This Privacy Policy explains how Gemiway Ltd (“we”, “us”, or “our”) collects, uses, stores, and protects personal data when you use the Gemiway mobile application (the “App”). We are committed to handling personal data responsibly and transparently and to protecting your privacy in accordance with applicable data protection laws. This Privacy Policy should be read together with our Terms of Use.
Data Controller Gemiway Ltd Registered in England and Wales Scope and Applicability This Privacy Policy applies to all users of the App, regardless of their location. As Gemiway Ltd is established in England and Wales, personal data is processed in accordance with UK data protection standards. Where necessary, data may be processed outside the UK or EU to enable the operation of the App and its features.
Children’s Privacy The App is intended for users aged 9 years and older. We do not knowingly collect personal data from children under the age of 9. If we become aware that such data has been collected, we will take reasonable steps to delete it promptly. If you believe that a child under the age of 9 has provided personal data through the App, please contact us.
Data We Collect Information You Provide:
email address
date of birth (optional)
place of birth (optional)
photos (temporary)
questionnaire responses
personal notes
Providing optional data is voluntary. The App functions without it.
Information Collected Automatically
push notification tokens
crash reports and diagnostic data (Crashlytics)
Information We Do Not Collect
IP addresses
precise location data
device fingerprinting
cookies or tracking technologies
Purpose of Data Processing We process personal data only to:
operate and provide the App
deliver requested features and insights
respond to user inquiries
communicate with users who have opted in
improve stability, performance, and security
Photos and AI Processing Photos are processed transiently, deleted immediately after use, not logged or backed up, and not used to train AI models.
AI and Third-Party Processing The App uses automated AI-based features and third-party AI services via backend infrastructure. Data is processed solely to deliver requested features and is not used for training, profiling, or advertising purposes.
Email Communications Emails are sent only with explicit opt-in consent. You may unsubscribe at any time.
Push Notifications Push notifications may include functional updates and informational insights. You can disable them in device settings.
Data Retention Account data is deleted within 30 days of account deletion unless required by law.
Your Rights You may access your data, delete your account, or withdraw email consent at any time.
Security We apply reasonable security measures, but no system is completely secure. You use the App at your own discretion.
Changes Material changes will be communicated in-app.
