Privacy Policy

Effective Date: March 24, 2026

Last Updated: March 24, 2025

This Privacy Notice explains how Credit Gems® collects, uses, stores, discloses, protects, and otherwise processes personal and business information in connection with our websites, portals, memberships, products, consulting, education, events, communities, applications, and related services.

1. Scope

This Privacy Notice applies to:

a. website visitors;

b. leads and prospective clients;

c. customers and members;

d. event attendees;

e. referral and affiliate applicants;

f. business representatives;

g. individuals who communicate with us by email, phone, text, social media, chat, or a portal.

2. Information We Collect

We may collect the following categories of information:

A. Identifiers

Name, alias, business name, mailing address, email address, phone number, username, password, account ID, customer ID, IP address, device identifiers, and online identifiers.

B. Sensitive and Financially Related Information

Date of birth, Social Security number or taxpayer identification information, where necessary, driver’s license or other government ID, bank statements, proof of income, tax returns, payroll records, business revenue records, articles of formation, EIN documents, utility bills, consumer-report data you provide or authorize, business-credit data, lender application data, and related identity-verification records.

C. Commercial Information

Products purchased, memberships enrolled in, payment history, subscription status, support history, consultations, downloads, and other service interactions.

D. Internet or Network Activity

Browser type, device type, session data, clickstream data, pages visited, referral URLs, approximate location based on IP, portal usage logs, and interactions with our websites or emails.

E. Communications

Emails, texts, chat messages, call notes, appointment logs, uploaded documents, support requests, survey responses, and communications with our team.

F. Audio/Visual Information

Call recordings where lawful, webinar participation, event photos, screenshots submitted by you, or testimonial videos voluntarily provided.

G. Inferences

General service preferences, likely interests, program eligibility indicators, and account-support insights generated from your use of Services.

3. Sources of Information

We collect information:

a. directly from you;

b. from your devices and browser;

c. from payment processors and service providers;

d. from forms, applications, consultation, and onboarding materials;

e. from consumer-report or business-report information you upload or authorize;

f. from lenders, vendors, or partners where you request a connection or service;

g. from referral partners or affiliates where lawful;

h. from public records or government filing databases where relevant to requested Services.

4. Why We Use Information

We may use information to:

a. provide requested products and services;

b. verify identity and prevent fraud;

c. communicate about your account, orders, sessions, updates, and legal notices;

d. process payments and manage subscriptions;

e. review documents and support requested credit, education, business-credit, or funding-readiness services;

f. connect you with third-party services you request;

g. improve website functionality, customer service, and offerings;

h. maintain records, backups, and legal compliance;

i. protect the security and integrity of our systems;

j. to market our products and services, subject to applicable law and your choices;

k. enforce contracts and resolve disputes;

l. comply with legal obligations, regulatory requests, subpoenas, and lawful process.

5. Our Legal Bases for Processing

Depending on the context, we process information because:

a. it is necessary to perform a contract or take steps at your request before entering a contract;

b. we have legitimate business interests, including fraud prevention, service improvement, and business operations;

c. you gave consent;

d. processing is necessary to comply with legal obligations;

e. processing is necessary to establish, exercise, or defend legal claims.

6. Sensitive Information

Where required by law, we will obtain consent before collecting, using, or sharing sensitive personal information for purposes that require consent. We do not use sensitive information to infer characteristics unrelated to the requested Services except as permitted by law.

7. Disclosure of Information

We may disclose information to:

a. payment processors;

b. cloud hosts, CRMs, portal vendors, automation tools, and communication platforms;

c. document-storage providers and IT/security vendors;

d. customer-support vendors and contractors;

e. mailing vendors and fulfillment providers;

f. lenders, banks, brokers, underwriters, business-service providers, and funding partners at your direction or in connection with a requested service;

g. accountants, attorneys, auditors, insurers, and professional advisors;

h. regulators, courts, law enforcement, or governmental authorities where required or appropriate;

i. acquirers, investors, successors, or transaction counterparties in connection with a merger, acquisition, financing, reorganization, or sale of assets;

j. affiliate or referral partners where you request a referral or where otherwise lawful and disclosed.

We do not sell personal information in exchange for money in the ordinary sense, unless expressly disclosed. If our activities are deemed a “sale” or “sharing” under a state privacy law, we will honor applicable opt-out rights where required.

8. Confidentiality of High-End Clients and Partner Network

Credit GEMS® treats client information, account details, credit files, funding relationships, partner relationships, and private/public lender information as confidential business information and discloses such information only as is reasonably necessary to provide requested Services, comply with law, protect rights, or as otherwise described in this Notice.

We do not publicly disclose private lender lists, partner contacts, client financial details, or strategy records except with authorization, as needed for service delivery, or where required by law.

9. Cookies and Similar Technologies

We may use cookies, pixels, tags, SDKs, analytics tools, and similar technologies to operate our website, authenticate sessions, remember preferences, understand traffic, and improve marketing. You can manage certain cookies through your browser settings or, where available, cookie preferences.

10. Email and SMS Marketing

You may receive promotional emails or texts if you opt in, engage with our services, or where otherwise allowed by law. You can unsubscribe from promotional emails by using the unsubscribe link. You can opt out of marketing texts by replying with the opt-out instructions provided in the message. Transactional messages may still be sent.

11. Security

Credit Gems® maintains administrative, technical, and physical safeguards reasonably designed to protect personal information. Security measures may include access controls, authentication procedures, encryption in transit, where available, vendor oversight, role-based permissions, logging, incident response procedures, and related controls.

No method of transmission or storage is perfectly secure. You are responsible for protecting your devices, passwords, email account, and network.

12. Data Retention

We retain information for as long as reasonably necessary for the purposes described in this Notice, including service delivery, recordkeeping, compliance, dispute resolution, fraud prevention, tax obligations, and enforcement of agreements. Retention periods vary based on the type of data and the purpose for which it was collected.

13. Your Privacy Rights

Depending on where you live and subject to applicable exceptions, you may have the right to:

a. know whether we process your personal information;

b. access certain personal information we maintain about you;

c. correct inaccuracies;

d. delete certain personal information;

e. obtain a portable copy of certain information;

f. opt out of targeted advertising, certain profiling, or certain “sale”/“sharing” practices where applicable;

g. appeal a denial of a privacy request where required by law;

h. limit certain uses of sensitive information where applicable.

To exercise rights, contact us at [Insert Privacy Email] or [Insert Webform]. We may verify identity before processing a request. We may deny requests where an exemption applies, and we will explain appeal rights where required.

14. Delaware Privacy Rights

If you are a Delaware resident and applicable law covers our processing activities, you may have rights relating to access, correction, deletion, portability, and certain opt-outs. You may appeal a denied request by contacting us at [email protected] with the subject line “Delaware Privacy Appeal.”

15. Minors

Our Services are not directed to children under 18. We do not knowingly sell or share personal information of minors in violation of law. If we learn that information was collected from a child in a manner not permitted by law, we will take appropriate steps to delete it.

16. Third-Party Sites and Services

Our websites and communications may link to third-party websites, lenders, platforms, or tools. We are not responsible for the privacy, content, security, or practices of third parties. Review their policies before sharing information.

17. Business Transfers

If Credit Gems® is involved in a merger, acquisition, financing, diligence process, reorganization, bankruptcy, receivership, or sale of all or part of its business or assets, information may be disclosed or transferred as part of that transaction, subject to applicable confidentiality and legal requirements.

18. Cross-Border Processing

If information is processed outside your state or the United States by a service provider, you acknowledge that it may be subject to the laws of those jurisdictions, subject to applicable contractual and security protections.

19. Data Breach Response

If a security incident occurs, Credit Gems® will investigate, take reasonable remedial measures, and provide notice when required by applicable law. Where applicable, notices may be provided by mail, email, posting, or other legally permitted methods.

20. Do Not Track

Our systems may not respond to browser “Do Not Track” signals in a uniform way, due to a lack of consistent industry standards, unless required by law.

21. Changes to this Notice

We may update this Privacy Notice from time to time. We will post the revised version with an updated effective date. Material changes may also be communicated by email, portal notice, website banner, or other appropriate method.

22. Contact and Legal Notices

Credit Gems®

Principal Office: Middletown, Delaware

For privacy-related inquiries or requests:
[email protected]

651 N Board St Middletown, DE 19709 or Send written request to our legal team 3000 Windy hill rd SE Suite 674832 Marietta, ga 30067

651 N. Board St. Middletown, DE 19709