Privacy Policy
We (also referred to as 'We', 'Us', or 'Our') are committed to protecting your privacy and Personal Data.
This Privacy Policy is designed to explain how we collect and store the information you provide through the Gaingate website (the 'Website').
We uphold the following principles:
To ensure transparency in how we collect and process your personal information:
We want you to be able to make informed choices about how your Personal Data is used and processed. This is why we created this website. To achieve this, we use various methods and procedures to provide you with relevant information about the use of Personal Data. If we believe you need specific details, we will provide them at the appropriate date and time. We are happy to answer any questions you may have and will offer any clarifications you require, subject to legal limitations. You can reach us by email at: info@blue-orion.com
Personal Data will be used solely for the purposes stated in this Policy.
Personal Data may be processed by Us for various purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, complying with regulatory or legal obligations, and conducting administrative and business activities to support the delivery and use of the Services. Personal Data are also processed by Us to better understand your preferences and needs.
To access essential tools designed to effectively safeguard your rights regarding Personal Data:
We want you to be able to make informed choices about the use and processing of Personal Data. This is why we created this website. To that end, we use various methods and procedures to provide you with relevant information about how Personal Data is used. If we believe you need specific details, we will share them with you at the appropriate time. We are happy to answer any questions and will provide any clarifications you require, subject to any legal limitations. You can reach us by email at: info@blue-orion.com
Protect Your Personal Data:
While we cannot guarantee the absolute security of your Personal Data, we guarantee that we will continue to employ a wide range of measures and techniques to ensure it remains protected. Our Privacy and Security Policy is comprehensive.
1. The Scope?
This Policy explains the types of Personal Data the Company collects about natural persons and how we process it, share it with third parties, and secure it. It concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including through additional information we hold or can access. In this Policy, “processing” refers to any operation involving Personal Data, including its collection, management, structuring, and storage. Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly allow such individuals to use our services. If we learn that we hold information about a child, we will delete it as quickly as possible.
2. What Personal Data Do We Hold About You?
When you access our services and channels or visit our website, we collect Personal Data. We may request your Personal Data in certain instances. We also collect your Personal Data by analysing how you use our Services or service channels, or by receiving information about you from our third-party partners.
3. No obligation to disclose personal information to the company and the potential consequences.
However, you are not obliged to provide Us with any Personal Data. In certain circumstances, though, if you choose not to do so, it may prevent Us from providing the Services or may restrict users from accessing the Website.
4. What types of Personal Data do we collect? When you visit our website, we will collect the following personal information from you:
This includes information about your online activity logs, traffic data (including IP address and the date and time of access), the language you use, software crash logs, the type of browser you use, as well as details about the device you utilise. The information we collect is not personal information and cannot be used to identify you. Personal data we receive from you: any personal data you choose to provide to us when you connect with a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading: this information may include your full name, address, telephone number, and email address.
5. Legal Basis and Justifications for the Processing of Personal Data
Your Personal Data is processed by the Company for the purposes described in this section and in accordance with the applicable legal basis.
Without a legal basis, the Company cannot use Personal Data relating to you. The legal grounds that allow the Company to process your Personal Data are:
- You have provided your consent to the processing of your Personal Data for one or more purposes. This applies, for example, when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may need to process personal data to pursue legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
- Processing must comply with a legal obligation.
Contact us via email for more details regarding the processing required to safeguard legitimate interests.
Below is a list of purposes and legal bases for which we may use the information you provide to us. Personal Data.
1. To share your personal information with third parties upon your request to enable access to digital trading.
If you request this, we may collect Personal Data from you to forward it to third-party companies
You have consented to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns
Personal Data is needed to help us address any inquiries you may have regarding the Services.
Processing is necessary to pursue the legitimate interests of the Company or those of a third party.
3. To comply with any legal, administrative, or judicial obligations, Personal Data is processed to satisfy applicable legal requirements.
To comply with legal obligations, processing is necessary.
4. To enhance Our Services
We may use Personal Data to enhance Our Services. This includes, among other things, crash or malfunction reports that we collect in connection with the Services.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of Our Services
Processing is required to pursue the legitimate interests of the Company or a third party.
6. To conduct and manage activities that align with the requirements of Our Services
These activities include back-office operations, business development, strategic decision-making, and governance and oversight mechanisms.
Processing is necessary for the legitimate interests pursued by the Company or a third party.
7. To perform analyses, including statistical analyses
To make decisions on various matters, we employ a range of analytical techniques (including statistical ones).
Processing is necessary for the legitimate interests pursued by the Company or a third party.
8. To safeguard our assets, rights, and interests, as well as those of third parties, we may establish and defend legal claims
Personal Data may be processed to protect our rights, interests, and assets, or those of third parties, in accordance with any applicable laws, regulations, or agreements, and any relevant terms, conditions, or policies.
Processing is necessary for the legitimate interests pursued by the Company or a third party.
6. Sharing of Personal Data with Third Parties
The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, for purposes including processing IP address information and analyzing user experiences.
You may also request that we provide specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you provide to Us with those third-party platforms. Their use of your Personal Data is governed by their privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to secure resources that help us enhance and improve the products and services we offer to our customers.
Where necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company in our group, in connection with a transaction (including the transfer or sale of assets of the Company or any other company within the group) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.
ONLINE TRACKING NOTICE
Third-party providers, such as advertising networks and analytics companies, may be used. These providers may also use cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or access the Website. They collect information about your preferences and browsing habits to enhance your user experience, remember your settings, and tailor products and services you may find relevant. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and expire shortly after you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognize you as a returning user and make it easier for you to come back to the site.
7. Cookies and Third-Party Services
We may use them based on their intended purpose:
Cookies are strictly necessary
Cookies are strictly necessaryThese cookies are essential to enable access to the features you request and to help you navigate our website effectively. We use cookies to deliver the information, products, and services you have requested.
They are required for your device to download and stream data. This allows you to move around the site seamlessly, use its features, and return to pages you have visited before.
Cookies collect personal data, including your username and the date of your last login, to verify that you are logged in to the site. They are deleted when you close your web browser (Session Cookies).
Functionality Cookies
ScopeCookies allow us to recognise you each time you visit our site and to remember your settings and preferences.
Additional informationThey persist until their expiry date and remain stored even after the browser is closed.
Cookies for performance
ScopeWe use cookies to collect statistical data on the site's performance and to improve it. They also enable us to conduct analysis on our website.
Additional informationCookies store anonymous data that is not linked to any identified or identifiable natural person. They can be removed when you close your browser. Other cookies may remain valid indefinitely.
Cookies are blocked or have been removed
To block or delete cookies, change your browser settings. Below are links to guide you through the process for several of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention of personal data about You
The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders. We will share your information with third-party trading platforms for 12 months. If you agree to this, we will continue to share your data for another 12 months.
We regularly review the Personal Data we hold to ensure it remains necessary.
9. Transfers of personal data to a third country or to an international organisation
Your personal information may be transferred to other countries (i.e., your personal data may be transmitted to a third country, meaning a country other than the one in which you reside, or to international organizations or jurisdictions). The Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data subjects have the ability to assert their rights and access effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or an international organisation that the European Commission has determined ensures an adequate level of protection for Personal Data transferred to it, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016. (the 'GDPR')
- The transfer is carried out under a legally binding, enforceable agreement between public entities or authorities pursuant to the requirements of Article 46(2)(a).
- The transfer was carried out in accordance with the European Commission’s standard contractual clauses adopted under Article 46(2)(c) GDPR. The clauses adopted by the European Commission can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
10. Personal Data Protection
We have implemented appropriate organizational and technical measures to protect Personal Data. These measures help prevent the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be error-free. We also cannot be held liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorized third party access, or other causes beyond our control.
In the event of legal or other obligations beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. In such situations, we cannot control the safeguards those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet with absolute security. The Company cannot ensure the security of any Personal Data you send to us online.
11. Hyperlinks to third-party websites
We provide links to third-party websites and applications on this site. These sites and apps are not under the Company’s supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any third-party website or app, we recommend reading its privacy policy before deciding to access or use it. We also suggest that you provide any Personal Data to them.
12. Amendments to this Policy
This Policy may be updated at any time. If we make changes, we will notify you by posting the revised Policy on our website. In addition, for significant updates, we will seek to inform you through the methods we consider appropriate and will publish an announcement on our website. Unless stated otherwise, any amendments take effect upon publication of the updated Policy.
13. Your rights regarding your personal information
You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we no longer require. You may also limit certain types of processing of your personal information. If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You can exercise your rights by emailing the address below.
Access rights
The Company can verify whether Personal Data about you is being processed. If so, you may access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. If you request it, the data will be provided electronically.
Your right of access must not conflict with the rights and freedoms of others. Where a request would adversely affect the rights and freedoms of another person, the Company may refuse the request or limit how it is fulfilled.
Right to rectification
The Company will correct inaccurate Personal Data. You may require that incomplete Personal Data about you be completed, taking into account the purposes of processing.
Right to erasure
You may request deletion of your Personal Data if: (a) the data is no longer needed for the purposes for which it was collected or processed; (b) you withdraw consent and no other legal basis applies; (c) you object, on grounds related to your situation, to processing based on legitimate interests pursued by us or a third party; (e) the data has been processed unlawfully; or (f) deletion is required to comply with a legal obligation of the Company. This right does not apply where processing is necessary (a) to comply with a legal obligation under EU or Member State law, or (b) to establish, exercise, or defend legal claims.
Restriction of processing
If you contest the accuracy of your Personal Data, you may ask the Company to restrict its processing. While processing is restricted, the data may be stored only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or for important reasons of public interest in the European Union or a Member State.
Right to data portability
Where processing is automated and based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company.
You may also request that your Personal Data be transmitted directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure and must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on the legitimate interests of the Company or a third party, including profiling on that basis. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.
For direct marketing, you have the right to object at any time to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to protect individuals’ fundamental rights with respect to the processing of Personal Data within the European Union.
EU and Member State laws may limit your rights regarding your Personal Data, as described in this Section 13.
We will respond to requests to exercise the rights set out in Section 13 within one month of receipt. Where necessary, this period may be extended by up to two further months, depending on the complexity and number of requests. We will inform you within one month of any extension and the reasons for it.
Subject to Section 13, information provided in response to your rights requests will be free of charge. If a request is unfounded or excessive, in particular because of its repetitive character, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have reasonable doubts about the identity of the person making the request, the Company may request additional information.
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