Privacy Policy
We ('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 is why we created this website. To support this, we use various methods and procedures to share relevant information about how Personal Data is used and processed. If we believe you need specific details, we will provide them at the appropriate time and in the appropriate context. We are happy to answer any questions you may have and to provide any clarifications you require, subject to any legal restrictions. You can reach us by email at the address below: info@vlug-bitline.com
Personal Data will be used solely for the purposes outlined in this Policy.
We may process Personal Data for various purposes, including to provide the website, connect you with third-party trading platforms (the 'Services'), enhance the site, protect our rights and interests, facilitate the maintenance and provision of the Services, comply with legal and regulatory obligations, and conduct 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.
Make use of essential tools to safeguard your rights regarding Personal Data:
Processing is necessary to pursue the Company’s legitimate interests or those of a third party.
Protect Your Personal Data:
While we cannot guarantee the complete security of your Personal Data, we can guarantee 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 explains the types of Personal Data the Company collects about natural persons and how we process it, share it with third parties, and protect it. This Policy 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 additional information we hold or can access. The Policy defines 'processing' as any operation involving Personal Data, including its collection, use, management, structuring, and storage. Our services are intended for a general audience and are not designed for individuals under 18. We do not knowingly solicit or collect information from anyone under 18 years of age, nor do we knowingly permit such individuals to use our services. If we become aware that we have 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 or channels, or visit our website, we collect Personal Data. In some cases, 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 and the potential consequences.
You are not required to provide Us with Personal Data. However, in certain situations, choosing not to do so may prevent Us from providing the Services or may restrict users' ability to access the website.
4. What types of Personal Data can we collect? When you visit our website, we may collect the following personal information about you:
This includes details about your online activity log, traffic data (including your IP address and the date and time of access), the language you use, software crash logs, the type of browser used, 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 with 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, telephone number, and email address.
5. The 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 line 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 given 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 need to process data to pursue legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
- Processing must comply with a legal obligation.
Contact us via email for additional details about processing that is necessary to pursue our 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 data with third parties at your request to enable access to digital trading.
If you ask, we may request Personal Data from you to share with 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
We require Personal Data to respond to any inquiries you may have about the Services.
Processing is necessary to pursue the Company’s legitimate interests or those of a third party.
3. To comply with any legal, administrative, or judicial obligations, Personal Data is processed to meet the applicable requirements.
Processing is necessary to comply with legal obligations.
4. Improving Our Services
We may use Personal Data to enhance Our Services. This includes, among other things, analyzing crash or malfunction reports we collect in connection with the Services.
Processing is necessary for the Company’s legitimate interests 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 a third party.
6. To carry out and manage activities that comply with the requirements of Our Services
Such activities include back-office operations, business development, strategic decision-making, 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 make decisions on various matters, we employ 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 protect our assets, rights, and interests, as well as those of third parties, we have established measures to pursue 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, 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 companies that provide services to us, such as hosting and storage providers, IP address information services, and user experience analytics.
You may also request that we disclose specific Personal Data about you to third-party trading platforms. In such cases, we will provide the Personal Data you supply to us to those third-party trading platforms. The use of your Personal Data is subject to 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. This helps provide the resources the Company needs to enhance and improve the products and services it offers its 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.
Additionally, we may share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company in the group, if such a transaction occurs (including the transfer or sale of assets of the Company or any other company within the group) 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 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 habits to improve your user experience, remember your settings, and tailor products and services to your interests. 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, ending when 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 for you to return to the site.
7. Cookies and third-party services
We may use them based on their intended purpose:
Cookies are strictly necessary
Cookies are strictly necessaryThese cookies are essential to access the features you request and to navigate our website. We use them to deliver the information, products, and services you have asked for.
They are necessary for your device to download and stream data. This enables you to browse the site, use its features, and return to pages you visited earlier.
Cookies collect personal data, such as your username and last login date, to verify that you are logged in to the site. They are deleted when you close your web browser (session cookies).
Functionality Cookies
ScopeCookies allow us to recognize you each time you visit our site and to save your settings and preferences.
Additional informationThey remain active until the expiry date and persist even after the browser is closed.
Cookies for performance
ScopeWe use cookies to gather statistical data on the site's performance and to help enhance it. They also allow us to carry out analysis on our website.
Additional informationCookies may store anonymous data that is not linked to any identified or identifiable natural person. They can be deleted when you close your browser. Other cookies may remain valid indefinitely.
Cookies are blocked or have been removed
To block or delete cookies, adjust your browser settings. Below are links with instructions for several major 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
The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing, as described in this Policy, or for longer periods as permitted by law, regulations, internal policies, and applicable orders. We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue to share your data for another 12 months.
We regularly review the Personal Data we retain to ensure it is no longer needed.
9. Transfers of personal data to a third country or an international organisation
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. Company takes all necessary steps to safeguard the Personal Data you provide and ensures that you can exercise your rights and obtain 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 carried out under a legally binding and enforceable agreement between public entities or authorities pursuant to Article 46(2)(a).
- The transfer was carried out in accordance with the European Commission’s standard data protection 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. Protection of Personal Data
We have taken appropriate organisational and technical measures to protect Personal Data. This includes preventing accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee that the security of your Personal Data will be error-free. We also cannot be held 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 other causes beyond our control.
In the event of legal obligations or other circumstances beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. We cannot control the security afforded to your Personal Data by third parties in these situations.
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 through the internet.
11. Hyperlinks to websites operated by third parties
This website includes links to third-party websites and applications. These sites and apps are not under the Company’s supervision. We are not responsible for the collection or processing of Personal Data by these third parties. This Policy does not apply to activities carried out on such sites or apps.
When you visit any third-party website or app, We recommend that you read its privacy policy before deciding to access or use it. We also suggest that you do so before providing any Personal Data to them.
12. Updates to this Policy
This Policy may be updated at any time. If we change this Policy, we will notify you by posting the updated Policy on our website. In addition, when we make significant changes to this Policy, we will seek to inform you through the methods we deem appropriate and will publish an announcement on our website. Unless expressly stated otherwise, amendments will take effect upon publication of the revised Policy.
13. Your rights concerning your personal data and privacy
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 the types or scope of processing of your Personal Data. If you are a resident of the EEA, please refer to this page:
These rights are available to you with respect to the information you provide regarding your Personal Data. You can request to exercise your rights by emailing the address below. Right of access
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 any additional copies. If requested, the data will be provided electronically.
The right of access must not infringe the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another person, 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 purposes of processing. Right to erasure
You may request erasure of your Personal Data when: (a) the Personal Data is no longer needed for the purposes for which it was collected or processed; (b) you withdraw consent and no other legal basis applies; (c) you object, 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) the Personal Data has been processed unlawfully; or (f) the 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.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If processing is restricted, Personal Data may be retained 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 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 are also entitled to request, where technically feasible, that your Personal Data be transmitted directly by the Company to another controller. Exercising your right to data portability does not affect your right to erasure. The right to portability must not adversely affect the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of your Personal Data based on the legitimate interests pursued by the Company or a third party, including profiling based on those interests. Unless we 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, we will cease such processing.
Concerning direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
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.
The laws of the European Union and Member States may limit your rights in relation to your Personal Data, as described in section 13. We will provide information in response to your requests under section 13 of this agreement within one month of receipt. This period may be extended by up to two further months where necessary, depending on 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.
Unless otherwise provided in section 13, information provided in response to your rights under section 13 will be supplied free of charge. If a request is manifestly unfounded or excessive, particularly due to repetition, 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 person making the request, the Company may request additional information.
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