Privacy Policy

1. Who We Are

Rise Investments Limited ("we", "us", "our") is the data controller responsible for your personal data collected through GemTees.com and GemTees.ie (collectively, the "Website"). We are incorporated in Ireland and our processing of personal data is subject to the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the Data Protection Acts 1988–2018.

For any data protection enquiries, please contact us at: privacy@gemtees.com

2. What Data We Collect

We collect only the minimum data necessary to operate the Website. Depending on how you use the Website, this may include:

Data you provide directly:

• Contact information if you reach out to us by email (name, email address, message content);
• Trip itinerary data you create or save using the Trip Planner feature (stored locally in your browser unless explicitly shared).

Data collected automatically:

• IP address and approximate geographic location (country/region level);
• Browser type, version, and operating system;
• Pages visited, time and date of visit, time spent on pages, and referring URLs;
• Device type and screen resolution;
• Cookies and similar tracking technologies (see Section 5 below).

We do not collect sensitive personal data (as defined under Article 9 GDPR), and we do not require you to create an account to use the Website.

3. How We Use Your Data

We use the data we collect for the following purposes and on the following legal bases:

• To operate and improve the Website — analysing usage patterns, fixing bugs, and optimising performance. Legal basis: Legitimate interests (Article 6(1)(f) GDPR).
• To respond to enquiries — if you contact us directly. Legal basis: Legitimate interests / performance of a contract (Article 6(1)(b) GDPR).
• To ensure security — monitoring for fraudulent, abusive, or illegal activity. Legal basis: Legitimate interests (Article 6(1)(f) GDPR).
• To comply with legal obligations — where required by applicable law. Legal basis: Legal obligation (Article 6(1)(c) GDPR).
• Analytics — understanding how visitors use the Website so we can improve it. Legal basis: Consent where required, or legitimate interests.

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

4. Data Sharing

We may share your data with the following categories of third parties, strictly as necessary:

• Hosting and infrastructure providers — our server and infrastructure partners who host the Website on our behalf, bound by data processing agreements;
• Analytics providers — third-party analytics services used to understand Website usage (see Section 5);
• Mapping services — services such as OpenStreetMap/Leaflet and CartoDB used to render maps on the Website. These services may process your IP address in the course of delivering map tiles;
• Professional advisers — lawyers, accountants, and other advisers where necessary;
• Law enforcement or regulatory authorities — where required by applicable law or court order.
• Tourism, hospitality and travel partners — where you have submitted a form or enquiry requesting information, a booking, a recommendation, or any other service that requires us to refer your details to a relevant third party, such as golf clubs, hotels, accommodation providers, tourist attractions, tour operators, or hospitality partners. In such cases, your data will be shared solely with the third party or parties necessary to fulfil your specific request, and only to the extent required to do so. You will be informed at the point of submitting any such form of the categories of third parties your data may be passed to.

Any third parties with whom we share data are required to process it in accordance with applicable data protection law and only for the purposes for which it was shared. Where we share your data with tourism or hospitality partners on foot of a request you have made, the legal basis for that sharing is the performance of pre-contractual steps taken at your request (Article 6(1)(b) GDPR) and/or your explicit consent provided at the point of form submission (Article 6(1)(a) GDPR). We do not share your data with any such partners for unsolicited marketing purposes.

5. Cookies

We use cookies and similar technologies on the Website. A cookie is a small text file stored on your device when you visit a website. Cookies help us understand how the Website is used and improve your experience.

The following categories of cookies may be used on the Website:

sessionStorage is also used locally within your browser to store temporary trip planner state (e.g. whether you have seen the onboarding tour). This data never leaves your device and is cleared when you close your browser tab.

To manage cookie preferences in common browsers:

• Chrome: Settings → Privacy and Security → Cookies and other site data
• Safari: Preferences → Privacy → Manage Website Data
• Firefox: Options → Privacy & Security → Cookies and Site Data
• Edge: Settings → Cookies and site permissions

6. Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. In practice:

• Server log data (including IP addresses) is retained for a maximum of 90 days;
• Email correspondence is retained for up to 2 years from the date of last contact;
• Trip planner data stored in your browser (via localStorage or sessionStorage) remains on your device until you clear your browser data — we do not store this on our servers unless you use the share-trip feature, in which case the itinerary is stored indefinitely until deletion is requested.

7. International Transfers

Where any of our service providers or analytics partners are based outside the European Economic Area ("EEA"), we ensure that appropriate safeguards are in place for the transfer of personal data, including Standard Contractual Clauses approved by the European Commission or reliance on an adequacy decision, in accordance with Chapter V of the GDPR.

8. Your Rights

Under the GDPR, you have the following rights in relation to your personal data:

• Right of access — you may request a copy of the personal data we hold about you;
• Right to rectification — you may request correction of inaccurate or incomplete data;
• Right to erasure — you may request deletion of your personal data in certain circumstances ("right to be forgotten");
• Right to restriction — you may request that we limit the processing of your data in certain circumstances;
• Right to data portability — you may request a copy of your data in a structured, machine-readable format;
• Right to object — you may object to processing based on legitimate interests or for direct marketing purposes;
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, please contact us at privacy@gemtees.com. We will respond within one month of receiving your request, as required by the GDPR.

You also have the right to lodge a complaint with the Data Protection Commission of Ireland (dataprotection.ie) if you believe we have not handled your personal data in accordance with applicable law.

9. Children's Privacy

The Website is not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately and we will take steps to delete it.

10. Links to Third-Party Sites

The Website may contain links to third-party websites. This Privacy Policy applies only to GemTees.com and GemTees.ie. We have no control over and accept no responsibility for the privacy practices of any third-party websites. We encourage you to review the privacy policy of any site you visit.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Where changes are material, we will post the updated policy on this page. Your continued use of the Website following any changes constitutes your acceptance of the updated policy.

12. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact:

Rise Investments Limited
GemTees.com / GemTees.ie
Ireland
privacy@gemtees.com