Gaimin values your privacy and is strongly committed to protecting your personal information.

This Privacy Policy tells you what to expect when we collect personal information from you. It also explains how we will store, handle and keep your personal information safe. This Privacy Policy (together with our Terms and Conditions and any additional terms of use, applies to your use of our websites, platform, applications, products, and services (regardless of where you visit us from). 

We keep our Privacy Policy under regular review to make sure it is up to date and accurate.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during our relationship with you.

Important Information about who we are: 

Our group of companies includes Gaimin Gladiators Ltd (Canada), GAIMIN.io Ltd (UK), GAIMIN LDA (Portugal) and GAIMIN AG (Switzerland) (collectively referred to as “our Group” in this policy). 

GAIMIN LDA is the controller for the personal information we process unless otherwise stated and is responsible for your personal information, collectively referred to as “we”, “us,” “our” or “Gaimin”. 

You can Contact us at: 

By post: 

Gaimin Gladiators Ltd: 80 Galaxy Boulevard, Unit 15, Etobicoke, M9W4Y8, Ontario, Canada

GAIMIN.io Ltd: 100 Barbirolli Square, Manchester, M2 3BD, UK

GAIMIN AG: Bahnhofstrasse 7, 6300, Zug, Switzerland

GAIMIN LDA: Rua José Alfredo da Costa Azevedo, Lisbon, 2635 585, Portugal

Email address: info@gaimin.io

General information 

All your personal information will be held and used in accordance with the relevant data protection laws. 

Your personal information may be stored in or accessed from multiple countries. Whenever we transfer personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by applicable data protection laws.

For individuals based in the UK, all personal information will be held and used in accordance with the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 and any other legislation relating to the protection of personal information.

For individuals based in the European Economic Area (EEA) and Switzerland, all personal information will be held and used in accordance with the General Data Protection Regulation (“EU GDPR”) and the Swiss Federal Data Protection Act and any other legislation relating to the protection of personal information. 

For individuals based in Canada, all personal information will be held and used in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and any other legislation relating to the protection of personal information.

If you are located outside of  the United Kingdom, the EEA or Switzerland, or Canada, you may have certain rights and protections under applicable laws regarding the processing of your personal information. No matter which country you are accessing our services from, we will use appropriate safeguards to protect your personal information in accordance with this Privacy Policy and the applicable data protection laws. 

Changes to our Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on our website (www.gaimin.io) and, where appropriate, notified to you by e-mail. 

Please check back frequently to see any updates or changes to our Privacy Policy.

Third-party Links

Websites, plug-ins and applications may include links enabling third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or policies. 

We encourage you to read the Privacy Policy of every website you visit.

Collection of your Personal Information

We use different methods to collect information from and about you.

We collect personal information to provide you with services. We also collect personal information when you visit our website, platform, applications or contact us by email or via social media.

Personal Information That We Collect and Process. 

When you provide personal information to us, we will treat that information in accordance with this Privacy Policy.

Personal information or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

Personal information we may collect, use, store and transfer about you, which we have grouped together, are as follows:

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Identity Data includes first name, last name, username or similar identifier, title.

• Financial Data includes bank account and / or payment card details.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• Usage Data includes information about how you use our website, products, and services. 

‍

Most of the personal information we process is provided to us directly by you for the purpose of providing you with our services. You provide us with personal information and other information which is necessary to provide the services requested and to register you as a member on our platform. 

Where we perform our due diligence checks, and to perform our obligations under Know Your Customer (KYC) We may also receive from you, information including: 

• passports,
• identity cards, driving license and
• utility bills that confirm your identity and / or otherwise prove proof of your home address;
• source of income document (payslip, invoice)
• as well as any other additional documentation as deemed necessary by us.

We collect and process your personal information through your use of your account, including any information you may provide through this website, platform or application or when you correspond with us by phone, email, live chat, social media or otherwise. 

We use your information to provide you with the services requested, to follow-up requests from you, to verify your identity, including for our KYC obligations, to contact you when necessary, or when you use other social media functions on our website, platform or applications, or when you enter a competition, promotion, or survey, and / or when you report a problem with our website, platform or application. 

We may also use information to match you with content that is associated with your interests and to direct you to additional resources and tools that can save you time. We may also use this information to send you our electronic newsletter, other information and content.

This list is not exhaustive, and, in specific instances, we may need to collect additional information for the purposes set out in this Privacy Policy.  

Sensitive Information 

Sensitive information or Special Category Data is information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics   or genetic characteristics, criminal background or trade union membership (“Special Category Data”).

We may receive Special Category Data from third party service providers and others in support of due diligence activities we undertake to satisfy various legal and regulatory requirements to which we are subject.

Financial information 

We process your financial information for payments, including where you purchase our GMRX tokens,  and for onboarding and ongoing client checks, due diligence and verification requirements, and tax reporting.

Payment Card information: 

We may process your personal information to process any payments made for the provision of services. The information may include information for identification and verification, such as your name, account number and sort code, or credit, debit or other card number, card expiration date, and CVV code.

Any payment transactions carried out by us, or our chosen third-party provider of payment processing services will be kept securely. 

Member Account Information 

Some personal information is required to set up your Gaimin Members account, whether you set up your account on the website, online or via the platform, personal information including your name, contact details, and email address will be required.

We may also process information about your browser type, settings and information about how and when you used our services, information about the type of device and/or operating system you are using, which videos you have watched, what content you like or share, and which adverts you saw and responded to. 

Information Received from Third Parties

This is information we receive about you from third parties, for example we receive information from third parties who provide services to us or you, including where appropriate from our partners, or our Group companies. 

We will only use this information and the combined information where we have a lawful basis.

We sometimes combine information received from other sources with information you give to us and information we collect about you. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Any information obtained from third parties will be kept in accordance with this Privacy Policy, and with any additional restrictions imposed by the third party that shared your personal information.

If You Fail to Provide Personal Information

Where we need to collect personal information by law, legitimate interest or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with the services requested). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

How We Use the Information We Collect

Data Protection Laws set out a number of different reasons for which a company may collect and process your personal information.

We will only use your personal information when the law allows us to do so. The lawful basis that we most commonly use to collect and process your personal information are:

• Where you have consented before the processing.
• Where we need to perform a contract, we are about to enter or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

In certain circumstances, we need your personal information to comply with our contractual obligations or to pursue our legitimate interests in a way which might be reasonably expected as part of running our business. 

For example, we use your personal information for, but not limited to the following purposes:

• For the purposes of setting up an account on our platform,
• For the purposes of managing our relationship with you, including your membership and account, 
• To respond to your queries and/or requests you send us to use/receive any of our services (including customer support services)
• To inform our members and potential members about products or services which we believe may be of interest, including marketing proposals or offers. 

Additionally, we and our service providers may use personal information to comply with our contractual obligations we have with you, or to enforce our agreements, including investigation of any potential violations of our terms.

We may use personal information where we need to comply with a legal or regulatory obligation to detect, prevent or otherwise address economic criminal activity (including financial crime, fraud, money laundering etc). 

Whenever you have given us your consent to use your personal information, you have the right to change your mind at any time and withdraw that consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Marketing 

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. 

If you have given your consent to receive marketing emails you can withdraw this at any time, or if we are relying on our legitimate interests to send you marketing you can object. In either case, just let us know. If you have received a direct marketing email from us and no longer wish to do so, the easiest way to let us know is to click on the unsubscribe link at the bottom of our marketing emails.   

Cookies 

When you visit our website, we may collect certain information by automated means, such as using cookies. 

A cookie is a piece of data stored locally on your computer containing information about your activities on the Internet. Each website can send its own cookie to your web browser if your browser's preferences allow it. Many websites do this whenever a user visits their website in order to track online traffic flows.

For more information about our cookies, what cookies we use and why we use them, please see our cookies policy on our website (www.gaimin.io).

Information We Share

Personal information may be shared or disclosed to trusted third parties in connection with the services we are providing. For example, we may share your personal information with a third party cryptoasset wallet for the transfer of a digital asset, or where we have employed other companies to perform functions on our behalf.  

We may also share your personal information with any member of our Group. Where we share your personal information within our Group, it is only to the extent required and always with the appropriate safeguards in place, so that we can provide you with the relevant services,

Where personal information is shared with a third-party supplier, we work closely with them to ensure that your personal information is secure and protected at all times. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. 

Our contracts with third parties make it clear that they must hold personal information securely, abide by the principles and provisions of data protection laws, and only use information as we instruct them to. 

In all instances where we disclose your information to third parties, we will ensure that your information is appropriately protected. If we stop using their services, any of your personal information held by them will either be deleted or rendered anonymous.

If we are required to do so by law, or in performance of our legal obligations, we may share your data with courts, law enforcement agencies or other governmental agencies.

Where Your Personal Information May Be Processed

Your personal information may be stored in or accessed from multiple countries, including the UK, EEA, Switzerland, and Canada. Transfers may also take place within the country where you live or to outside that country. All transfers are made to provide the services and for the purposes listed in this Privacy Policy. 

If we do undertake transfers, we have procedures in place to ensure your personal information receives the protections as stipulated by the relevant data protection laws. For example, our contracts with third parties stipulate the standards they must follow at all times.

For all transfers of your personal information to other jurisdictions, we will ensure that the information is transferred in accordance with this Privacy Policy  and as permitted by applicable data protection laws. 

How Long We Will Retain Your Personal Information

We will only retain your personal information for as long as is necessary for the purpose or purposes for which we have collected it.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

In some circumstances we will anonymise your personal information (so that it can no longer be associated with you) for analytical or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Data Security 

We work hard to keep your information safe. We use a combination of technical, administrative, and physical controls to maintain the security of your personal information and protect against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.  

All information you provide to us is stored on secure servers . Some of the controls we have in place to protect your personal data include technological controls such as firewalls, user verification, and strong data encryption. We utilise industry best practice standards to support the maintenance of a robust information security management system. 

We have put in place procedures to deal with any suspected personal information data breach and will notify you and any applicable regulator when we are legally required to do so.

Your Rights 

You are also able to exercise your rights which include: 

• Your Right to be Informed  

We aim to be transparent within our Privacy Policy and provide you with information about how we use your personal information.

• Your Right to Object

In some circumstances you can stop the processing of your personal information for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal information. 

Where your details are used for marketing, you can opt out at any time. You are able to unsubscribe from marketing on each contact or you can contact us to object to any processing.

• Your Right to Rectification 

You have the right to request the correction of your personal information when it is incorrect, out of date or incomplete. If you notify us that the personal information we hold is incomplete or inaccurate we will correct or complete the information as soon as possible. 

• Your Right to Erasure or the Right to be Forgotten

You have the right to request that your personal information be deleted; including if we no longer need it for the purpose we collected it, you withdraw your consent or you object to its processing.

Following your request, we will erase your personal information without undue delay unless the continued retention is necessary and permitted by law. If we make the personal information public, we shall take reasonable steps to inform other data controllers processing about your erasure request.

• Your Right to Restrict Processing

You have the right to request that we restrict the processing of your personal information. This can be done in circumstances where we need to verify the accuracy of the information, if you do not wish to have the information erased or you have objected to the processing of the information, and we are considering this request. Once the processing is restricted, we will only continue to process your personal information if you consent, or we have another legal basis for doing so.

• Your Right to Access

You have the right to access the personal information we hold about you. Any access request will usually be free of charge and responded to within one month. We will endeavour to provide information in the format requested, but we may charge you a reasonable fee for additional copies. 

• Your Right to Data Portability

You have the right to receive a copy of your personal information which you gave to us. The copy will be provided in a commonly used and machine-readable format.  You can also have it transmitted directly from us to another data controller, where technically possible.

• The right not to be subject to automated decision making and profiling.

You have the right to not be subject to solely automatic decisions (i.e. decisions that are made about you by computer without any human input) in relation to any processes that have a legal or similarly significant effect on you. 

You will be notified if we make a solely automated decision which produces a legal effect or significantly affects you.

When you request to exercise your rights

You will not have to pay a fee to exercise any of the rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded or excessive, including where requests are repetitive. Alternatively, we could refuse to comply with your request in these circumstances.

If you have any questions about our use of your personal information, you can contact us at info@gaimin.io or by post using our postal address.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How can we help? 

For further information on data protection please visit the Information Commissioner Office (ICO) website.

The Information Commissioner Office regulates data protection. If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113 or visit the website.