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 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 decisions about the use and processing of your Personal Data. That is why we created this website. To achieve this, we employ 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 supply them at the appropriate time. We are happy to answer any questions you may have and will provide any clarifications you require, subject to any limits imposed by law. You can contact us by email at the address below: info@lume-portdex.com

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

Personal Data may be processed by us for a range of purposes, including to provide the website to you, to connect you with third-party trading platforms (the 'Services'), to enhance the site, to protect our rights and interests, to facilitate the maintenance and provision of the Services, to meet applicable regulatory or legal obligations, and to conduct administrative and business activities that support the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.

To access essential tools to safeguard 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’s why we created this website. To achieve this, we use various methods and procedures to provide you with clear, 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 subject to legal limitations. You can reach us by email at: info@lume-portdex.com

Protect Your Personal Data:

Although we cannot guarantee the absolute security of your Personal Data, we will continue to implement a range of measures and controls to help ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy explains the types of Personal Data the Company collects from natural persons and how we process it, share it with third parties, and protect it. It concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly through information we hold or can reasonably access. The Policy defines ‘processing’ as any operation that involves the use or collection of Personal Data, including its management, structuring, and storage. Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly solicit or collect information from individuals under 18, nor do we knowingly allow them to use our services. If we become aware that we have collected information about a child, 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 also occasionally request your Personal Data in certain situations. In other cases, we collect it by analysing your use of our Services and service channels, or by receiving information about you from our trusted external third‑party partners.

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

But you are not required to provide Us with Personal Data. However, in certain circumstances, not providing Personal Data may prevent Us from delivering the Services or may restrict users' ability to access the website fully.

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

This includes details of 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 used, and information about the device you use. The information we collect is non-personal and, on its own, cannot be used to identify you. Personal data we receive from you: any personal information you choose to provide to us, at your discretion, when you connect with a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading may include your full name, address, telephone number, and email address, as required to open and service your trading account.

5. The Legal Basis and Grounds 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.
Without a valid legal basis, the Company cannot use 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 provide 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 process data to pursue their legitimate interests, for example to enhance Our Services or to establish, exercise, or defend legal claims.
• Processing must comply with a legal obligation.

Contact us by email for more information about processing necessary 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. Transfers of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, IP address services, and user experience analytics.
You may also ask us to provide certain Personal Data about you to third-party trading platforms. In these 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 affiliates or business partners to obtain resources that help 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 official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders of 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 group company) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other group company.

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 when you visit or access the website. They collect information about your preferences and browsing habits to enhance your experience, remember your settings, and tailor products and services you may enjoy. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and remain active only for a short time, ending when you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period after you close your browser and can be retained until they expire or are deleted. They help the website recognise you as a returning user and make it easier for you to return and continue where you left off.

7. Cookies and Third-Party Services

We may use them based on their intended purpose:

Cookies are blocked or have been removed
To block 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 note that some or all of the Website's features and functions may not work as expected if this occurs.

ONLINE TRACKING NOTICE This service does not currently recognize 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 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 12 months. With your consent, we will continue sharing 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 to an international organisation

Your personal information may be transferred to other countries—for example, to a third country (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 data subjects can assert their rights and obtain 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 made 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 compliance 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 it is transferred to third countries or international organisations. To request this information, please send an email to info@lume-portdex.com

10. Personal Data Protection

We have implemented appropriate organisational and technical measures to protect Personal Data, including steps to prevent accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant error-free security of your Personal Data, nor can we be held liable for any non-material, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures caused by transmission errors, unauthorised third-party access, or other circumstances beyond our control.
In the event of legal requirements or other obligations beyond our control, 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 transferring Personal Data over the internet is completely secure. The Company cannot ensure the security of any Personal Data you transmit to Us online.

11. Hyperlinks to websites owned or operated by third parties

Our website may include 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 those websites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any third-party websites or apps, we recommend reviewing their privacy policies before deciding to access or use their sites or apps. We also suggest that you provide any Personal Data directly 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 by posting the updated version on our website. In addition, when we introduce significant modifications to this Policy, we will endeavour to inform you through the channels we deem appropriate and will publish an announcement on our website. Unless explicitly stated otherwise, any amendments will take effect upon publication of the revised Policy.

13. 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, correct any errors, and delete any Personal Data we do not require. You may also limit certain types or purposes of processing 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 can exercise them by emailing the address below. Right of access
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 any additional copies. The data will be made available electronically if you request it.
Your right of access must not conflict with the rights and freedoms of others. If fulfilling your request would adversely affect another’s rights and freedoms, the Company may refuse the request or limit its response. Right to rectification
The Company may 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
You may request erasure if: (a) the 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, on grounds relating to your particular situation, to processing of your Personal Data based on legitimate interests pursued by us or by a third party; (e) the Personal Data have been processed unlawfully; or (f) the Personal Data must be deleted 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) for the establishment, exercise, or defence of legal claims.
Restrictions on processing
If you contest the accuracy of your Personal Data, you may ask the Company to restrict its processing. While processing is restricted, the Personal Data may be retained 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 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 and must not prejudice 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 legitimate interests pursued by the Company or a third party, including profiling based on those interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless processing is necessary for the establishment, exercise, or defence of legal claims.
For direct marketing, you have the right at any time to object 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 carried out on the basis of consent before its withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may also appeal to a supervisory authority established by a Member State to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union.
European Union and Member State laws may restrict your rights regarding your Personal Data, as described in this section 13.
We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months, if 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, information supplied in response to your rights under section 13 will be provided free of charge. If a request is unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs for providing the information or taking the requested action, or we may refuse to act.
If we have doubts about the identity of the person making the request, the Company may request additional information.