Privacy Policy

We are committed to being transparent about how we collect and process your personal information:

We want you to make informed decisions about how your Personal Data is used and processed. To support this, we use various methods to keep you informed about how your Personal Data is handled.
Where specific information is relevant to you, we will provide it at the appropriate time.
We welcome any questions you may have and will clarify any limitations imposed by law. You can reach us by email at the address below: info@dunegainex.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for the following purposes: to provide the website and connect you with third-party trading platforms (the "Services"); to improve the site and protect our rights and interests; to support the maintenance and delivery of the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities necessary for the Services to function. We also process your personal data to better understand your preferences and needs.

To exercise your rights in relation to your Personal Data, you have access to the following tools:

To exercise your rights, contact us at any time to submit a request regarding your personal data. We can update or delete your personal data, restrict its use for specific or general purposes, or transfer it to you or a third party. We will accommodate your request accordingly.

Protect Your Personal Data:

While we cannot guarantee the absolute security of your personal data, we are committed to employing a variety of methods and techniques to keep it protected.
Our Privacy and Security Policy is complete.

1. The Scope?

This policy describes the personal data the Company collects about natural persons, how it processes that data, and how it is shared with third parties and secured.
This policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or through a combination of additional information the Company holds or can reasonably access.
"Processing" refers to any operation involving the use or collection of personal data, including its organisation, structuring, and storage.
Our services are intended for users aged 18 and older. We do not knowingly collect information from persons under 18 or permit them to use our services. Any such information discovered will be deleted promptly upon becoming aware of it.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect personal data. This may occur directly — when you provide it to us — or indirectly, through analysis of how our services and channels are used, or via information received from our third-party partners.

You are not required to share personal information with us. However, choosing not to may limit our ability to deliver our Services or grant you access to the website.

Providing personal data is not mandatory. However, declining to do so may prevent us from delivering the Services or restrict access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes information collected automatically when you visit our platform: your online activity log, traffic data (including IP address, access dates and times), language settings, software crash logs, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data we receive from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through us.
Personal information shared with 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

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties in the following circumstances: With service providers and business partners who assist us in operating our platform, processing transactions, or delivering services to you. These third parties are contractually required to handle your personal data securely and only for the purposes for which it was shared. With regulatory authorities, law enforcement agencies, or other government bodies where disclosure is required by applicable law or regulation. With successor entities in the event of a merger, acquisition, or sale of all or part of our business assets, provided your personal data remains protected under equivalent terms. With your explicit consent, where you have agreed to the transfer of your personal data to a specified third party for a stated purpose. Where personal data is transferred to third parties located outside your jurisdiction, we take appropriate measures to ensure that such transfers comply with applicable data protection requirements and that your personal data receives a comparable level of protection. We do not sell your personal data to third parties for their own marketing or commercial purposes.

We may share Personal Data with third-party service providers who support our operations, including hosting and storage providers and user experience analytics services.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be provided to those platforms as directed, and its use will be governed by their respective privacy policies. Your Personal Data may be shared with more than one trading platform.
We may share Personal Data with related entities or business partners where doing so supports the development and improvement of our products and services.
Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data with prospective investors, buyers, or lenders in connection with any transaction involving the Company or another entity within the group — including the transfer or sale of assets, or any merger, restructuring, consolidation, or insolvency process — whether relating to the Company or any other entity within the group.

7. Cookies and Third-Party Services We use cookies and third-party services on our website. These may collect and process certain information about you in accordance with their own privacy policies. By continuing to use our website, you acknowledge and consent to the use of such cookies and services. Third-party providers integrated into our platform may set their own cookies or use similar tracking technologies to collect data about your browsing behaviour. We do not control how these third parties collect, store, or use your data. You should review the relevant third-party privacy policies directly to understand their practices. You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of our website or the availability of specific features.

We may engage third-party services, such as advertising providers and analytics companies, to support the operation of our website. These companies may also use cookies or similar technologies. Cookies are small text files placed on your device when you visit or access the website. They are used to gather information about your preferences and browsing habits, improve your user experience, and customise the products and services presented to you. Cookies are also used for statistical and analytics purposes. Some cookies we use are session cookies — temporary files downloaded to your device that expire once you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies help the website recognise you as a returning user and enable a smoother experience on subsequent visits.

Types of Cookies:

We may use them based on their purpose:

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods where permitted by applicable law, regulation, or order.
Your information may be shared with third-party trading platforms for up to 12 months. With your consent, this sharing will continue for a further 12 months.
We periodically review the personal data we hold to confirm it is no longer required.

9. Transfers of Personal Information to a Third-Party Country or International Organisation Where we transfer personal information to a third-party country or international organisation, we ensure appropriate safeguards are in place to protect that information in accordance with applicable data protection requirements. Such transfers are carried out only where permitted by law and subject to the necessary contractual or legal protections.

10. Security of Personal Data We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. While we apply industry-standard safeguards, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security, but we continually review and update our security practices to address emerging risks. Access to your personal data is restricted to employees, contractors, and service providers who require it to perform their functions. All such parties are bound by confidentiality obligations and may only process personal data in accordance with our instructions. In the event of a personal data breach that poses a risk to your rights and freedoms, we will take prompt action in accordance with our obligations, including notifying the relevant supervisory authority and, where required, affected individuals. You are responsible for keeping your account credentials confidential. If you suspect any unauthorised access to your account or personal data, contact us immediately.

We have implemented appropriate organisational and technical measures to protect personal data, including against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your personal data will be maintained without error, nor can we accept liability for any intangible, incidental, or consequential damages arising from the use or disclosure of personal data. This includes, but is not limited to, personal data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our control.
Where required by 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 have no control over the security measures those third parties apply to your personal data.
Personal data cannot be transmitted over the internet with complete security. We cannot guarantee the security of personal data you transmit to us online.

11. Hyperlinks to Third Party Websites

Our website contains links to third-party websites and applications. These sites and apps are not under the Company's supervision, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through third-party sites or apps.
Before accessing or using any third-party website or app, we recommend reading their privacy policy carefully before sharing any Personal Data with them.

12. Modifications to this Policy We may update this Policy from time to time. Any changes will be posted on this page, and where appropriate, we will notify you directly. Continued use of our services after changes are published constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed of any updates.

Before visiting any third-party website or app, read their privacy policy carefully. Only provide your personal data to them once you are satisfied with how it will be handled.

13. Your rights with respect to your personal information You have the following rights regarding your personal information, subject to applicable law: Right of access. You may request confirmation of whether we process your personal information and, if so, obtain a copy of that information along with details about how it is processed. Right to rectification. You may request that we correct any inaccurate personal information we hold about you, or complete any incomplete records. Right to erasure. In certain circumstances, you may request that we delete your personal information. This right is not absolute and may be subject to legal or regulatory obligations that require us to retain specific data. Right to restriction of processing. You may ask us to restrict the processing of your personal information in certain situations — for example, while the accuracy of your data is being contested. Right to data portability. Where processing is based on your consent or a contract, and is carried out by automated means, you may request that we provide your personal information in a structured, commonly used, and machine-readable format. Right to object. You may object to the processing of your personal information where we rely on legitimate interests as the legal basis, unless we can demonstrate compelling grounds that override your rights. Right to withdraw consent. Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal. Right to lodge a complaint. You have the right to lodge a complaint with the relevant supervisory authority if you believe your personal information has been processed in a manner that does not comply with applicable data protection law. To exercise any of these rights, please contact us using the details provided in this policy. We will respond to your request within the timeframes required by applicable law. We may need to verify your identity before processing your request.

You have the right to request that we verify the accuracy of Personal Data collected about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also restrict the types or scope of processing applied to your personal information.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, please submit your request by email to the address below.
Access rights
The Company can verify whether your Personal Data is being processed. If it is, you may access that Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be provided electronically upon request.
The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would be detrimental to the rights or freedoms of another person, the Company may refuse or limit its response.
Right to rectification
The Company will correct inaccurate Personal Data upon request. You may also request that incomplete Personal Data be completed, taking into account the purpose for which it is processed.
Right to Erasure
You may request erasure of your Personal Data where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) erasure is required to comply with a 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) to establish, exercise, or defend 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 only be retained with your consent, or for the establishment, exercise, or defence of legal claims, for the protection of the rights of another person, or for reasons of substantial public interest within 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 a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used format.
You may request that your Personal Data be transferred 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 have the right to object at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or where processing is not necessary for the establishment, exercise, or defence of legal claims, we will cease such processing.
Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data for that purpose.
Right to withdraw consent
You may withdraw your consent to the processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to that withdrawal.
You have the right to lodge a complaint with a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit the rights described in this section.
We will respond to requests submitted under the rights in this section within one month of receipt. Where necessary, and depending on the complexity or volume of requests, this period may be extended by up to two additional months. We will notify you of any extension, and the reasons for it, within one month of receiving your request.
Unless otherwise provided under this section, information provided in response to your rights requests will be supplied free of charge. Where requests are unfounded or excessive, particularly where they are repetitive, we may charge a reasonable administrative fee or decline to act on the request.
Where we have reasonable doubts about the identity of the person submitting a request, we may ask for additional information to confirm identity.