Privacy Policy
We (referred to as '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 adhere to the following principles:
To ensure transparency in how we collect and process your personal data:
We want you to be able to make informed decisions about how your Personal Data is used and processed. That is why we created this website. To support this, we use various methods and procedures to deliver relevant information about the use of Personal Data on this site and in our services. If we believe you need more specific details, we will provide them at the appropriate time, for example within forms, prompts, or notices at the point of collection. We are happy to answer any questions and will offer any clarifications permitted under applicable law. You can reach us by email at: info@blue-orion.com
Personal Data will be used solely for the purposes specified in this Policy.
Personal Data may be processed by us for a range of purposes, including providing the website to you and 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, meeting regulatory or legal obligations as applicable, and carrying out necessary 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.
Make use of essential tools to safeguard your rights with respect to Personal Data:
We want you to be able to make informed decisions about how your Personal Data is used and processed. That is why we created this website. To do so, we use a range of methods and procedures to share clear, relevant information about the use of Personal Data. If we determine you need more specific details, we will provide them at the appropriate time and place. We are also happy to answer any questions and to offer any clarifications you may need, subject to applicable legal limits. 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 will continue to implement a broad range of methods and safeguards to ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.
1. The Scope?
This Policy explains the types of Personal Data Company collects about natural persons and how we process it, share it with third parties, and keep it secure. 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 a combination of 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, organisation, and storage of Personal Data. Our services are intended for a general audience and are not designed for anyone under 18 years of age. We do not knowingly seek or collect information from individuals under 18, nor do we knowingly permit such individuals 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 Have About You?
When you use our services and channels or visit our website, we collect Personal Data. In certain situations, we may ask you to provide Personal Data. In others, we collect it by analysing your use of our Services and channels or by receiving information from our third-party partners.
3. No obligation to disclose personal information to the company; consider possible consequences.
You are not required to provide Us with any Personal Data. However, in certain circumstances, choosing not to do so may prevent Us from providing the Services or prevent users from accessing the Website.
4. What types of Personal Data can We collect? When you visit our website, We will collect the following Personal Data:
This includes details about your online activity log and traffic data (such as IP address and the date and time of access), the language you used, software crash logs, the type of browser, and information about the device you used. The information we collect is not 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 to 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, phone number, and email address.
5. Legal Basis and Reasons 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 valid legal basis, the Company cannot process your Personal Data. The legal bases on which the Company may process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more purposes. This applies when you submit personal information through 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 legitimate interests. For example, this may be necessary to improve our services or to establish, exercise, or defend legal claims.
- Processing must comply with a legal obligation.
Contact us by email for more information about the processing necessary to protect legitimate interests.
Below is a list of purposes and legal bases for the ways we may use the personal data you provide to us.
1. To provide your Personal Data to third parties at your request to enable access to digital trading.
If you request it, we may collect Personal Data from you to forward to third-party companies
You have provided consent to the processing of your Personal Data for one or more purposes.
2. To address your requests, questions, or concerns
We process Personal Data to respond to any inquiries you may have about the Services.
Processing is necessary for the Company’s legitimate interests or those of a third party.
3. To comply with legal, administrative, or judicial obligations, Personal Data is processed to meet applicable legal requirements.
Processing is required to ensure compliance with legal obligations.
4. To enhance Our Services
We may use Personal Data to enhance Our Services. This includes, among other things, analyzing crash and malfunction reports collected 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
Processing is necessary to pursue the legitimate interests of the Company or those of a third party.
6. To carry out and manage activities that comply with the requirements of Our Services
These activities include back-office operations, business development, strategic decision-making, governance and oversight, and related functions.
Processing is necessary to pursue the Company’s legitimate interests or those of a third party.
7. To carry out analyses, including statistical analyses
To make decisions on various matters, we employ a range of analytical techniques (including statistical techniques).
Processing is necessary to pursue the Company’s legitimate interests or those of a third party.
8. To safeguard our assets, rights, and interests, as well as those of third parties, we rely on HTML0 to establish and defend legal claims
We may process Personal Data to protect 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 to pursue 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-party companies that provide services to us, such as hosting and storage providers, as well as vendors that process IP address information and conduct user experience analytics.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In such cases, we will transmit the Personal Data you supply to us to those third-party trading 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 share Personal Data with affiliated entities or business partners, which helps provide the resources needed to enhance and improve the products and services we offer 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 Personal Data about you with potential investors or purchasers, or with lenders to the Company or any other company within our group, in connection with such transactions (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 group entity.
ONLINE TRACKING NOTICE
Third-party services, such as advertising partners on our website and analytics providers, may be used. These companies 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 behavior to enhance your user experience, remember your settings, and tailor products and services you might 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 only until you close your browser. Other cookies are persistent. Persistent cookies remain on your device after you close your browser. They help the website recognize you as a returning user and facilitate your return visits to the website.
7. Cookies and services provided by third parties
We may use them depending on 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 ask for.
They enable your device to download and stream data, allowing you to move around the site, use its features, and return to pages you’ve visited.
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 enable us to recognize you each time you visit our site and to save your settings and preferences.
Additional informationThey persist until their expiration date and remain stored even after the browser is closed.
Cookies for performance
ScopeWe use cookies to collect statistical data on site performance and to improve it. They also enable us to conduct analysis on our website.
Additional informationCookies may store anonymous data that is not linked to any identifiable natural person. You can delete them when you close your browser. Some cookies remain valid indefinitely.
Cookies are blocked or have been removed
To block or delete cookies, change your browser settings. Below are helpful links for several of the most widely used 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
We will retain your Personal Data for as long as necessary to fulfill 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 a period of 12 months. With your consent, we will continue sharing your data for an additional 12 months.
We regularly review the Personal Data we hold to confirm whether it remains necessary.
9. Transfers of personal data to a third country or an international organisation
Your personal information may be transferred to other countries—that is, to a third country (a country other than the one where you reside)—or to international organizations or jurisdictions. The Company takes all necessary measures to safeguard the Personal Data you provide and ensures that data subjects can exercise 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 an international organisation that the European Commission has found ensures 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 carried out under a legally binding and enforceable agreement between public authorities or bodies, in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. The European Commission’s adopted 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. Security of Your Personal Data
We have implemented appropriate organizational and technical measures to protect Personal Data, including preventing accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee or warrant that the security of your Personal Data will be error-free, nor can we be liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures resulting from transmission errors, unauthorized access by third parties, or other causes beyond our control.
Where required by law or by other obligations beyond our control, we may be compelled to provide your Personal Data to third parties, such as public authorities. We cannot control the level of protection those third parties afford your Personal Data in such circumstances.
No transfer of Personal Data over the internet is completely secure, and the Company cannot ensure the security of Personal Data you transmit to Us online.
11. Hyperlinks to third-party websites
The website may include links to third-party websites and applications. These sites and apps are not controlled or supervised by the Company. 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 on such sites or apps.
When you visit any third-party website or app, we recommend reading their privacy policies before deciding to access or use their services. We also suggest 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, we will notify you by posting the revised Policy on our website. When significant updates are made, we will also seek to inform you through appropriate channels 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 data
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 that are no longer required by us. You may also restrict 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 connection with your Personal Data. You can request to exercise your rights by sending an email to the address below. Access rights
The Company can confirm whether Personal Data about you are 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, where permitted by law. Upon request, the data will be made available electronically.
Your right of access must not conflict with the rights and freedoms of others. If a request would adversely affect another person’s rights and freedoms, the Company may refuse the request or limit its ability to fulfill it. Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to request that incomplete Personal Data concerning you be completed, taking into account the purpose of processing, including by providing a supplementary statement. Right to Erasure
You may request erasure where: (a) the Personal Data are no longer required 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, on grounds relating to your particular situation, to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data have been processed unlawfully; or (f) the Personal Data must be deleted to comply with the Company’s legal obligations. 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 are concerned about the accuracy of your Personal Data or other aspects of processing, you may ask the Company to restrict processing of your Personal Data. While 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 in 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 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 are also entitled to request that your Personal Data be transmitted directly by the Company to another controller, where technically feasible. Exercising the 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 Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is required for the establishment, exercise, or defense of legal claims.
For direct marketing, you have the right at any time to object to the processing of Personal Data concerning you, including profiling related to such marketing.
Right to withdraw consent
You may withdraw your consent for us to process 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 also appeal 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 Personal Data concerning you, as described in this Section 13. We will provide the information requested under your rights in Section 13 within one month of receiving your request. The timeframe may be extended by up to two months if necessary, depending on 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 contrary to Section 13, the information you request under these rights 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 administrative costs or decide not to act on the request.
If we have doubts about the identity of the person making the request, the Company may ask for additional information.
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