Customer Wellbeing Questionnaire Terms of Use

Dernière mise à jour : September 4, 2025



These Terms of Use, together with
, collectively referred to as the “Terms”, govern your participation in the Customer Wellbeing Questionnaire (the "Questionnaire"). You must read and agree to these Terms before completing the Questionnaire.

Purpose and Scope of the Questionnaire

The Questionnaire aims to assist Gemini in its compliance with the Financial Conduct Authority’s (FCA) Consumer Duty obligations, which sets high standards of consumer protection across financial services, and requires firms to put their customers' needs first. The duty consists of the principle of acting to deliver good outcomes for retail customers and three cross-cutting rules to act in good faith, to avoid causing foreseeable harm and to enable and support customers to pursue their financial objectives. It is necessary, therefore, for Gemini to survey its customers to better understand their needs.Through analysing Questionnaire responses, Gemini expects to be able to identify customers with particular circumstances and requirements that would benefit from reasonable adjustments being provided (such as but not limited to additional support or additional explanation of key product performance and features).
Your participation and responses in the Questionnaire is voluntary, and will solely be used to enhance Gemini’s understanding of customer characteristics and to inform how we can provide services tailored to specific needs.
Participation in the Questionnaire is voluntary. Your explicit consent for processing special category data will be clearly captured via a mandatory tick box within the Questionnaire, in line with Gemini’s obligations under UK General Data Protection Regulation (UK GDPR). Your explicit consent enables Gemini to lawfully process your data solely for vulnerability identification purposes. 
Gemini will not use Questionnaire responses for any other commercial or non-commercial purposes, nor will Questionnaire responses impact your ability to maintain your account with Gemini.


Handling of Sensitive Data

Gemini is committed to maintaining the confidentiality and security of all data collected through the Questionnaire. Questionnaire responses will be processed strictly in accordance with UK GDPR, the Data Protection Act 2018, and Gemini’s Privacy Policy. Gemini will maintain accurate, secure and up-to-date records of your responses. Should your responses require updating, you may contact Gemini support to update the information to ensure ongoing accuracy and relevance.  
You retain the right to withdraw your consent to data processing at any time by notifying Gemini via the contact information provided below. Upon withdrawal, Gemini will cease processing your personal data related to the Questionnaire.


Account Management

Gemini reserves the right to take necessary actions in accordance with applicable law and regulatory requirements if other legitimate factors, unrelated to your responses, necessitate such measures. Instead, Questionnaire data is intended exclusively to assist Gemini in providing an enhanced duty of care and tailored services to customers. Gemini ensures that staff responsible for processing and handling Questionnaire responses are appropriately trained and capable of addressing such issues sensitively and competently.  


Your Obligations

You warrant that all information provided in the Questionnaire is truthful, accurate, and reflective of your genuine circumstances. You acknowledge that Gemini relies solely on the accuracy and completeness of your self-declared responses.


Acceptable Use

When participating in the Questionnaire, you agree not to:
  • Provide false, misleading, or inaccurate information.
  • Use the Questionnaire in a manner which could compromise its integrity or confidentiality.
  • Infringe Gemini’s intellectual property rights or those of any third parties.
  • Use the Questionnaire data or responses for commercial gain.


Intellectual Property

All intellectual property rights related to the Questionnaire remain exclusively with Gemini. You are not authorised to reproduce, distribute, modify, or commercially exploit the Questionnaire or associated materials without explicit written consent from Gemini.


Liability Limitation

Gemini provides the Questionnaire on an "as is" basis without warranties or representations of any kind, whether express or implied. To the maximum extent permitted by law, Gemini limits its liability, excluding liability only where legally permissible and reasonable to do so, for any indirect, consequential, or incidental loss, damage, or inconvenience arising from your participation in or use of the Questionnaire.


Changes to Terms

Gemini reserves the right to modify these Terms at any time. Any substantial changes - such as alterations to data processing purposes, significant amendments affecting your rights, or material modifications to consent requirements - will be communicated to you via email. 


Termination

You may cease participation in the Questionnaire at your discretion. Gemini reserves the right to suspend or terminate your participation if these Terms are breached.


Contact Information

If you have concerns, queries, or complaints regarding the Questionnaire or these Terms, please contact Gemini Customer Support at support@gemini.com who have specialised processes in place to assist vulnerable customers effectively.

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