Privacy Policy

Last reviewed: August 2026.

Introduction

Gemini Shale Solutions LLC (“Gemini”, “Company”, or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you and share, or that you may provide, when you visit the website www.geminishale.com, our online workplace and platform, including the associated mobile and desktop applications (collectively, “Services”), including any subdomain of our Services, and our practices for collecting, using, maintaining, protecting, sharing, and disclosing that information.

This policy applies to information we collect:

• On the Services.
• In email, text, and other electronic messages between you and the Services.
• Through mobile applications you download, which provide dedicated non-browser-based interaction between you and the Services.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. Optional analytics cookies are used only with your consent, which you can give or withdraw at any time through our cookie settings. This policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including information:

• by which you may be personally identified, such as name, postal address, e-mail address, and telephone number entered in text which may be personally identified, or any other identifier by which you may be contacted online or offline (“personal information”);
• that is about you but individually does not identify you, such as analytical information, IP address, flow tracking; and/or
• about your internet connection, the equipment you use to access our Services, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, Google Analytics, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Services may include:

• Information that you provide by filling in forms on our Website or Services. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• Your passwords, email, or name via access to our Services in the course of gaining access to utilize Services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, data input actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Details of your utilization and usage of our Services in the course of conducting business via our Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection may include, but are not limited to:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. We use strictly necessary cookies for core site, security, and service functionality. Where required, optional analytics cookies are used only after you make a cookie preference choice through our cookie controls. You may also refuse to accept browser cookies by activating the appropriate setting on your browser, though some parts of the Website or Services may not work as expected.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content, applications, analytics, or linked services on the Website may be served by third parties, including content providers, analytics providers, application providers, or other service providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies according to their own policies. Where our Website uses optional analytics cookies, those cookies are governed by the cookie preference controls described in our Cookie Policy.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between clients and us.
• To notify you about changes to our Services or any products or services we offer or provide through it.
• To allow you to participate in interactive features with regard to our Services.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Disclosure of Your Information

We may disclose aggregated information about our users, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gemini's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Gemini about our Services users is among the assets transferred.
• To fulfill the purpose for which you provide it. We will transmit the text and your personal information to the recipients in the course of business as related to our Services.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Gemini, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can manage optional analytics cookies through our Cookie Policy and cookie settings controls. You can also set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Global Privacy Control. We honor the Global Privacy Control (GPC) browser signal as a valid opt-out: if your browser sends GPC, optional analytics cookies remain disabled automatically.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website or Services and visiting your account profile page.

You may also send us an email at support@geminishale.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), provides you with the following rights, subject to certain exceptions:

• Right to Know. You may request the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties to whom we have disclosed personal information.
• Right to Delete. You may request that we delete personal information we have collected from you.
• Right to Correct. You may request that we correct inaccurate personal information.
• Right to Opt Out of Sale or Sharing. We do not sell personal information for money and do not share personal information for cross-context behavioral advertising. If that changes, we will post a "Do Not Sell or Share My Personal Information" link and honor opt-out requests, including the Global Privacy Control signal.
• Right to Limit Use of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes requiring a right to limit.
• Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights.

How to submit a request. You (or your authorized agent) may submit a request by emailing support@geminishale.com or through the contact form on our website. We will verify your identity by matching the information you provide against information we already maintain, and we will not charge a fee to process verification. We will confirm receipt within 10 business days and respond within 45 calendar days (extendable once by an additional 45 days with notice). If we deny a request, we will explain why. Requests submitted through an authorized agent require proof of the agent's signed authorization.

Global Privacy Control. We honor the Global Privacy Control (GPC) browser signal. If your browser sends a GPC signal, we treat it as a valid opt-out and optional analytics cookies remain disabled without any further action from you.

California's "Shine the Light" law (Civil Code § 1798.83) also permits California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. Requests may be sent to support@geminishale.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on cloud-based secure servers behind firewalls. Certain sensitive personal user information (e.g., login passwords) will be encrypted while it is in motion. Gemini Services support the latest recommended secure cipher suites and protocols to encrypt all traffic in transit. Client and user data is encrypted at rest. Gemini partners with Tier One organizations and self-monitors the landscape closely to upgrade the Services against newly identified vulnerabilities as they are discovered. Gemini implements best practices as they evolve.

Disaster Recovery

Customer data is stored redundantly at multiple locations in our hosting provider's data centers to ensure availability. We have tested, best-practice backup and restoration procedures. Client data and our source code are automatically backed up on a daily basis. The Senior Technology Lead is alerted in the event of failure. Backups follow a rigorous testing process every quarter to confirm procedures work as expected.

Logging

Gemini maintains an extensive logging environment. In conjunction with our hosting partner, these logs are analyzed for security events via automated monitoring software, overseen by the hosting partner and the internal Senior Technology Lead.

Incident Management

In the event of a breach, Gemini will promptly notify you of any unauthorized access to client data. Gemini has incident management policies and procedures.

Product Security Practices

New features, functionality, and design changes go through a security review process facilitated by the development team.

External Security Audits

Gemini contracts with respected external security firms who perform regular audits on a minimum annual basis. These partners monitor for new vulnerabilities and perform periodic and targeted audits.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services. The information you share in public areas may be viewed by any user of the Services.

Gemini is in the process of receiving Service Organization Control (SOC) compliance. Please check back for updates on our progress. A copy of the full report will be available for download.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us by email at support@geminishale.com.