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').
We are guided by the following principles:

To ensure transparency about how we collect and process your personal data:

Our goal is to help you make informed decisions about how your Personal Data is used and processed. That’s why we created this website. To do so, we use a range of methods and procedures to share clear, relevant information about the use of Personal Data. If we believe you need specific details, we will provide them to you at the appropriate date and time. We are happy to answer any questions and will offer any clarifications you require, subject to legal limitations. You can contact us at the email address below: info@clarum-monerra.com

Personal Data will be used solely for the purposes specified in the Policy.

Personal Data may be processed by us for various 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 delivery of the Services, meeting regulatory and legal obligations, and conducting administrative and business activities to support the provision and use of the Services. Personal Data are also processed by us to better understand your preferences and needs.

To utilise essential tools to protect your rights in relation to 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 various methods and processes to provide you with relevant information about how Personal Data is used. 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@clarum-monerra.com

Protect Your Personal Data:

While we cannot guarantee complete security of your Personal Data, we remain committed to continually implementing a range of methods and safeguards designed 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 protect it. It concerns information that relates to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including by reference to additional information we hold or can reasonably 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 the age of 18. We do not knowingly solicit 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 a child, we will delete it as quickly as reasonably practicable.

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 request your Personal Data in certain instances. In other instances, we collect your Personal Data by analysing how you use 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 possible consequences.

However, you are not required to provide Us with any Personal Data. In some circumstances, you may choose not to share Personal Data with Us. This may prevent Us from providing the Services or limit users' access to the Website.

4. What types of Personal Data do we collect? When you visit our website, we may collect the following Personal Data from you:

This includes information about your online activity log and traffic data (including IP address, date and time of access), the language you use, software crash logs, the type of browser, and details 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 includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for the Processing of Personal Data

The Company processes your Personal Data for the purposes described in this section and in line with the applicable legal basis.
Without a valid legal basis, the Company cannot process your Personal Data. The legal grounds that permit the Company to 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 enhance Our Services or to defend against legal claims.
• Processing is necessary to fulfil a legal obligation.

Contact us by email for more information on processing activities necessary to protect our legitimate interests.
Below are the purposes and legal grounds under which we may use the Personal Data you provide.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, including hosting and storage providers, IP address information processing services, and user experience analytics firms.
You may also request that we disclose specific Personal Data about you to third-party trading platforms. In such instances, we will provide the Personal Data you have given to Us to those third-party trading platforms. The use of your Personal Data is governed by their respective 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 enables the Company to access the resources needed to enhance and improve the products and services it provides to its 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.
Additionally, we may 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 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

Third-party service providers, such as advertising networks on our website or analytics firms, may be engaged. These providers 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 behaviour to enhance your user experience, remember your settings, and tailor products and services you may be interested in. 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 last only 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 recognise you as a returning user and facilitate your return to the website.

7. Cookies and Third-Party Services

We may use them according to their intended purpose:

Cookies are blocked or have been removed
To block or remove cookies, adjust your browser settings. Below are links to help you through the process for several 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 does not currently respond to Do Not Track (DNT) signals.
8. Retention of Your Personal Data

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, 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 your data for another 12 months.
We regularly review the Personal Data we hold to ensure it is not retained longer than necessary.

9. Transfers of personal information to a foreign country or to an international organisation

Your personal information may be transferred to other countries (i.e., your personal data may be transmitted to a third country—meaning a country other than the one in which you reside)—or to international organizations or other jurisdictions. The Company takes all necessary steps to safeguard the Personal Data you provide and ensures that you can assert your rights and access effective legal remedies.
These protections and safeguards are accessible to all those who reside in the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has determined provides 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 agreement between public entities or authorities in accordance with Article 46(2)(a).
• The transfer was conducted in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. These clauses 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 of the security measures it uses to protect your Personal Data when transferred to third countries or international organisations. Please email us at info@clarum-monerra.com

10. Protection of Personal Data

We have implemented 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 that the security of your Personal Data will be error-free. We are also not responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data, including, without limitation, disclosures resulting from transmission errors, unauthorised third-party access, or any other cause beyond our control.
In circumstances where we are legally obligated or otherwise compelled beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. In such cases, we cannot control the security measures those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet with absolute security, and the Company cannot ensure the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to websites owned by third parties

This website may include links to third-party websites and applications. These sites and apps are not under the Company’s control. We are not responsible for the collection or processing of Personal Data by these sites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any third-party website or app, we recommend that you read their privacy policies before deciding to access or use them. We also suggest that you do so before providing any Personal Data to them.

12. Changes to this Policy

This Policy may be updated at any time. If we make changes to this Policy, we will notify you of such changes by posting the updated version on our website. In addition, when significant changes are made, we will endeavour to inform you using methods we consider appropriate and will publish an announcement on our website. Unless stated otherwise, any amendments will take effect upon publication of the revised Policy on our website.

Your rights in relation to your personal information

You have the right 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 no longer required by Us. You may also limit the scope and types of processing of your personal information. If you are an EEA resident, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You may exercise your rights by emailing the address below. Right of access
The Company can verify whether your Personal Data is being processed. If it is, 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 you request it, the data will be provided electronically.
Your right of access must not infringe the rights and freedoms of others. If your request would adversely affect the rights and freedoms of another person, the Company may refuse to act on the request or limit how it is fulfilled. 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 processing. Right to erasure
You may request erasure where: (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 and based on your particular situation, to processing based on legitimate interests pursued by Us or a third party; (e) the Personal Data has been unlawfully processed; 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, we may store the Personal Data but process it 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 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 on 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 may also request that your Personal Data be transmitted directly by 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 any profiling based on those interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your rights, freedoms, or interests, or the processing is required for the establishment, exercise, or defence of legal claims.
Direct marketing You may object at any time to the processing of your Personal Data for direct marketing purposes.
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 respond to your request under section 13 of this policy within one month of receipt. Where necessary, this period may be extended by up to two additional months depending on the complexity and number of requests. We will inform you within one month of receiving your request if an extension is required and explain why.
Unless otherwise provided under section 13, information provided in response to your request 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 on the request.
If we have doubts about the identity of the person making the request, the Company may request additional information.