Who We Are

Gabriel Merchant Incorporated has offices located at 200 South 10th Street, Suite 1600 Richmond, Virginia, VA 23219, United States of America. At GM, we are committed to safeguarding your personal and financial information. We recognize the importance of protecting the information that you provide to us in order for us to provide our services and products and that you provide when you visit our website located at https://gabmer.com/. The following information is designed to help you understand GM’s information collection practices.

Federal and state law gives consumers the right to limit some but not all sharing. Such laws also require us to you how we collect, share, and protect your personal information. Please read this carefully to understand what we do. By providing GM with your personal or financial information, or by visiting this Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not provide us with personal or financial information or use this Website.

What Information We Collect

GM may collect the following types of non-public personally identifiable information (“PII”) about you:

• Identifiers, such as your name, postal address, email address, or IP address.
• Information contained in our customer records, such as postal address, telephone number, social security number, account information and account balances.
• Commercial information, such as information regarding products or services you purchased.
• Internet or other electronic network activity information, such as how you interact with our website.
• Professional or employment information, such as you job title or employer.
• Geolocation data, such as your general location information (e.g., city/state) which may be collected or derived from your IP address.

GM and our licensees may collect PII about you from the following sources: (1) information that we receive about you on applications, agreements, or other forms; (2) information that you give us verbally; (3) information about your transactions with us or our affiliates; (4) information that you submit to us in written correspondence, including emails and other electronic communications. Information from these sources generally includes, but is not limited to, financial transactions and account numbers.

We generally record certain usage information, such as the number and frequency of visitors to this Website. This information may include the Internet browser you are using and your Internet Protocol (IP) address. If we use this data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

Cookies

Cookies are small bits of computer code that we may install on your computer when it accesses our Website. Cookies make your visit to our Website easier and more convenient. We may use cookies for purposes such as to authenticate users, provide tailored content, and to determine whether a visitor is new or has visited the site before.

While most browsers are set to accept cookies by default, Web browsers typically also have features that permit you to refuse cookies or to alert you before accepting them. Your browser manufacturer has information on changing the default setting for your specific browser. Please understand that if you refuse to accept cookies from our Website, you may not be able to use some portions of our Website and services.

Our Website may also use various technologies to collect non-PII when someone visits our Website. For example, as you browse our Website, we may collect information about your visit, but not about you personally. We may monitor statistics such as the number of people that visit our Website, and from which domain our visitors come. We also may use outsourcing programs to assist us in analyzing this data to better tailor our websites and services.

How We Use and Disclose Your Information

In the section below, we list the reasons we can share our customers’ personal information; the information GM chooses to share; and whether you can limit this sharing.

We use your PII only to: (1) provide and service our products and services; (2) provide information to our affiliates and Service Providers; and (3) fulfill our legal obligations to any regulatory or government body to whom we are required to report, or to fulfill certain obligations; (4) to present our website and its content to you; (5) to provide you with notices about your account, if you maintain an account with us; (6) to fulfill any other purpose for which you provide it; (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;  (8) to notify you about changes to our Website or any products or services we offer or provide though it; and (9) for any other purpose with your consent.  We will not sell, share, or rent your PII to non- affiliated third parties or to affiliated parties for marketing purposes in contravention of this Privacy Policy.

In the course of providing our services, we may disclose PII to non-affiliated companies that perform services for us (“Service Providers”), such as companies that provide transaction processing. These Service Providers, however, act on our behalf and are contractually obligated to keep the information we provide them confidential and to use the information only for the purposes authorized.

We also may disclose PII to non-affiliated third parties for other purposes as required or permitted by law or regulation. Such disclosures may include: (1) to comply with a court order, legal process, or other judicial or investigative proceeding that produces a request for information from us; (2) to fulfill or respond to a request from you or your authorized representative; (3) to protect against fraud or as otherwise permitted or required by law, including to protect our legal interest; (4) 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 GM’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by GM about our Website users is among the assets transferred; (5) for any other purpose disclosed by us when you provide the information; and (6) as otherwise indicated in this Privacy Policy.

With respect to any disclosure made pursuant to clauses (4) through (6), we will notify you of the disclosure and provide you with an opportunity to opt out of such disclosure by contacting our administrator designated below.  You can also opt out of such disclosures at any time by contacting our administrator.

How We Protect Your Information

To protect personal information for you from unauthorized access or use, we permit access only to GM employees, our licensees and our Service Providers’ employees who have a need to know. In addition, we have implemented, and we maintain, technical, administrative, personnel and physical security safeguards.

Changes to This Privacy Policy

GM reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. Such changes shall be effective immediately upon posting. We suggest that you visit the Website and review the Privacy Policy periodically for changes. You acknowledge that by accessing our Website after we have posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.

Access, Correction and Questions

If you have any questions as to this Privacy Policy, or wish to access the PII that we hold with respect to you or to notify us of any errors or changes as to any PII you provide to GM, you can contact our Administrator: at Gabriel Merchant Incorporated, 200 South 10th Street, Suite 1600 Richmond, Virginia, VA 23219, United States of America.

Your State Privacy Rights

Colorado, Connecticut, Virginia, and Utah each provide their state residents with certain rights related to personal data, which may include:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Compliance with State laws.  To the extent that you are a resident of any state whose laws impose obligations upon us in addition to those set forth in this policy, we will comply with such requirements.

If you wish to view, update, amend or delete any personal data we hold about you please get in touch with us at Gabriel Merchant Inc., 200 South 10th Street, Suite 1600 Richmond, Virginia, VA 23219, United States of America. We will try to respond to all legitimate requests within one month. We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of the above rights. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHERE WE STORE YOUR PERSONAL DATA

Data you provide to us is stored on secure servers in the United States, which are provided and managed by external suppliers appointed by us. The server suppliers are subject to strict contractual requirements on data security and also to abide by relevant data protection laws. We also have internal policies and controls in place to minimise the risk of your personal data being lost, misused, accidentally destroyed or disclosed.

If any of your data is transferred to any location in the European Union, we shall comply with all provisions of the General Data Protection Regulations with respect to the handling, storage and access to such data.