We (also referred to as 'We', 'Us', or 'Our') are fully committed to safeguarding your Personal Data and protecting your privacy.
Our Privacy Policy explains how we collect and store the information you provide on the Gaingate website (the 'Website').
We maintain and uphold the following principles:

We are committed to transparency in how we collect and use your personal data for your benefit:

Through these efforts, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website employs several methods and procedures to provide clear information on Personal Data usage. If you require specific details about your data, we will make every effort to deliver them promptly and at the appropriate time. If you have any questions, we are happy to explain any legal constraints. To contact us, please email us at info@strom-gainlux.com

We will use Personal Data solely for the purposes described in this Policy

We process Personal Data for various purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, safeguarding our rights and interests, performing ongoing maintenance and provisioning of the Services, ensuring full compliance with legal and regulatory requirements, and carrying out administrative, operational, and business activities that enable the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs for the Services.

Providing access to vital resources to better protect and uphold your rights when it comes to Personal Data

Our goal is to help you make well-informed choices about how we process your data. With that in mind, this is why we invested the time and resources to develop this website. To support that purpose, we use a range of methods, controls, and procedures to ensure you continue to receive the most relevant and accurate information about the use of your personal data. If you need specific details, we will provide them to you when appropriate and where necessary. If you have any questions about how this process works, we are more than happy to answer them and offer clear explanations, all within the bounds of applicable legal requirements. For anyone who would like to learn more or needs further clarification, please contact us by email at: info@strom-gainlux.com

Ensure Your Personal Information Stays Secure

Although no one can guarantee absolute security of Personal Data, we remain fully committed to using a wide range of measures to protect your Personal Data. Our Privacy and Security Policy covers all key areas to help ensure your long-term safety and privacy.

Scope?

In this Policy, we outline the categories of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and protect it. This Policy applies to information about an identified or identifiable individual—that is, someone who can be recognised directly or indirectly, including through a combination of other information in our possession or accessible to us. Under this Policy, ‘processing’ means any operation performed on Personal Data, including its management, organisation, and storage. Our services are intended for general audiences but are prohibited for anyone under the age of 18. We do not authorise use by individuals under this age and do not knowingly collect their information. If we become aware of any collection involving persons under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

By using our services or channels, or by browsing our website, you agree that we may collect personal data about you. In certain situations, we may also ask you to provide personal data directly. Alternatively, we may analyze how you interact with our services or channels to obtain this information, or receive it from our third-party partners

3. You are not required to submit your personal information to our company or address any related implications

You are not required to share any personal data with us. However, in some cases, if you choose not to provide this data, it may affect how we deliver our services, which could lead to limited website access or restricted use of certain features.

4. What types of personal data do we collect? When you visit our website, we may collect and process the following categories of personal information:

The Personal Data we collect includes information such as your activity log details, traffic data (including IP address and access date and time), the language used on our site, software crash reports, browser type, and device specifications. This portion of the data is non-personal and we do not use it to identify you. We also obtain certain Personal Data directly from you, namely information you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we may receive from those platforms the personal details you submit to them, which can include your full name, email address, phone number, and address.

5. What Are Our Legal Bases and Justifications for Processing Personal Data

Our Company processes your personal data for the purposes set out in this section, and does so in accordance with the applicable legal framework.
This legal basis is essential because, without an appropriate legal basis, our Company cannot use Personal Data about you. The legal bases that permit our Company to process your personal data include:

• We have obtained your consent to process your Personal Data for one or more of the following purposes, including when you provide personal information through the Website for us to share with a third-party trading platform
• The Company or a third party may need to process this information to pursue their legitimate interests. For example, this can include improving our Services or defending against potential legal claims that may arise from time to time.
• All processing activities on our website must comply with applicable legal requirements, and we confirm that they do.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we’ve outlined the reasons and legal bases under which we may use the personal information you provide to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Depending on the circumstances, the Company may disclose Personal Data to third parties that provide services such as data storage, IP address hosting, or user experience analytics.
We also accommodate requests to share specific Personal Data with third-party trading platforms. In such cases, we will transfer the Personal Data you provide to the platforms you designate. Once shared, their privacy policies will govern its use. Depending on your request, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners or affiliated entities to access the resources needed to enhance and improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or official authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or buyers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or related parties.

Online Tracking Notice

On our website, we may use third-party services, such as advertising networks or analytics providers. These partners may also use cookies and similar technologies to collect data.
When we say cookies, we mean small text files stored on your device when you visit or access our website. We use cookies to collect information about your preferences and browsing patterns to improve the user experience, understand those preferences, and help us design products and services based on customer interests. Cookies also help us gather data for statistics and analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily stored on your device and expire when you close your browser. Other cookies are persistent cookies, which remain on your device after you close your browser. These allow the website to recognise you as a returning visitor and keep the preferences you previously set.

7. How We May Use Cookies and Third-Party Services

Each cookie and its use may differ, depending on its intended purpose.

Cookies are blocked or have been removed
You can manage your cookie preferences in your browser settings. You can use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that some of the website's functions and features may not operate as intended if this occurs.

Online Tracking Notice Please note that, at this time, our service does not recognise Do Not Track requests.
8. Learn More About How Your Personal Information Is Stored

Please note that Our Company retains your Personal Data for as long as needed to fulfil the purposes described in this Policy, and may keep it for a longer period as permitted by law and for order‑related requirements where applicable. Your information may, in some cases, be shared with third‑party trading platforms for up to 12 months. With your consent, we may extend this sharing for an additional 12 months if needed.
We periodically review and assess the Personal Data we hold to ensure we do not retain it longer than necessary.

9. Transfers of Personal Data to Third Countries or to International Organizations

Under certain circumstances, we may transfer your Personal Data to other countries. This means you consent to the transfer of your Personal Data outside your country of residence, including to international organizations. We take all necessary measures to safeguard and defend your Personal Data and ensure you can exercise your rights and access effective legal remedies if needed.
All residents of the EEA (European Economic Area) can rely on these protections and safeguards.

• In some cases, we may transfer your Personal Data to a third country or an international organisation that the European Commission recognises as providing an adequate level of protection for Personal Data, 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')
• When a transfer occurs, we carry it out under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
• We transfer data in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, review the clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

If you would like to learn more about these details and how they relate to the security measures we apply to protect your Personal Data when it is transferred to third countries or international organisations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To safeguard your Personal Data, we have implemented robust security measures. These measures are designed to prevent accidental or unlawful destruction, loss, or alteration.
However, despite our precautions, we cannot guarantee that your Personal Data will be maintained without error, nor can we be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorized access by third parties, or other causes beyond our control.
Where we are legally required, or due to other circumstances beyond our control, we may need to share your Personal Data with third parties, such as public authorities. In such cases, we cannot control the security measures employed by those third parties.
Please note that transferring Personal Data over the internet cannot be made entirely secure and carries inherent risks. As a result, we cannot guarantee the security of Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website contains links to external sites and applications that are outside our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. While this Policy explains what happens on our website, it does not apply to third-party websites.
Before visiting any third-party website or app, please review its privacy policy before using its services. You should also carefully consider whether you wish to share your Personal Data with them.

12. Understanding the Amendments to Our Policy

We may update this Policy at any time. If changes are made, we will notify you on our website and provide the updated Policy. For material changes, we will use the communication methods we deem most appropriate and will also publish an announcement on our website. Unless stated otherwise, all amendments to this Policy take effect immediately upon publication of the revised Policy.

Your Rights Regarding Your Personal Data

Under applicable law, you may request access to the personal data we hold about you, ask us to correct it, request deletion of Personal Data you no longer want us to process, and limit the categories of data we collect. If you reside in the EEA, please also consult this page:
To exercise any of your data rights, contact us at the email address below. Right of access
We will verify the accuracy of the Personal Data we process. If accurate, we will provide you with access to your Personal Data, including an electronic copy of the processed data. We may charge a reasonable fee for additional copies. On request, this data will be provided electronically.
Your right of access must not adversely affect the rights and freedoms of others. If a request would do so, we may refuse or limit our response. Right to rectification
If your Personal Data is inaccurate or incomplete, you may ask us to correct or complete it. Right to erasure
You may request erasure where: (a) the personal data is no longer needed for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (e) the Personal Data has been processed unlawfully; or (f) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with EU or Member State law or (b) to establish, exercise, or defend legal claims.
Restriction of processing
You may ask us to restrict processing, for example when you contest the accuracy of the data. During restriction, we may store the data and process it only with your consent, to protect the rights of another person, or for important public interest of a Member State or the EU.
Right to data portability
Where processing is automated and based on your consent or a contract, you have the right to receive your Personal Data that the Company processes.
You may also request that we transmit that data to another controller where technically feasible. Exercising data portability does not affect your right to erasure.
Right to object
You may object at any time to our processing of your Personal Data based on the Company’s or a third party’s legitimate interests, including related profiling. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
You may object at any time to processing of Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent to processing at any time without affecting the lawfulness of processing before withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data.
You may additionally seek protection from a supervisory authority in a Member State regarding Personal Data processing within the EU.
As described in this section 13, your Personal Data rights may be limited by EU and Member State laws. We will provide the information requested under section 13 within one month of receiving your request, which may be extended to two months depending on the complexity and number of requests. We will notify you within one month of any extension and the reasons.
We will provide the information requested under section 13 free of charge unless a request is unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act.
If we have doubts about your identity in connection with a request, the Company may request additional information.