Privacy Policy
We ('we', 'us', or 'our') are committed to protecting your Personal Data and your privacy.
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 about the collection and processing of your personal information:
Our aim is to help you make informed choices about the use and processing of your Personal Data. That is why we created this website. To achieve this, we use various methods and procedures to provide relevant information about the use of Personal Data. If we believe you require specific details, we will provide them at the appropriate date and time. We are happy to answer any questions and provide any clarifications, subject to any limitations imposed by law. You can contact us by email at: info@blue-orion.com
Personal Data will be used solely for the purposes set out in the 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'), enhancing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, complying with legal and regulatory obligations, and conducting administrative and business activities that support the delivery and use of the Services. Personal Data are also processed by Us to better understand your preferences and needs.
Access essential tools to safeguard your rights in relation to Personal Data:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we created this website. To achieve this, 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 provide them at the appropriate time. We are happy to answer any questions and will offer any clarifications permitted by law. You can contact us by email at the address below: info@blue-orion.com
Protect your personal data:
While we cannot guarantee the absolute security of your Personal Data, we will continue to use a range of measures and best practices to keep it 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 protect 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 by reference to identifiers or to additional information we hold or can access. The Policy defines ‘processing’ as any operation or set of operations that involves the use or collection of Personal Data, including its management, structuring, storage, use, disclosure, and deletion. Our services are intended for a general audience and are not designed for individuals under 18 years of age. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly permit such individuals to use our services or submit information. If we become aware that we have collected information about a minor, we will delete it as promptly as possible.
2. What Personal Data do we hold about you?
When you use our Services or channels, or visit our website, we collect Personal Data. In some cases, we ask you to provide this information. In others, we collect it by analysing how you use our Services and channels, or by receiving information from our third-party partners.
3. No obligation to provide personal data to the company and the potential consequences.
While you are not required to provide us with Personal Data, there are situations where we may request it. If you choose not to share such data, this may prevent us from providing the Services or restrict users’ access to the website.
4. What types of Personal Data do we collect? When you visit our website, we may collect the following Personal Data:
This includes details of your online activity log, traffic data (including IP address and the date and time of access), the language you used, software crash logs, the type of browser used, and information about the device you use. The information we collect is not personal data and cannot be used to identify you. Personal data we receive from you: any personal information you choose to provide when you connect to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading may include your full name, address, phone number, and email address.
5. Legal Basis and Reasons for the Processing of Personal Data
The Company processes your Personal Data for the purposes set out in this section, and only where an appropriate legal basis applies.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company may process your Personal Data are:
- You have provided consent to the processing of your Personal Data for one or more purposes. This applies when you submit Personal Data 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 data to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to defend against legal claims.
- Processing is necessary to comply with a legal obligation.
Contact us via email for more information about the processing required to safeguard our 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 data with third parties at your request to enable access to digital trading.
If you request this, we may collect personal data from you to forward 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 required to address any inquiries you may have regarding the Services.
Processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party.
3. To comply with legal, administrative, or judicial obligations, Personal Data is processed to meet all applicable legal requirements.
Processing is necessary to comply with legal obligations.
4. To improve Our Services
We may use Personal Data to improve Our Services. This includes, among other things, crash or malfunction reports that we collect in connection with the Services.
Processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
5. To prevent fraud and abuse of Our Services
Processing is necessary for the legitimate interests of the Company or a third party.
6. To execute and manage activities that comply with the requirements of Our Services
Such activities include back-office operations, business development, strategic decision-making, oversight mechanisms, etc.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
7. To perform analyses, including statistical analyses
To inform decisions on various issues, we apply a range of analytical methods (including statistical ones).
Processing is necessary to pursue the legitimate interests of the Company or a third party.
8. To protect our assets, rights, and interests, as well as those of third parties, we have implemented appropriate measures to establish and defend legal claims
Personal Data may be processed by us to safeguard our rights, interests, and assets, or those of third parties, in compliance with applicable laws, regulations, or agreements, and any relevant terms, conditions, or policies.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
6. Sharing Personal Data with Third Parties
The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, providers that process IP address information, and user experience analytics firms.
You may also ask us to disclose specific Personal Data about you to third-party trading platforms. In such cases, we will transfer to those third-party trading platforms the Personal Data you have provided to Us. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners, enabling the Company to access the resources needed to enhance and improve the products and services it offers to customers.
Where necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or purchasers, 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 services, such as advertising providers on our website or analytics companies, may be used. These companies may also use cookies or other technologies.
Cookies are small text files placed on your device whenever you visit or access the website. We use cookies to collect information about your preferences and browsing habits to enhance your user experience, remember your settings, and tailor products and services you may enjoy. 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 last for a short time until 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 recognise you as a returning user and make it easier to return to the site.
7. Third-Party Cookies and Services
We may use them according to their purpose:
Cookies are strictly necessary
Cookies are strictly necessaryThese cookies are essential to access the features you request and to navigate our website. We use cookies to deliver the information, products, and services you ask us to provide.
They are necessary for your device to download and stream data, enabling smooth browsing. This allows you to move around the site, make use of its features, and return to pages you have visited before.
Cookies collect Personal Data—such as your username and last login date—to confirm that you are logged in to the site. They are deleted when you close your web browser (session cookies).
Functionality Cookies
ScopeCookies help us recognize you each time you visit our site and enable us to remember your settings and preferences.
Additional informationThey remain active until their expiry date and persist even after you close the browser.
Cookies for performance
ScopeCookies help collect statistical data about site performance and support ongoing improvements. They also allow us to analyse how our website is used.
Additional informationCookies store anonymous data that is not linked to any identified or identifiable natural person. Some are deleted when you close your browser. Other cookies remain valid indefinitely.
Cookies are blocked or have been removed
To prevent or delete cookies, update your browser settings. Below are links with guidance for several of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
ONLINE TRACKING NOTICE This service does not currently recognise Do Not Track signals.
8. The retention of your personal data
The Company will retain your Personal Data for as long as necessary to fulfill the purposes 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. With your consent, we will continue to share it for an additional 12 months.
We regularly review the Personal Data we retain to ensure it is not kept longer than 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 organisations or jurisdictions. Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data subjects can assert their rights and obtain effective legal recourse.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the European Commission has determined ensures an adequate level of protection for Personal Data pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the 'GDPR')
- The transfer is carried out pursuant to a legally binding and enforceable instrument between public authorities or bodies under Article 46(2)(a) of the GDPR.
- The transfer was carried out in accordance with the Standard Contractual Clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. These 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. Protection of Personal Data
We have implemented appropriate organisational and technical measures to safeguard Personal Data. These measures include preventing 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. Nor can we 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, unauthorised access by a third party, or other causes beyond our control.
In cases of legal requirements or other obligations beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. We cannot control the security measures applied to your Personal Data by third parties in these situations.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot ensure the security of Personal Data you transmit to us via the internet.
11. Hyperlinks to third-party websites
Our website includes links to third-party sites and applications. These sites and apps are not under the control or supervision of the Company. We are not responsible for the collection or processing of Personal Data by those websites or apps. This Policy does not apply to activities conducted on such sites or apps.
When you visit any third-party website or app, we recommend that you read their privacy policies before deciding to access or use their services. We also recommend doing so before providing any Personal Data to them.
12. Changes to this Policy
This Policy may be updated at any time. If we make changes to this Policy, we will notify you by posting the updated Policy on our website. In addition, for significant modifications, we will seek to inform you through the channels we consider appropriate and will publish a notice on our website. Unless explicitly specified otherwise, any amendments will take effect upon publication of the revised Policy.
13. Your rights regarding the processing of your personal data
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 restrict certain types or scopes of processing of your personal information. If you are a resident of the EEA, please refer to this page:
These rights are available to you with respect to the information you provide relating to your Personal Data. You may exercise your rights by sending an email to the address below.Access rights
The Company will verify whether Personal Data about you is being processed. If so, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any 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. If a request would adversely affect the rights and freedoms of another person, the Company may refuse the request or limit its scope.Right to rectification
The Company will rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be completed, taking into account the purposes of the processing.Right to erasure
You may request erasure where: (a) the Personal Data are no longer necessary for the purposes for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time, based on reasons related to your particular situation, to processing of Personal Data about you that is based on legitimate interests pursued by us or by a third party; (e) the Personal Data have been processed unlawfully; or (f) the Personal Data must be erased 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 European Union or Member State law, or (b) for the establishment, exercise, or defence of legal claims.
Restrictions on processing
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If processing is restricted, Personal Data may be stored only with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another natural person, or for reasons of important public interest in the European Union or a Member State.
Right to data portability
If processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the right to receive the Personal Data you provided to the Company.
You may also request that your Personal Data be transmitted directly by the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. This right must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time to processing of Personal Data concerning you that is based on the legitimate interests of the Company or a third party, including profiling based on those legitimate interests. We will stop processing unless we can demonstrate compelling legitimate grounds that override your rights and freedoms, or the processing is for the establishment, exercise, or defence 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 for us to process your Personal Data at any time. This will not affect the lawfulness of processing based on your 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 the fundamental rights of individuals regarding the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights regarding your Personal Data as described in section 13. We will provide the information requested under section 13 of this agreement within one month of receiving your request. 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 receiving your request of any extension and the reasons for it.
Unless otherwise provided by section 13, information requested under your rights in section 13 will be provided free of charge. If a request is manifestly unfounded or excessive, in particular because of its repetitive character, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information.
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