We (also referred to as 'We', 'Us', or 'Our') remain fully committed to safeguarding your Personal Data and ensuring your privacy.
Our Privacy Policy is designed to inform you, the consumer, about how we collect and store the information you provide on the Gaingate website (the 'Website').
We uphold the following principles:

We are committed to being transparent about how we collect and use your personal information for your benefit:

By doing so, our aim is to help you make informed decisions about the use and processing of Personal Data. To this end, our website employs several methods and procedures to provide clear information on Personal Data use. If you require specific details about your data, we will make every effort to provide them promptly and at the appropriate time. If you have any questions, we are happy to clarify anything related to legal requirements. To contact us, please email info@oikko-portdex.com

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

You will find that we process Personal Data for a variety of purposes, including providing the website to you, linking you with third-party platforms for trading (referred to as 'Services'), improving the site, safeguarding our rights and interests, carrying out the ongoing maintenance and provisioning of the Services, ensuring full compliance with regulatory and legal obligations, and performing administrative and business operations to support the effective delivery and use of the Services. In addition, we process your Personal Data to help us better understand your preferences and needs.

Ensuring access to essential resources to safeguard your rights regarding Personal Data

We are committed to helping you make well‑informed decisions about how we manage your data. This goal explains why we invested time in developing this website. To support it, we use clear processes, methods, and safeguards to ensure you continue receiving the most relevant information about our use of your Personal Data. When specific details are needed, we will provide them at the appropriate time. If you have questions about how this works, we are glad to answer and clarify, all within applicable legal requirements. To learn more, contact us via email at: info@oikko-portdex.com

Keep Your Personal Information Secure and Private

While we cannot guarantee the absolute security of your Personal Data, as no system can, we remain fully committed to using a wide range of measures to protect it. Our Privacy and Security Policy covers all essential safeguards to help ensure your long-term safety.

Scope?

In this Policy, we outline the types of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and protect it. Our Policy applies to information about an identified or identifiable individual, whom we can recognize directly or by combining it with other information we hold or can access. For the purposes of this Policy, 'processing' means any operation involving the use or handling of Personal Data. This includes activities such as the management, organization, and storage of Personal Data. Our services are intended for a general audience; however, they are not available to anyone under the age of 18. We do not authorize individuals under this age to use our services. Accordingly, we do not knowingly collect information from persons under 18, as they are not permitted to use our services. If we become aware that data has been collected from anyone under 18, we will delete it promptly.

2. What Personal Information Do We Collect from You?

By using our services or channels, or by browsing our website, you acknowledge that we may collect personal data about you. In some cases, we may ask you to provide personal data directly. Alternatively, we may collect this information by analyzing your interactions with our services or channels, or through our third-party partners

3. You are not required to provide your personal information to our company or deal with any resulting implications

You are not required to share personal data with us. However, in certain situations, choosing not to provide this information may affect how we deliver our services to you, which could result in limited access to our website or restricted use of certain features.

4. What Personal Data Do We Collect? When you visit our website, we may gather the following types of personal information:

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

5. Our Legal Bases and Justifications for the Processing of Personal Data

Our Company processes your personal data for the purposes outlined in this section and complies with all applicable legal requirements.
We rely on a lawful basis because, without one, our Company cannot use your personal data. The legal grounds under which our Company processes 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 via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process your information, when necessary, to further their legitimate interests. Examples include enhancing our Services, improving user experience, or defending against legal claims or litigation that may arise.
• All processing on our website must comply with applicable legal requirements, and we can confirm that it does comply with those requirements.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email for assistance.
Below, we have highlighted the reasons and legal bases explaining how we may use the personal information you have provided 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 storage, hosting, IP address data handling, or user experience analytics.
We also accept requests from individuals who want us 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. If you choose this, their privacy policies will govern how it is used. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners or affiliated entities. We do this to access the resources needed to enhance and continually improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or other competent 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 affiliated companies. This typically occurs in connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy relating to the Company or other parties associated with the Company.

Online Tracking Notice

You may encounter our use of third-party services, such as advertising networks or analytics providers, on our website. These companies may also use cookies and similar technologies to collect data.
When we say cookies, we mean small text files stored on your device each time you visit or access our website. We use cookies to collect information about your preferences and browsing patterns with the aim of improving the user experience, understanding user preferences, and shaping products and services around customer interests. In addition, cookies help us compile statistics and perform analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily stored on your device and expire once you close your browser. Other cookies are persistent cookies, which remain on your device even after you close your browser. These cookies allow the website to recognize you as a returning visitor and retain the preferences you previously set.

7. How We May Use Cookies and External Services

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

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

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some website features and functions may not operate as intended if this occurs.

Online Tracking Notice Please note that, at present, our service does not recognise Do Not Track requests.
8. Learn More About Storing Your Personal Information

Please note that Our Company retains your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, or for a longer period as permitted by applicable laws and regulations, and for order-related requirements where applicable. In certain cases, your information may 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 required.
We periodically review and evaluate the Personal Data we hold to ensure it is no longer retained unnecessarily.

9. Transferring Personal Data to a Third Country or an International Organization

Under certain circumstances, we may transfer your Personal Data to other countries. This means we have your permission to send this data outside your country of residence, or to international organizations. We take all necessary measures to protect and safeguard your Personal Data and ensure that you can exercise your rights and effectively access legal remedies if needed.
All residents of the EEA (European Economic Area) can benefit from these protections and safeguards.

• In certain 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 do so under a legally binding and enforceable agreement between public authorities or bodies, in line with Article 46(2)(a)
• We conduct such transfers in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under GDPR Article 46(2)(c). For more information, please review the approved 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 more information about these details and how they relate to the security measures we apply to protect your Personal Data when transferring it to third countries or international organizations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

In order to protect your Personal Data, we have implemented robust security measures. This includes preventing accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee that your Personal Data will be kept completely secure or error-free, nor can you hold us liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This covers, without limitation, any disclosures caused by transmission errors, unauthorised access by third parties, or other events 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 those third parties implement.
Please note that transmitting Personal Data over the internet cannot be made entirely secure and carries inherent risks. Because of these risks, 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 assume no responsibility for how these third-party websites collect or process your Personal Data. While Our Policy applies to our website, it does not extend to third-party websites.
Before visiting any third-party website or app via our links, please review their privacy policies before using their services. You should also carefully consider whether you want to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We reserve the right to amend this Policy at any time. If changes are made, we will notify you via a notice on our website and provide access to the updated Policy for your review. For material revisions, we will use the communication methods we consider most appropriate, and we will also issue an announcement on our website to highlight the update. Unless we state otherwise, all amendments to this Policy will take effect immediately upon publication of the revised Policy.

Your Rights in Relation to Your Personal Data

You have the right to review the Personal Data we collect about you, request corrections, and ask us to delete Personal Data you no longer want us to process. You may also request that we restrict the types of data we collect. For residents of the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us at the email address below. Access rights
We will verify the accuracy of the Personal Data we process. If it is accurate, we will provide you access to your Personal Data, including an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies. When requested, we will provide this data electronically.
Your right of access must not infringe the rights of others. If a request would compromise others’ rights, we may refuse to comply or limit our response. Your rights related to rectification
If you believe your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Your right to erasure
Valid grounds may include: (a) we no longer need the Personal Data for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to specific processing; (e) the Personal Data was processed unlawfully; or (f) erasure is required to meet 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 limit processing if you believe the data is inaccurate. While restricted, the data will be stored and processed only with your consent, to protect another person’s rights, to establish, exercise, or defend legal claims, or for important public interest of the EU or a Member State.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive all Personal Data the Company holds about you.
You also have the right, where technically feasible, to request transfer of that data to another controller. 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 third parties’ legitimate interests, including related profiling. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is needed to establish, exercise, or defend legal claims.
You have the right to 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 based on consent before its withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data.
You may further request that a supervisory authority in a Member State protect your individual rights concerning the processing of Personal Data within the EU.
As outlined in 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, but we may extend this by up to two months depending on the nature and number of requests. You will be notified within one month if an extension is applied and the reasons.
Information provided under section 13 will be 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 on the request.
If we have doubts about your identity in connection with a request, the Company may request additional information.