This Privacy Policy is designed to help you understand how GEM Asset Management, LLC (“we”, “us” or “our”), collects, uses, and shares personal information collected through this website and related sites (the “Site”). We value your privacy, and we will not share your personal information with third parties except as described in this Privacy Policy without your consent.
BY USING THIS SITE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH ANY OF THE TERMS OF THE PRIVACY POLICY, PLEASE DO NOT USE THIS SITE OR PROVIDE US WITH YOUR INFORMATION.
This Privacy Policy applies to our collection, use and sharing of your personal information when you visit our Site or receive our communications. This Privacy Policy does not apply to any other information or websites not owned or operated by GEM Asset Management or information collected by GEM Asset Management by other means. The information you provide may also be subject to additional terms. For example, the information we collect about you if you engage us to provide investment services is subject to additional terms detailing how we use and share your information as your financial adviser, which can be found here.
Information You Give Us. Personal information you may provide through the Site or otherwise communicate to us includes:
Information We Get From Others. We may obtain additional information about you from third party sources, such as service providers, vendors, social media sites, and advertising agencies to provide you with more relevant information about our services.
Information Automatically Collected. Our servers and third-party service providers may automatically record certain information about how you use the Site, such as your Internet Protocol (IP) address, device and browser type, operating system, DNS, the pages or features of the Site that you browsed and the time spent on those pages or features, the frequency with which you use the Site, the links that you click on or use, and other statistics. We collect this information in server logs and by using cookies and similar tracking technologies. See our Cookie Policy, below, for more information.
We utilize advanced digital tracking technologies on our Site, including Google Analytics 4 (GA4) and the Meta Pixel. These tools track your interactions with our content to help us evaluate website performance, improve our advisory services, and deliver relevant informational marketing.
Sensitive Personal Information. If you are a client, we may collect certain sensitive personal information about you through the Site in connection with the services we provide as an investment advisor. This information may include your social security number and financial holdings and account numbers, among other information. In collecting this sensitive personal information, GEM Asset Management respects individual privacy, protects against unauthorized access to or use of information, and complies fully with all laws and government regulations in the collection, use, storage, display, distribution and disposal of such information. Authorized uses of sensitive information with are limited to uses which are necessary to: a) meet our legal and regulatory requirements; or b) facilitate access to services, transactions, facilities and information.
We use your personal information for the following purposes and as otherwise described to you in this Privacy Policy or at the time of collection:
To Provide our Site and Communicate With You. We use your personal information:
To Provide our Services and Create and Maintain Your Account. To utilize the services provided through the Site, you may create an account using certain personal information. You have choices about the information you provide through your account.
To Send You Marketing Communications. We may send you newsletters, promotions or other marketing communications, but you may opt out of receiving them as described in the Your Choices section, below.
For Compliance, Fraud Prevention and Safety. We may use your personal information as we believe appropriate to: (a) investigate or prevent violation of the law or your agreements with us; (b) protect our, your or others’ rights, privacy, safety or property (including by prosecuting and defending legal claims); (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; and (e) where permitted by law in connection with a legal investigation. For example, we may share information with law enforcement to reduce the risk of fraud or if someone uses or attempts to use our site for illegal reasons.
With Your Consent. In some cases we may ask for your consent to collect, use or share your personal information.
We may use third parties to help us design and operate the Site, provide services to support the Site, or otherwise process your information. For example, we may hire a company to run certain website applications, help us analyze our data, or send information on our behalf about services and events in which you may be interested. Unless otherwise indicated at the time we collect your information, if we allow third parties to access the personal information we collect, we will have contractual provisions or other appropriate protections in place to ensure such access is for limited purposes and in compliance with this Privacy Policy. We do not share your personal information with third parties without your consent, except in the following circumstances:
Related and Affiliated Organizations. We may share your personal information with GEM Asset Management’s affiliates and related organizations for use consistent with this Privacy Policy.
Service Providers and Business Partners. We may share your personal information with third party companies and individuals as needed for them to provide us with services that help us with our business activities and to promote our services to you. We may also share your personal information with our business partners who offer a service to you jointly with us.
Security, Compliance, Fraud Prevention, Safety; Compliance with Law. We may disclose your personal information as we believe appropriate to government or law enforcement officials or private parties for the purposes of complying with applicable law as well as described under the above section titled “For Compliance, Fraud Prevention and Safety.”
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy.
Opt Out of Communications. You may opt out of email notifications by changing the communication preferences in your account settings.
Opt Out of Marketing. You may opt out of marketing-related emails by following the opt-out prompt in the email. To opt out of other forms of marketing communications, please contact us using the contact information provided at the end of this Privacy Policy.
Consequences of Not Providing Personal Information. You are not required to provide all personal information identified in this Privacy Policy to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide personal information. For example, if you do not provide personal information, we may not be able to respond to your request, perform a transaction with you, or provide you with marketing that we believe you would find valuable.
What are Cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies set by the website are called “first party cookies”. Cookies set by parties other than the website are called “third party cookies”. Third party cookies enable third party features or functionality, such as advertising or website analytics, to be provided on or through the website. The parties that set these third party cookies can recognize your computer or device both when it visits the website in question and also when it visits certain other websites and/or mobile apps.
What Cookies and Other Tracking Technologies does GEM Asset Management Use? We use several different kinds of cookies on this Site, including strictly necessary cookies, which are cookies that are necessary for the Site to function and cannot be switched off in our systems; performance cookies, which allow us to count visits and traffic sources so we can measure and improve the performance of our Site; and functional cookies, which enable the Site to provide enhanced functionality and personalization. We also collaborate with various third-party service providers who also use cookies to help us optimize our website and understand more about the visitors to our website. For example, we use Google Analytics to provide us with demographic information about our visitors and to help us analyze how people use our website. To learn more about how Google uses cookies, please click the link above or visit its website to view its privacy policy.
How Can You Disable Cookies and Other Tracking Technology? Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.
Universal Opt-Out and Browser Signals. Some internet browsers can be configured to send “Do Not Track” signals to the online services you visit. Because there is currently no industry consensus on a uniform standard for recognizing traditional “Do Not Track” signals, we do not systematically alter our data collection practices in response to them. However, we explicitly recognize and honor the Global Privacy Control (GPC) signal. If you utilize a browser or a browser extension that transmits a valid, automated GPC opt-out preference signal, our Site detects and treats that signal as a valid request to opt out of the collection and sharing of your personal information for cross-context behavioral advertising. Upon detecting the GPC signal, our third-party tracking scripts, including the Meta Pixel and Google Analytics, will be automatically restricted or disabled for your browsing session. To learn more about this universal preference signal and how to enable it on your browser, please visit Global Privacy Control (https://globalprivacycontrol.org/).
Third Party Sites and Services. The Site may contain links to other websites and services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites, applications or services, and we are not responsible for their actions. Other websites and services follow different rules regarding their collection, use and sharing of your personal information. We encourage you to read their privacy policies to learn more.
Security. The security of your personal information is important to us. We take a number of organizational, technical and physical measures that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your personal information.
Data Retention and Minimization. We adhere to strict data minimization principles and do not retain personal or automatically collected browsing information longer than is necessary to fulfill the operational and analytical purposes outlined in this Privacy Policy, or as required to meet our regulatory recordkeeping obligations as a Registered Investment Advisor.
International Data Use and Cross-Border Transfers. We are located in the United States and have service providers in other countries, and your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. However, we will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is kept. Regarding transfers from the European Economic Area, Switzerland or United Kingdom to the United States, we rely on the derogations for transfers which are necessary to perform the transaction with you. Where required by law, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below. If you reside in other non-US jurisdictions, your use of the Site or provision of any personal information constitutes your consent for the transfer of such data to the United States for the purposes identified in this Privacy Policy. If you have questions about cross-border transfers, please contact us as detailed at the end of this Privacy Policy.
Verifying, Changing, and Deleting Your Information. State-Specific Consumer Privacy Rights and DSAR Requests. Depending on your state of residence (including states such as Virginia, Colorado, Connecticut, and others enforcing comprehensive consumer privacy laws), you may possess specific statutory rights regarding the personal data we collect through your use of the Site.
Subject to certain legal exceptions—including exemptions for data regulated under the federal Gramm-Leach-Bliley Act (GLBA) and SEC recordkeeping rules—these rights may include:
How to Submit a Request (DSAR). To exercise any of these consumer privacy rights, please submit a formal Data Subject Access Request (DSAR) to our compliance team by emailing us directly at Info@gemasset.net with the subject line “Consumer Privacy Rights Request.”
Verification and Downstream Deletion Processing. Upon receiving your request, we will verify your identity using reasonable security measures matching the information we have on file. Once verified, if you have requested data deletion, we will execute the request within the legally mandated timelines of your home state (typically 45 days). Furthermore, we will systematically propagate your deletion request downstream to our core analytical and advertising tracking vendors, instructing platforms like Google and Meta to purge your associated session data from our integrated dashboards.
Children. The Site and are services are not intended for use by anyone under the age of 18, nor do we knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, you should not attempt to use the Site or send any information about yourself to us.
We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will post them on the Site and indicate the effective date of the change. If we make material changes to this Privacy Policy we will notify you by email or through the Site.
GEM Asset Management, LLC
261 S. Main Street
Plymouth, MI 48170
United States of America
Email: Info@gemasset.net
Phone: 734-737-9108
This Privacy Policy was last updated July 3, 2026.
