Privacy Policy
We (referred to as 'We', 'Us', or 'Our') are committed to protecting your Personal Data and your privacy.
This Privacy Policy is intended 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 we collect and process your personal information:
We want you to be able to make informed choices about the use and processing of Personal Data. That is why we created this website. To that end, we use various methods and procedures to provide you with relevant information about how Personal Data is used. If we believe you need specific details, we will provide them at the appropriate time. We are happy to answer any questions and will offer any clarifications you require, subject to any legal limitations. You can reach us by email at: info@brilho-gainetra.com
Personal Data will be used solely for the purposes outlined 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"), enhancing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, meeting regulatory or legal obligations, and conducting administrative and business activities to support the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.
To make use of essential tools to protect your rights regarding Personal Data:
Processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party.
Protect Your Personal Data:
Although we cannot guarantee the absolute security of your Personal Data, we remain committed to continually applying a range of measures and safeguards to keep your Personal Data protected. Our Privacy and Security Policy is comprehensive.
1. The Scope?
This Policy describes the types of Personal Data the Company collects from natural persons and how we process it, share it with third parties, and secure 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 additional information we hold or can access. The Policy defines 'processing' as any operation that involves the use or collection of Personal Data, including the organisation, management, structuring, and storage of Personal Data. Our services are intended for a general audience and are not designed for individuals under 18. We do not knowingly seek or collect information from anyone under 18, nor do we knowingly permit such individuals to use our services. If we become aware that we have collected information about children, we will delete it as promptly as possible.
2. What Personal Data Do We Hold About You?
If you access our Services and channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain situations. In other cases, we collect your Personal Data by analysing how you use our Services and service channels, or by receiving your information from our third-party partners.
3. No obligation to provide personal information to the company and the related consequences.
However, you are not required to provide Us with any Personal Data. In certain circumstances, if you choose not to share such data, it may prevent Us from delivering the Services or limit 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:
This includes details about your online activity log, traffic data (such as IP address and the date and time of access), the language you use, software crash logs, the type of browser, and 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 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 information may include your full name, address, phone 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 set out in this section, and in accordance with the applicable legal basis under law.
Without a valid legal basis, the Company is not permitted to use your Personal Data. The legal bases on which the Company may rely to process your Personal Data are:
- 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 need to process data to pursue their legitimate interests. For example, to improve Our Services or to establish or defend legal claims.
- Processing is necessary to comply with a legal obligation.
Contact us by email for more information about the processing required to protect our legitimate interests.
Below is a summary of the purposes and legal bases on which we may use the information you provide to us. Personal Data.
1. To share your personal information with third parties at your request to facilitate access to digital trading.
If you request it, we may ask you for Personal Data to pass on to third-party companies
You have given your consent to the processing of your Personal Data for one or more purposes.
2. To respond to your requests, questions, or concerns
Personal Data is required to help us address any inquiries you may have about the Services.
Processing is necessary for the purposes of the legitimate interests pursued by the Company or a third party.
3. To comply with legal, administrative, or judicial obligations, Personal Data is processed to meet applicable legal requirements.
Processing is necessary for compliance with a legal obligation.
4. To enhance Our Services
We may use Personal Data to enhance Our Services, including, among other things, any crash or malfunction reports we collect in relation to the Services.
Processing is necessary to pursue the Company's legitimate interests or those of a third party.
5. To prevent fraud and misuse of Our Services
Processing is necessary for the purposes of the Company's legitimate interests or those of a third party.
6. To carry out and manage activities that comply with the requirements of Our Services
These activities include back-office operations, business development, strategic decision-making, and oversight mechanisms, among others.
Processing is necessary to pursue the Company's legitimate interests or those of a third party.
7. To conduct analyses, including statistical analyses
To support decision-making on various issues, we apply a range of analytical techniques (including statistical methods).
Processing is necessary to pursue 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
Personal Data may be processed by us to safeguard our rights, interests, and assets, or those of third parties, in compliance with applicable laws, regulations, agreements, and relevant terms, conditions, or policies.
Processing is necessary to pursue 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, processing of IP address information, and user experience analytics.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you provide to Us with those third-party 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, enabling the Company to access 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 competent authorities.
We may additionally share your Personal Data with potential investors, buyers, or lenders of the Company or any other company within 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 business within the group.
ONLINE TRACKING NOTICE
We may use third-party services, such as advertising providers on our website or analytics companies. These partners 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 behavior to enhance your experience, remember your settings, and tailor products and services you may enjoy. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and expire 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 to return to the site.
7. Third-party cookies and services
We may use them according to their intended 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 them to deliver the information, products, and services you have asked for.
They enable your device to download and stream data. This allows you to move around the site, use 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 enable us to recognize you each time you visit our site and to remember your settings and preferences.
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 enable us to conduct analysis on our website.
Additional informationCookies 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 removed
To block or delete cookies, adjust your browser settings. Below are links to guide you through the steps for several popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
ONLINE TRACKING NOTICE This service does not currently honor Do Not Track signals.
8. Retention of personal data about You
The Company will retain your Personal Data only for as long as necessary to fulfil the purposes of processing, as set out in this Policy, or for longer periods where 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 consent, we will continue to share it for a further 12 months.
We regularly review the Personal Data we hold to confirm that it is no longer required.
9. Transfers of personal data to a third country or to an international organisation
Your personal information may be transferred to other countries (i.e., to a third country, meaning a country other than the one in which you reside, or to international organizations) or other jurisdictions. Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data subjects can assert their rights and access effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).
- Transfer to a third country or 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, 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 clauses are available 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 organisational and technical measures to protect Personal Data. These measures aim to prevent 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. We also cannot be held liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosure resulting from transmission errors, unauthorised third-party access, or any other cause beyond our control.
In the presence of legal or other obligations beyond our control, we may be required to disclose Personal Data about you to third parties, such as public authorities. We cannot control the level of security applied to your Personal Data by third parties in such circumstances.
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 via the internet.
11. Hyperlinks to websites operated by third-party providers
Links to third-party websites and applications are provided on our website. 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 actions taken on such sites or apps.
When visiting any third-party website or app, we recommend that you read their privacy policies before deciding to access or use those services, and 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. Additionally, when we implement significant updates to this Policy, we will attempt to inform you through the methods we deem appropriate and will publish a notice on our website. Unless explicitly stated otherwise, any amendments will take effect upon publication of the updated Policy.
13. Your rights regarding your personal data
You are entitled to ask us to verify the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data that we do not require. 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 them by emailing the address below. Access rights
The Company can verify whether Personal Data about you are 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.
Your right of access must not conflict with the rights and freedoms of others. If a request would adversely affect another person’s rights and freedoms, the Company may refuse to comply or limit its response. Right to rectification
The Company is required to rectify inaccurate Personal Data. You have the right to require that incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to Erasure
This applies where: (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, on grounds relating to your particular situation, to processing of Personal Data based on legitimate interests pursued by us or a third party; (e) Personal Data have been processed unlawfully; or (f) Personal Data must be erased 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) for the establishment, exercise, or defence of legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may ask the Company to restrict processing of your Personal Data. If processing is restricted, Personal Data may be stored 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 have provided to the Company.
You also have the right to request that your Personal Data be transmitted directly from 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 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 rights, freedoms, or interests, or the establishment, exercise, or defence of legal claims, we will cease such processing.
For direct marketing, you have the right to object at any time to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent for us to process 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 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 limit your rights regarding your Personal Data, as set out in section 13. We will provide the information requested under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months where 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 for it.
Unless otherwise provided under section 13, the information you request under section 13 will be provided free of charge. If a request is unfounded or excessive, particularly if repeated, 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 reasonable doubts about the identity of the person making the request, the Company may ask for additional information.
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