Gemalli

Company Policy

Effective date:

This Company Policy sets out the standards of conduct that apply to everyone who uses the Gemalli platform — Manufacturers, Buyers, and visitors. It complements the Terms of Service and the Privacy Policy. Where this policy refers to specific obligations, the full and binding terms are set out in the Terms of Service.

1. Who This Policy Applies To

This policy applies to every account holder and visitor on Gemalli, operated by Lux-Promo. By using the Platform you agree to follow it. Serious or repeated breaches may result in content removal, account suspension, or account termination, as described in the Terms of Service.

2. Acceptable Use

When using the Platform, you agree to:

  • Provide accurate, current, and complete information in your profile, product listings, and RFQ submissions.
  • Use the Platform only for genuine B2B sourcing, lead-generation, and related business communication.
  • Communicate professionally with other users and keep RFQ follow-up relevant to the subject of the original inquiry.
  • Keep your account credentials confidential and report any suspected unauthorised access.

3. Prohibited Conduct

The following are not permitted on the Platform:

  • Bulk scraping or automated extraction of data, profiles, or contact details without prior written permission from Lux-Promo.
  • Sending spam or unsolicited bulk communications using contact data obtained through the Platform.
  • Misrepresenting your identity, company, certifications, product specifications, or affiliation with any entity.
  • Listing or promoting counterfeit goods, goods that infringe intellectual property rights, or goods prohibited for export or import under applicable law.
  • Attempting to access accounts or data belonging to other users, reverse-engineering the Platform, or circumventing security and anti-bot measures.
  • Uploading malware, phishing material, or any content designed to deceive or harm users.

4. Content Standards

Content you upload — including company profiles, product listings, images, blog posts, and director profiles — must be lawful, accurate, and your own (or properly licensed). It must not infringe third-party rights or mislead Buyers. Lux-Promo may remove Content that breaches these standards and is not obliged to host or display any particular Content.

5. Sanctions and Export Compliance

Gemalli connects Ukrainian manufacturers with international buyers, and trade compliance is taken seriously. Entities incorporated or registered in the Russian Federation, and individuals or entities on OFAC SDN lists, EU consolidated sanctions lists, or Ukrainian NSDC sanctions lists, may not register or use the Platform. Users are responsible for ensuring that any proposed transaction complies with export controls, sanction regimes, and applicable law in their jurisdiction. Lux-Promo may terminate any account where there is reasonable belief of sanction exposure, without prior notice.

6. Reporting and Enforcement

If you encounter content or behaviour that breaches this policy, please report it to editorial@gemalli.com. Lux-Promo reviews reports and may remove Content, issue warnings, or suspend or terminate accounts. Enforcement decisions follow the process described in the Terms of Service.

7. Changes to This Policy

Lux-Promo may update this Company Policy from time to time. When we make material changes, we will update the effective date above and, where appropriate, notify registered users. Continued use of the Platform after a change takes effect constitutes acceptance of the updated policy.

8. Contact

Questions about this Company Policy can be sent to Gemalli by Lux-Promo at editorial@gemalli.com. For questions about personal data, see the Privacy Policy.

Company Policy — Gemalli