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GEM4D Legal

Privacy Policy

How GEM4D collects, uses, discloses, stores, and protects information across the platform, published projects, builder tools, tokens, wallet features, and support services.

Last updated June 3, 2026

This Privacy Policy explains how ION COMPANIES LLC ("ION," "GEM," "GEM4D," "Company," "we," "us," or "our") collects, uses, discloses, stores, and protects information when you access or use GEM4D, gem4d.com, GEM-hosted projects, builder tools, project runtimes, APIs, project keys, hosted assets, marketplace features, wallet features, token services, support tools, documentation, and related services that link to this Privacy Policy (collectively, the "Services").

GEM4D is operated by ION COMPANIES LLC, a Delaware limited liability company. Our mailing address is P.O. Box 205, Great Bend, NY 13643-9998. You can contact us through GEM support or by email at [email protected].

This Privacy Policy applies to information we process for our own Services. If you use a GEM-hosted project created or operated by a third-party project owner, that project owner may independently collect, use, or control information through its project. Project owners are responsible for their own privacy notices, consents, data practices, scripts, embeds, forms, and legal compliance. GEM may process project-user data as a platform provider for the project owner, but GEM is not responsible for a project owner's independent privacy practices.

INFORMATION WE COLLECT

Depending on how you use the Services, we may collect the following categories of information:

  • Account and contact information. Name, email address, username, password credentials, phone number, company or project information, account settings, profile details, and similar information you provide.
  • Authentication and security information. Login records, verification codes, two-factor authentication settings, device identifiers, session information, security alerts, fraud signals, access logs, legal policy acceptance timestamps, policy version records, IP address, user agent, and other information used to secure accounts and projects.
  • Payment, token, wallet, and transaction information. Token purchases, token balances, token usage, support-mediated transfer requests, order history, chargebacks, refunds where required by law, wallet records, marketplace activity, billing contact information, payment-provider transaction identifiers, tax records, and related transaction metadata. Payment card and PayPal account details are processed by our payment provider, PayPal, and are subject to PayPal's terms and privacy practices.
  • User Content and project data. Websites, images, 3D models, audio, video, scripts, avatars, chat messages, comments, marketplace listings, project settings, project keys, hosted assets, user records, communications, files, metadata, and other content or data uploaded, created, published, transmitted, displayed, edited, or stored through GEM by you or by users of your projects.
  • Project-user information. Information submitted by or about users of GEM-hosted projects, including usernames, profile details, avatars, chat content, project activity, permissions, preferences, gameplay or interaction records, form submissions, messages, and other project-specific records.
  • Device, usage, and log information. IP address, browser type, device type, operating system, referring pages, pages viewed, project visits, feature usage, session activity, approximate location inferred from IP address, error reports, performance logs, security logs, and analytics or diagnostic information.
  • Communications and support information. Support tickets, appeals, takedown requests, copyright complaints, moderation reports, emails, SMS messages, chat with support, attachments, screenshots, and other information you provide when communicating with us.
  • Cookies and similar technologies. Session cookies, authentication cookies, security cookies, preference cookies, analytics technologies, local storage, and similar tools described in our Cookies Policy.
  • Information from third parties. Information from payment processors, communications providers, anti-abuse providers, cloud infrastructure providers, support tools, public sources, business partners, project owners, law enforcement, rights holders, or other users where needed to operate, secure, support, or enforce the Services.

We do not intentionally request sensitive personal information unless it is necessary for a specific feature, legal requirement, support request, safety issue, payment review, identity verification, or other disclosed purpose. However, users and project owners may upload or submit content that contains sensitive information. You are responsible for the information you choose to provide or publish through the Services.

HOW WE USE INFORMATION

We use information for the following purposes:

  • Provide, operate, maintain, host, publish, render, and deliver the Services and GEM-hosted projects;
  • Create, authenticate, administer, secure, and support accounts, teams, projects, wallets, and project keys;
  • Process token purchases, wallet records, marketplace transactions, chargebacks, payment reviews, taxes, and related records;
  • Host, store, cache, transmit, display, back up, troubleshoot, moderate, and support User Content and project data;
  • Provide support, respond to tickets, review appeals, investigate reports, and communicate with you;
  • Send transactional emails, SMS verification codes, two-factor authentication messages, security notices, and service notices;
  • Detect, prevent, investigate, and respond to spam, fraud, abuse, security incidents, unauthorized access, policy violations, payment misuse, intellectual-property violations, and unlawful activity;
  • Maintain platform integrity, reliability, performance, availability, debugging, analytics, and product improvement;
  • Enforce our Terms of Use, support policies, payment policies, copyright policies, and other posted terms;
  • Comply with law, legal process, recordkeeping obligations, tax obligations, sanctions screening, and lawful requests from authorities;
  • Protect the rights, privacy, safety, property, and security of GEM, users, project owners, project users, rights holders, and the public;
  • Carry out any other purpose disclosed to you or authorized by you.

AI AND INTERNAL SYSTEM INTEGRATIONS

GEM may use internal AI-assisted tools and backend system integrations, including OpenAI integrations, to help operate, administer, secure, diagnose, support, and improve the Services. GEM does not use customer data, User Content, or project-user data for AI model training, public AI ingestion, or user-facing AI feature processing. GEM does not permit AI features to process customer data, User Content, or project-user data.

SMS AND COMMUNICATIONS

If you provide a mobile phone number, we may use it to send transactional SMS messages, including verification codes, two-factor authentication, login alerts, password reset confirmations, security alerts, support notifications, and important account or project notices. Message and data rates may apply. Message frequency varies based on account activity. You may reply STOP to opt out of eligible SMS messages or HELP for help.

GEM does not use SMS for unsolicited marketing unless you separately authorize it. We do not sell or share mobile opt-in data, SMS consent records, or SMS message content with third parties for their marketing or promotional purposes.

HOW WE DISCLOSE INFORMATION

We may disclose information in the following circumstances:

  • Service providers and processors. We use vendors and service providers to operate the Services, including PayPal for payments, DigitalOcean for cloud infrastructure and CDN services, Twilio for SMS and communications, Google reCAPTCHA for abuse prevention, OpenAI for backend system integrations, and other vendors that provide hosting, storage, analytics, security, support, email, logging, monitoring, billing, and operational services.
  • Public projects and project settings. If you publish a project, list a project, enable discovery, submit content for promotion, or otherwise make content public, the project name, URL, thumbnail, artwork, screenshots, descriptions, owner information, metadata, previews, marketplace listings, chat, user-facing content, and related public project information may be visible to other users, search engines, public viewers, or third-party services according to your settings.
  • Project owners and team members. If you interact with a GEM-hosted project, the project owner and authorized project team members may access project-user information and project activity connected to that project.
  • Payment, fraud, and security review. We may disclose information to payment providers, banks, card networks, fraud-prevention services, communications providers, identity or account verification services, and similar parties where needed for purchases, chargebacks, account security, token records, fraud prevention, abuse prevention, or compliance.
  • Legal, safety, and enforcement. We may disclose information if we believe disclosure is required or appropriate to comply with law, legal process, court orders, subpoenas, law-enforcement requests, government requests, intellectual-property complaints, safety concerns, fraud investigations, sanctions compliance, or to enforce our terms and protect rights, safety, property, or security.
  • Business transfers. We may disclose or transfer information as part of a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, transfer of the Services, or similar business transaction.
  • With your direction or consent. We may disclose information when you direct us to do so, authorize a transfer, connect a third-party service, request support, publish content, or otherwise consent.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising as those terms are defined by applicable state privacy laws. We do not knowingly sell or share personal information of users under 16. We do not use sensitive personal information for targeted advertising. If our practices change in a way that requires additional opt-out rights, we will update this Privacy Policy and provide any required notices or choices.

COOKIES, RECAPTCHA, AND TRACKING CHOICES

We use cookies and similar technologies to keep you signed in, secure accounts, remember preferences, operate projects, analyze performance, detect abuse, and improve the Services. Google reCAPTCHA may collect device, browser, interaction, and network information to help determine whether activity is human, automated, abusive, or fraudulent. Your use of reCAPTCHA is also subject to Google's applicable terms and privacy policies.

You can control cookies through your browser settings. Disabling cookies may prevent login, project publishing, account security, checkout, wallet, marketplace, or other Services from working correctly. Our Cookies Policy provides more information.

Some browsers offer "Do Not Track" signals. Because there is no uniform industry standard for these signals, we do not currently respond to them. Where legally required, we will treat Global Privacy Control or similar legally recognized browser signals as opt-out requests for sale or sharing of personal information, if applicable to our practices.

DATA RETENTION

We retain information for as long as reasonably necessary to provide, maintain, secure, support, improve, and enforce the Services; comply with legal, tax, accounting, payment, security, and recordkeeping obligations; resolve disputes; prevent fraud and abuse; maintain backups and logs; and protect our rights and the rights of others.

Retention periods vary depending on the type of information, the account or project status, legal requirements, operational needs, fraud and security risks, payment records, support records, backup cycles, and whether the information is part of public projects or User Content. Deleted content may remain in backups, logs, archives, support records, legal records, or security records for a limited period or longer where required or permitted by law.

DATA SECURITY

We use reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, and destruction. These safeguards may include access controls, authentication controls, logging, monitoring, encryption, provider security controls, backups, and internal security procedures. No system or transmission is completely secure, and we cannot guarantee absolute security.

YOUR PRIVACY CHOICES

Depending on where you live and the laws that apply, you may have rights to request access to, correction of, deletion of, or portability of certain personal information; to opt out of certain sales, sharing, targeted advertising, or profiling; to limit certain uses of sensitive personal information; to withdraw consent where processing is based on consent; and to appeal a denied privacy request.

To exercise privacy rights, submit a request through the GEM support ticket system or email [email protected]. We may need to verify your identity, account control, project ownership, request authority, jurisdiction, or relationship to the relevant data before responding. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and verification of the consumer's identity.

We will not discriminate against you for exercising privacy rights. Some information may be exempt from deletion, access, correction, portability, or other requests where permitted by law, including information needed for security, fraud prevention, legal compliance, transactions, support records, backups, free expression, internal uses, debugging, payment records, or to provide the Services you requested.

We will respond to privacy requests within the time required by applicable law. If a law gives you a right to appeal a denied privacy request, you may submit the appeal through the GEM support ticket system. If a Delaware resident's appeal is denied and Delaware law applies, we will provide information about how to contact the Delaware Department of Justice. Delaware residents may contact the Delaware Department of Justice at [email protected].

STATE PRIVACY NOTICE

GEM does not sell personal information and does not currently meet the gross-revenue threshold for the California Consumer Privacy Act as represented by GEM. This State Privacy Notice is provided for transparency and is not an admission that GEM is subject to any particular state privacy law. In the preceding 12 months, we may have collected the categories of information described in "Information We Collect" above from you, your devices, your use of the Services, project owners, project users, service providers, payment providers, anti-abuse providers, communications providers, and other sources described in this Privacy Policy.

We may disclose those categories of information for the purposes described in "How We Use Information" and to the categories of recipients described in "How We Disclose Information." We do not sell personal information, do not share personal information for cross-context behavioral advertising or targeted advertising, and do not knowingly sell or share personal information of users under 16. If you believe a state privacy law applies to your information and you want to exercise a privacy right, submit a request through the GEM support ticket system or email us.

CHILDREN'S PRIVACY

GEM is not directed to children under 13, and children under 13 may not create accounts, use builder tools, submit content, publish projects, use chat, or provide personal information through the Services. We do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without required parental consent, we will take reasonable steps to delete it or take other action required by law.

Project owners may not use GEM to operate projects directed to children under 13 unless GEM separately approves that use in writing and all required child-privacy compliance measures are in place. If you believe a child under 13 has provided personal information through GEM, contact us through GEM support or at [email protected].

INTERNATIONAL USERS

GEM is operated from the United States and is not intended to intentionally target users in the European Union or United Kingdom. If you access the Services from outside the United States, your information may be processed in the United States and other locations where we or our service providers operate. Privacy laws in those locations may differ from the laws where you live.

THIRD-PARTY LINKS, PROJECTS, AND EMBEDS

The Services and GEM-hosted projects may include third-party links, embeds, scripts, APIs, marketplaces, payment flows, media, forms, services, or content. Third parties may collect information directly from you under their own terms and privacy policies. GEM is not responsible for third-party privacy practices that we do not control.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. The updated version will be posted with a new "Last updated" date. If changes are material, we may provide additional notice where required by law. Your continued use of the Services after an updated Privacy Policy is posted means the updated Privacy Policy applies to information collected after the effective date, except where applicable law requires otherwise.

CONTACT US

ION COMPANIES LLC
P.O. Box 205
Great Bend, NY 13643-9998
Email: [email protected]
Support: https://gem4d.com/support