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 be transparent about how we collect and process your personal information:
We want you to be able to make informed decisions about the collection, use, and processing of your Personal Data. That is why we created this website. To achieve this, we use a range of methods and procedures to provide you with clear, relevant information about how Personal Data is handled. If we believe you need specific details, we will share that information with you at the appropriate time. We are happy to answer any questions you may have and will provide any clarifications you require, subject to any limits imposed by law. You can reach us by email at the address below: info@blue-orion.com
Personal Data will only be used for the purposes set out in this Policy.
Personal Data may be processed by us for a range of purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory and legal obligations, and conducting administrative and business activities to support the Services. We also process Personal Data to better understand your preferences and needs.
To access essential tools to safeguard your rights regarding Personal Data:
We want you to be able to make informed choices about the collection, use, and processing of Personal Data. That’s why we created this website. To support this, we use a range of methods and processes to share clear, relevant information about how Personal Data is used and processed. If we believe you need more specific details, we’ll provide them to you at the appropriate time and in the appropriate format. We’re happy to answer any questions and will offer any clarifications you 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 complete security of your Personal Data, we can assure you that we will continue to use a range of measures and techniques to ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.
1. The Scope?
This Policy outlines the types of Personal Data the Company collects about natural persons and how it processes that data, shares it with third parties, and keeps it secure. This Policy concerns information relating to an identified or identifiable natural person. A natural person is identifiable if they can be identified directly or indirectly, alone or in combination with other information we hold or can access. This 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 general audiences and are not designed for anyone under 18 years of age. We do not knowingly collect or solicit information from anyone under 18 years old, nor do we knowingly permit such individuals to use our services. If we become aware of any information about children, we will delete it as soon as practicable.
2. What personal information do we hold about you?
When you use our Services and channels, or visit our website, we collect Personal Data. We may ask you to provide Personal Data in certain circumstances. We also collect Personal Data by analysing how our Services and service channels are used, or by receiving information from our third-party partners.
3. No obligation to provide personal information to the company and the potential consequences.
However, you are not obliged to provide Us with any Personal Data. In certain circumstances, you may choose not to supply Personal Data to Us. This could 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 Data:
This includes details of your online activity log, traffic data (including your IP address and the date and time of access), the language settings you used, software crash logs, the type of browser used, and information about the device you used. 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 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: this 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 set out in this section, and always in accordance with the applicable legal basis.
Without a valid legal basis, the Company is not permitted to use Personal Data about you. The legal grounds that permit the Company to lawfully process Personal Data relating to you are as follows:
- 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 require processing to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to defend against legal claims.
- Processing must comply with a legal obligation.
Contact us via email for more information about the processing required to protect our legitimate interests.
Below is a list of reasons and legal bases on 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 this, 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 respond to your requests, questions or concerns
We process your Personal Data as needed to address any enquiries you may have about the Services.
Processing is necessary for the legitimate interests of the Company or a third party.
3. To meet legal, administrative, or judicial obligations, Personal Data is processed to comply with 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, crash and malfunction reports we collect in connection with the Services.
Processing is necessary to pursue the legitimate interests of the Company or a third party.
5. To prevent fraud and misuse of our services
Processing occurs where necessary for the Company’s legitimate interests or those of a third party.
6. To carry out and oversee activities that align with the requirements of Our Services
These may include back-office operations, business development, strategic decision-making, governance and oversight mechanisms, etc.
Processing is necessary for the Company’s legitimate interests or those of a third party.
7. To conduct analyses, including statistical analyses
To inform decisions on various matters, we use a range of analytical techniques (including statistical ones).
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 have implemented measures to establish and defend legal claims
We may process Personal Data to safeguard our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations and agreements, and any relevant terms, conditions or policies.
Processing is necessary for the Company’s legitimate interests or those of a third party.
6. Transfer of Personal Data to Third Parties
The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, and with providers that process IP address information and analyse user experience.
You may also request that we provide specific Personal Data about you to third-party trading platforms. In such cases, we will share with those third-party platforms the Personal Data you provide to Us. Their use of your Personal Data is subject to their own 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, enabling the Company to access resources that help 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 your Personal Data with potential investors or buyers, or with lenders to the Company or any other company in 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 company within the group.
ONLINE TRACKING NOTICE
We may use third-party services, such as advertising providers on our website and analytics companies. These providers may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the website. They collect information about your preferences and browsing behaviour to improve your experience, remember your settings, and tailor products and services you may find useful. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies, which are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device for a period after you close your browser. These help the website recognise you as a returning user and make it easier to return to the site.
7. Cookies and Services from 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’ve requested and for navigating our website. We use cookies to deliver the information, products and services you’ve asked us for.
They enable your device to download and stream data, allowing you to move around the site, utilise its features, and return to pages you’ve previously 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 help us recognise you each time you visit our site and also remember your settings and preferences.
Additional informationThey remain active until their expiry date and are retained even after the browser is closed.
Cookies for performance
ScopeWe use cookies to collect statistical data about site performance and to help improve it. They also allow us to analyse usage on our website.
Additional informationCookies store anonymous data that is not linked to any identifiable natural person. Some are deleted when you close your browser; other cookies may remain until they expire.
Cookies are blocked or have been removed
To prevent or delete cookies, adjust your browser settings. Below are links to guide you through the process for a few 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 where permitted by law, regulations, policies, and applicable orders. We will share your information with third-party trading platforms for 12 months; if you consent, we will continue to share it for a further 12 months.
We regularly review the Personal Data we hold to ensure it is not kept longer than necessary.
9. Transfers of personal information to a third country or an international organisation
Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country—an additional 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 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 an 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 pursuant to a legally binding, enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
- The transfer was carried out in accordance with the European Commission's standard contractual clauses adopted under Article 46(2)(c) of the GDPR. These European Commission 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. Security of Personal Information
We have implemented appropriate organisational and technical measures to protect Personal Data. These measures help prevent the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant the error-free security of your Personal Data. Nor are we responsible 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 compelled to disclose your Personal Data to third parties, such as public authorities. We cannot control the safeguards applied to your Personal Data by third parties in these circumstances.
Personal Data cannot be transmitted over the internet with complete safety. The Company cannot ensure the security of Personal Data you transmit to Us via the internet.
11. Hyperlinks to websites owned or operated by third parties
Our website includes links to third-party websites and applications. These websites and applications are not controlled by the Company. We are not responsible for the collection or processing of Personal Data by these sites 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 policy before deciding to access or use their services. We also recommend that you review these policies before providing any Personal Data to them.
12. Changes to this Policy
This Policy may be updated at any time. If we revise this Policy, we will notify you by posting the updated version on our website. Additionally, when we make material changes to this Policy, we will seek to inform you through methods we consider appropriate, and we will publish an announcement on our website. Unless expressly stated otherwise, any amendments will take effect upon the publication of the revised Policy.
13. Your rights regarding your personal information
You are entitled to ask us to verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we do not need. You may also restrict 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. Access rights
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. If requested, 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 another person’s rights or freedoms, the Company may refuse or limit compliance. Right to rectification
The Company is entitled to correct inaccurate Personal Data. You are entitled to request that any incomplete Personal Data about you be rectified, taking into account the purposes of processing. Right to erasure
The following reasons apply: (a) Personal Data is no longer required 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 your Personal Data based on legitimate interests pursued by us or a third party; (e) Personal Data has been processed unlawfully; or (f) Personal Data must be deleted to comply with the Company’s legal obligations. This right does not apply where processing is necessary (a) to meet a legal obligation under European Union or Member State law, or (b) for the establishment, exercise, or defence of legal claims.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you can ask the Company to limit its processing. Where processing is restricted, Personal Data may be retained 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 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 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 transferred directly by the Company to another controller, where technically feasible. Exercising data portability does not alter your right to erasure and must not prejudice the rights or freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on legitimate interests pursued by the Company or a third party, including profiling on that basis. Unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims, we will cease such processing.
For direct marketing, you have the right at any time to object to the processing of your Personal Data.
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 have the right to lodge a complaint with your supervisory authority.
You may also appeal to 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 restrict your rights regarding your Personal Data, as detailed in 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 if necessary, depending on the complexity and number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Unless section 13 provides otherwise, information provided in response to your section 13 rights will be supplied free of charge. If a request is unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs or decline to act.
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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