Privacy Policy

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').
These principles will be upheld:

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

We want you to be able to make informed choices about the use and processing of your Personal Data. That is why we created this website. To achieve this, we use various methods and procedures to provide you with clear, relevant information about Personal Data. 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@aishugairiinvestments.com

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

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

To use key tools and resources that help safeguard your rights concerning Personal Data:

We want you to be able to make informed choices about how your Personal Data is used and processed. That’s why we’ve created this website. To support this, we use a range of methods and procedures to provide you with relevant information about the use of Personal Data. If we believe you need specific details, we will provide them at the appropriate time. We are happy to answer any questions you may have and will offer any clarifications you require, subject to any legal limitations. You can contact us by email at: info@aishugairiinvestments.com

Protect Your Personal Data:

Although we cannot guarantee the absolute security of your Personal Data, we are committed to continually employing a range of measures and technologies to keep it 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 the Company processes it, shares it with third parties, and protects it. It relates to information about an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly through additional information we hold or can access. The Policy defines 'processing' as any operation that involves the use or collection of Personal Data, including the management, structuring, and storage of such data. Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly collect or request information from anyone under 18, nor do we knowingly allow such individuals to use our services. If we learn that we have information about a child, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

If you use our Services and service channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain instances. In other cases, we collect your Personal Data by analysing the use of our Services and our service channels, or by receiving your information from our third-party partners.

3. Whether you must disclose personal information to the company and the consequences.

You are not obliged to provide Us with any Personal Data. However, in certain circumstances, if you choose not to supply specific Personal Data, it may prevent Us from providing the Services or may restrict users’ access to the website.

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

This includes details of your online activity log, traffic data (including your 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 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 to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading: this may include your full name, address, phone number, and email address.

5. Legal Basis and Purposes for Processing 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 bases that allow the Company to process your Personal Data are:

  • You have given your consent to the processing of your Personal Data for one or more reasons. This applies when you submit Personal Data 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, to improve Our Services or to defend legal claims.
  • Processing must fulfil a legal obligation.

Contact us by email for more information about processing that is necessary to safeguard our legitimate interests.
Below is a list of purposes and legal bases for which we may use the Personal Data you provide.

Scope Legal Basis

1. To share your personal information with third parties at your request to access digital trading services.
If you ask, we may request Personal Data from you to forward to third-party companies

You have consented to the processing of your Personal Data for one or more purposes.

2. To respond to your requests, questions, or concerns
Personal Data is required to help us answer any questions you may have regarding the Services.

Processing is necessary for the Company's legitimate interests or those of a third party.

3. To comply with any legal, administrative, or judicial obligations, Personal Data is processed to meet applicable legal requirements.

Processing is necessary to comply with legal obligations.

4. Improving Our Services
We may use Personal Data to improve Our Services. This includes, among other things, crash or malfunction reports that we collect in connection with the Services.

Processing is necessary for the Company’s legitimate interests or those of a third party.

5. To prevent fraud and misuse of Our Services

Processing is necessary to pursue the Company’s legitimate interests or those of a third party.

6. To perform and manage activities that align with the requirements of Our Services
These activities include back-office operations, business development, strategic decision-making, and oversight mechanisms, among others.

Processing is necessary for the legitimate interests of the Company or those of a third party.

7. To conduct analyses, including statistical analyses
To make decisions on various matters, we employ a range of analytical techniques (including statistical ones).

Processing is necessary for the legitimate interests of the Company or those of a third party.

8. To safeguard our assets, rights, and interests, as well as those of third parties, we have implemented measures to establish and defend legal claims
Personal Data may be processed by us to safeguard our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, or agreements, and any relevant terms, conditions, or policies.

Processing is necessary for the legitimate interests of the Company or those of a third party.

6. Transfers of Personal Data to Third Parties

The Company may also share Personal Data with third-party companies that provide services to us, including hosting and storage providers, services that process IP address information, and user experience analytics providers.
You may also request that we provide specific Personal Data about you to third-party trading platforms. In such cases, we will provide the Personal Data you supply to us to those third-party platforms. The 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 affiliated entities or business partners to secure the resources needed to enhance and improve the products and services we provide to 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 Personal Data about you with potential investors or purchasers, or with lenders to the Company or any other company in our group, in connection with a relevant transaction (including the transfer or sale of assets of the Company or any other group company) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

ONLINE TRACKING NOTICE

We may engage third-party services, such as advertising providers on our website or analytics companies. These companies may also utilise cookies or other technologies.
Cookies are small text files placed on your device whenever you visit or access the website. They are used to gather information about your preferences and browsing habits to enhance your user experience, remember your settings, and customise the products and services you may find relevant. Cookies are also utilised for statistics and analytics.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and last for a short period of time until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period of time after you close your browser. They help the website recognise you as a returning user and enable you to return to the website.

7. Cookies and Third-Party Services

We may use them according to their purpose:

Type of cookie Scope Legal Basis
Type of cookie

Cookies are strictly necessary

Cookies are strictly necessary

These cookies are essential for you to access the features you’ve requested and to navigate our website with ease. We use them to deliver the information, products, and services you have asked us to provide.
They enable your device to download and stream data, allowing you to move around the site smoothly, utilise its features, and return to pages you’ve visited before.

Cookies collect personal data, such as your username and last login date, to confirm you are logged in to the site. They are deleted when you close your web browser (session cookies).

Type of cookie

Functionality Cookies

Scope

Cookies help us recognise you on each visit to our site and also save your settings and preferences.

Additional information

They remain in place until their expiry date and are retained even after the browser is closed.

Type of cookie

Cookies for performance

Scope

We use cookies to collect statistical data on site performance and to help enhance it. They also enable us to conduct analysis on our website.

Additional information

Cookies store anonymous data that is not linked to any identified or identifiable natural person. They can be removed when you close your browser. Some cookies persist indefinitely.

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 of the most widely used 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 respond to Do Not Track 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 law, regulations, policies, and applicable 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 confirm whether it remains necessary.

9. Transfers of personal data to a third country or an international organisation

Your personal information may be transferred to other countries—i.e., your personal data may be sent to a third country (a country other than the one in which you reside)—or to international organisations or jurisdictions. The Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data subjects can assert their rights and access effective legal remedies.
These protections and safeguards are available to all residents of 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, in accordance with Article 45(3) of Regulation 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 instrument between public authorities or bodies under Article 46(2)(a).
  • The transfer was carried out in accordance with the European Commission’s standard contractual clauses adopted under Article 46(2)(c) of the GDPR. The clauses adopted by the European Commission are available 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 it is transferred to third-party countries or international organisations. To request this information, please email us at info@aishugairiinvestments.com


10. Security of Your Personal Data

We have implemented appropriate organisational and technical measures to protect Personal Data. These measures include preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be error-free. Nor can we be held responsible for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure caused by transmission errors, unauthorised third-party access, or other events beyond our control.
In the event of legal requirements or other obligations beyond our control, we may be required to provide Personal Data about you to third parties, such as public authorities. We cannot control the level of security applied to your Personal Data by third parties in these situations.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company therefore cannot ensure the security of Personal Data you transmit to Us over the internet.

11. Hyperlinks to third-party websites and resources

Links to third-party sites and applications are provided on this website. These sites and apps are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken on 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 reviewing them 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 by posting the updated Policy on our website. In addition, where we make significant changes to this Policy, we will seek to inform you through methods we deem appropriate and will publish a notice on our website. Unless expressly stated otherwise, any amendments will take effect once the revised Policy is published.

Your rights in relation to your personal information

You are entitled 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 we do not require. You may also limit the scope or 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 can exercise your rights by emailing the address below. Access rights
The Company will 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. If requested, the data will be provided electronically.
The right of access must not conflict with the rights and freedoms of others. If your request would adversely affect another person’s rights and freedoms, the Company may refuse to comply or limit its response. Right to rectification
The Company will rectify inaccurate Personal Data. You have the right to request that any 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 are no longer necessary 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, based on your particular situation, to processing based on legitimate interests pursued by us or 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 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) for the establishment, exercise or defence of legal claims.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If processing is restricted, Personal Data may only be stored with your consent or 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 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. The right to data portability must not adversely affect the rights and freedoms of others.
Right to object
You may object at any time to processing of Personal Data concerning you that is 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 can demonstrate compelling legitimate grounds that override your rights, freedoms or interests, or for the establishment, exercise or defence of legal claims.
For direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.
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 concerning your Personal Data, as described in section 13. We will provide information in response to your requests under section 13 of this agreement within one month of receipt. Where necessary, this period may be extended by up to two further months depending on the complexity and number of requests. We will inform you within one month of receiving your request of any extension and the reasons for it.
Unless otherwise provided in section 13, information provided in response to your requests under section 13 will be supplied free of charge. If a request is unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have doubts as to the identity of the individual making the request, the Company may request additional information.