We (also referred to as 'We', 'Us', or 'Our') are committed to protecting your Personal Data and your privacy.
This Privacy Policy is designed to explain how we collect and store the information you provide through the Gaingate website (the 'Website').
The following principles will be upheld:

To ensure transparency about the collection and processing of your personal data:

We want you to be able to make informed decisions about the use and processing of Personal Data. That is why we created this website. To achieve this, we use a variety of methods and procedures to provide relevant information about the use of Personal Data. If we believe you need specific details, we will share them at the appropriate time. We are happy to answer any questions and provide clarifications, subject to any legal limitations. You can reach us by email at: info@puro-portdex.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 and 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 and regulatory obligations, and performing administrative and business operations to support the provision and use of the Services. We also process Personal Data to better understand your preferences and needs.

To access essential tools to protect your rights in relation to Personal Data:

Our goal is to enable you to make informed decisions about the use and processing of your Personal Data. That is why we created this website. To this end, we use various methods and procedures to provide you with relevant information on 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 offer any clarifications permitted by law. You can reach us by email at: info@puro-portdex.com

Protect Your Personal Data:

Although we cannot guarantee the absolute security of your Personal Data, we will continue to employ a broad range of safeguards 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 and how it is processed, shared with third parties, protected, and related practices. 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 through a combination of 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 management, organization, and storage of such data. Our services are intended for general audiences and are not designed for individuals under 18 years of age. 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 learn that we have collected information about a child, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

When you access our Services and channels or visit our website, we collect Personal Data. We may ask you to provide Personal Data in certain cases. We also collect Personal Data by analysing how our Services and channels are used, or by receiving information about you from our third-party partners.

3. No obligation to disclose personal data to the company and the related consequences.

You are not required to provide Us with any Personal Data. However, in certain circumstances, you may choose not to share Personal Data with Us. This may prevent Us from providing the Services or restrict 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 Data:

This includes details about your online activity logs and traffic data (including IP address, 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 and cannot be used to identify you. Personal data we receive from you includes any information you voluntarily provide when you connect to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to enable 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 described in this section, 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 may occur, for example, when you submit personal information through the Website so that we can transmit 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, this can be necessary to improve Our Services or to establish or defend legal claims.
• Processing must comply with a legal obligation.

Contact us via email for more information about the processing necessary to protect our 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 that support us, including hosting and storage providers, processors of IP address information, and user experience analytics providers.
You may also ask us to transmit specific Personal Data about you to third-party trading platforms. In these cases, we will provide to such third-party trading platforms the Personal Data you have provided to us. The use of your Personal Data by those platforms is governed by their privacy policies. 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 offer our 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 also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company in our group in connection with a relevant 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 company in the group.

ONLINE TRACKING NOTICE

Third-party services, such as advertising providers and analytics companies, may be used on our website. These companies may also use cookies or other 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 improve your experience, remember your settings, and personalize the products and services you might enjoy. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are temporarily downloaded to your device and expire shortly after 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 revisit the site.

7. Third-Party Cookies and Services

We may use them depending on their purpose:

Cookies are blocked or have been removed
To prevent or remove cookies, adjust your browser settings. Below are links to guide you through the process for several popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please be aware that some or all of the Website's features and functions may not operate as expected if this occurs.

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 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 we do not retain it longer than necessary.

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 jurisdictions. The Company takes all necessary steps to safeguard the Personal Data you provide and ensures that individuals can assert their rights and access effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has determined, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, ensures an adequate level of protection for Personal Data. (the 'GDPR')
• The transfer is carried out 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 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@puro-portdex.com

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect Personal Data, including preventing its accidental or unlawful destruction, loss, or alteration.
We cannot guarantee or warrant the error-free security of your Personal Data. Nor can we be held liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data, including—but not limited to—disclosure due to transmission errors, unauthorised third-party access, or any other cause beyond our control.
In the event of legal obligations or other requirements beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot control the safeguards applied to your Personal Data by such third parties in these circumstances.
Personal Data cannot be made completely secure when transmitted over the internet, and the Company cannot guarantee the security of Personal Data you transmit to Us online.

11. Hyperlinks to websites owned or operated by third parties

Links to third-party websites and applications are provided on this website. These sites and apps are not controlled or supervised by the Company. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to activities carried out on such sites or apps.
When you visit any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. We also suggest that you provide any Personal Data to them only after doing so.

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 revised Policy on our website. In addition, when we make significant changes to this Policy, we will aim to inform you through the methods we consider appropriate and will publish an announcement on our website. Unless explicitly stated otherwise, amendments take effect upon publication of the updated Policy.

13. Your rights in relation to your personal data

You are entitled to ask us to verify the accuracy of the Personal Data collected about you, correct any errors, and delete any Personal Data that we do not require. You may also restrict the scope or 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 request to exercise your rights by emailing the address below. Right of access
The Company will verify whether your Personal Data 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. If requested, the data will be provided electronically.
Your right of access must not conflict with the rights and freedoms of others. If your request would adversely affect the rights and freedoms of another person, the Company may refuse the request or limit its response. Right to rectification
The Company will rectify inaccurate Personal Data. You may require that incomplete Personal Data about you be completed, taking into account the purposes of the processing. Right to erasure
The following grounds apply: (a) Personal Data is no longer necessary 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, based on reasons related to your situation, to processing based on legitimate interests pursued by us or a third party; (e) Personal Data has been unlawfully processed; or (f) Personal Data must be erased 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.
Restriction of processing
If you contest 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, or to establish, exercise, or defend 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
If 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.
You may also 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 your Personal Data based on the Company’s or a third party’s legitimate interests, including profiling based on those interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or the processing is necessary to establish, exercise, or defend legal claims.
For direct marketing, you may object at any time 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 have the right 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 laws may limit your rights regarding your Personal Data as described in Section 13. We will provide the information requested under your rights in Section 13 within one month of receiving your request. This period may be extended by up to two additional months if 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 contrary to Section 13, information provided under your rights in Section 13 will be supplied free of charge. If a request is unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs or decline to act.
If we have doubts about the identity of the person making the request, the Company may ask for additional information.