Privacy Policy
We (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 uphold the following principles:
To ensure transparency about how we collect and process your personal information:
We want you to be able to make informed choices about the use and processing of your Personal Data. That’s why we created this website. To achieve this, we use a range of methods and procedures to provide you with relevant, timely information about how Personal Data is used. If we believe you require specific details, we will share them with you at the appropriate time. We are pleased to answer any questions you may have and will provide any clarifications permitted by law. You can reach us by email at: info@blue-orion.com
Personal Data will be used solely for the purposes described 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, ensuring the security and integrity of our systems, protecting our rights and legitimate interests, facilitating the maintenance and provision of the Services, meeting regulatory or legal obligations, and carrying out administrative and business activities that support the ongoing delivery and effective use of the Services. We also process Personal Data to better understand your preferences and needs.
Use these essential tools to protect your rights regarding your Personal Data:
We want you to be able to make informed decisions about the use and processing of your Personal Data. That’s why we created this website. To support this, we use various technical and organizational methods and procedures to provide you with relevant information about how Personal Data is used. If we believe you need specific details, we’ll share them with you at the appropriate date and time, whenever it is relevant. We’re happy to answer any questions and offer any clarifications you may need, subject to any limitations imposed by law. You can reach 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 remain committed to continually employing a range of safeguards and practices to keep your Personal Data protected. Our Privacy and Security Policy is comprehensive.
1. The Scope?
This Policy explains the types of Personal Data Company collects from natural persons, how we process it, share it with third parties, and protect it through appropriate security processes. It concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly in combination with other 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, organization, and storage of such data. Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly collect information from anyone under 18 or allow such individuals to use our services. If we learn that we have collected information about a child, we will delete it as promptly as possible.
2. What Personal Data Do We Have 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 it by analysing how you use our Services and channels, or by receiving information about you from our third-party partners.
3. There is no obligation to disclose personal information to the company and any consequences.
However, you are not required to provide Us with any Personal Data. In certain circumstances, you may choose not to share any Personal Data with Us. This could prevent Us from providing the Services or could restrict 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 about your online activity log and traffic data (including your IP address, the date and time of access), the language you use, software crash logs, the type and version of the 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 information 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 typically includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing 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 legal basis, the Company cannot use Personal Data concerning you. The legal grounds that allow the Company to process your Personal Data are:
- You have provided consent to the processing of your Personal Data for one or more purposes. For example, 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 might require processing to pursue legitimate interests. For example, this may be needed to improve Our Services or to defend legal claims
- Processing must comply with a legal obligation.
Contact us by email for more information about the processing required to protect 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 ask us to, we may request 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
We require Personal Data to address any inquiries you may have regarding the Services.
Processing is necessary for the Company's legitimate interests or those of a third party.
3. To meet all legal, administrative, judicial, or regulatory obligations, Personal Data is processed to comply with applicable requirements.
Processing is necessary to ensure compliance 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 we collect related to 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 for the legitimate interests of the Company or a third party.
6. To carry out and oversee activities that comply with the requirements of Our Services
This includes back-office operations, business development, strategic decision-making, governance and oversight processes, etc.
Processing is necessary for the legitimate interests of the Company or those of 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 methods).
Processing is necessary for the legitimate interests of the Company or those of a third party.
8. To protect our assets, rights, and interests, as well as those of third parties, we may pursue, establish, and defend 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 legitimate interests of the Company or those of a third party.
6. Transfer of Personal Information 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, IP address-related services, and user experience analytics.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these cases, we will transfer the Personal Data you provide 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 affiliated entities or business partners to obtain the resources needed to enhance and improve the products and services we offer our customers.
When necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory, municipal, or other governmental authorities.
We may also share your Personal Data with prospective investors or purchasers, or with lenders to the Company or any other company in our group, if a similar 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 partners on our website or analytics providers. These third parties may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the website. We use cookies to collect information about your preferences and browsing to enhance your experience, remember your settings, and tailor products and services you may find useful. Cookies are also used for statistical and analytics purposes.
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 your browser is closed. They help the Website recognize you as a returning user and make it easier to navigate back to the site.
7. Third-Party Cookies and Services
We may use them in line with their purpose:
Cookies are strictly necessary
Cookies are strictly necessaryThese cookies are essential for you to access the features you’ve requested and to navigate our website. We use cookies to deliver the information, products, and services you have asked for.
They are necessary for your device to download and stream data, allowing you to move around the site, use its features, and return to pages you visited before.
Cookies collect personal data, such as your username and last login date, to confirm 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 whenever you visit our site and to save your settings and preferences.
Additional informationThey persist until their expiry date and remain stored even after the browser is closed.
Cookies for performance
ScopeCookies are used to collect statistical data about the site's overall performance and to help further improve it. They also allow us to perform analytics on our website.
Additional informationCookies store anonymous data that is not linked to any identified or identifiable natural person. Some are removed when you close your browser, while others may remain indefinitely.
Cookies appear to be blocked or removed
To block or remove cookies, please update your browser's settings. Below are links to guide you through the steps 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 a period of 12 months. With your consent, we will continue to share your data for an additional 12 months.
We regularly review the Personal Data we hold and delete it when it is no longer needed.
9. Transfers of personal information to a third country or an international organization
Your personal information may be transferred to other countries—that is, it may be sent to a third country (a country other than the one where you reside) or to international organizations or jurisdictions. Company takes all necessary steps to safeguard the Personal Data you provide and to ensure individuals 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 international organization 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 made pursuant to a legally binding and enforceable instrument between public authorities or bodies under Article 46(2)(a).
- The transfer was conducted in accordance with the European Commission's Standard Contractual Clauses adopted under Article 46(2)(c) of the 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 Information
We have implemented appropriate organizational and technical measures to protect Personal Data, including 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 maintained without error, and we are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, disclosures caused by transmission errors, unauthorized access by third parties, or any other events beyond our control.
Where required by law or by other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot control the safeguards those third parties apply to your Personal Data 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 over 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 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 through such sites or apps.
When you visit any third-party site or app, we recommend reviewing their privacy policies before deciding to access or use them. 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 occur, we will also try to inform you using methods we deem appropriate and will publish a notice on our website. Unless stated otherwise, all 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, correct any errors, and delete any Personal Data that is not required by Us. You may also limit the scope or types of processing performed on 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 them by sending an email to the address below. Access rights
The Company can confirm whether your Personal Data 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. The data will be provided electronically if you request it. In addition to a copy, you may obtain information about the purposes of processing, the categories of Personal Data concerned, recipients or categories of recipients, retention periods, the source of the data (where not collected from you), and the existence of automated decision-making, including profiling, and meaningful information about the logic involved.
Your right of access must not conflict with the rights and freedoms of others. If your request would adversely affect another person’s rights or freedoms, the Company may refuse to comply or may limit its response. Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be completed, taking into account the purposes of the processing. Where reasonable, we may ask you to provide supporting documentation, and, where feasible, we will notify relevant recipients of corrections. Right to erasure
The following grounds apply: (a) Personal Data are no longer needed 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 and for reasons related to your particular situation, to processing based on legitimate interests pursued by Us or a third party; (e) Personal Data have been processed unlawfully; or (f) Personal Data must be deleted 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) to establish, exercise, or defend legal claims. Where appropriate, we will take reasonable steps to inform other controllers processing the data of your erasure request.
Processing restrictions
If you question the accuracy of your Personal Data, you may ask the Company to restrict its processing. You may also request restriction where processing is unlawful and you oppose erasure, where the Company no longer needs the data but you require it for legal claims, or where you have objected to processing pending verification of overriding legitimate grounds. Where processing is restricted, Personal Data may be kept 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 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 in a structured, commonly used, and machine-readable format.
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. 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. Unless we demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or the processing is for the establishment, exercise, or defense of legal claims, we will cease such processing.
With respect to direct marketing, you have the right to object at any time to the processing of your Personal Data, including profiling to the extent it relates to direct marketing.
Right to withdraw consent
You may withdraw your consent for Us to process Personal Data about you at any time. This will 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 individuals’ fundamental rights regarding the processing of Personal Data within the European Union, typically in your place of habitual residence, place of work, or place of the alleged infringement.
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 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 where necessary, taking into account 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. If we are unable to act on your request, we will provide reasons for not taking action.
Unless otherwise provided in section 13, information provided in response to your requests under section 13 will be supplied free of charge. If a request is manifestly unfounded or excessive, particularly due to its repetitive character, 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 individual making a request, the Company may ask for additional information.
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