Privacy Policy

1. Controller

Gems4Gens Inc., 8 The Green, Dover 19901, USA, represented by Robert Rother, Director. Email: info@gems4gens.com, telephone: +1 (302) 440-5909.

2. Overview

We process personal data only where necessary to operate this website and handle your enquiry, or where you have given consent. We explain the strategy and answer questions about it, but provide no investment advice and do not accept client money.

3. Hosting and server logs

This website is operated and hosted via the Lovable platform. The provider is Lovable Labs Sweden AB, Regeringsgatan 25, 111 53 Stockholm, Sweden. Lovable uses further service providers for operation and delivery (e.g. Supabase for database and backend, Cloudflare for delivery and security), some of which also process data in the USA. When you access the website, technical data is processed automatically: IP address, date and time of access, page accessed, browser type and version, operating system and referrer URL. The purpose is the secure and stable provision of the website. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in the technically error-free and secure operation. Lovable processes this data on our behalf (Art. 28 GDPR). Log data is stored only for as long as necessary for secure operation and is then deleted. Transfers to the USA are based on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR) or, where the recipient is certified, the EU-US Data Privacy Framework (Art. 45 GDPR).

4. Contact form

If you send us an enquiry using the contact form, we process the following details: name, email address, telephone number (optional), country, intended investment amount, investment horizon, experience with futures or CFDs, preferred contact method and time, purpose of enquiry (optional), and your message. We also store the date and time of the enquiry and your consent.

Purpose: we store your enquiry and forward it to the licensed financial portfolio manager CTM Global Investment Ltd so that it can contact you, review your details and, where appropriate, carry out client onboarding.

Your enquiry is first stored on this website and then sent server-to-server to our central Iceberg CRM. The CRM receives the form details, your consent, language and enquiry time to handle your enquiry and forward it to CTM.

The legal basis is your consent under Article 6(1)(a) GDPR. Where your enquiry is aimed at entering into a contract with the financial portfolio manager, processing is also necessary for pre-contractual measures (Article 6(1)(b) GDPR).

Providing these details is voluntary. Without your name, email address, country and consent, we cannot forward your enquiry.

5. Disclosure to the financial portfolio manager

The recipient of your enquiry is CTM Global Investment Ltd, C2-401, 4th Floor, Grand Baie La Croisette, Grand Baie, Mauritius, regulated by the Financial Services Commission Mauritius (licence GB24203653). CTM is itself responsible for further processing of your data in connection with client onboarding, identity and suitability checks, and the contractual relationship; details of its data processing are available directly from CTM.

We do not disclose your data to other third parties or sell it.

6. Transfer to a third country (Mauritius, USA)

Mauritius is outside the EU and the EEA. There is no EU Commission adequacy decision for Mauritius; the level of data protection may therefore be lower than in the EU, and your rights may be harder to enforce there. The transfer to CTM is based on your explicit consent under Art. 49(1)(a) GDPR. GEMS4GENS INC. is also based in the USA. The transfer of your enquiry to us is based on your explicit consent (Art. 49(1)(a) GDPR) and, where you request pre-contractual steps, on its necessity for those steps (Art. 49(1)(b) GDPR).

7. Retention period

We delete your enquiry data 12 months after the last contact, provided no client relationship with the financial portfolio manager is established, you have not withdrawn your consent earlier, and no statutory retention obligations apply. After consent is withdrawn, we delete your data without delay unless it is needed as evidence of consent or for legal reasons.

8. Cookies and analytics

On the published website, we use Lovable’s visitor analytics. It uses no cookies, stores nothing on your device, does not keep IP addresses and does not identify visitors. With no consent banner, page visits, where visitors came from, country, browser, operating system, device type, time on page, page speed and errors, as well as clicks on buttons and links, are recorded for every visitor. Clicks are identified by their position on the page, not their text. The website also sends error reports to Lovable, but no other app events.

Detailed data is kept for 90 days and daily summaries for a year. Lovable collects this data for us. Lovable’s privacy policy explains how it handles it.

For the Plus Jakarta Sans font, your browser loads a Google Fonts file from Google. Google receives your IP address and technical request data. Font files may be cached in your browser. The font is used to display the website; we use no advertising pixels, embedded content or sign-in.

9. Your rights

You have the right of access (Article 15 GDPR), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20), and objection to processing based on legitimate interests (Article 21). You may withdraw consent at any time with effect for the future (Article 7(3) GDPR), for example by emailing info@gems4gens.com. We will also inform CTM of your withdrawal.

You may also lodge a complaint with a data protection supervisory authority, particularly in the EU Member State where you normally live or work (Article 77 GDPR).

10. No automated decision-making

We do not carry out automated decision-making, including profiling, under Article 22 GDPR.

11. Security

This website is transmitted using encryption (TLS/HTTPS). We and our service providers apply appropriate technical and organisational measures, including encryption in transit and at rest, role-based access restrictions and regular backups.

12. Changes

We update this privacy policy if the website or legal requirements change.