Privacy Policy

1. Controller

GEMS4GENS INC., 8 The Green, Dover 19901, USA, represented by Robert Rother, Director. Email: info@gems4gens.com, phone: +1 (302) 440-5909.

2. Overview

We process personal data only to the extent necessary to operate this website and to handle your enquiry, or where you have given consent. We explain our strategies and answer questions about them, but we do not provide investment advice and do not accept client money.

3. Hosting and server log files

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 forms

We process the details from the respective form: name, email address, phone number (voluntary), country, message and – depending on the form – trading experience, markets, current results, available capital and preferred path (traders) or investor type, volume, area of interest and conversation format (investors) or company, role, interest in cooperation, licence and client base (partners) or company, industry, revenue range (voluntary), employees (voluntary), time horizon and succession status (business exit). In addition, we store the date and time of the enquiry and your consent.

Purpose: handling your enquiry, contacting you and preparing a strategy conversation, a confidential first conversation about business exit or The Iceberg Path. The legal basis is your consent under Art. 6(1)(a) GDPR and, where pre-contractual steps are concerned, additionally Art. 6(1)(b) GDPR. Providing the details is voluntary; without the mandatory details and your consent we cannot handle your enquiry.

5. Disclosure

This website does not currently collect Pooled Accounts enquiries or forward enquiry data to CTM. Your data is not passed to Iceberg Funding without informing you first. We do not disclose your data to any other third parties and do not sell it.

6. Transfer to a third country (USA)

GEMS4GENS INC. is based in the USA. The transfer of your enquiry to us is based on your explicit consent under Art. 49(1)(a) GDPR and, where you request pre-contractual steps, because it is necessary for those steps under Art. 49(1)(b) GDPR.

7. Retention period

We delete your enquiry data 12 months after the last contact, unless a further business relationship arises, you withdraw your consent earlier, or statutory retention obligations apply. After withdrawal, we delete your data without undue delay unless we need it to evidence consent or for legal reasons.

8. Cookies and analytics

Your language choice is stored locally in your browser in localStorage and the “iceberg_lang” cookie; this is technically necessary under § 25 Abs. 2 Nr. 2 TDDDG and based on Art. 6(1)(f) GDPR.

This website uses only technically necessary cookies or storage technologies (§ 25(2) TDDDG). We use Lovable for visitor analytics. Lovable analytics uses no cookies, stores nothing on your device, does not keep IP addresses and does not identify visitors. It records pages visited, where visitors came from, country, browser, operating system and device type, time spent, page loading speed, errors, and clicks on buttons and links. These data are recorded for every visitor. Detailed data is kept for 90 days and daily summaries for a year. Lovable collects this data for us. Lovable’s privacy policy at https://lovable.dev/privacy explains how it handles it.

External links (e.g. Bookmap, Skool, Iceberg Funding) open in a new window; when clicked, the privacy policy of the respective provider applies.

9. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). You can withdraw any consent given at any time with effect for the future (Art. 7(3) GDPR), e.g. by email to info@gems4gens.com.

You may also lodge a complaint with a data protection supervisory authority, in particular in the EU member state of your habitual residence or place of work (Art. 77 GDPR).

10. No solely machine-based decisions

We do not carry out decision-making based solely on machine processing, including profiling, within the meaning of Art. 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 will update this privacy policy if the website or the legal situation changes.