We (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 are committed to the following principles:

To ensure transparency in the collection and processing of your personal information:

Our goal is to put you in a position to make informed decisions about the use and processing of Personal Data. That is why we created this website. To achieve this, we use various methods and procedures to provide clear, relevant information about the use of Personal Data. If we believe you require specific details, we will provide that information at the appropriate date and time. We are happy to answer any questions you may have and will provide any clarifications you require, subject to any limitations imposed by law. You can reach us by email at: info@brilho-finlore.com

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

Personal Data may be processed by us for a range of purposes, including providing access to the website, 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, complying with regulatory and legal obligations, and carrying out 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 access essential tools designed to safeguard your rights in relation to Personal Data:

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

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we remain committed to employing a range of methods and techniques to ensure it is protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy explains the types of Personal Data the Company collects about individuals and how we process it, share it with third parties, and keep it secure. It concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including by reference to additional information we hold or can 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 a general audience and are not designed for anyone under 18 years of age. We do not knowingly collect information from persons under 18, nor do we knowingly permit them to use our services. If we become aware of information about children, we will delete it as promptly as possible.

2. What personal data do we hold about you?

When you use our Services and channels or visit our website, we collect Personal Data. In some situations, we may ask you to provide Personal Data. In other instances, we collect Personal Data by analysing how you use our Services and channels, or by receiving information from our third-party partners.

3. No requirement to disclose personal information to the company and the potential consequences.

You are not required to provide Us with Personal Data. In certain circumstances, however, you may choose not to share any Personal Data. Doing so may prevent Us from delivering the Services or may limit 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 and traffic data (such as IP address and the date and time of access), your language settings, software crash logs, the type of browser used, and information about the device you use. The information we collect is not personal 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 with a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading includes your full name, address, phone number, and email address.

5. Legal basis and reasons for the processing of Personal Data

Your Personal Data is processed by the Company for the purposes described in this section, in line with the applicable legal basis.
Without a valid legal basis, the Company cannot process Personal Data about you. The legal grounds on which the Company may process your Personal Data are:

• You have consented to the processing of your Personal Data for one or more reasons. This applies when you submit personal information 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 their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
• Processing must fulfil a legal obligation.

Contact us by email for further details on the processing required to protect legitimate interests.
Below is a list of purposes and legal bases under which we may use the information you provide to us. Personal Data.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, including hosting and storage providers and providers of IP address information and user experience analytics.
You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you submit to us to those third-party platforms. Their use of your Personal Data is subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to access resources that help us 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 or purchasers, or with lenders to the Company or any other company within the group, in connection with a transaction (including the transfer or sale of assets of the Company or any other company within the group) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

ONLINE TRACKING NOTICE

Third-party services, such as advertising providers on our Website and analytics companies, may be used. These providers 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 behaviour to enhance your user experience, remember your settings, and tailor products and services you may find relevant. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and last only until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and make it easier for you to come back to the site.

7. Cookies and Third-Party Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To block or remove cookies, you'll need to adjust your browser settings. Below are links to guide you through the process for several of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that some or all of the Website's features and functionality may not work as expected if this occurs.

ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention of personal data concerning You

The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing, as described in this Policy, or for longer periods as permitted by laws, regulations, policies, and applicable orders. We will share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue to share your data for another 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 an international organisation

Your personal information may be transferred to other countries, including to a third country (a country other than the one in which you reside), or to international organizations. The Company takes all necessary steps to safeguard the Personal Data you provide and ensures that data subjects can assert their rights and access effective legal remedies.
These protections and safeguards apply to all residents of the EEA (European Economic Area).

• Transfer to a third country or an international organisation that the European Commission has determined provides 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, enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
• The transfer was carried out in accordance with the standard data protection 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 of 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 email info@brilho-finlore.com

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect Personal Data. These measures aim to prevent 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 liable for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised third-party access, or other causes beyond our control.
In the event of legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot control the level of security those third parties provide for your Personal Data.
No method of transmitting Personal Data over the internet is completely secure. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to external websites operated by third parties

This website includes links to third-party websites and applications. These sites and apps are not supervised or controlled by the Company. We are not responsible for the collection or processing of Personal Data by those websites or apps. This Policy does not apply to activities carried out on such sites or apps.
When visiting any third-party site or app, we recommend that you read its privacy policy before deciding to access or use it. We also suggest that you provide any Personal Data to them only after reviewing their policies.

12. Amendments to this Policy

This Policy may be updated at any time. If we make changes, we will notify you by posting the updated Policy on our website. Additionally, for significant modifications, we will attempt to inform you through methods we consider appropriate and will publish a notice on our website. Unless expressly stated otherwise, amendments take effect upon publication of the revised Policy.

13. Your rights regarding your personal data

You are entitled to request that we verify the accuracy of the Personal Data collected about you, correct any inaccuracies, and delete any Personal Data that is not required by Us. You may also restrict the types and scope of processing of your personal information. If you are a resident of the EEA, please refer to this page:
These rights are available to you with respect to the information you provide in relation to your Personal Data. You may exercise your rights by sending an email to the address below. Access rights
The Company can verify whether Personal Data about you is being processed. If so, you are entitled to 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.
The right of access must not conflict with the rights and freedoms of others. If fulfilling your request would adversely affect another person’s rights and freedoms, the Company may refuse the request or limit its ability to fulfill it. Right to rectification
The Company is obliged to rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be completed, taking into account the purposes of the processing. Right to erasure
The following grounds apply: (a) 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 at any time, 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) Personal Data have been processed unlawfully; or (f) Personal Data must be erased 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 defense of legal claims.
Processing restrictions
If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If processing is restricted, Personal Data may be stored only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or for important reasons of public interest in the European Union or a Member State.
Right to data portability
If processing is carried out by automated means and is based on your consent or 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, machine-readable format.
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 alter your right to erasure and does not affect the rights or freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Unless the Company demonstrates compelling legitimate grounds for processing that override your rights, freedoms, and interests, or for the establishment, exercise, or defense of legal claims, the Company will cease such processing.
For direct marketing, you have the right to object at any time to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent for Us to process your Personal Data at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.
You are entitled 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 regarding the processing of Personal Data within the European Union.
Laws of the European Union and Member States may limit your rights concerning Personal Data as described in section 13. We will provide the information requested under the rights in section 13 within one month of receiving your request. This period 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, the Company will inform you of any extension and the reasons for it.
Unless otherwise provided in section 13, information provided pursuant to your rights under section 13 will be supplied free of charge. If a request is unfounded or excessive, particularly if repetitive, the Company may charge a reasonable fee to cover administrative costs or decline to act.
If the Company has doubts about the identity of the person making the request, it may ask for additional information.