Privacy Policy
We (also referred to as 'We', 'Us', or 'Our') are committed to protecting your Personal Data and your privacy.
This Privacy Policy is intended to explain how we collect and store the information you provide through the Gaingate website (the 'Website').
We will uphold the following principles:
To ensure transparency about how we collect and process your personal data:
We want you to be able to make informed decisions 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 you with relevant information about the use of Personal Data. If we believe you need specific details, we will share them at the appropriate time. We are happy to answer any questions and provide 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 outlined in this Policy.
We may process Personal Data for a range of purposes, including operating the website; connecting you with third-party trading platforms (the 'Services'); enhancing the site's functionality and performance; ensuring site security; protecting our rights and legitimate interests; maintaining and delivering the Services; complying with regulatory and legal obligations; and performing administrative and business operations that support the provision, delivery, and use of the Services. We also process Personal Data to better understand your preferences and needs.
To use essential tools to protect your rights regarding Personal Data:
We want you to be able to make informed decisions 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 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 need, subject to any legal limitations. You can reach us by email at: info@blue-orion.com
Protect Your Personal Data:
Although we cannot guarantee the absolute security of your Personal Data, we will continue to employ a wide range of measures and technologies to ensure your Personal Data remains 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 protect it, among other related practices. This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly 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 the management, structuring, and storage of such data. Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly seek or collect information from persons under 18, nor do we knowingly permit them to use our services. If we become aware 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 use our Services and service channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain situations. We also collect Personal Data by analysing how you use our Services and service channels, or from information provided by our third-party partners.
3. No obligation to disclose personal information to the company and potential consequences.
However, you are not obliged to provide us with any Personal Data. In certain circumstances, you may choose not to share Personal Data with us. This may prevent us from providing the Services or limit users’ access to the website.
4. What types of Personal Data do we collect? When you visit our website, we will collect the following personal information:
This includes details of your online activity log; traffic data (including IP address, access date and time), the language you use, software crash reports, the type of browser, and information about the device you use. The information we collect is non-personal 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 may include your full name, address, phone number, and email address.
5. Legal Basis and Purposes for Processing 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 process your Personal Data. The legal grounds on which the Company may process your Personal Data are:
- You have given 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 need to process personal data to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
- Processing must fulfil a legal obligation.
Contact us by email for more information about the processing required to protect our legitimate interests.
Below is a list of purposes and legal bases for which we may use the Personal Data you provide to us.
1. To share your personal information with third parties at your request to enable access to digital trading.
If you request it, we may ask for Personal Data from you so we can forward it to third-party companies
You have provided your consent to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns
Personal Data is processed as necessary to address any questions you may have about the Services.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
3. To meet any legal, administrative, or judicial obligation, Personal Data is processed to fulfill legal requirements.
Processing is necessary to ensure compliance with legal obligations.
4. Enhancing Our Services
We may use Personal Data to enhance Our Services. This includes, among other things, crash and malfunction reports we collect in connection with the Services.
Processing is necessary for the legitimate interests of the Company or those of a third party.
5. To prevent fraud and misuse of Our Services
The processing is necessary for the legitimate interests of the Company or those of a third party.
6. To carry out and manage activities that align with the requirements of Our Services
These activities include back-office operations, business development, strategic decision-making, oversight mechanisms, etc.
Processing is necessary for the purposes of the legitimate interests pursued by the Company or 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 purposes of the legitimate interests pursued by the Company or a third party.
8. To protect our assets, rights, and interests, as well as those of third parties, we may 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 accordance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.
Processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, processors of IP address information, and user experience analytics providers.
You may also request that we 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 trading 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 related entities or business partners. Doing so provides the Company with the resources needed to enhance and improve the products and services it offers to customers.
When necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other competent authorities.
Additionally, we may share Personal Data about you with potential investors, buyers, or lenders of the Company or any other company in our group if a relevant transaction occurs (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, such as advertising providers and analytics companies. 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 help collect information about your preferences and browsing habits to enhance your experience, remember your settings, and tailor products and services to your interests. We also use cookies 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 to return to the website.
7. Cookies and third-party services
We may use them according to their purpose:
Cookies are strictly necessary
Cookies are strictly necessaryThese cookies are essential for accessing the features you request and for navigating our website. We use them to deliver the information, products, and services you have asked for.
They enable your device to download and stream data, allowing you to move through the site, utilise 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 that you are logged in to the site. These are session Cookies and are deleted when you close your web browser.
Functionality Cookies
ScopeCookies help us recognize you on each visit to our site and enable us to store your settings and preferences.
Additional informationThey remain valid until their expiry date and persist even after the browser is closed.
Cookies for performance
ScopeCookies are used to collect statistical data on the site's performance and to help enhance it. They also enable us to carry out analysis on our website.
Additional informationCookies store anonymous data that is not linked to any identifiable natural person. They can be deleted when you close your browser. Other cookies have indefinite validity.
Cookies are blocked or have been removed
To block or delete cookies, adjust your browser settings. Below are helpful 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 honor 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 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; with your consent, we will continue sharing it for a further 12 months.
We regularly review the Personal Data we hold to ensure we do not keep it longer than necessary.
9. Transfers of personal data to third countries or international organisations
Your personal information may be transferred to other countries (i.e., your personal data may be transmitted to a third 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 ensures that data subjects can assert their rights and access effective legal remedies.
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 and enforceable agreement between public entities or authorities pursuant to Article 46(2)(a).
- The transfer was conducted in accordance with the European Commission's Standard Contractual Clauses adopted under Article 46(2)(c) GDPR. The European Commission's clauses 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 protect Personal Data. This includes preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant error-free security of your Personal Data. Nor can we be held liable for any non-material, 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 other causes beyond our control.
In the event 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 applied to your Personal Data by third parties in such cases.
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 websites operated by third parties
Links to third-party websites and applications are available on this website. These sites and apps are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by these third parties. This Policy does not apply to actions taken on such sites or apps.
When you visit any third-party site or app, we recommend reviewing their privacy policies before accessing or using their services. We also advise exercising caution before providing any Personal Data to them.
12. Changes to this Policy
This Policy may be updated at any time. If we make changes, we will notify you by posting the updated Policy on our website. In addition, when we implement significant updates, we will seek to inform you through appropriate channels and will publish a notice on our website. Unless explicitly stated otherwise, any amendments will take effect upon publication of the revised Policy.
13. Your rights in relation to your personal information
You have the right to ask us to verify the accuracy of the Personal Data we collect about you, correct any errors, and 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. Right of access
The Company can 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 additional copies. The data will be provided 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 the request or limit its scope. Right to rectification
The Company must rectify inaccurate Personal Data. You are entitled to require that incomplete Personal Data concerning you be completed, taking into account the purpose of processing. Right to erasure
The following grounds 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 and on grounds relating to your particular situation, to processing based on legitimate interests pursued by us or 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.
Restriction of processing
If you contest 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 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 your consent or a contract to which you are party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used, machine-readable format.
You may also request, where technically feasible, that your Personal Data be transmitted directly from the Company to another controller. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time to the processing of Personal Data concerning you that is based on the legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
Direct marketing You have the right to object at any time to the processing of your Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent for 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 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 law may limit your rights concerning your Personal Data, as described in this section 13. We will provide the information requested under section 13 within one month of receiving your request. This period may be extended by up to two months where necessary, taking into account the complexity and number of requests. Within one month of receiving 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 request additional information.
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