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

We are committed to being transparent about how we collect and use your personal data in your best interests:

By doing so, 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, relevant information about how Personal Data is used. If you need specific details about your data, we will work diligently to provide them promptly and at the appropriate time. Should you have any questions, we are happy to clarify any legal constraints. To contact us, please send us an email at info@flambit-fondo.com

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

We process Personal Data for various purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, maintaining and delivering the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities that support the provision and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Providing access to essential resources to help protect your rights when it comes to Personal Data

We have set a clear objective: to help you make well‑informed choices about how we handle your data and what that means for you. With that in mind, this page explains why we invested the time to develop this website and how we approach transparency. To support this, we apply a range of methods and procedures to ensure you continue to receive the most relevant information about our use of your personal data, including updates when practices change. If you need specific details, we will provide them at the appropriate time and in a format that is easy to understand. If you have questions about how this process works, we are happy to respond and offer clarification, all within applicable legal requirements and best practices. To learn more or request further information, contact us by email at: info@flambit-fondo.com

Keep Your Personal Information Safe and Secure

While we cannot guarantee the absolute security of Personal Data—no system can—we remain fully committed to protecting your Personal Data through a range of robust safeguards. Our Privacy and Security Policy covers all essential areas to support your long-term protection.

Scope?

Within this Policy, you will find an outline of the types of Personal Data our Company collects from our customers, along with the methods we use for processing, sharing with third parties, and securing that data. This Policy covers information about an identified or identifiable individual, where a person can be recognized directly or indirectly through additional details in our possession or data to which we have access. For the purposes of this Policy, 'processing' means any operation involving the use or handling of Personal Data, including its management, organization, and storage. Our services are intended for a general audience; however, they are prohibited for anyone under the age of 18. We do not authorize individuals under this age to use our services, nor do we knowingly collect information from them. If we become aware that we have collected data regarding a person 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 acknowledge that we may collect personal data about you. In some cases, we may ask you to provide this information directly. We may also collect it by analyzing your interactions with our services or channels, or via our third-party partners

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

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

4. What types of personal data do we collect? When you visit our website, you can expect us to collect the following personal information:

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

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

Our Company processes your personal data for the purposes described in this section and in line with the relevant legal framework.
We must have a valid legal basis; without such a basis, our Company cannot use your Personal Data in relation to you. The legal grounds that enable 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 via 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. Examples include enhancing our Services or defending against potential legal claims.
• All processing on our website is carried out in accordance with applicable legal requirements, and we confirm that these requirements are fully met.

If you would like further information on how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we have highlighted a list of the reasons and legal bases for which we may use the personal information you provide to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Where appropriate, 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 process requests from individuals who ask us to share specific Personal Data with third-party trading platforms. In such cases, we will transfer the Personal Data you provide and deliver it to the platforms you choose. When you do so, the use of your Personal Data will be governed by their privacy policies. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners or affiliated entities. Doing so allows us to access the resources we need to enhance and continuously improve our customer offerings.
When required, the Company may disclose Personal Data to regulatory, local, or other official authorities to protect the rights or property of others.
We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or its affiliated entities. This would typically occur in the context of transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or other parties connected to the Company.

Online Tracking Notice

Our website may use third-party services, such as advertising providers and analytics firms. These providers may also use cookies and similar technologies to collect data.
By “cookies,” we mean small text files stored on your device when you visit or access our website. We use cookies to understand your preferences and browsing patterns, enhance the user experience, and design products and services that reflect customer interests. Cookies also help us gather information for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device after you close your browser. They allow the website to recognize you as a returning visitor and retain the preferences you previously set.

7. How We Use Cookies and External Services

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

Cookies are blocked or have been removed
You can adjust your cookie preferences in your browser settings. You can use the links below for assistance with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that certain website functions and features may not work as expected if this occurs.

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

Please note that Our Company retains your Personal Data for as long as necessary to fulfill the purposes described in this Policy, and we may retain it for a longer period as permitted by applicable law and for relevant orders. 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 needed.
From time to time, we 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 International Organizations

In certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to transfer it outside your country of residence or to international organizations. We take all necessary measures to safeguard your Personal Data and ensure 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 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 the transfer occurs, we execute it under a legally binding, enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
• We carry out transfers 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, you can review the adopted 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 it is transferred to third countries or international organisations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented robust security measures. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
Despite these precautions, we cannot guarantee that your Personal Data will always be kept error-free and secure, nor can we be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures resulting from transmission errors, unauthorised access by third parties, or other events beyond our control.
Where we are legally required, or due to other constraints 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 used by those third parties.
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 send to us online.

11. Regarding Links to Third-Party Websites

Our website includes links to external sites and applications that are beyond our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. Our Policy applies to our website only and does not cover 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 such providers.

12. Understanding Our Policy Amendments

We may update this Policy at any time. When changes occur, we will notify you on our website and provide access to the revised Policy. For material changes, we will use the communication methods we deem most appropriate, including a prominent announcement on our website, and where appropriate we will highlight key updates. Unless we state otherwise, all amendments to this Policy take effect immediately upon publication of the updated Policy.

Your Rights Regarding Your Personal Data

You have the right to request access to the personal data we hold about you, to have it rectified, and to ask us to delete Personal Data in certain circumstances. You also have the right to restrict the types of data we may collect and process. If you reside in the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us at the email address below. Right of access
We will assess the accuracy of the Personal Data we process. Where appropriate, we will grant 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 of your data. On request, we will provide this data electronically.
Your right of access must not infringe the rights of others. If a request would adversely affect others’ rights, we may refuse to comply or limit our response. Your right to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Your right to erasure
Legitimate reasons 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 processing is unlawful; or (f) deletion is required to meet a legal obligation. You cannot exercise this right where processing is necessary (a) to comply with EU or Member State laws or (b) to establish, exercise, or defend legal claims.
Restriction of processing
You may ask us to limit processing, for example if you believe the data is inaccurate. While restricted, the data may be stored and processed only with your consent, to protect another person’s rights, or for important public interest of the EU or a Member State.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive the Personal Data you have provided to the Company.
You may also request that we transfer this 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 use of your Personal Data based on the legitimate interests pursued by the Company or third parties, including related profiling. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for legal claims.
You have the right to object to processing for direct marketing at any time.
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 overseeing your Personal Data rights.
You may also ask a supervisory authority in any Member State to protect your individual rights regarding Personal Data processing within the EU.
As outlined in section 13, your Personal Data rights may be limited by EU and Member State laws. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request, but we may extend this to two months depending on the nature and number of requests. You will be informed within one month if an extension is applied and the reasons.
We will provide the information you request under section 13 free of charge unless the request is unfounded or excessive, especially 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 relation to a request, the Company may ask for additional information.