As Required by the Gramm-Leach-Bliley Act

Effective Date: September 10, 2025

FACTS

WHAT DOES GEMM DO WITH YOUR PERSONAL INFORMATION?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. It also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Name, email address, and government-issued identification
• Social Security number or other tax identification numbers
• Financial account details and transaction history
• Contact information and IP address
• Information shared with us through our platform or during onboarding

When you are no longer our customer, we continue to share your information as described in this notice.

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information, the reasons Gemm chooses to share, and whether you can limit this sharing.

WHO WE ARE

Who is providing this notice?

Gemm, a platform that partners with regulated financial institutions to facilitate account creation and payments for creators and agencies.

WHAT WE DO

How does Gemm protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Gemm collect my personal information?

We collect your personal information, for example, when you:

• Create or access an account through our platform
• Provide identifying documents or verification
• Use our services for payments or deposits

We may also collect information from our banking or payment processing partners.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

• Sharing for affiliates’ everyday business purposes—information about your creditworthiness
• Affiliates from using your information to market to you
• Sharing for nonaffiliates to market to you

State laws and individual companies may give you additional rights to limit sharing.

Definitions

• Affiliates: Companies related by common ownership or control. They can be financial and nonfinancial companies. Gemm is a subsidiary of Teal Pay Global, Inc.
• Nonaffiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies. Gemm does not share with nonaffiliates for marketing purposes.
• Joint marketing: A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Gemm does not jointly market.

Other Important Information

Do Not Call Policy

This notice serves as Gemm's Do Not Call Policy under the Telephone Consumer Protection Act. We do not solicit via telephone numbers listed on the state or federal Do Not Call lists, unless the law allows.

Questions?

Email us at: info@gemm.app

Visit: www.mygemm.app/legal/privacy