This Privacy Policy explains how Gemiway Ltd (“Company”, “we”, “us”, or “our”) collects, uses, and protects personal data when you use the Gemiway mobile application (the “App”). We are committed to protecting your privacy and handling personal data in accordance with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and, where applicable, the EU General Data Protection Regulation (GDPR).
Data Controller The data controller responsible for your personal data is: Gemiway Ltd Registered in England and Wales For privacy-related inquiries please contact: support@gemiway.com
Information We Collect We may collect the following categories of information when you use the App. Account Information When you sign in using Apple or Google authentication, we may receive:
your email address
authentication identifiers associated with your account
If you voluntarily provide your email address, it may also be used to manage your account and, where you opt in, for marketing communications.
User Input Data When using certain features of the App, you may voluntarily provide information such as:
responses to check-in questions
personal reflections or notes
selections made within the App
This information is used to generate personalised insights and features within the App.
Photo Data Some App features, including FaceMatch, may involve the temporary processing of photos provided by the user. Photos uploaded for these features:
are processed solely to generate results
are processed temporarily
are not stored or retained by the Company
are automatically deleted after processing
are not used to train artificial intelligence models
Usage Data We may collect information about how users interact with the App, including:
features used
interactions within the App
general usage patterns
This information helps us improve the functionality and performance of the App.
Device and Technical Data We may collect limited technical information such as:
device type
operating system version
crash reports
diagnostics data
This information helps us maintain the stability, security, and performance of the App.
How We Use Your Data We process personal data in order to:
operate and maintain the App
provide personalised features and insights
generate AI-assisted outputs
improve the App’s functionality and performance
monitor technical performance and prevent misuse
communicate with users when necessary
Where you have provided consent, we may also use your email address to send updates or marketing communications. You may unsubscribe at any time.
Legal Basis for Processing Under UK GDPR and EU GDPR, we rely on the following legal bases for processing personal data:
Performance of a contract to provide the App and its services.
Legitimate interests to maintain, secure, and improve the App.
Consent for optional activities such as marketing communications.
AI Processing The App uses automated systems and artificial intelligence to analyse user inputs and generate informational outputs. This processing may include analysis of:
questionnaire responses
user-provided inputs
optional photos provided for certain features
AI-generated outputs are produced automatically and are intended for informational and reflective purposes only.
AI Transparency Some features of the App generate content using automated systems and artificial intelligence. Certain insights, suggestions, or informational outputs may therefore be created automatically without human review. By using the App, you acknowledge that such content is generated by automated systems and is intended solely for informational and self-reflection purposes.
Third-Party Service Providers We rely on trusted third-party providers to operate the App. These providers may process data on our behalf and act as data processors. These providers include:
Amazon Web Services (AWS) – cloud infrastructure
Firebase (Google) – analytics and crash reporting
Apple and Google authentication services – account login
Third-party AI service providers used to generate automated outputs
These providers process data only as necessary to enable the operation of the App and its features.
International Data Transfers Some service providers may process data outside the United Kingdom or the European Economic Area. Where such transfers occur, appropriate safeguards are implemented in accordance with applicable data protection laws.
Data Retention We retain personal data only for as long as necessary to provide the App and fulfil the purposes described in this Privacy Policy. User-generated content such as responses or notes may be retained while your account remains active. Photos submitted for FaceMatch are processed temporarily and deleted immediately after processing.
Your Data Protection Rights Depending on your location, you may have the following rights under applicable data protection laws:
the right to access your personal data
the right to request correction of inaccurate data
the right to request deletion of your data
the right to restrict processing
the right to object to processing
the right to data portability
To exercise these rights, please contact us at: support@gemiway.com
Complaints If you believe your data protection rights have been violated, you have the right to lodge a complaint with a supervisory authority. In the United Kingdom, this authority is the Information Commissioner’s Office (ICO).
Security We implement appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, or misuse. However, no system can guarantee absolute security.
Changes to This Privacy Policy We may update this Privacy Policy from time to time. If significant changes are made, we will notify users within the App or through other appropriate means. Continued use of the App after such updates constitutes acceptance of the revised policy.
Contact For privacy-related questions or requests: support@gemiway.com
