Privacy Policy
We (referred to as 'we', 'us', or 'our') are committed to safeguarding your Personal Data and protecting 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 uphold the following principles:
To ensure transparency about how your personal information is collected and processed:
Our goal is to help you make informed decisions about the collection, 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, clear information on how Personal Data is handled, including timely notices and in-context explanations. If more specific details are needed, we will provide them at the appropriate date and time. We are available to answer any questions you may have and to provide any clarifications you require, subject to applicable legal limitations. You can reach us by email at the address below: info@blue-orion.com
Personal Data will be used solely for the purposes outlined in the Policy.
Personal Data may be processed by us for a variety of purposes, including providing the website to you and connecting you with third-party trading platforms (the “Services”), enhancing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, complying with legal and regulatory obligations, and performing administrative and business activities that support the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.
To access essential tools designed to safeguard your rights regarding Personal Data:
We want to put you in a position to make informed decisions about the use and processing of Personal Data. This is why we created this website. To achieve this, we use a variety of methods and procedures to provide clear, relevant information about the use of Personal Data. If we determine you need specific details, we will share them with you at the appropriate time. We are happy to answer any questions and provide any clarifications, subject to any limitations imposed by applicable law. You can reach us via email at: info@blue-orion.com
Protect Your Personal Data:
While we cannot guarantee the absolute security of your Personal Data, we can assure you that we will continue to employ a variety of methods and techniques 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, how it processes and shares it with third parties, and the security measures applied, among other matters. 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 additional information we hold or can access. The 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 the age of 18. We do not knowingly seek or collect information from individuals under 18, nor do we knowingly allow such persons to use our services. If we learn 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 channels or visit our website, we collect Personal Data. In some cases, we may ask you to provide Personal Data. In others, we collect Personal Data by analysing how you use our Services and channels, or by receiving information about you from our third-party partners.
3. No obligation to disclose personal data to the company and associated consequences.
But you are not required to provide Us with any Personal Data. However, in some cases, choosing not to do so may prevent Us from providing the Services or may limit users' access to the website.
4. What types of Personal Data can we collect? When you visit our website, we may collect the following personal information:
This includes details of your online activity log, traffic data (including IP address, date and time of access), the language you use, software crash logs, the browser type, and information about the device you use. 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 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 outlined 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 that allow the Company to process your Personal Data are:
- You have consented to the processing of your Personal Data for one or more purposes. This applies, for example, when you submit Personal Data through the Website so that we can transfer it to a third-party trading platform.
- The Company or third parties may process data to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to establish, exercise, or defend legal claims.
- Processing is necessary to comply with a legal obligation.
Contact us via 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 information you provide to us. Personal Data.
1. To share your personal data with third parties at your request to enable access to digital trading.
If you request it, we may collect Personal Data from you to transmit 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 inquiries you may have regarding the Services.
Processing is necessary for the legitimate interests of the Company or those of a third party.
3. To comply with legal, administrative, or judicial obligations, Personal Data is processed to satisfy applicable legal requirements.
Processing is necessary to ensure compliance with legal obligations.
4. To improve Our Services
We may use Personal Data to improve Our Services, including, among other things, crash and malfunction reports we collect in connection with the Services.
The processing is necessary to pursue the legitimate interests of the Company or 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 a third party.
6. To perform and manage activities consistent with the requirements of Our Services
These activities include back-office functions, business development activities, strategic decision-making, and oversight mechanisms, etc.
Processing is necessary for the Company’s legitimate interests or those of a third party.
7. To perform analyses, including statistical analyses
To make decisions on various matters, we apply a range of analytical techniques (including statistical methods).
Processing is necessary for 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 may establish and defend legal claims
Personal Data may be processed by us to protect 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, providers that process IP address information, and user experience analytics providers.
You may also ask us to share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you give 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 also share Personal Data with affiliated entities or business partners. This helps the Company secure the resources needed to 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.
Additionally, we may share your Personal Data with potential investors, purchasers, or lenders of 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 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 or analytics companies. These providers may also use cookies or other 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 habits to enhance your user experience, remember your settings, and tailor products and services you may enjoy. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. They are temporarily stored on your device and last only for a short time 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 recognize 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’ve requested and for navigating our website smoothly. We use them to deliver the information, products, and services you have requested from us.
They enable your device to reliably download and stream data. This allows you to move around the site, use its features, and easily return to pages you’ve visited before during your session.
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 recognize you whenever you visit our site and enable us to remember your preferences and settings.
Additional informationThey persist until their expiry date and remain stored even after the browser is closed.
Cookies for performance
ScopeWe use cookies to collect statistical data on the site's performance and to improve it. They also allow us to perform analytics on our website.
Additional informationCookies store anonymous data that is not associated with any identifiable or identified natural person. They can be removed when you close your browser. Other cookies can have indefinite validity.
Cookies are blocked or have been removed
To manage or delete cookies, you’ll need to adjust your browser settings. Below are links with step-by-step guidance for several of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
ONLINE TRACKING NOTICE This service does not currently respond to Do Not Track signals.
8. Retention of your personal data
The Company 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. If you agree, we will continue to share your data for an additional 12 months.
We regularly review the Personal Data we hold to ensure that it is no longer needed.
9. Transfers of personal data to third countries or international organisations
Your personal information may be transferred to other countries, meaning it may be sent 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 protect the Personal Data you provide and to ensure 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 determined 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 made under a legally binding and enforceable instrument between public authorities or bodies pursuant to 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. The clauses adopted by the European Commission 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 appropriate organizational and technical measures to protect Personal Data, including preventing accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be error-free, nor can we be responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure caused by transmission errors, unauthorized third-party access, or other events beyond our control.
If required by law or by other obligations beyond our control, we may be compelled to disclose your Personal Data to third parties, such as public authorities. We cannot control the level of security applied to your Personal Data by third parties in such cases.
Personal Data cannot be transmitted over the internet with complete security. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.
11. Hyperlinks to third-party websites and online services
Links to third-party websites and applications are provided on this website for your convenience. These websites and apps are not under the Company’s supervision or control. We are not responsible for the collection or processing of Personal Data by these third-party services. This Policy does not apply to activities carried out through such sites or apps.
When you visit any third-party website or app, we recommend that you review its privacy policy before deciding to access or use it. We also advise doing so before providing any Personal Data to those services.
12. Changes to this Policy
This Policy may be updated at any time and without prior notice. If we do so, we will notify you by posting the revised Policy prominently on our website. In the event of material changes to this Policy, we will also seek to inform you through the channels we deem appropriate and will publish a notice on our website. Unless expressly stated otherwise, any amendments will take effect upon publication of the updated Policy.
13. Your rights concerning your personal data
You are entitled to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data that is not required by us. You may also restrict certain types or the scope 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 may request to exercise the rights you have by sending an email to the address below. Access rights
The Company can verify the accuracy of the Personal Data being processed about you. Where processing occurs, you may access your Personal Data. The Company will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you request it.
The 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 the request or limit its scope. Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to require that incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to Erasure
The following reasons 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 by a third party; (e) Personal Data have been processed unlawfully; or (f) Personal Data must be deleted to comply with the Company’s legal obligation. 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.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. While restricted, Personal Data may be retained only with your consent, to establish, exercise, or defend legal claims, to protect the rights of another natural person, or for 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 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 transmitted directly by the Company to another controller, where technically feasible. Your right to erasure is not affected by exercising data portability, and portability must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on the Company’s or a third party’s legitimate interests, including profiling based on those legitimate interests. We may continue processing only if we can demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or where processing is necessary to establish, exercise, or defend legal claims.
Concerning 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 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 laws 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 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.
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 if repetitive, we may charge a reasonable fee to cover administrative costs or refuse 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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