GIA Website Privacy Notice



Last Updated September 25, 2023, v. 5.0

1. Introduction

Gemological Institute of America, Inc. and our related entities (“GIA,” “GIA Entities,” “we,” “us,” or “our”) respect your privacy. GIA provides this website privacy notice (“Privacy Notice”) to describe how we collect, use, disclose, or otherwise process the data, including personal data, that we collect about you through our website,  https://www.gia.edu, and other GIA websites on which this Notice is posted (collectively, the “Sites”), our mobile application(s) on which this Notice is posted (the “App(s)”), offline (such as at tradeshows or at GIA locations), and the services available through our Sites, App, and offline (collectively, the Sites, the App, and GIA services offered offline are referred to as our “Services”). We collect data directly from you, automatically as you use our Services, from vendors, and from other individuals, as set forth below.

This Privacy Notice does not apply to information, data, or materials collected by third party websites, applications, or social or media platforms (“Platforms”). These Platforms have their own privacy and security practices for which GIA is not responsible. Your use of these Platforms is at your sole risk. If you use these Platforms to communicate with us, we will use the information we collect from you in accordance with this Privacy Notice.

Depending on your relationship with GIA, other privacy notices also may apply to you. For example, if you are accessing the Client Portal or My Laboratory as a client of GIA, then our collection of your personal data is governed by the Client Privacy Notice, not this Privacy Notice. If you are a student, then please review the Student Privacy Notice.

GIA provides its Services across the world. The data controller for any data submitted through our Services is Gemological Institute of America, Inc. at the address set forth below and, where relevant, other applicable GIA Entities.

Gemological Institute of America, Inc.
The Robert Mouawad Campus
5345 Armada Drive
Carlsbad, CA 92008
United States

Please see GIA-Affiliated Entities and GIA Data Controllers for complete listings.

2. Information We Collect About You

We collect information, including personal data, about you directly from you, from vendors, other parties, and automatically through your use of our Services. We combine the information we collect from these various sources. The type of personal data that we collect from you varies based on your particular interaction with our Services as set out below.

 

  • Account and Registration: Your full name, email address, home and mailing address, telephone number, mobile number, and, where applicable, payment information. You may also provide additional required or voluntary information, where relevant. We also collect information in accordance with GIA’s Know Your Customer and Due Diligence Program.
  • Communications: When you communicate with us, provide information through our surveys, in the context of a trade show, or otherwise, for example, if you participate in one of our seminars.
  • Request That Your Establishment Be Listed on GIA’s Site:  Information about your store and business contact information for a representative of the store. (Note: in this context, someone other than you may provide us with your information if you are listed as the representative of that store).
  • Seek to Find a Store Near You: Your location information (through the collection of your IP address) in order to locate a store near you.
  • Purchase Items From Our Store:  Your full name, contact information, items purchased, billing and shipping information, and payment data. You may also provide additional required or voluntary information, where relevant.
  • Your Usage of Our Services:  Your submission history, inquiries that you submit to us, records of purchases, and other interactions with us.
  • At Trade Shows and Other Events:  We collect information from or about you at trade shows and other events, including at trade shows or other events that we may host or at booths that we may operate. We take photographs and film video at many of our events and use the photographs and videos to share information about our events on social media and other platforms and generally promote GIA’s products and services. Accordingly, when you attend our events, your likeness and image may be contained within these photos and videos.
  • Social Network Form Fill: We may process your personal data when you authorize your social network to prefill a form on a Site (e.g., by signing into your social media account(s) through a button that appears on a Site). In that case, we will receive personal data about you from the social network pursuant to the policies of that social network. Examples of the personal data that we may receive includes your display name, first name, last name, profile URL, profile photo URL, social reach (number of followers), gender, email, date of birth, job title, and company. Your personal data will be processed by us in accordance with this Privacy Notice.
  • User Content: You may post to the blogs and forums available within our Services. Any information that you post to a publicly facing blog or forum may be viewable by any other visitor to our Sites or App. We are not responsible for the privacy of any information that you choose to post to our Sites or App, or for the accuracy of any information contained in those postings. We cannot prevent such information from being used in a manner that may violate this Notice, the law or your personal privacy.
  • Social Media: The Services may allow you to connect to and share information with social media platforms and we may be required to implement cookies, plug-ins, and APIs provided by those social media platforms to facilitate those communications and features. We may share information that you provide us or that we may collect about your use of the Services with those platforms and that information will be subject to their privacy policies. We encourage you to review the privacy policy of any social media platform that you use in connection with the Site. In addition, by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. We cannot control any policies or terms of such third-party platforms. As a result, we cannot be responsible for any use or disclosure of your information or content by third party platforms, which you use at your own risk.

3. Information We Collect Automatically

  • Device and Online Usage: We collect information about your computer, browser, mobile or other device that you use to access the Services. We may use cookies, pixels, log files and other techniques to collect such information, including IP address, device identifiers and other unique identifiers, browser type, browser language, operating system name and version, device name and model, version, referring and exit pages, dates and times you access our Services, the length of time that you are logged in to or using our Services, the links you click or features you use, software crash reports and session identification number. Please see the “Cookies and Other Tracking Technologies” section below or our Cookie Policy for more information.
  • Analytics: Using service providers, we compile and analyze information derived from the use of our Services, such as aggregate usage patterns, user preferences, and other usage information.
Please see the “Cookies and Other Tracking Technologies” section below or our Cookie Policy for additional information about our use of cookies.

4. Our Use of Your Information

We use your information, including your personal data, for the following purposes:

 

  • Providing and Improving Our Services: To provide you with our Services, to improve our Services to enhance your experience using the Services, to respond to your inquiries, to develop new features, products, or services; to authenticate you; to perform technical operations, such as updating software; as well as for other customer service and support purposes;
  • Marketing and Similar Communications: For marketing and advertising purposes, such as, to the extent permitted by applicable law, to send you emails and SMS about products, services, and events that we believe would be of interest to you; to send our newsletter to you;
  • To Solicit Donations;
  • Personalizing Content and Ads: To assist us in determining relevant advertising (i) on our Sites and App; (ii) on non-GIA websites and mobile applications; and (iii) through other media;
  • Research and Analytics: To better understand how users access and use our Services, both on an aggregated and on an individualized basis, including monitoring, evaluating, and analyzing which features and portions of our Site and our Apps are most popular, for troubleshooting, for statistical purposes including identifying geographic regions of visitors to our Services, evaluating frequently asked questions from visitors, and for other statistical purposes;
  • Protecting Rights and Interests: To protect the safety, rights, property, or security of GIA, the Services, any service provider, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Notice or our Terms of Use; and
  • Legal Compliance: To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
GIA may also enhance or merge your personal data with the data that we obtained from the analytics providers referenced above. We will use this information to assist us in our marketing efforts and for the purposes described in this Notice.

5. Disclosing Your Information

We will not disclose your personal data to non-GIA Entities for their own marketing purposes. We will, however, disclose your information, including personal data, to entities as described below:

 

  • GIA Entities:  We will share your information with GIA Entities, so that they may contact you about our Services (marketing) or respond to your customer service inquiries.
  • Service Providers: We disclose your personal data to our service providers, contractors, professional advisors, agents, or others who perform functions on our behalf.  These service providers include vendors who assist us with sending out email correspondence, SMS messages, payment processors, and other providers consistent with completing your request to GIA.
  • Social Networking Companies: We disclose your email address to Facebook to assist us in determining relevant advertising on Facebook and through other media. See Online Advertising below.
  • Other Users: As stated above, you may choose to submit information on a blog or in a forum. Any information that you submit will be available to other users of our Services.
  • General Business Operations: We disclose personal data where necessary to the administration of our general business, accounting, record keeping and legal functions, to our tax advisors, legal counsel and other professional services entities or agents.
  • Business Transfers: If we are acquired by or merge with another entity, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the acquiring entity. We also may transfer certain of your personal information to another company in the course of evaluating a prospective transfer, where permitted by law.
  • In Response to Legal Process: We disclose your personal data to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a subpoena or warrant.
  • To Protect Us and Others: We disclose your information where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety rights, property, or security of GIA, the Services, or of any person or violations of our Terms of Service or this Notice.
  • Aggregate and Anonymized Information: We may share aggregate or anonymized information about use of the Services with service providers for marketing, advertising, research, analytics or other similar purposes. We also may publish reports in the aggregate about usage trends of our Services.
Other than as described in this Notice, you will not be subject to decisions based on automated information processing without your prior consent.

6. Cookies and Other Technologies

We use cookies, web beacons (including clear GIFs), Flash Local Storage Objects (“Flash LSOs”) and similar technologies, including technologies designed for mobile applications, to track user activity and collect usage data about our Sites and App. We may combine this data with the personal data we have collected from you.

Cookies. Cookies allow a web server to transfer data to a computer for record keeping and other purposes. We and our service providers use “cookies” on our Sites and similar devices designed for mobile applications, to, among other things, better serve you with tailored information and facilitate your ongoing access to and use of the Site. For further information and details about the cookies used on the Services, please see our Cookie Policy. There are two types of cookies: session-based and persistent cookies.

 

  • Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged in to the Site (and the Apps). This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Sites and App.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Sites who disable their web browsers’ ability to accept cookies will be able to browse the Sites; however, certain site features, such as the shopping cart or the ability to find the location of a lab, may not function if you disable cookies.

Local Storage Objects. We may use Flash LSOs in order to store your Site preferences and to support individual applications. Flash LSOs are different from browser cookies because of the amount and type of data stored. In addition, you cannot control, delete or disable the acceptance of Flash LSOs through your browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash cookies, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.

Web Beacons, Pixel Tags and Other Technologies. Our service providers use web beacons in HTML emails to our customers, to help us track email response rates, measure the success of our marketing campaigns, identify when our emails are viewed and track whether our emails are forwarded.

Analytics. We work with service providers (including Google Analytics and Flurry) who conduct analytics to help us track and understand how visitors use our Sites and our App. If you prefer not to participate in Flurry, please follow the instructions provided at http://www.flurry.com. Google Analytics is a web analytics service provided by Google that uses cookies to help us analyze how users use our Sites and our App. The information generated by the cookies about your use of the services will be transmitted to and stored by Google on servers in the United States. If you access the Sites or our App through different devices, Google may associate your devices with one another. For more information about how Google Analytics uses cookies to measure user interactions, visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. Google has developed the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js). You can prevent Google’s collection and use of the data it collects as defined in its policy by downloading and installing this browser plug-in: https://tools.google.com/dlpage/gaoptout?hl=en-GB. For more information about Google Analytics cookies, please see Google’s help pages (https://support.google.com/analytics/answer/6004245), FAQ on how they use the data (https://policies.google.com/technologies/partner-sites), and privacy policy (https://www.google.com/intl/en/policies/privacy/).

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

 

Google Maps.

Our Sites may include Google Maps features and content. Google Maps features and content is subject to the then-current versions of Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html and Google Privacy Policy at https://www.google.com/policies/privacy/.

 

YouTube.

Our Sites may use YouTube to make content in video format available to you. By accessing a part of the Sites where videos are available, watching an embedded video, or otherwise interacting with any content made available through YouTube, you signify your agreement with YouTube’s terms and conditions. YouTube collects and otherwise has access to usage data (e.g., what videos you accessed and watched) through videos embedded in the Services as further described in YouTube’s Privacy Policy. YouTube adheres to Google's privacy policies and principles, part of which allow you to control certain privacy settings and which data are collected. For more information, please visit https://www.youtube.com/howyoutubeworks/user-settings/privacy/.

 

7. Online Advertising

To display more relevant advertising on our Services, to manage our advertising on non-affiliated sites, mobile apps, and online services, and to measure and improve our ads and marketing efforts, we work with Facebook, Google and other non-affiliated ad companies, ad exchanges, channel partners, measurement services and ad networks. Please see the “Cookies and Other Tracking Technologies” section above or our Cookie Policy for more information. For more information and to exercise your choices please see Facebook’s privacy policy and ad preferences page and/or Google/DoubleClick’s privacy policy, ad settings, and ads help page.

You can also learn more about online advertising here and opt out of interest-based advertising from many participating ad companies at the ad industry websites, including:

 

Similarly, you can learn about your options to opt out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see:

 

Please note that opting out of advertising network services does not mean that you will not receive any advertising while using our Services or other services, nor will it prevent the receipt of interest-based advertising from non-affiliated parties that do not participate in these programs.

Facebook. For certain Facebook advertising services, Facebook Ireland is a Joint Controller (as defined in the GDPR) and that information required under the GDPR related to such processing can be found at https://www.facebook.com/about/privacy. We work with Facebook and use their advertising services to measure and improve our ads and marketing efforts, as well as to display more relevant advertising to you. For further information on how Facebook Ireland processes your personal information, including the legal basis, and the ways to exercise your rights, please visit https://www.facebook.com/about/privacy.

Custom Audiences and Matching. We may disclose certain information (such as your email address) with non-affiliated parties such as Facebook (more information on Facebook Custom Audience here or see above) so that we can better target ads and content to you, and others with similar interests on these non-affiliated parties’ platforms or networks (“Custom Audiences”).  We may also work with ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. To opt out of being included in our Custom Audiences going forward, email us at privacy@gia.edu.

Do Not Track. Your browser or device may include “Do Not Track” settings or functionality. Currently, our systems do not recognize browser "Do Not Track" requests. However, you may disable certain tracking on our Sites, as discussed above (e.g., by disabling cookies), and you may opt out of certain ad networks as described in this Notice. For more information about Do Not Track signals, please click here.

8. Marketing Choices

To the extent permitted by applicable law, we periodically send you electronic communications about GIA’s various products, services, or newsletters via email or in selected markets also via SMS. You may opt out of the receipt of marketing communications by clicking the “unsubscribe” options, by sending an opt-out request to privacy@gia.edu, or where applicable, texting us STOP at the number you received the SMS. If you opt out of receiving marketing communications from us, please note that we may still send you email regarding your account, or for any Services you have requested or received from us (e.g., to notify you about the status of a purchase that you have made with us).

9. Links

For your convenience, GIA may provide links to certain non-affiliated websites or referrals to certain non-GIA products or services. If you choose to visit these websites or to use such products or services, please be aware that the third party’s privacy policy, and not this Notice, will govern your activities and any information you disclose while interacting with these limited websites. We are not responsible for the information practices of such non-affiliated websites or applications.

10. Rights of California Residents

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information regarding the types of personal information the business shares with third parties for direct marketing purposes by such third party, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To see a copy of the information disclosure provided by GIA pursuant to Section 1798.83 of the California Civil Code, please contact privacy@gia.edu.

11. California Automated License Plate Recognition (“ALPR”) Usage

GIA’s employees and contractors responsible for physical security use ALPR technology (the “ALPR Technology”) as vehicles enter and pass through the GIA campus in Carlsbad, California. The ALPR Technology enables automated detection of vehicle information, including license plate details.  The ALPR Technology and the data it collects (the “ALPR Data”) is accessed and used by GIA employees and contractors who are responsible for managing physical security at the GIA campus.  ALPR Technology and ALPR Data is used for purposes of restricting access to authorized vehicles and maintaining the safety and security of the GIA campus.  Relevant GIA employees and contractors are trained to use ALPR Technology and ALPR Data in a manner that complies with this Privacy Notice and applicable law.  ALPR Data may be shared with law enforcement.  ALPR Data is not sold by GIA.  Use of ALPR Technology and ALPR Data is monitored by GIA’s legal, information security, and compliance functions for purposes of security and compliance with applicable law.  GIA deploys security measures in alignment with its company security policies that are designed to maintain the accuracy of ALPR Data.  GIA will correct known errors in the ALPR Data.  ALPR Data will be retained by GIA in accordance with its record retention policies, and GIA will refer to applicable legal requirements in order to determine when to destroy retained ALPR Data.  The title of the official custodian of the ALPR Technology at GIA responsible for implementing this section of the Privacy Notice is the Sr. Manager, Security Operations.

12. Security

We have taken steps to help protect the personal data we collect. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your device and account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your login and password private.

13. Job Applicants

You may apply for employment online. If you submit an application for employment online, we request information such, as contact information, languages spoken, skills, prior work experience, and resume. Your submission of a resume, job application, or related information does not in any way require us to review that information or consider you for employment.  The information you provide will be used for purposes of processing your employment application, for any legally-required purposes (including to protect our rights and interest and the rights and interests of others), and as described during the application process and on GIA’s websites.

14. Transfer of Your Personal Data

Depending upon your particular interaction with us, your personal data may be transferred, accessed, stored and otherwise processed by us, other GIA entities, or service providers for the purposes described above, and subject to requests from law enforcement (including courts and tribunals in accordance with laws applicable in those jurisdictions), in jurisdictions outside of your home jurisdiction, including the United States and India, and may not provide an equivalent level of data protection as your home jurisdiction. GIA take steps to protect personal data, including, where required by law, through appropriate written data processing terms and/or data transfer agreements, for example, by signing relevant EU standard contractual clauses as approved by the European Commission (the form for these clauses can be found here). Subject to applicable law, you have the right to obtain details about the mechanism under which your personal data is transferred cross-border. For more information about these transfer mechanisms, please contact us as set out in the “Contact” section below.

15. Additional Information for EEA Individuals or Where Applicable and Required by the Laws of Your Jurisdiction

To the extent the GDPR or other law granting particular rights to data subjects applies to you, you have the following rights with regard to our processing of your personal data:

 

  • Right to Access, Correct and Delete Your Personal Data: GIA will use reasonable measures designed to ensure that all personal data is accurate and up to date. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address, bank account, etc.) are notified to GIA so that we can ensure that your personal data is up-to-date.

    You have the right to request access to any of your personal data that GIA may hold and to request correction of any inaccurate personal data relating to you. You furthermore have the right to request deletion of personal data we hold about you.
  • Right to Withdraw Consent: In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time with effect for the future.
  • Data Portability: To the extent that we use your personal data on the basis of consent for the performance of a contract and that personal data is processed by automatic means, you have the right to receive all such personal data that you have provided to GIA in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.
  • Right to Restrict Personal Data Use and Right to Object: You have the right to restrict our use of your personal data where (i) you contest the accuracy of the personal data; (ii) the use is unlawful but you do not want us to erase the personal data; (iii) we no longer need the personal data for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims; or (iv) you have objected to our personal data use justified on our legitimate interests pending verification as to whether GIA has indeed compelling interests to continue the relevant personal data use.
  • Lodge a Complaint: You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the collection and use of your personal data violates this Notice or applicable law.
Legal Bases We Rely on When Processing Your Personal Data

 

Where EU data protection law applies, and where applicable under other data protection laws, we process your personal data for the purposes set out in Appendix A, under the following legal bases:

  • Our Contract With You: Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you (e.g., to verify the information you have provided to us).
  • Our Legitimate Interests: Our processing is necessary for our legitimate interests, including to protect the security of our services; to protect the health and safety of you or others; to establish, protect and defend our legal rights and interests; to prevent fraud and verify identity and authorization of clients; to understand and analyze usage trends; and to improve our products and services.
  • Legal Compliance: Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes: e.g., in response to subpoenas, court orders and other lawful requests by regulators, courts and law enforcement agencies, or related to national security requests).
  • Your Consent: When we have your express consent as defined by applicable law.

16.Changes to This Notice

GIA reserves the right to modify this Notice as it deems appropriate from time to time. If we make a material change to the Notice, you will be provided with appropriate notice, in accordance with applicable legal requirements, for example via email or prominent notice on our Sites. You may find the most current version of the Notice by visiting the Sites. Your continued use of our Sites will be subject to the then-current Notice.

17.Contact

If you would like to contact us regarding our privacy practices or to exercise your rights, please contact us at:
Attn: Privacy Office – MS 20
Gemological Institute of America, Inc.
The Robert Mouawad Campus
5345 Armada Drive
Carlsbad, CA 92008
United States
or via email at privacy@gia.edu.
 


 

Appendix A: Our Purposes and Legal Bases for Processing Personal Data
of Individuals Located in the European Union and Where Applicable Under Other Data Protection Laws

 

Our Processing Purpose(s)

Our Legal Bases in the EU and Where Applicable Under Other Data Protection Laws

Providing Support and Services

  • Review and process an account sign-up and registration
  • Process and administer your gem submission
  • Assist with quality assurance, training, respond to inquiries, complaints, and provide customer service
  • Manage troubleshooting and technical customer service and support
  • Provide you or your employer with laboratory services and products
  • Deliver publications and subscriptions
  • Process, administer payments, refunds, credits

To perform our contract with you or take steps to enter into a contract with you

Our Legitimate Interest

Communicate with You

  • Communicate with you about your account or transactions with us (including Services-related announcements) or your comments to a blog post or forum
  • Communicate with you about changes to our Notice

To perform our contract with you or take steps to enter into a contract with you

Our Legitimate Interest

Legal Obligation

Verification

  • To verify the identity of users with whom we interact
  • To confirm authorization of users of our Services

To perform our contract with you or take steps to enter into a contract with you

Our Legitimate Interest

Personalize Services and Ads

  • Assist us in advertising our Services on non-GIA Sites and Services or through other channels
  • Help us to determine what advertisements to direct to you, to place on our Services and where to advertise our products and services

Our Legitimate Interest

Your Consent (for online advertising)

Marketing and Promotions

  • Deliver publications and subscriptions
  • Direct marketing, for example, as permitted by applicable law, to send you news and newsletters, special offers and promotions, or to contact you about products or information we think may interest you, including via postal mail and email and where applicable in accordance with our opt in /opt out practices.
  • To send you promotional SMS messages if you opt in.

Our Legitimate Interest

Your Consent (where you have opted-in)

Legal Compliance

  • Ensure that GIA provides services to individuals and entities who engage in ethical business practices, are not sanctioned individuals or entities and who comply with all applicable laws and regulations.
  • Ensure compliance with applicable laws including sharing your data with law enforcement (disclosures described below)
  • Monitor compliance with our existing policies and procedures
  • Respond to formal or informal government requests, (e.g., in response to subpoenas, court orders and other lawful requests by regulators, courts and law enforcement agencies, or related to national security requests)

Comply with Law

Our Legitimate Interests

Protect Legal Rights and Prevent Misuse

  • Monitor compliance with our existing policies and procedures
  • Ensure the integrity and security of GIA’s premises and processes
  • Investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use, this Notice, or our Client Agreement where we believe it is appropriate

Our Legitimate Interests

To perform our contract with you or take steps to enter into a contract with you

Legal Obligation

General Business Operations

  • To administer our general business, accounting, recordkeeping and legal functions
  • Routine business administration, (e.g., employee training, compliance auditing and similar internal activities)

Our Legitimate Interests

Legal Obligation