We (also referred to as 'we', 'us', or 'our') are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains 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 do so, we use various methods and procedures to provide relevant information about the use of 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 will provide any clarifications you need, subject to legal limitations. You can reach us by email at: info@svoboda-bitdex.com

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

Personal Data may be processed by us for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the "Services"), enhancing the site, protecting and safeguarding our rights and interests, supporting the ongoing maintenance and provision of the Services, meeting applicable regulatory and legal obligations, and conducting administrative, operational, and business activities to facilitate and support the delivery and use of the Services. Personal Data is also processed by us to better understand your preferences, behaviours, and needs more accurately.

To access essential tools to help protect your rights regarding Personal Data:

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 do so, we use various methods and procedures to provide you with 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 offer any clarifications you may need, subject to legal limitations. You can reach us via email at the address below: info@svoboda-bitdex.com

Protect Your Personal Data:

Although we cannot guarantee the absolute security of your Personal Data, we assure you we will continue to implement a variety of measures and safeguards to keep it protected. For full details, please refer to our Privacy and Security Policy.

1. The Scope?

This Policy explains the types of Personal Data the Company collects about natural persons and how we process it, share it with third parties, secure it, and related matters. This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, alone or in combination with 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 Personal Data. Our services are intended for general audiences and are not designed for individuals under 18. We do not knowingly seek or collect information from anyone under 18 years of age, nor do we knowingly permit such individuals 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 request your Personal Data in certain situations. In other cases, we collect your Personal Data by analysing the use of our Services and service channels, or by receiving your information from our third-party partners.

3. There is no obligation to disclose personal data to the company and the associated consequences.

However, you are not required to provide Us with any Personal Data. In certain circumstances, you may choose not to supply Us with such data. This may prevent Us from providing the Services or limit users' access to the Website.

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

This includes details about your online activity log and traffic data (such as your IP address and the date and time of access), the language you use, software crash logs, the type of browser, and information about the device you use. The information we collect is not personally identifying and cannot be used to identify you. Personal data we receive from you: any personal data you voluntarily 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: this may include your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

Your Personal Data is processed by the Company for the purposes described in this section and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot use Personal Data relating to you. The legal grounds on which the Company may process Personal Data relating to you:

• You have consented to the processing of your Personal Data for one or more purposes. 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 legitimate interests. For example, this may be necessary to improve Our Services or to defend against legal claims.
• Processing is necessary to comply with a legal obligation.

Contact us via email for more information about the 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. Disclosure of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, such as hosting and storage providers and analytics firms, including IP address information and analyses of user experience.
You may also request that we provide specific Personal Data about you to third-party trading platforms. In such cases, we will transmit the Personal Data you provide to Us to those third-party platforms. Their use of your Personal Data is governed by their own privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities or business partners. This helps us secure the resources needed to enhance and improve the products and services we provide to our customers.
Where necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other competent authorities.
We may additionally share your Personal Data with potential investors, buyers, or lenders of the Company or any company within our group of companies in connection with a contemplated 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 company within the group.

ONLINE TRACKING NOTICE

We may engage third-party services, such as advertising providers on our website or analytics companies. These partners may also use cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or access the website. They collect information about your preferences and browsing habits to enhance your user 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 last only for a short period 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 to return to the website.

7. Cookies and Third-Party Services

We may use them according to their intended purpose:

Cookies are blocked or have been removed
To block or remove cookies, adjust your browser settings. Below are links to help 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 functions and features may not work as expected if this occurs.

ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention of Your Personal Data

The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing described in this Policy, or for longer periods as permitted by applicable laws, regulations, internal policies, and relevant orders. We will share your information with third-party trading platforms for 12 months; with your consent, we will continue sharing it for an additional 12 months.
We regularly review the Personal Data we hold to confirm it is still needed.

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

Your personal information may be transferred to other countries (i.e., a third country other than the one in which you reside), to international organizations, or to other jurisdictions. The Company takes all necessary measures to safeguard the Personal Data you provide and to ensure that data subjects can exercise their rights and obtain effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or an 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 an enforceable, legally binding agreement between public entities or authorities under Article 46(2)(a).
• The transfer was carried out in compliance with the European Commission’s Standard Contractual Clauses adopted 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 transferred to third countries or international organisations. To request this information, please email us at info@svoboda-bitdex.com

10. Personal Data Security

We have implemented appropriate organizational and technical measures to safeguard Personal Data. These measures include preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
While we work to protect your Personal Data, we cannot guarantee or warrant error-free security. We also cannot be responsible for any intangible, 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 access by a third party, or other circumstances 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 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 cannot ensure the security of Personal Data you transmit to us over the internet.

11. Hyperlinks to websites owned or operated by third parties

Links to third-party websites and applications are available on this site. These sites and apps are not supervised by the Company. We are not responsible for the collection or processing of Personal Data by these parties. This Policy does not apply to activities conducted on such sites or apps.
When visiting any third-party website or app, we recommend reviewing their privacy policy before deciding to access or use their services. We also advise exercising caution before providing any Personal Data to them.

12. Changes to this Policy

This Policy may be updated at any time. If we change this Policy, we will notify you by posting the updated version on our website. Additionally, when we make significant changes to this Policy, we will try to inform you using methods we consider appropriate and will publish an announcement on our website. Unless expressly stated otherwise, any amendments will take effect upon publication of the revised Policy.

13. Your rights in relation to your personal data

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 of processing of your personal information. If you are an EEA resident, 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 can 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 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 upon request.
Your right of access must not conflict with the rights and freedoms of others. If a 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 may rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purposes of processing.Right to Erasure
You may request deletion of your Personal Data if: (a) it is no longer needed for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, for reasons related to your particular situation, to processing based on legitimate interests pursued by us or by a third party; (e) the Personal Data has 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 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. Where 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 reasons of important public interest in the European Union or a Member State.
Right to data portability
Where processing is automated and 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.
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 adversely 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 the Company’s or a third party’s legitimate interests, including profiling based on those interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.
For direct marketing, you have the right to object to the processing of your Personal Data at any time.
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 based on your 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 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 regarding your Personal Data, as described in section 13. We will provide the information requested under 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, we will inform you of any extension and the reasons for it.
Unless otherwise provided in section 13, information provided in response to your rights under section 13 will be 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 ask for additional information.