Effective 2/17/2015

GemIIni is created by GemIIni Systems, Inc. At GemIIni, Inc. (“GemIIni”, “Company”, “we”, “us” or “our”), we know your privacy is important to you and GemIIni is fully committed to your privacy.

This Privacy Policy covers our treatment of personally identifiable information (“Personal Information”, as more fully defined below) that we gather when you are accessing our App and supporting services. This policy does not apply to processes we do not control, or to individuals that we do not employ or manage.

BY USING THE APP, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF, THIS PRIVACY POLICY. IF YOU DO NOT UNDERSTAND OR DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY, YOU MUST IMMEDIATELY REMOVE THE APP FROM YOUR DEVICE.

WHAT INFORMATION DO WE COLLECT?

We gather information which enables us to personalize and improve our services. We collect the following types of information from our customers.

Personal Information You Provide To Us:

In order for you to use certain of the App’s Services, you may be asked to provide to us with certain Personal Information. Personal Information includes, without limitation: (1) “Contact Data” (such as your name, company name, mailing address, and e-mail address); (2) “Demographic Data” (such as you zip code and age); (3) “Diagnostic Data”; and (4) “Academic Data” (such as the results of a student’s progress). In each case, you will be asked to provide Personal Information or to take tests; the App will not gather it surreptitiously. Company may supplement the Personal Information you provide with additional Personal Information gathered from public sources or from third-parties (e.g., consumer reporting agencies) who may lawfully provide such information to us.

You are under no obligation to provide Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the App’s Services.

Information Collected Automatically:

We may receive and store certain types of information whenever you interact with our App or services. The Company automatically receives and records information on our server logs from the App including your IP address, Company cookie information, the videos you requested, test and training program data.

Generally, our service automatically collects usage information, such as the number and frequency of App login and video viewing, similar to TV ratings that indicate how many people watched a particular show. Company uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally.

HOW WE USE YOUR PERSONAL INFORMATION

We use information we collect to authenticate your App usage and send you information and products.

If you have opted in to receiving marketing information, we use your personal information to customize and deliver that information to you.

We also use the information to manage and improve our App, our videos and our training. We may use your information, in aggregate form and in collaboration with outside researchers, to measure and quantify the effectiveness of our program or to help researchers analyze data to better formulate studies and advance their knowledge of developmental disorders or language acquisition. In our research, all the data is used in aggregate form or with your personal information removed. At no point will you be personally identifiable.

We may enhance or merge personal information with your other information and with data from third parties in order to better market and provide our products and services.

The App may contain features, e.g. blogs, chat rooms, etc., that permit you to upload, post, transmit, display, perform or distribute content, information or other, including personal information. Any information that you choose to disclose by means of such features becomes public information over which we are unable to exercise control. You should exercise caution when deciding to disclose information by means of such features, and you agree to assume all responsibility for doing so.

LIMITED DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES

Personal Information about our customers is an integral part of our business. We do not share Personal Information with unrelated third parties for their direct marketing purposes. We share your Personal Information only with our partners and affiliates as described below. We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Examples include processing credit card payments with a secure third party provider. Unless we tell you differently, these agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us.

We also disclose Personal Information when required to do so by law, or in response to a subpoena, court order, or other legal mechanism, or when we believe, in our sole discretion, that disclosure is reasonably necessary to protect the property or rights of the Company, third parties or the public at large.

We reserve the right to sell, transfer or otherwise share some or all of our assets, including information provided by you, in connection with a merger, reorganization or sale of some or all of our assets or in the event of bankruptcy. In any such event, personally identifiable and other information may be one of the assets transferred. We will post notice before personal information is transferred and becomes subject to a different privacy policy. You hereby consent to our sharing of Personal Information for the above purposes.

IS PERSONAL INFORMATION ABOUT ME SECURE?

The App has implemented and maintains reasonable security procedures and practices to protect against the unauthorized access, use, modification, destruction or disclosure of your Personal Information.

CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be updated from time to time as our services change and grow. Accordingly, each time you use the App you should check the “Last Updated” date of this privacy policy (located at the top), and review any changes since you last accessed the App. Such changes are effective ten (10) calendar days after the Last Updated date (the date they become effective is the “effective date”). Unless Company obtains your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier Privacy Policy.

QUESTIONS AND CONCERNS

We welcome inquiries or comments about our Privacy Policy and any queries or concerns about GemIIni by email at info@gemiini.org. You may also send a letter to the following address:

Director of Privacy 
GemIIni Systems 
801 South Stevens 
Spokane, WA 99223