privacy
Policy
Effective as of November 1, 2025.
This privacy policy (the “Privacy Policy”) applies to Jemini Consultancy LLC, (the “Company”, “us”, “our” or “we”) website, located at Jemini.co, and any other websites owned or operated by the Company on which this Privacy Policy appears (collectively, the “Website”).
The purpose of this Privacy Policy is to disclose to you what information the Company may collect, how the Company may collect and use it, with whom the Company may share it, and certain other matters related to such information, including the choices you have regarding the Company’s collection of information and the Company’s use and disclosure to other parties of information the Company may have collected from you. It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your information. This privacy policy supplements such other policies and is not intended to override them.
Acceptance/Notification of Changes to the Privacy Policy
By using the Website, you signify your agreement to the terms of this Privacy Policy. The Company may amend this Privacy Policy at any time. If the Company makes a material change to the way in which the Company collects, uses, and/or shares your personal information, the Company will post a notice on the Website and / or send an email to users who have provided an email address. The Company will assume that you have given your permission for your information to be used under the terms of the Privacy Policy, as modified, if you continue to use the Website after a notice is provided. Please note that you should always update your personal information to provide the Company with a current email address.
1. The Information We Collect.
The Company collects information from users of our Website, potential clients and clients of our services, suppliers and vendors (actual and potential), applicants for employment and participants in events that we may organize or promote. Depending on the nature of the services provided by the Company, we may receive information from You (a Website visitor, potential client, or client) directly, or from our clients, who may send us Your information in order to fulfill a service to You on their behalf. The information may include Your name, mailing address, email address, phone number, credit card information and other data required to provide You with the product or service You requested.
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) You use to access the Website or services. As described further below, we may collect and analyze information such as (a) IP addresses, location information, unique device identifiers, IMEI and TCP/IP address, and other information about Your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which You accessed the Website or services; and (b) information related to the ways in which You interact with the Website or services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Website or services, the amount of time spent on particular pages, the date and time You used the Website or services, the frequency of Your use of the Website or services, error logs, and other similar information.
As described further below, we may use third-party analytics providers and technologies, including “Cookies”, as defined below, and similar tools, to assist in collecting this information.
Whether for our own purposes of those of our clients, we may also collect data about Your use of our Website, our ads, or ads and sites we track on behalf of our clients, through the use of Internet server logs (where we store Website activity) and cookies and/or tracking pixels. We may be provided information relating to visitors to the Website by third-parties that use tracking technology to identify such visitors based on their IP addresses.
If You wish to opt out of interest-based advertising, by opting out of many of the online advertising and data platforms that provide this advertising, You may go to the DAA opt-out portal or the NAI opt-out portal.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in Websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user Cookies. We also may include web beacons in email messages, newsletters and other electronic communications to determine whether the message has been opened and for other analytics, personalization and advertising. As we adopt additional technologies, we may also gather additional information through other methods.
Please note that You can change Your settings to notify You when a Cookie is being set or updated, or to block Cookies altogether. Please consult the “Help” section of Your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including Cookies and local storage objects with the Flash management tools available at Adobe’s Website. Please note that by blocking any or all Cookies, You may not have access to certain features or offerings of the Services.
2. How We Use the Information We Collect.
3. How We Disclose Your Information.
The Company may disclose Your information as follows:
To vendors and service providers who perform services on our behalf, including without limitation marketing, market research, customer and tech support, data storage, analysis and processing, billing and collection, and legal, security and accounting and payment services.
To manage its relationships, correspondence and record-keeping in respect of clients and prospective clients.
To process financial records.
To suppliers employed by our clients who will then fulfill the product or service requested to You directly.
Where required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (a) to comply with legal process; (b) to enforce this Privacy Policy or other contracts with You, including investigation of potential violations thereof; (c) to respond to claims that any content violates the rights of third parties; (d) to respond to Your requests for customer service; and/or (e) to protect the rights, property, or personal safety of the Company, its agents and affiliates, its users, and the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
As part of business transactions, (including in contemplation of such transactions, e.g., due diligence), such as buying, merging with, or partnering with other businesses or as part of an asset sale.
4. Requests for Personal Information by Law Enforcement or Government Agencies.
The Company may be required to respond to subpoenas, court orders or be asked to respond to legitimate requests for Your personal information from law enforcement or government agencies. In such situations, we will release Your information to these organizations as we reasonably believe appropriate for us to comply with the law and to prevent against fraud. The Company will not provide You with these requests for information made by law enforcement or government agencies.
5. Cookies, Web Pixels and Online Analytics
This section provides more information about that we, our Clients and our business partners may use, and how they work.
Cookies: A Cookie is a small piece of code that is sent from a website You browse, and stored in Your web browser. Cookies relay certain information to us or to third parties that enables us to: (a) recognize Your computer; (b) store Your preferences and settings; (c) understand the web pages You have visited; (d), enhance Your user experience by delivering content and advertisements (including across websites) specific to Your inferred interests; (e) perform searches and analytics; and (f) assist with security and administrative functions.
Pixels or web beacons: Pixels or web beacons may also communicate information from Your Internet browser to a web server. Pixels can be embedded in web pages, videos, or emails, and can allow a web server to read certain types of information from Your browser, check whether You have viewed a particular web page or email message, and determine, among other things, the time and date on which You viewed the Web beacon, the IP address of Your computer, and the URL of the web page from which the Web beacon was viewed.
We sometimes work with third parties to advertise, provide or complement our Services, and these partners may set and access their own Cookies, pixel tags and similar technologies on Your device. Likewise, if You receive email from us, we may use these technologies to capture data such as when You open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The information collected and stored through these technologies includes IP address, unique identifiers, time stamps, browser type and other browser information, referring website, and more generally, what web pages You visit and how You interact with them, and what content (or ads) You view and how You interact with them. We and our partners, including Google Analytics, may also use these technologies for analyzing usage trends, assisting with fraud prevention, and providing certain features to You. To prevent Google Analytics from using Your information for analytics, You may install the Google Analytics Opt-out Browser Add-on by clicking here.
X (formerly known as Twitter) Post Button, LinkedIn Button, YouTube, Threads, and Instagram: These are functions provided by Twitter, LinkedIn, YouTube, Instagram respectively, companies with whom we are not related. By simply clicking on these push-buttons on the Website, the function makes it possible to share liking of Company articles and other content on the relevant social media site, without having to exit the page. This way the user links his/her/its relevant social media profile to the Company and makes this information accessible to anyone on the web, subject to the terms of use and privacy policies of each social media platform. For further information on the use of the Personal Information by the social media platforms, please consult the following links:
6. Links to Other Sites
Our Website may contain links to other websites. Therefore, it is important that You know that our Privacy Policy does not extend to those third-party Websites, as their policy(ies) may differ from ours.
7. Security
We have implemented administrative, technical, and physical security measures designed to protect against the loss, misuse, and/or alteration of Your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose Your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure.
Additionally, we may process the information You provide to us either directly or by a third-party data processor appointed by us. In common with a number of other websites, we may transfer the data that we collect from You to a cloud service provider which has data servers which are based in a variety of locations, including outside the European Economic Area (which includes all EU Member countries as well as Iceland, Liechtenstein and Norway; the “EEA”). By submitting Your personal data, You agree to this transfer and the storing and/or processing of Your personal data on these servers. For any transfer, we will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.
Whenever we collect or process Your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of that retention period, we will either deleted Your data completely or anonymise it, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
8. Data Transfers
Our computer systems are currently based in the both the United States and EEA and we may process and store Your information in one or both of these locations. As such, we may not provide the same level of protection as the privacy laws of Your jurisdiction. By providing us with Your information, You understand that Your personal information will be processed in the United States or the EEA.
Additionally, we will ensure, through contractual clauses that Your data receives at least the same protection as if it were being processed inside the US and EEA.
Moreover, any transfer of Your personal data will be subject to the applicable laws and the guiding principles of this Privacy Policy.
9. Your Choices and Rights Regarding Our Marketing and Targeted Advertising
You can review and update certain information by contacting us as described below. You can unsubscribe from marketing emails by clicking the “unsubscribe” link they contain.
If You are interested in more information about tailored browser advertising and how You can generally control Cookies from being put on Your computer or mobile browser to deliver tailored advertising (i.e., not just for the Services), You may visit the Network Advertising Initiative’s Consumer Opt-Out Link and/or the Digital Advertising Alliance’s Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs.
10. California “Shine the Light” Law
California Law permits visitors who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. To make such a request, please email us as described below with “Shine the Light” in the subject line or write to us at the contact information below.
In addition, we work with various online advertising and data platforms in order to send online ads for our own benefit, and for the benefit of our clients – including through the use of Cookies and similar technologies described in Section 5, above. If You are interested in more information about tailored browser advertising and how You can generally control Cookies from being put on Your computer or mobile browser to deliver tailored advertising (i.e., not just for the Services), You may go to the DAA opt-out portal or the NAI opt-out portal to opt-out of receiving tailored advertising from companies that participate in those programs.
11. Children’s Privacy
Our Website and services are intended for general audiences and not for children under the age of 18. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 18, we will take reasonable steps to delete it as soon as practical.
12. How to Contact Us
If You have any questions regarding our privacy practices, You may contact Rich Wulwick, Deputy General Counsel by mail at Stagwell Global LLC. 1808 Eye Street NW, Flr 8, Washington DC 20006, by phone at +1 (202) 539-6253 or email at notice@stagwellglobal.com.
13. General Data Protection Regulation
The EU General Data Protection Regulation (or the “GDPR”) requires the Company and those using our services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used in Europe that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, Cookie identifiers, mobile device identifiers, precise location data and biometric data.
To comply with the GDPR, we provide the below representations and information, which are specific to persons located in EEA countries or Switzerland (so please don’t rely on the below, if You’re not):
b. Personal Data Retention
As a general matter, we retain Your Personal Data for as long as necessary to provide our Website and services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements, as well as for auditing, corporate record-keeping, compliance accounting or security and bug-prevention purposes.
14. Notice Regarding California and U.S. State Privacy Laws and Your Rights
If you live in the State of California or other U.S. states with privacy laws (including Colorado, Connecticut, Delaware, Maryland, Minnesota, New Jersey, Oregon, Virginia, and elsewhere) you may have certain rights regarding the personal information (also called personal data) we collect and share from or about you, including the:
Right to know the categories and specific pieces of personal information we have collected, used, or disclosed;
Right to delete, correct, or update your personal information;
Right to prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling, if any);
Right to restrict the way that we process and disclose certain information about you;
Right to object to certain processing of your personal information;
Right to revoke your consent for the processing of your personal information;
Right to be free from discrimination for exercising your rights; and
Right to data portability.
If you would like information regarding your rights or would like to make a request (or if you are an authorized agent acting in accordance with applicable law), please email us at notice@stagwellglobal.com. In addition, you may exercise your rights to restrict our sale or sharing of information (including for purposes of targeted advertising) by emailing notice@stagwellglobal.com.
We will take reasonable steps to verify your identity and requests, including by verifying your account information, residency or the email address you provide. If you are an authorized agent submitting a request on behalf of another individual, we may require proof of your written authorization before processing the request.
Certain information may be exempt from such requests under applicable law such as information we retain for legal compliance and to secure, provide and audit our Services. We may need certain information in order to provide the Services to you; if you ask us to delete it, you may no longer be able to use the Services.
Residents of certain jurisdictions (such as Colorado, Delaware, Maryland, Minnesota, New Jersey, and Oregon) may appeal the denial of a request by emailing us at notice@stagwellglobal.com.
Notice of Right to Opt Out
Residents of certain states (such as Colorado, Delaware, Maryland, Minnesota, New Jersey, and Oregon) also have the right to opt out of the “sale” of your personal information or our processing/sharing of your information for online targeted advertising purposes.
While we do not “sell” personal information in the traditional sense, our disclosure of personal information to third-party [advertising or] analytics partners as described in the section titled “Disclosure of Information” above may be considered a “sale” subject to these opt-out rights. You can opt out of such disclosures by clicking the “Your Privacy Choices” link on our website footer, or designate an authorized agent to do so on your behalf. Note, if you use a cookie blocker such as Ghostery, it may block visibility of this tool or link, including in your web footer. If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law.
Please note that you must opt out on each device and each browser where you want your choice to apply. Your preference may be lost if you clear, or your browser is set to clear, cookies.