We ('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 in how we collect and process your personal information:

We want you to be able to make informed choices 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 you with 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 provide clarifications, subject to any legal limitations. You can reach us by email at: info@greyhaven-finflow.com

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

Personal Data may be processed by Us 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, facilitating the maintenance and delivery of the Services, complying with legal and regulatory obligations, and conducting administrative and business activities to support the provision and use of the Services. We also process Personal Data to better understand your preferences and needs.

To make use of key tools to protect your rights in relation to Personal Data:

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

Protect Your Personal Information:

While we cannot guarantee the absolute security of your Personal Data, we will continue to employ a range of methods and techniques to ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy describes the types of Personal Data the Company collects about natural persons, and how we process it, share it with third parties, and secure it through appropriate safeguards. 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 through additional information we hold or are able to access. The Policy defines ‘processing’ as any operation that requires the use or collection of Personal Data, including the management, organisation, and storage of such data. Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly solicit or collect information from anyone under 18, and we do not knowingly permit such persons to use our services. If we learn that we hold information about a child, we will delete it as soon as reasonably practicable.

2. What Personal Data Do We Hold About You?

When you use our services or channels, or visit our website, we collect Personal Data about you. We may ask you to provide your Personal Data in certain cases. We also collect such data by analysing your use of our Services and service channels, or by receiving information about you from our third-party partners.

3. There is no requirement to provide personal information to the company and the consequences of not doing so.

You are not obliged to provide us with any personal data. However, in certain circumstances, not providing personal data may prevent us from offering the Services or may limit users’ access to the website.

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

This includes details of your online activity logs and traffic data (such as IP address and the date and time of access), the language you use, software crash logs, the type of browser used, as well as information about the device you utilise. 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 includes 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 set out in this section, in accordance with the applicable legal basis.
Without such a legal basis, the Company cannot use Personal Data about you. The legal grounds on which the Company may process your Personal Data are:

• You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information on the Website so 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 legal claims.
• Processing must comply with a legal obligation.

Contact us by email for more details about the processing required to protect our legitimate interests.
Below is a list of purposes and legal grounds for which we may use the Personal Data you provide.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, including hosting and storage partners, for purposes such as processing IP address information and analysing user experience.
You may also request that we transfer 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. 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 share Personal Data with affiliated entities or business partners to access the resources needed to enhance and improve the products and services we provide to customers.
Where it is 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 also share Personal Data about you with potential investors, purchasers, or lenders of the Company or any other company within our group in connection with a 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 insolvency of the Company or any other business within the group.

ONLINE TRACKING NOTICE

We may use third-party service providers, such as companies that serve advertising on our website or provide analytics. These providers 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 behaviour to enhance your experience, remember your settings, and customise the products and services you might enjoy. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only for a short time, ending when 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 site.

7. Cookies and Services from Third Parties

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. The links below provide guidance 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 functions 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 about You

The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing, as described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and orders. We will share your information with third-party trading platforms for 12 months. If you agree to this, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to ensure we do not retain it longer than necessary.

9. Cross-border transfers of personal information to a foreign country or an international organisation

Your personal information may be transferred to other countries, including to third countries (i.e., countries 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 ensures that data subjects can exercise 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 international organisation recognised by the European Commission as ensuring 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')
• 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 compliance 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 information on the security measures it applies to protect your Personal Data when it is transferred to third countries or international organisations. Please send an email to info@greyhaven-finflow.com

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect Personal Data. This includes 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 maintained without error. Nor can we be held liable 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 of Personal Data due to transmission errors, unauthorised access by a third party, or other causes 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 circumstances.
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 via the internet.

11. Hyperlinks to websites belonging to third parties

Links to third‑party sites and applications may be available on this website. These sites and apps are not under the Company’s control. We are not responsible for the collection or processing of Personal Data by such sites or apps. This Policy does not apply to activities conducted on those sites or apps.
When you visit any third‑party site or app, we recommend reading its privacy policy before choosing to access or use it. We also suggest that you only provide Personal Data to them after reviewing those policies.

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 version on our website. In addition, for significant changes to this Policy, we will attempt to inform you through methods we deem appropriate and will also publish a notice on our website. Unless explicitly stated otherwise, any amendments will take effect upon publication of the revised Policy.

13. 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 we do not require. You may also restrict specific types or purposes of processing your personal information. If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You can exercise them by emailing the address below.Access rights
The Company can confirm whether Personal Data about you are 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. Data will be provided electronically if you request it.
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 the request or limit how it is fulfilled.Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to request that incomplete Personal Data concerning you be completed, taking into account the purposes of processing.Right to Erasure
You may request erasure of your Personal Data if: (a) the 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, on grounds relating to your particular situation, to processing based on legitimate interests pursued by us or a third party; (d) the Personal Data have been unlawfully processed; or (e) the Personal Data must be erased to comply with a legal obligation of the Company. This right does not apply where processing is necessary (i) to comply with a legal obligation under European Union or Member State law; or (ii) for the establishment, exercise, or defence of legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, or otherwise request restriction, you may ask the Company to limit processing of your Personal Data. While restricted, Personal Data may be stored and processed only with your consent, for the establishment, exercise, or defence of legal claims, to protect the rights of another natural person, or for 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 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 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 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 interests, rights, and freedoms, or the processing is 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 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 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 regarding the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights regarding Personal Data as described in this section 13. We will provide information in response to your requests 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.
Unless otherwise provided in section 13, information provided in response to your requests 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 or refuse to act.
If we have reasonable doubts about the identity of the person making the request, the Company may request additional information.