Gem is a registered brand of Gem Pack Foods Limited (“Gem”, “we”, “our” or “us”), registered in the Republic of Ireland under company number 182913.

We take the protection of your personal data seriously and respect your right to privacy.

Maintaining the security of your data and ensuring that you understand how your data is handled is important to us. This Privacy Policy explains what personal data we collect, how and why we use it, and the circumstances in which it may be shared with others.

This Privacy Policy applies when you visit or use our website (the “Site”), enter a competition or promotional activity, participate in an in-store promotion or event, submit content, subscribe to the Gem Bake Club or other Gem marketing communications, contact us or otherwise interact with us.

This Privacy Policy is intended to provide information in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Data Protection Act 2018 and applicable electronic marketing and privacy legislation in Ireland.

1. NON-PERSONAL DATA WE COLLECT AND HOW WE USE IT

Certain information may be collected about the use of our Site for analytics and Site improvement purposes.

Where information is anonymous or aggregated and cannot reasonably be used to identify you, it is not treated as personal data.

We may use this information to:

  • understand how visitors use our Site;
  • improve the performance and efficiency of our Site;
  • identify and resolve technical issues; and
  • improve the overall user experience.

2. COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files stored on your device when you visit a website. They can enable website functionality, remember preferences and provide information about how a website is used.

Our Site uses first-party cookies and may use cookies or similar technologies provided by third-party service providers.

We may use cookies and similar technologies to:

  • register and support your visit to our Site;
  • remember your privacy and cookie preferences;
  • enable essential Site functionality;
  • understand how visitors use our Site; and
  • analyse and improve Site performance.

Essential / Functional Cookies

These cookies are necessary for our Site to function or to provide functionality requested by you. Where they are strictly necessary, they do not require your consent.

Analytics / Marketing Cookies

These cookies may be used to understand how visitors use our Site, measure Site performance and, where applicable, support marketing and advertising activities.

Where consent is required, these cookies will only be used in accordance with your cookie preferences.

When you first visit our Site, you may be presented with a Manage Consent notice providing further information about the cookies used and allowing you to manage your preferences.

You can change your optional cookie preferences at any time using the cookie consent tools available on our Site.

You may also control cookies through your browser settings. Disabling certain cookies may affect some functionality of our Site.

3. PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

We collect personal data when you voluntarily provide it to us through our Site, at an in-store promotion or event, or when you otherwise interact with us.

This may include when you:

  • subscribe to the Gem Bake Club or another Gem newsletter;
  • sign up to receive Gem communications through an in-store promotion, event or QR code;
  • complete an online form;
  • enter a competition, prize draw or promotional activity;
  • submit a recipe, story, photograph, video or other content;
  • contact us with an enquiry or feedback; or
  • otherwise communicate with us.

Depending on how you interact with us, the personal data we collect may include:

Contact Data

This may include your:

  • name;
  • email address;
  • telephone or mobile number;
  • home or postal address, where required; and
  • other contact information you choose to provide.

Identity and Eligibility Data

Where you enter a competition, promotion or other activity, we may collect your:

  • first name and last name;
  • county or other location information;
  • date of birth or confirmation of age, where necessary;
  • information required to establish your eligibility; and
  • other information requested as part of the relevant activity.

Competition and Promotional Data

Where you enter a competition, prize draw, promotion or campaign, we may collect information necessary to administer that activity.

This may include:

  • your name and contact details;
  • your competition or promotional entry;
  • recipes, stories or other written content;
  • photographs, videos or other content submitted by you;
  • information required to verify your eligibility;
  • correspondence relating to your entry; and
  • information required to contact and verify winners and arrange prize fulfilment.

Competition and promotional entries may be reviewed for eligibility and suitability in accordance with the applicable Terms & Conditions.

Where content is submitted for publication, the use and publication of that content will be governed by the applicable competition or promotional Terms & Conditions.

Marketing and Communications Data

This includes your preferences regarding receiving marketing communications from us, including Gem Bake Club newsletters and other Gem communications.

Where you provide the required consent to receive marketing communications, we may use your email address or other permitted contact information for this purpose.

Usage and Technical Data

We may collect information about how you use our Site and the technology you use to access it.

This may include:

  • IP address;
  • browser type and version;
  • time zone setting;
  • operating system and platform;
  • device information; and
  • information about how you interact with our Site.

Interaction Data

This includes information about your interactions and communications with us, including correspondence, enquiries and telephone communications.

4. HOW WE USE PERSONAL DATA

We may use personal data for purposes including:

  • administering competitions, prize draws, promotions and campaigns;
  • receiving, processing and reviewing entries;
  • verifying competition or promotional eligibility;
  • contacting entrants and winners;
  • selecting, verifying and announcing winners in accordance with applicable Terms & Conditions;
  • awarding and arranging prizes;
  • publishing competition entries or submitted content where permitted by the applicable Terms & Conditions;
  • responding to enquiries, feedback and complaints;
  • managing subscriptions to the Gem Bake Club and other Gem communications;
  • sending marketing communications where you have provided the required consent or another lawful basis applies;
  • administering in-store promotions, events and other promotional activities;
  • improving our Site, products, services and communications;
  • understanding how visitors use our Site;
  • administering and protecting our business and Site;
  • preventing fraud, abuse or misuse;
  • complying with legal and regulatory obligations; and
  • establishing, exercising or defending our legal rights.

5. COMPETITIONS AND PROMOTIONAL ACTIVITIES

We may run competitions, prize draws, in-store promotions, events and other promotional campaigns from time to time.

When you participate in one of these activities, we may collect and process the personal data necessary to administer the activity, verify entries and eligibility, contact entrants and winners, select winners and fulfil prizes.

The specific information collected and how it will be used may be explained in the relevant Terms & Conditions, entry form, promotional materials or other information provided to you when you participate.

Where an entry includes a recipe, story, photograph, video or other content, the applicable Terms & Conditions may explain how that content may be reviewed, published, featured, edited or otherwise used by Gem.

Where a competition or promotion requires email verification, your email address may be used to send the verification email and other communications necessary to administer your participation.

Where a telephone or mobile number is collected for a competition or promotion, it may be used for administration purposes, including contacting entrants or prize winners where necessary.

Contact details collected for the administration of a competition or promotion will not automatically be used for marketing purposes.

Competition entrants will only receive Gem Bake Club newsletters or other marketing communications where they have provided the required consent or where another lawful basis permitted by applicable law applies.

Marketing consent is separate from the processing necessary to administer a competition or promotion. Choosing not to consent to marketing will not affect participation where marketing consent is not a condition of entry.

6. GEM BAKE CLUB AND MARKETING COMMUNICATIONS

If you subscribe to the Gem Bake Club, sign up to receive Gem marketing communications through an in-store promotion, event or QR code, or otherwise provide the required consent to receive marketing communications from us, we may use your contact details to send you relevant Gem communications.

These communications may include:

  • Gem Bake Club newsletters;
  • recipes and baking inspiration;
  • information about Gem products;
  • competitions and prize draws;
  • promotions and offers;
  • campaigns and events; and
  • other relevant Gem news and content.

Electronic direct marketing will be carried out in accordance with applicable data protection and electronic marketing legislation.

Where we rely on your consent, you may withdraw your consent at any time.

Every marketing email will include an unsubscribe mechanism.

Withdrawing consent or unsubscribing from marketing communications will not affect the lawfulness of processing carried out before your consent was withdrawn.

Where you unsubscribe, we may retain limited information necessary to ensure that we continue to respect your unsubscribe or objection request.

7. LEGAL BASIS FOR PROCESSING PERSONAL DATA

We will only use your personal data where the law allows us to do so.

Depending on the processing activity, our legal basis may include:

  • Consent – where you have given consent to a particular use of your personal data, such as receiving marketing communications where consent is required;
  • Performance of a contract or steps taken at your request – where processing is necessary to provide a service or fulfil an arrangement with you;
  • Legitimate interests – where processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms;
  • Legal obligation – where we need to process personal data to comply with a legal or regulatory obligation; or
  • Other lawful bases permitted under applicable data protection legislation.

For competitions and promotional activities, personal data may be processed where necessary to administer the activity, verify entries and eligibility, contact entrants and winners and fulfil prizes.

Where we rely on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

For electronic direct marketing, we will also comply with applicable requirements under Irish electronic marketing and ePrivacy legislation.

8. THIRD-PARTY SERVICE PROVIDERS

We may use third-party service providers to help us operate our Site, administer competitions and promotions, send communications, manage technology, process entries, provide analytics or fulfil prizes.

For example, service providers may assist us with:

  • website hosting and development;
  • competition entry and verification systems;
  • email and newsletter distribution;
  • data storage and management;
  • analytics;
  • marketing technology;
  • customer communications; and
  • prize fulfilment.

Where third-party service providers process personal data on our behalf, we will take appropriate steps to ensure that the information is processed in accordance with applicable data protection requirements and only for authorised purposes.

Third-party service providers will not be permitted to use personal information provided to them for their own purposes except where permitted by law and appropriately disclosed.

9. DISCLOSURE OF INFORMATION TO THIRD PARTIES

We may disclose personal data where reasonably necessary to:

  • authorised service providers;
  • agencies, contractors or suppliers involved in administering a competition, promotion, event or campaign;
  • prize providers or fulfilment partners;
  • professional advisers;
  • law enforcement or regulatory authorities where required by law; or
  • other parties where disclosure is necessary to protect our legal rights, prevent fraud or protect the safety of individuals.

We will not disclose personal data to third parties for their own direct marketing purposes unless this is permitted by law and the appropriate information and consent requirements have been satisfied.

10. INTERNATIONAL TRANSFERS

Some of our service providers may process personal data outside Ireland or the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, we will take appropriate steps to ensure that the transfer is carried out in accordance with applicable data protection legislation and that appropriate safeguards are in place where required.

11. THIRD-PARTY SITES

Our Site may contain links to websites that are not maintained or controlled by us.

Different privacy policies and Terms & Conditions may apply to those websites.

We do not accept responsibility for the privacy practices or content of third-party websites. We recommend reviewing the privacy policy of a third-party website before submitting personal data to it.

12. SECURITY

We recognise the importance of safeguarding the security and confidentiality of personal data.

We take reasonable technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction.

However, no data transmission or storage system can be guaranteed to be completely secure.

If you believe your personal data has been compromised or your privacy has been breached through the use of our Site, please contact us using the details below.

13. DATA RETENTION

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to:

  • administer competitions and promotions;
  • manage newsletter and marketing subscriptions;
  • deal with enquiries, complaints or disputes;
  • fulfil prizes;
  • comply with legal and regulatory obligations; and
  • establish, exercise or defend legal claims.

Different categories of personal data may therefore be retained for different periods depending on the purpose for which they are processed.

Competition and promotional information may be retained for a reasonable period following the end of the relevant activity to allow us to administer the activity, deal with queries, complaints or disputes, verify winners and comply with our legal obligations.

Content submitted for publication may be retained for longer where permitted under the applicable Terms & Conditions.

Where you have subscribed to the Gem Bake Club or another Gem marketing list, we will retain the relevant contact information for as long as necessary for that marketing purpose unless you withdraw your consent or otherwise request that your information no longer be used for marketing, subject to any legal or regulatory requirements.

Where you unsubscribe from marketing communications, we will stop using your personal data for direct marketing purposes.

We may retain limited information necessary to ensure that we continue to respect your unsubscribe or objection request.

14. YOUR DATA PROTECTION RIGHTS

Under applicable data protection legislation, you may have the following rights in relation to your personal data:

  • the right to be informed about how your personal data is collected and used;
  • the right to access personal data we hold about you;
  • the right to request correction of inaccurate or incomplete information;
  • the right to request erasure of your personal data where there is no lawful reason for us to retain it;
  • the right to request restriction of processing in certain circumstances;
  • the right to object to certain processing, including direct marketing;
  • the right to data portability where applicable;
  • the right to withdraw consent where processing is based on consent; and
  • the right to lodge a complaint with the relevant data protection supervisory authority.

Where you have provided consent for marketing communications, you may withdraw that consent at any time using the unsubscribe link included in the relevant marketing communication.

If you wish to exercise any of your data protection rights, request access to your personal data under a Subject Access Request (“SAR”), withdraw consent or raise a privacy concern, please contact us at:

Email: [email protected]

Address:
Gem Pack Foods Limited
Damastown Way
Damastown Industrial Estate
Dublin 15
Ireland

You also have the right to lodge a complaint with the Data Protection Commission, the relevant supervisory authority in Ireland.

Data Protection Commission

Your existing policy already contains these rights and identifies the Data Protection Commission as the relevant Irish supervisory authority.

15. AUTOMATED DECISION-MAKING AND PROFILING

We do not generally make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

Where automated decision-making or profiling is introduced in a way that triggers additional obligations under applicable data protection law, we will provide the information required by law.

16. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business, our Site, the way we process personal data or applicable legal requirements.

Any changes will be posted on this page and the Last updated date will be amended accordingly.

Where required by law, we will provide additional information or notification where we introduce a new use of personal data that is materially different from the purposes described in this Privacy Policy.

We encourage you to review this Privacy Policy periodically to remain informed about how we handle personal data.

17. CONTACT

If you have any questions or comments regarding this Privacy Policy, please contact us:

Gem Pack Foods Limited
Damastown Way
Damastown Industrial Estate
Dublin 15
Ireland

Email: [email protected]
Telephone: +353 (1) 811 9466
Company registration number: 182913

Last updated: September 2026