Introduction
Gemini Intergalactic Australia, Pty Ltd ("Gemini", "we", "us" or "our") is committed to respecting your privacy. We’re bound by the Privacy Act 1988 (Cth) and handle personal information in accordance with the Australian Privacy Principles (APPs). This supplemental notice applies to individuals in Australia and must be read together with our global Privacy Policy. If anything in this notice conflicts with the global Privacy Policy for Australian users, this notice applies.
Sensitive information
Certain types of personal information are classified as sensitive under Australian law. This includes information that uniquely identifies you, such as biometric data. In Australia we collect biometric data (for example, images of identity documents and facial images) only when it is necessary under our Privacy Policy. We will ask for your consent before collecting sensitive information unless an exception in the Privacy Act applies. We do not use biometric or other sensitive information for marketing. Sensitive information is stored securely and is deleted or de-identified when it is no longer required by law or our business purposes.
How we collect personal information
We collect personal information in the following ways:
Directly from you – when you create or update an account, place orders, transfer funds, communicate with us, participate in surveys or promotions or otherwise provide information to us.
Automatically – when you use our websites, mobile applications or other services, we collect device and usage information through cookies and similar technologies.
From third parties – for example, identity verification services, banking partners, public blockchains and other service providers.
We collect information only by lawful and fair means. You may browse our website anonymously. However, due to financial services and anti-money-laundering laws, we must verify your identity to provide services such as opening an account or facilitating transactions.
Handling information about children and vulnerable people
Our services are intended for people aged 18 years and over. We do not collect personal information from children under 18. If we discover that we have inadvertently collected such information, we will securely delete it. We only collect personal information about vulnerable people when necessary to provide our services and with appropriate consent. We explain the purpose of collection, how it will be used and disclosed, and the procedures we follow to protect that information. If you believe we have collected information about a child or vulnerable person without proper consent, please contact us immediately.
How we hold and secure personal information
Personal information is stored on secure servers operated by Gemini or trusted service providers. These servers may be located in the United States, the United Kingdom, the European Economic Area, Singapore and other countries where we or our affiliates operate. Our trusted service providers that hold personal information include but are not limited to Amazon Web Services, Inc. (“AWS”), Databricks, Inc. and Zendesk. We use physical, administrative and technical safeguards to protect personal information from misuse, loss, unauthorised access, modification or disclosure. Measures include encryption, multi-factor authentication, role-based access controls and monitoring of staff access. Service providers that handle personal information on our behalf are subject to contractual obligations to protect the information and to use it only for the purposes for which it was disclosed.
Data quality, retention and destruction
We take reasonable steps to ensure that the personal information we hold is accurate, complete and up to date. This includes verifying the information you provide when you open an account, allowing you to review and update your details through your account settings or by contacting us, and periodically checking information that is likely to change.
We retain personal information for as long as necessary to provide our services, meet record-keeping obligations, resolve disputes and enforce our agreements. Sensitive information and data that can quickly become outdated are reviewed regularly. When personal information is no longer needed and we are not required by law to retain it, we destroy or de-identify it using secure methods.
Accessing and correcting your personal information
You may request access to personal information that we hold about you. To do so, please email us at privacy@gemini.com or write to our Privacy Officer at the address below. We will respond within a reasonable time and provide you with access in the manner you request if it is reasonable and practicable. We do not charge for making an access request; if there are costs associated with providing copies of information, we will let you know before proceeding.
If you believe that personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us. We will take reasonable steps to correct the information. If we decline to provide access or to correct your information, we will provide written reasons.
Complaints and dispute resolution
If you have a concern about how we have handled your personal information, please contact our Privacy Officer first.
Privacy Officer – Gemini Intergalactic Australia, Pty Ltd
Postal address: InCorp Advisory, Level 1, 6-10 O' Connell Street, Sydney New South Wales 2000
We will acknowledge your complaint as quick as possible and respond in a reasonable amount of time. If you are not satisfied with our response, you can contact the Australian Financial Complaints Authority (AFCA) and the Office of the Australian Information Commissioner (OAIC). AFCA provides a free, independent dispute resolution service for financial complaints. You may also have the right to lodge a complaint with the OAIC if you believe we have breached your privacy rights.
Overseas disclosure
Because Gemini operates internationally, we may transfer personal information to our affiliates and service providers in countries outside Australia. These recipients may be located in the United States, the United Kingdom, the European Economic Area, Singapore or other jurisdictions. We ensure that overseas recipients handle personal information in a way that is consistent with Australian privacy requirements by using contractual protections and technical measures. By providing us with your personal information or using our services, you consent to such overseas transfers.
Updating this notice
We may update this Supplemental Privacy Notice from time to time to reflect changes in our practices, legal obligations or for other reasons. When we make material changes, we will publish the updated notice on our site and indicate the new version number and effective date at the top. If changes may significantly affect your privacy rights, we will provide more prominent notice (such as by email or through your account) so you can review the changes.
