Privacy Policy
We (also referred to as 'We', 'Us' or 'Our') are committed to safeguarding your Personal Data and privacy.
This Privacy Policy outlines how we collect and store the information you provide through the Gaingate website (the 'Website').
We will uphold the following principles:
To clearly outline how we collect and process your personal information:
Our goal is to put you in a position to make well-informed choices about how your personal data is collected, used and processed. To achieve this, we’ve created this website to share clear, relevant details about our policies, standards and practices. We employ a variety of methods and procedures—monitoring updates, reviewing compliance and updating content—to keep you informed with accurate, timely information. Our team regularly reviews industry best practices to enhance our data protection measures. If you require further specifics, we’ll provide them as soon as they become available. We’re also happy to address your questions and clarify any legal constraints. You can reach us at info@blue-orion.com
Personal Data will be used solely for the purposes specified in the Policy.
Personal Data may be processed by us for various purposes, including providing the website and connecting you with third-party trading platforms (the “Services”); enhancing and securing the site; facilitating maintenance and delivery of the Services; fulfilling regulatory or legal obligations; and conducting administrative and business activities related to the Services. We also process Personal Data to better understand your preferences and needs.
To utilise robust tools to safeguard your Personal Data rights:
We want you to be fully informed about the use and processing of your Personal Data. That's why we've developed this website. Using a range of methods and procedures, we provide clear, up-to-date information about Personal Data handling. If you need further details, we'll supply them promptly at the right time. We're happy to answer any questions and clarify any legal limitations. You can reach us via email at info@blue-orion.com
Protect Your Personal Data:
While we cannot guarantee complete security of your Personal Data, we guarantee that we will continue to employ a variety of methods and techniques to ensure it remains protected. Our Privacy and Security Policy is comprehensive.
1. The Scope?
This policy outlines the categories of Personal Data the Company collects from natural persons and explains how we process that data, share it with third parties, secure our operations, and otherwise manage information. It applies to any data relating to identified or identifiable individuals—that is, persons who can be recognised directly or through other information we hold or can access. The policy defines “processing” as any action involving the use or collection of Personal Data, including its organisation, structuring, management, storage, and related activities, such as retention and logging procedures. Our services are intended for a broad audience and are not designed for individuals under the age of 18. We do not knowingly seek, collect, or permit access to our services by minors. If we become aware that we have inadvertently obtained Personal Data from a person under 18, we will promptly remove such information from our systems.
2. What Personal Data Do We Hold About You?
If you access our Services and channels or visit our website, we collect Personal Data. In certain circumstances, we may ask you to provide this data directly. Otherwise, we gather Personal Data by analysing your usage of our Services and channels or by obtaining information from our third-party partners.
3. There is no requirement to provide personal information to the company and no penalties for choosing not to do so.
You are not required to provide us with any personal data. However, if you withhold personal data in certain circumstances, it may prevent us from delivering our services or restrict users' access to 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 your online activity log; traffic data (including IP address, access date and time), the language used, software crash logs, browser type, and device information. This data is not private and cannot be used to identify you. Personal Data We receive from you: any personal data you provide voluntarily when connecting to a third-party online trading platform through us. Personal information you provide specifically to third-party platforms to facilitate trade: your full name, address, phone number, and email address.
5. The legal basis and underlying reasons 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 valid legal basis, the Company cannot use your personal data. The legal grounds on which the Company may process your personal data are:
- You have provided consent for 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 meet their legitimate interest, for example to improve Our Services or defend legal claims.
- Processing must comply with legal obligations.
Contact us by email for more information about the processing required to protect our legitimate interests.
Below is a list of reasons and legal grounds under which we may use the Personal Data you provide.
1. Provide your personal information to third parties at your request to access digital trading.
If you request it, we may obtain 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 required to respond to any enquiries you may have about the Services.
The Company’s legitimate interests, or those of a third party, must be processed.
3. To fulfil any administrative, judicial or other legal obligations, Personal Data is processed as necessary.
Processing is necessary to fulfil our legal obligations.
4. To enhance Our Services
We may use Personal Data to improve Our Services, including crash or malfunction reports we collect regarding the Services.
The legitimate interests of the Company, or those of a third party, must be processed.
5. To prevent fraud and misuse of Our Services
The Company’s legitimate interests, as well as those of a third party, must be processed.
6. To carry out and oversee tasks that comply with Our Services requirements
These tasks include back-office operations, business development initiatives, strategic decision-making, oversight processes, etc.
The Company’s legitimate interests or the interests of a third party must be processed.
7. We conduct analyses, including statistical analysis
and use various analytical techniques (including statistical methods) to guide decision-making on a range of issues.
The Company’s legitimate interests or the interests of a third party must be processed.
8. To protect our assets, rights and interests—and those of third parties—we have developed HTML0 to 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 compliance with any applicable laws, regulations or agreements, and any conditions, terms or policies.
The Company’s legitimate interests or the interests of a third party must be processed.
6. Personal Data Transfers to Third Parties
The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, for storing IP address information and analysing user experience.
You may also request that we disclose specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you have provided with those platforms. Any use of your Personal Data by these platforms is governed by their own privacy policies. Please note that your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners. This allows the Company to access resources needed to enhance and improve the products and services it offers to customers.
If necessary to protect the rights of third parties or to safeguard assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors, buyers, or lenders to the Company (or any other company in the group) in the event of a transaction (including the transfer or sale of the Company’s or another group company’s assets), or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any group business.
ONLINE TRACKING NOTICE
Third-party services, such as ad providers or analytics companies, may be engaged. These parties 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 habits to enhance your user experience, remember your settings and personalise products and services you may enjoy. Cookies also support statistical analysis and insights.
We use session cookies, which are temporarily downloaded to your device and expire when you close your browser. Persistent cookies remain on your device for a set period after you close your browser. They help the website recognise you as a returning user and allow you to revisit the site seamlessly.
7. Third-Party Cookies and Services
We may use them according to their purpose:
Cookies are essential
Cookies are essentialThese cookies are essential for accessing the features you’ve requested and navigating our website. They allow us to deliver the information, products and services you need.
They also enable your device to download and stream data, so you can move through the site, use its features and return to pages you’ve visited before.
Cookies gather personal data such as your username and last login date to verify you are signed into the site. They are deleted when you close your web browser (session cookies).
Functionality Cookies
ScopeCookies allow us to recognise you each time you visit our site and 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
ScopeCookies are used to collect statistical data on site performance and enhance its functionality. They also allow us to analyse user behaviour on our website.
Additional informationCookies store anonymous data that isn't linked to any identifiable individual. You can remove them by closing your browser. Other cookies remain valid indefinitely.
Cookies have been blocked or removed
To block or delete cookies, simply change your browser settings. Below are step-by-step instructions 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. The Retention of Your Personal Data
The Company retains Personal Data about you only for as long as is necessary to fulfil the purposes of processing Personal Data as described in this Policy, or for longer periods if required by law, regulation, policy or applicable orders. We share your information with third-party trading platforms for 12 months and, with your consent, will continue to do so for an additional 12 months.
We routinely review retained Personal Data to confirm it’s no longer needed.
9. Transfers of personal information to third-party countries or international organisations
Your personal information may be transferred to other countries (for example, to a third country other than your country of residence) or to international organizations or jurisdictions worldwide. The Company takes all necessary steps to safeguard the personal data you provide and to ensure you can exercise your rights and access effective legal remedies.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the European Commission has determined provides adequate security for Personal Data transferred to it under Article 45(3) of Regulation 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 under Article 46(2)(a).
- The transfer was carried out in compliance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR. These 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. Personal Data Security
We have implemented robust organisational and technical measures to safeguard Personal Data against accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee error-free security of your Personal Data and are not liable for any indirect, incidental, or consequential damages arising from its use or disclosure, including—but not limited to—transmission errors, unauthorised third-party access, or any events beyond our control.
If required by law or otherwise beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities, and cannot be responsible for their data security practices.
No data transfer over the Internet can be completely secure. The Company cannot ensure the safety of Personal Data you transmit to us online.
11. Hyperlinks to third-party websites
Links to third-party websites and applications on this website are provided for your convenience and are not supervised by the Company. We are not responsible for how these sites or apps collect or process your Personal Data. This Policy does not apply to activities conducted on such external platforms.
Before accessing or using any third-party service, we recommend reviewing its privacy policy and exercising caution when sharing your Personal Data.
12. Updates to This Policy
This Policy may be updated at any time. If we do so, we will notify you by posting the revised Policy on our website. For significant changes, we will also endeavour to inform you through the methods we consider appropriate and publish an announcement on our website. Unless explicitly specified, amendments take effect upon publication of the revised Policy.
Your rights regarding your personal information
You have the right to request verification of the accuracy of any Personal Data we hold about you, to correct any errors, or to delete any Personal Data that we no longer require. You may also restrict certain types of processing of your personal information. If you are an EEA resident, please refer to this page:
These rights apply to any information you have provided as Personal Data. To exercise your rights, please email us at the address below. Access rights
The Company can verify the Personal Data we are processing about you. Upon request, you may access your Personal Data. We will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be delivered electronically if requested.
Your right of access must not infringe on the rights and freedoms of others. If your request adversely affects the rights of another individual, the Company may refuse or limit the request. Right to rectification
The Company will correct any inaccurate Personal Data. You may request that we complete or update any incomplete Personal Data concerning you, taking into account the purposes of the processing. Right to Erasure
You may request the deletion of your Personal Data in the following circumstances: (a) the data are no longer necessary for their original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests pursued by us or a third party; (d) the data have been unlawfully processed; or (e) the data must be erased to comply with a legal obligation.
This right does not apply when processing is necessary (a) to comply with a legal obligation under EU or Member State law; or (b) to establish, exercise or defend legal claims. Processing restrictions
If you contest the accuracy of your Personal Data, you may request that the Company restrict its processing. During the restriction period, your Personal Data will only be processed with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or for reasons of substantial public interest in the EU or a Member State. Right to data portability
If the processing is based on your consent or a contract and carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format. You may also request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising this right does not affect your rights to erasure and must not infringe on the rights and freedoms of others. Right to challenge
You have the right to 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. If you object, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims. Concerning direct marketing
You have the right to object at any time to the processing of your Personal Data for direct marketing purposes. Right to refuse consent
You may withdraw your consent for us to process your Personal Data at any time. This will not affect the lawfulness of any processing carried out before you withdrew consent.
You also have the right to lodge a complaint with your supervisory authority.
You may appeal to a supervisory authority established by a Member State to safeguard individuals’ rights in relation to Personal Data processing within the EU. The laws of the European Union and Member States may limit your rights to Personal Data as described in this Section 13. We will respond to your request regarding your rights under Section 13 within one month of receipt. This period may be extended by up to two months depending on the complexity and number of requests. We will inform you of any extension and its reasons within one month of receiving your request.
Unless Section 13 of the law provides otherwise, information provided in response to your request will be free of charge. If your request is unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have any doubts regarding the identity of the individual making the request, the Company may request additional information.
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