We (also referred to as 'We', 'Us', or 'Our') are committed to protecting your personal data as well as your privacy.
This Privacy Policy is intended to explain the ways in which we collect and store the information you provide through the Gaingate website (the 'Website').
We uphold the following principles:

To maintain transparency about how your personal information is collected and processed:

We want you to be able to make informed choices about how your Personal Data is used and processed. That is why we created this website. To support this, we use various methods and procedures to provide you with relevant information about the use of Personal Data. If we believe you need specific details, we will share them with you at the appropriate time. We are happy to answer any questions and to provide any clarifications you may need, subject to applicable legal limitations. You can reach us by email at: info@vasto-gainlux.com

Personal Data will be used solely for the purposes described 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'), improving the site, protecting our rights and interests, maintaining and delivering the Services, complying with legal or regulatory obligations, and performing administrative and business operations that support the provision and use of the Services. We also process Personal Data to better understand your preferences and needs.

To access key tools that safeguard your rights regarding Personal Data:

Processing is necessary to pursue the Company's legitimate interests or those of a third party.

Safeguard Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we assure you that we will continue to apply a range of measures and safeguards to keep your Personal Data 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 secure it. It concerns information relating to an identified or identifiable natural person—someone who can be identified directly or indirectly through information we hold or can access. The Policy defines “processing” as any operation involving Personal Data, including collection, management, structuring, and storage. Our services are intended for general audiences and are not designed for individuals under 18. We do not knowingly collect information from anyone under 18 or allow such individuals to use our services, and if we become aware of such data, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you use our Services and channels or visit our website, we collect Personal Data. We may ask for your Personal Data in some cases. In other cases, we collect your Personal Data by analysing how our Services and service channels are used, or by receiving information about you from our third-party partners.

3. No obligation to disclose personal information to the company and potential consequences.

You are not obliged to provide Us with any Personal Data. However, in certain situations, choosing not to do so may prevent Us from providing the Services. This could also limit users' ability to access the website.

4. What types of Personal Data can we collect? When you visit our website, we will collect the following Personal Data about you:

This includes information about your online activity log, traffic data (including IP address and the date and time of access), the language you used, software crash logs, browser type, and details about the device you used. The information We collect is not personal and cannot be used to identify you. Personal Data We receive from you: any personal data you voluntarily provide when you connect with a third-party online trading platform through Us. Personal information you provide directly to third-party platforms to facilitate trading includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing 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.
Without a legal basis, the Company cannot use Personal Data relating to you. The legal grounds that permit the Company 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 through the Website so that we can transfer it to a third-party trading platform.
• The Company or a third party may need to conduct processing to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to establish or defend legal claims.
• Processing must comply with a legal obligation.

Contact us by email for more details 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.

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 vendors, who process IP address information and conduct user experience analysis.
You may also request that we transmit 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 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 to obtain the resources needed to enhance and improve the products and services we provide to our customers.
Where necessary to safeguard the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share Personal Data about you with potential investors or purchasers, or with lenders to the Company or any other company within our 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 group business.

ONLINE TRACKING NOTICE

We may use third-party services, such as advertising providers or analytics companies. These partners 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 behaviour to enhance your experience, remember your settings, and personalise the products and services you may enjoy. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on 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 recognise 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 blocked or have been removed
To prevent or delete cookies, adjust your browser’s settings. Below are links to guide you through the process for several of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that some or all of the Website’s functions and features may not work as expected if this occurs.

ONLINE TRACKING NOTICE This service currently does not 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 periods as permitted by applicable laws, regulations, policies, or 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 an additional 12 months.
We regularly review the Personal Data we hold to ensure it is not kept longer than necessary.

9. Transfers of personal data to a third country or an international organisation

Your personal information may be transferred to other countries—for example, to a third country (a country other than your place of residence)—or to international organizations or jurisdictions. The Company takes all necessary measures to protect the Personal Data you provide and to ensure that individuals can exercise their rights and access effective legal recourse.
These protections and safeguards apply to all residents of 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 pursuant to 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 Standard Contractual Clauses adopted by the European Commission 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.

The Company can provide details on the security measures it uses to protect your Personal Data when transferred to third countries or international organisations. To request this information, please email info@vasto-gainlux.com

10. Personal Data Security

We implement appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration of Personal Data.
However, we cannot guarantee or warrant the error-free security of your Personal Data, nor can we be responsible for intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.
In cases where legal obligations or other requirements beyond our control apply, we may be required to provide your Personal Data to third parties, such as public authorities. We cannot control the security measures those third parties apply to your Personal Data in such situations.
No method of transmitting Personal Data over the internet is completely secure. The Company cannot ensure the security of Personal Data you send to us through the internet.

11. Hyperlinks to websites owned or operated by third parties

Our website includes links to third-party sites 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 websites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any third-party site or app, we recommend that you read its privacy policy before deciding to access or use it. We also suggest reviewing those policies before providing any Personal Data to them.

12. Amendments 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. When we make significant changes, we will also try to inform you through the methods we consider appropriate and will publish a notice on our website. Unless explicitly stated otherwise, amendments take effect upon publication of the revised Policy.

13. Your rights in relation to your personal data

You have the right to ask us to verify the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data 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 connection with your Personal Data. You may 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. 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 your request would adversely affect another person’s rights or freedoms, the Company may refuse it or limit its scope. Right to rectification
The Company will rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data about you be completed, taking into account the purposes of the processing. Right to erasure
The following grounds apply: (a) the Personal Data is no longer needed 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 based on legitimate interests pursued by us or by a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be deleted to comply with the Company’s legal obligations. 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.
Restriction of processing
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 stored only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or for important reasons of 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 provided to the Company in a structured, commonly used, machine-readable format.
You also have the right, where technically feasible, to have your Personal Data transmitted directly by the Company to another controller. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time to 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 legitimate interests. We will stop processing unless we demonstrate compelling legitimate grounds that override your rights and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
Direct marketing You have the right to object at any time to the processing of Personal Data for direct marketing.
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 individuals’ fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit your rights regarding Personal Data as described in this section 13. We will provide the information requested under section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two additional months depending on the complexity and number of requests. Within one month of receipt, we will inform you if an extension is required and explain why.
Unless otherwise provided in section 13, the information provided in response to your requests under section 13 will be 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 doubts about the identity of the person making the request, the Company may ask for additional information.