Privacy Policy
We (also referred to as “we,” “us,” or “our”) are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the “Website”).
We adhere to the following principles:
To ensure transparency about the collection and processing of your personal information:
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 a range of methods and procedures to provide you with relevant information on the use of Personal Data. If we believe you need specific details, we will share them at the appropriate date and time. We are happy to answer any questions and will provide any clarifications you require, subject to applicable legal constraints. You can contact us by email at: info@blue-orion.com
Personal Data will be used solely for the purposes outlined in this Policy.
Personal Data may be processed by us for various purposes, including providing the website, connecting you with third-party trading platforms (the “Services”), improving the site, protecting our rights and interests, supporting the maintenance and delivery of the Services, meeting legal or regulatory obligations, and conducting administrative and business operations to enable the provision and use of the Services. We also process Personal Data to better understand your preferences and needs.
To access important tools that help protect your rights in relation to Personal Data:
We want you to be able to make informed choices about the collection and processing of Personal Data. That is why we created this website. To support this, we use a range of methods and procedures to provide you with relevant information on our use of Personal Data. If we believe you need more specific details, we will share them with you at the appropriate date and time. We are happy to answer any questions you may have and will offer any clarifications permitted by law. You can reach us by email at the address below: info@blue-orion.com
Protect Your Personal Data:
Although we cannot guarantee the complete security of your Personal Data, we remain committed to continually applying a range of methods and best-practice techniques to keep your Personal Data protected. Our Privacy and Security Policy is comprehensive.
1. The Scope?
This Policy describes 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. A person is identifiable if they can be identified directly or indirectly, including through additional information we hold or can access. The Policy defines “processing” as any operation that involves the use or collection of Personal Data, including its management, structuring, and storage. Our services are intended for a general audience and are not designed for anyone under the age of 18. We do not knowingly collect information from individuals under 18 or allow them to use our services. If we become aware of such data, we will delete it promptly.
2. What Personal Data Do We Hold About You?
When you use our services or channels, or visit our website, we collect Personal Data. We may ask you to provide Personal Data in certain situations. In other cases, we collect Personal Data by analysing your use of our Services and channels, or by receiving information about you from our third-party partners.
3. No obligation to disclose personal information to the company and related consequences.
However, you are not required to provide Us with any Personal Data. In certain situations, though, choosing not to share Personal Data may prevent Us from delivering the Services or may restrict users' ability to access the website.
4. What types of Personal Data can we collect? When you visit our website, we will collect the following personal information:
This includes information about your online activity log, traffic data (including IP address, the date and time of access), the language you use, software crash logs, the type of browser used, as well as information about the device you use. 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 provide to us at your discretion when you connect with a third-party online trading platform through us. Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, phone number, and email address.
5. The Legal Basis and Reasons for the Processing of Personal Data
Your Personal Data is processed by the Company for the purposes outlined in this section, and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot process Personal Data about you. The legal grounds on which the Company may rely 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 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 process data where necessary to pursue their legitimate interests. For example, to improve Our Services or to defend legal claims.
- Processing must satisfy a legal obligation.
Contact us by email for more information about the processing carried out to protect our legitimate interests.
Below is a list of purposes and legal bases on which we may use the information you provide. Personal Data.
1. To share your personal information with third parties at your request to access digital trading.
If you request it, 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 address your requests, questions, or concerns
Personal Data is processed as necessary to enable us to respond to any questions you may have regarding the Services.
Processing is necessary for the legitimate interests pursued by the Company or by a third party.
3. To comply with any legal, administrative, or judicial obligation, Personal Data is processed to meet applicable legal requirements.
Processing is necessary to comply with legal obligations.
4. To enhance Our Services
We may use Personal Data to refine and improve Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.
Processing is necessary for the legitimate interests pursued by the Company or a third party.
5. To prevent fraud and misuse of our services
Processing is necessary for the legitimate interests of the Company or a third party.
6. To carry out and manage activities that comply with the requirements of Our Services
These activities include back-office functions, business development initiatives, strategic decision-making, oversight mechanisms, etc.
Processing is necessary for the Company's legitimate interests or those of a third party.
7. To perform analyses, including statistical analyses
To make decisions on various issues, we use a range of analytical techniques (including statistical methods).
Processing is necessary for the Company's legitimate interests or those of a third party.
8. To protect our assets, rights, and interests, as well as those of third parties, we may take action, including establishing and defending legal claims
Personal Data may be processed to safeguard our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.
Processing is necessary for the Company's legitimate interests or those of a third party.
6. Transfers of Personal Data to Third Parties
The Company may also share Personal Data with third parties that provide services to us, such as hosting and storage providers, IP address services, and user experience analytics.
You may ask us to transmit specific Personal Data about you to third-party trading platforms. In such cases, we will provide the Personal Data you supply to us to those third-party platforms. Their use of your Personal Data is governed by their own privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities or business partners to obtain the resources needed to enhance and improve the products and services we provide to 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 your Personal Data with prospective investors or buyers, or with lenders to the Company or any other company within the group, in connection with a transaction (including the transfer or sale of assets of the Company or any other group company) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.
ONLINE TRACKING NOTICE
We may use third-party services, including advertising providers on our Website and analytics companies. These partners may also use cookies and similar technologies.
Cookies are small text files placed on your device whenever you visit or access the Website. Cookies help collect information about your preferences and browsing behaviour to enhance your experience, remember your settings, and tailor products and services to your interests. They are also used for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and last only 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 for you to come back to the Website.
7. Cookies and Third-Party Services
We may use them depending on their purpose:
Cookies are strictly necessary
Cookies are strictly necessaryThese cookies are essential for accessing the features you’ve requested and for navigating our website. We use them to deliver the information, products, and services you have asked us for.
They are necessary for your device to download and stream data. This allows you to move around the website, use its features, and return to pages you’ve visited before.
Cookies collect Personal Data—such as your username and most recent login date—to verify your session on the site. These session cookies are deleted when you close your web browser.
Functionality Cookies
ScopeCookies help us recognise you each time you visit our site and enable us to store your settings and preferences.
Additional informationThey remain active until their expiry date and persist even after the browser is closed.
Cookies for performance
ScopeWe use cookies to collect statistical insights on our site's performance and to help improve it. They also allow us to perform analysis across our website.
Additional informationCookies may store anonymous data that is not linked to any identified or identifiable natural person. They can be deleted when you close your browser. Some cookies remain valid for an indefinite period.
Cookies are blocked or have been removed
To block or delete cookies, adjust your browser settings. Below are links to help you with the process for several popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention of Your Personal Data
The Company will retain your Personal Data for as long as necessary to fulfil the purpose for which it is processed, as outlined in this Policy, or for longer periods as allowed by applicable laws, regulations, policies, and orders. We will share your information with third‑party trading platforms for 12 months. If you consent, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold and delete information that is no longer needed.
9. Transfers of personal data to a third country or an international organisation
Your personal information may be transferred to other countries (i.e., your personal data may be sent to a third country—meaning a country other than the one in which you reside—or to international organizations or jurisdictions). Company takes all necessary steps to safeguard the Personal Data you provide and ensures that individuals can assert their rights and access effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area).
- Transfer to a third country or international organisation that the European Commission has determined provides an adequate level of protection for personal data transferred to it, in accordance with 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 made under a legally binding, enforceable agreement between public entities or authorities pursuant to Article 46(2)(a).
- 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 are available 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 protect Personal Data. These measures include preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We strive to protect your Personal Data, but we cannot guarantee or warrant error-free security. Nor can we be 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 third-party access, or any other cause beyond our control.
Where required by law or by obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot control the security applied to your Personal Data by third parties in such 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 through the internet.
11. Hyperlinks to third-party websites
Links to third-party websites and applications are provided on this website. 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 activities carried out 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 and before you provide 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 version on our website. In addition, when we introduce significant modifications to this Policy, we will seek to inform you through the methods we consider appropriate, and we will publish a notice on our website. Unless explicitly stated otherwise, any amendments will take effect after we publish the revised Policy.
13. Your rights regarding your personal data
You are entitled to request that we verify the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data that is not required by Us. You may also limit the scope and 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 may exercise your rights by sending an email to the address below. Access rights
The Company can verify whether the Personal Data about you is being processed and, 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 any additional copies. The data will be made available electronically if you request it.
Your right of access must not conflict with the rights and freedoms of others. If fulfilling your request would adversely affect the rights and freedoms of another person, the Company may refuse to comply or limit its response. Right to rectification
The Company is entitled to 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
The following reasons apply: (a) Personal Data is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time, on grounds relating 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) Personal Data has been processed unlawfully; or (f) 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 defense of legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may ask the Company to restrict its processing. While processing is restricted, Personal Data may be processed only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or for reasons of important public interest of the European Union or a Member State.
Right to data portability
Where processing is carried out by automated means and is based on 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. The right to portability must not adversely affect the rights or freedoms of others.
Right to challenge
You may object at any time to the processing of Personal Data about you that is based on the legitimate interests pursued by the Company or a third party, including profiling on that basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or the processing is necessary for the establishment, exercise, or defense of legal claims.
Concerning direct marketing You have the right at any time to object to the processing of your Personal Data for direct marketing.
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 are entitled to lodge a complaint with your supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect individuals’ fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights regarding Personal Data as described in section 13. We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months if necessary, depending on the complexity and number of requests. Within one month of receipt of your request, we will inform you of any extension and the reasons for it.
Unless otherwise provided in section 13, information requested under your rights in section 13 will be provided free of charge. If a request is manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or we may refuse to act.
If we have doubts about the identity of the person making the request, the Company may ask for additional information.
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