Consumer Privacy Notice

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:
• Social Security number and account balances
• Payment history and transaction history
• Credit scores and wire transfer instructions

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Gemini chooses to share; and whether you can limit this sharing.

For our everyday business purposes—
such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes—
to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes—
information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes—
information about your creditworthiness

Yes

Yes

For our affiliates to market to you

Yes

Yes

For our nonaffiliates to market to you

No

We don’t share

To Limit Our Sharing

Call 1-877-725-1116
Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

Questions?

Go to https://support.gemini.com/hc/en-us/requests/new

Who is providing this service?

Gemini Trust Company, LLC and Gemini Constellation, LLC (“Gemini”)

How does Gemini protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Gemini collect my personal information?

We collect your personal information, for example, when you

• Open an account or give us your contact information
• Make deposits or withdrawals from your account
• Use your credit card or pay your bills

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes—information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account.

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.
• Our affiliates include Gemini NuSTAR, LLC and Nifty Gateway, LLC.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.
• Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
• Our joint marketing partners include financial companies such as Flexa.

We may transfer personal information to other countries, for example, customer service.

For California Customers. If your Gemini account has a California mailing address, we will not share personal information we collect about you except to the extent permitted under California law.

For Vermont Customers. We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at https://www.gemini.com/legal/privacy-policy.