove Flash cookies. For more information about Flash cookies and how to remove them from your computer, please visit Adobe Flash website for more information.
Please be aware that certain areas and features of GEMS Sites can only be accessed in conjunction with Tracking Technologies, and that disabling Tracking Technologies might prevent you from accessing such content.
C. Computer Information Collected By Others: Third parties may collect, use or disclose cookie information, IP addresses or other identifiers from devices and/or browsers of users who visit GEMS Sites for the purposes of supporting the internal operations of the GEMS Sites, which can include, for example: 1) providing content or allowing features to run on the Sites; 2) serving contextual advertising; and 3) using analytics and other tools to improve the quality and performance of the GEMS Sites.
Among the service providers we engage, GEMS Sites use a variety of third-party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers, and other third-party service providers (collectively, "Third Party Advertising Service Providers") to, for example, serve advertisements on the GEMS Sites, help prevent you from seeing repeated advertisements, and measure and analyze traffic on the GEMS Sites. On websites directed to older audiences, Third Party Advertising Service Providers may also be used to facilitate targeting of advertisements and measure and analyze advertising effectiveness ("Targeting Services"). These Targeting Services enable us, for older audiences, to display advertisements based on your visits to the GEMS Sites and other websites you have visited and may include delivering advertisements or other content for products and services that may interest you. Targeting Services also enable us to research the usefulness of certain advertisements. GEMS does not behaviorally target advertising to children under 13 on sites that are directed to children or where GEMS has actual knowledge that a user is under 13.
These Third Party Advertising Service Providers do not have access to Tracking Technologies set by the GEMS Sites except to the extent necessary to provide services to the GEMS Sites. The Third Party Advertising Service Providers, as well as advertisers, may themselves set and access their own Tracking Technologies on your device if you choose to have Tracking Technologies enabled in your browser (or, for Flash cookies, if you have not removed them) and/or they may otherwise have access to other information about you. In addition, Third Party Advertising Service Providers may collect aggregate log data separately and independently from what the GEMS Sites collect.
You should be aware that different rules might apply to the collection, use or disclosure of your information by third parties in connection with their advertisements, promotions and other websites you encounter on the Internet. The use of such technology by these third parties is within their control and not the GEMS Sites. Even if we have a relationship with the third party, we do not control those sites or their policies and practices regarding your information and those sites may use the information they collect from you consistent with their own privacy policies, which we encourage you to review. We encourage you to research and direct any of your questions in this regard to these third parties.
With respect to the Tracking Technologies set by Third Party Advertising Service Providers and advertisers (and outside the control of the GEMS Sites), you have a number of options:
Do-Not-Track Signals and Similar Mechanisms. Some web browsers may transmit "do-nottrack" signals to the websites with which the browser communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. There currently is disagreement, including among participants in the leading Internet standards-setting organization, concerning what, if anything, websites should do when they receive such signals.
We currently do not take action in response to these signals, but, if and when a final standard is established and accepted, we may reassess how to respond to these signals.
D. Electronic Newsletters: Visitors can provide their email addresses to receive email newsletters and promotions from the GEMS Group and our business partners. Visitors may change their preferences regarding emails at any time through the unsubscribe link in the newsletters or, for certain GEMS Sites, by logging into and changing the preferences for their account.
When visitors to GEMS Sites that are directed to children under 13 ask to receive our email newsletter(s), they will be asked to provide their first name, email address and the email address of their parent/guardian. We will send the child's parent/guardian a notification email informing them of the child's request to receive by email the newsletter on an ongoing basis and give the parent/guardian the option to have his or her child's information removed from our newsletter database. The link to remove the child's information will expire approximately 48 hours from the time it is sent, but at any time after receiving this notification email, the child's parent/guardian may request that we stop sending the child the newsletter(s) by following the "unsubscribe" instructions found at the end of any of the newsletter emails. Parents/guardians may at any time review any personally identifiable information collected online about their child.
E. Interactive Features and Services: Some of the GEMS Sites offer interactive features and services, such as message boards and comment boxes. For certain countries, on GEMS Sites that either are directed to children under 13 or when we have actual knowledge that a user is a child under 13 years old, we either will obtain the consent of the child's parent/guardian before allowing the child to use these interactive features and services or use reasonable technical measures to delete all or virtually all personal information from a child's postings before they are made public and delete such information from our records. We use the information collected through interactive features and services to enable you to participate in such features and services.
G. Financial Information: We collect and use financial information, such as credit card numbers and security codes, for the limited purposes described below.
Other Data Collection and Use.
We collect search query information when visitors search for information on the GEMS Sites. We also collect information from visitors when they contact us with questions and comments.
We may use this information, along with any of the other information described above, to (i) analyze use of the GEMS Sites and understand and improve our service offerings; (ii) prevent potentially prohibited or illegal activities; and (iii) for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
We may combine information collected through the GEMS Sites with information we collect from other sources (e.g., social media integration services), offline records or publicly available information). It is your responsibility to provide complete and accurate information and to keep such information up to date. We are not responsible for any problem or liability arising from your failure to do so.
We may share your information with third parties for the limited purposes described below. In the U.S., parents of children under the age of 13 have the option of consenting to the collection and use of their child's personal information without consenting to the disclosure of that information to certain third parties.
A. Law Enforcement and Safety.
If you have concerns about the conduct of a particular user, please send an e-mail to firstname.lastname@example.org. This email is not to contact us about the status of your account.
Information collected through the GEMS Sites may be transferred, disclosed or shared with third parties engaged by us to handle and deliver certain activities, such as message boards, e-cards, payment processing, newsletters, and advisory boards, and to perform other technical and processing functions, such as sending postal mail and email, maintaining data integrity, programming operations, user services or technology services. We may provide these third parties information collected as needed to perform their functions, but they are prohibited from using it for other purposes and specifically agree to maintain the confidentiality of such information. Some of these agents, such as payment processors, may request additional information during the course of offering their services. Before you provide additional information to third party agents, we encourage visitors to review their privacy policies and information collection practices.
C. Third Parties/Advertisers.
Some GEMS Sites partner with outside third parties to provide you with additional content, products, or services that we believe may be of interest. For example, we may partner with a software manufacturer, social media plugin provider, or mobile phone provider to offer you electronic cards, social networking, text messaging services or customized video content. These partners operate websites and services that are separate and independent from the GEMS Sites and, accordingly, may have their own privacy policies. If you consent or register with one of our partners, that means you grant the GEMS Sites permission to give your registration and other information, including e-mail address, to that third party. If you have identified yourself as residing in the EU, we will not share your email address or other personally identifiable information with third parties for advertising purposes unless you have "opted-in."
In addition, Third Party Advertising Service Providers may use their own Tracking Technologies to gather information about you.
D. Business Transfer
In the event that assets relating to one or more of the GEMS Sites are transferred or sold to another entity as a result of, for example, a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy, information collected at the GEMS Sites may be transferred to the acquiring company.
E. With Your Consent
We may otherwise disclose your information pursuant to your consent.
The GEMS Sites are designed for and targeted to U.S. audiences and are governed by and operated in accordance with the laws of the U.S. While users from countries other than the U.S. may access certain of the GEMS Sites, we make no representation that the GEMS Sites are operated in accordance with the laws or regulations of, or governed by, other nations.
If you are located outside of the U.S., the EEA and Switzerland, you use this Site at your own risk and initiative and you, not we, are responsible for compliance with any applicable local and national laws. Please be aware that any personal information and other information you provide to us or we obtain as a result of your use of this Site shall be collected in the U.S. and/or transferred to the U.S. and subject to U.S. law.
The GEMS Sites maintain reasonable technical and organizational steps to help ensure that information collected is secure, including limiting the number of people who have physical access to our database servers and use of electronic security systems and password protections which guard against unauthorized access. The GEMS Sites conduct financial transactions via secured transmissions. We limit access to visitor's information to employees and contractors who are authorized for the proper handling of such information, and any employee found violating our standards of security and confidentiality will be subject to our disciplinary processes. We also take reasonable steps to help make sure our third-party agents protect the security of your personal information. However, as with most Internet sites or services, it is possible that third parties may unlawfully access such personal information through a number of means despite our efforts.
A. Reviewing Your Information
You have the right to access, update and correct factual inaccuracies in personally identifiable information that we collect online at the GEMS Sites, subject to certain exceptions. To do so, you should log into your account or you may e-mail us at email@example.com.To help protect your privacy and the security of your personally identifiable information, we will take reasonable steps to verify your identity before granting access.
Registered users of this Site who are California residents and are under 18 years of age may request and obtain removal of Postings on this Site that they themselves post by emailing us at firstname.lastname@example.org. All requests must be labeled "California Removal Request" on the email subject line. All requests must provide a description of the content or information in your Posting that you want removed and information reasonably sufficient to permit us to locate the material and, so that we can process your request and contact you if we have questions, include your registered username and the name and URL (if applicable) of the website, application or other interactive service. We shall not accept requests via postal mail, telephone or facsimile. We are not responsible for notices that are not labeled or sent properly, or may not be able to respond if you do not provide complete information.
B. Parental Access
Parents/guardians of children under the age of 13 can print out and mail or fax us a signed form that allows them to review any personally identifiable information collected about their child, have this information deleted, and/or request that there be no further collection or use of their child's personally identifiable information. We will take steps to verify the identity of anyone requesting personally identifiable information about a child and to ensure that the person is in fact the child's parent or legal guardian.
The websites that comprise the GEMS Sites may contain links to other sites, including those of sponsors, advertisers, social networking platforms, and survey companies. These other websites are governed by their own privacy policies or information collection practices, which may be substantially different from ours. We encourage visitors to other websites to review the privacy policies and information collection practices of those websites.
California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to or write us: email@example.com email, or you may contact us via regular mail at:
GEMS The Education Partners
70 West 40th St, FL 6
New York, NY 10018
If you have any other questions about our information handling practices, including our practices with respect to children's personal information, or would like further information regarding the GEMS Sites that are directed to children under 13 years of age, please contact us at:
GEMS The Education Partners
70 West 40th St, FL 6
New York, NY 10018
Or email us at: firstname.lastname@example.org
Or call this number: 646-779-3810
Other corporate affiliates may collect or maintain information through the GEMS Sites.