Privacy Policy

1. Data controller

1.1 ForeGate is the entity responsible for processing the personal data of ForeGate users.

1.2 ForeGate users can contact the data controller via email to raise any questions or get clarification regarding personal data protection: [e-mail].

2. Principles of Personal Data Protection

ForeGate adheres to the fundamental data protection principles established by the General Data Protection Regulation (GDPR) and other applicable laws. Our commitment includes:

• Lawfulness, Fairness & Transparency

Your personal data is processed legally, fairly, and with full transparency about how and why it is used.

• Purpose Limitation

Data is collected only for explicit, legitimate purposes and is never processed in ways incompatible with those purposes.

• Data Minimization

We collect strictly necessary, relevant, and appropriate data, avoiding excessive or irrelevant information.

• Accuracy

Inaccurate or outdated data is promptly corrected or deleted to maintain reliability.

• Storage Limitation

Personal data is retained only as long as necessary to fulfill its intended purpose.

• Integrity & Confidentiality

We implement robust security measures (technical and organizational) to safeguard your data, ensuring its confidentiality and protection against unauthorized access or breaches.

3. Concepts/definitions

3.1 Personal Data

Any information that directly or indirectly identifies a natural person, including but not limited to:

• Names and identification numbers

• Location data and electronic identifiers

• Physical, physiological or genetic characteristics

• Mental, economic, cultural or social identity markers This applies regardless of the format or medium in which the information exists.

3.2 Data Subject

A natural person whose personal data is being processed. For ForeGate's operations, this includes:

• Website and application users

• Clients and customers

• Employees and contractors

• Service providers and suppliers

3.3 Personal Data Processing

Any operation or set of operations performed on personal data, whether automated or manual, including:

• Collection, recording and organization

• Storage, modification and retrieval

• Use, disclosure and transmission

• Comparison, restriction or deletion, and/or destruction. This comprehensive definition covers all data handling activities conducted by ForeGate.

4. Use of your personal information

We process personal data to:

• Operate and maintain our website, including monitoring usage and ensuring security

• Communicate with you via email, phone, SMS, or app notifications regarding:

  • Service updates and functionality changes

  • Security notices

  • Responses to your inquiries

• Fulfill legal and regulatory obligations

• Enhance our services through:

  • Usage analysis and trend identification

  • Website and service improvements

  • Marketing optimization and user experience development

4.1 Consent

• We obtain consent for collecting and using personal information, with the form varying by circumstance

• By agreeing to our Privacy Policy and Terms, you consent to the described data practices

• We may process data without consent when permitted by law

4.2 Information Sharing

We may share your information with:

• Affiliated companies and trusted service providers for operational purposes

• Legal and regulatory authorities when required

Additional disclosures may occur when:

• Enforcing our Terms and Conditions

• Protecting against legal liability

• Responding to legal proceedings or government requests

• Safeguarding company security and integrity

• Undergoing business transitions (mergers, acquisitions, bankruptcy, etc.)

5. Personal data category

5.1 Data Classification

ForeGate processes different types of personal data, with varying levels of sensitivity, according to the specific business activity and processing purpose involved.

5.2 Data Categories

The personal data we process may include, but is not limited to:

Basic Identification Data:

• Full name

• Signature

• Government-issued identification numbers

Contact Information:

• Physical address

• Email address

• Telephone number

• Professional contact details

Digital Identifiers:

• IP addresses

• Device information

• Cookie data and online identifiers

Financial Information:

• Payment details

• Transaction records

• Billing information

Technical Usage Data:

• Website interaction logs

• Service usage patterns

• Preference settings

6. Purposes of processing the data and legal grounds

6.1 Purpose-Limited Processing

ForeGate processes user personal data exclusively for defined, legitimate purposes. Subsequent processing will never diverge from these original purposes.

6.2 Data Minimization Principle

We collect and process only the essential personal data required to achieve our specified purposes, adhering to strict necessity and proportionality standards.

6.3 Processing Purposes and Legal Grounds

We process personal data for the following key purposes:

Core Service Operations

• Website/Application Access Management: Processing necessary to enable platform functionality and service delivery (Legal Basis: Contractual Necessity)

• Financial Compliance: AML/CTF screenings, fraud prevention, and regulatory obligations (Legal Basis: Legal Compliance)

• Customer Support: Addressing user inquiries and resolving service issues (Legal Basis: Legitimate Interest)

Communication & Engagement

• Marketing Communications: Product/service promotions via electronic channels (Legal Basis: Consent/Legitimate Interest)

• Event Participation: Competition invitations and special event coordination (Legal Basis: Consent)

Business Operations

• Information and quality management systems

• Complaint and incident resolution procedures

• External communications dissemination

• Accounting and financial administration

• Payment processing and verification

Security & Compliance

• IT support request handling

• Information security controls and access management

• System logging and backup administration

• Security incident response

• Audit processes (internal/external)

Additional Processing

• Conflict resolution and litigation management

• Statistical analysis and business intelligence

• Other legitimate business interests

*We ensure all processing activities maintain appropriate legal grounds, whether based on:

• Contractual requirements

• Legal obligations

• User consent

• Legitimate business interests

7. Personal data recipients

7.1 Disclosure to Third Parties

In accordance with our processing purposes and legal obligations, we may share your personal data with the following categories of recipients:

A. Authorized Service Providers

We engage specialized third-party processors who provide:

• Contract fulfillment services

• IT infrastructure and data storage solutions

• Professional services (auditing, accounting, legal)

• Security and compliance services (including AML/CTF where applicable)

All processors are:

• Bound by strict data protection agreements

• Required to implement appropriate technical and organizational safeguards

• Subject to our ongoing oversight and compliance monitoring

B. Regulatory & Government Entities

We may disclose information when legally required to:

• Tax authorities and customs agencies

• Judicial bodies and courts

• Financial and data protection regulators

• Other official government institutions

7.2 Data Transfer Safeguards

All data disclosures adhere to:

1. The principle of minimum necessary disclosure

2. Applicable data protection regulations

3. Strict confidentiality requirements

4. Purpose limitation for the receiving party

We maintain records of all data disclosures to ensure accountability and compliance with GDPR requirements. Any international transfers undergo proper adequacy assessments and implement appropriate safeguards as required by law.

8. Storage period

8.1 Standard Retention Framework

ForeGate maintains personal data only for the duration required to fulfill the specific processing purposes outlined in this policy. Retention periods are determined based on:

• The original collection purpose

• Ongoing business requirements

• User rights activity (including consent withdrawal or erasure requests)

8.2 Extended Retention Circumstances

We may prolong data retention when necessary for:

• Legal Compliance: To meet statutory obligations under applicable laws

• Regulatory Requirements: As specified by governing authorities

• Litigation Holds: During active or anticipated legal proceedings

• Industry Standards: Following guidelines from data protection authorities

*We conduct annual reviews of stored data to ensure compliance with these retention principles while maintaining our ability to serve user needs and meet legal requirements.

1. Different data categories have customized retention schedules

2. Legal statutes of limitation may require extended preservation

3. All retained data continues to receive full protection under this policy

4. When retention periods expire, data is securely disposed of or anonymized

9. Data subject’ rights

As a ForeGate user, you possess the following rights regarding your personal data:

9.1 Right of Access

You may request:

• Confirmation of whether we process your data

• The purposes and legal bases for processing

• Categories of personal data involved

• Recipients or recipient categories (including international transfers)

• Anticipated retention periods or criteria

• Information about international data transfers and safeguards

• Your right to file complaints with supervisory authorities

9.2 Right to Rectification

You may:

• Request correction of inaccurate personal data

• Supplement incomplete data through additional statements

• Ensure all processed information remains current and accurate

9.3 Right to Erasure ("Right to be Forgotten")

You may request deletion when:

• Data is no longer necessary for its original purpose

• You withdraw consent (where processing was consent-based)

• You legitimately object to processing

• Data was processed unlawfully

• Legal obligations require deletion

9.4 Right to Restriction of Processing

You may limit processing when:

• Contesting data accuracy

• Processing is unlawful but you oppose erasure

• We no longer need the data but you require it for legal claims

• You've objected to processing pending verification

9.5 Right to Data Portability

You may obtain and reuse your data when:

• Processing is based on consent or contract

• Processing is automated

• Data is provided in a structured, commonly used format

• Technical feasibility is permitted and ensures secure transfer to another controller

9.6 Right to Withdraw Consent

For consent-based processing:

• You may withdraw consent at any time

• Withdrawal does not affect processing lawfulness prior to withdrawal

• We will cease processing unless alternative legal bases exist

All rights may be exercised by contacting [e-mail]. We will respond within 30 days of receiving valid requests, with possible extensions for complex cases as permitted by law.

10. Minors

Our services are not intended for anyone under 18 (eighteen) years old and we do not knowingly collect personal information from anyone under this age.

11. Links

Our website contains links to other websites. Those websites have their own privacy practices, for which we do not accept responsibility or liability. Please review those policies before submitting any personal data.

12. Updates

This Privacy Policy was updated in May 2025. We reserve the right to amend this Privacy Policy from time to time to reflect changing legal requirements or our processing practices. Any such changes will be posted on this website and will be effective upon posting. Significant changes may be communicated via email or in-app notice.

13. Use of cookies

13.1 What Are Cookies?

We use cookies - small text files stored on your device - to enhance your browsing experience by:

• Improving website performance

• Increasing loading speeds

• Remembering your preferences

• Eliminating repetitive data entry

13.2 Cookie Types

We utilize two primary cookie categories:

Persistent Cookies

• Remain on your device between browsing sessions

• Enable personalized services by remembering your preferences

• Support continuous improvement of our digital platforms

Session Cookies

• Temporary files deleted when you close your browser

• Help analyze traffic patterns and user behavior

• Identify technical issues in real-time

• Facilitate seamless navigation during single visits

13.3 Cookie Purposes

Our cookies serve distinct functions:

Essential Cookies

• Enable core website functionality

• Provide access to secure areas

• Required for basic service delivery

Analytical Cookies

• Generate anonymous usage statistics

• Help optimize website performance

• Support continuous service improvement

Functional Cookies

• Remember user preferences

• Maintain session information

• Customize your browsing experience

13.4 Data Utilization

We responsibly use cookie-collected information to:

• Ensure proper website operation

• Personalized content display

• Remember login credentials

• Optimize display settings

• Enhance service offerings

This may include processing:

• Account details

• Geographic location

• Session duration

• Service selections

• Device specifications

• Browser characteristics

• IP address information

13.5 Marketing Applications

Cookie data helps us:

• Display relevant advertisements on partner platforms

• Reach potential customers with shared interests

• Measure campaign effectiveness

• Optimize marketing strategies

13.6 Security & Controls

Important notes about cookies:

• Contain no viruses or malicious code

• Cannot damage your device

• Can be disabled via browser settings

• May be blocked through our website interface

13.7 Importance

Disabling certain cookies may:

• Impair website functionality

• Limit service availability

• Reduce user experience quality

• Prevent access to some features

We recommend maintaining standard cookie settings for optimal service performance. Current cookie preferences can be adjusted at any time through our cookie management portal.

14. Blockchain-Specific Data Considerations

14.1 On-Chain vs Off-Chain Data Handling

ForeGate utilizes blockchain technology to facilitate certain platform functions, such as transaction recording and market verification. This involves both: * On-Chain Data: Permanently stored on public blockchain networks, typically pseudonymized and linked to wallet addresses.

* Off-Chain Data: Stored within ForeGate-controlled databases and systems, subject to full GDPR compliance and modification or deletion upon request.

14.2 Irreversibility of On-Chain Records

Due to the decentralized and immutable nature of blockchain protocols, on-chain data cannot be altered or deleted after being confirmed. This includes prediction trades, wallet interactions, or transaction logs. While this limits the full exercise of certain data subject rights (e.g., the right to erasure), we implement technical and procedural safeguards to minimize risks.

14.3 Data Minimization and Pseudonymization

To support privacy-by-design principles:

* No personally identifiable information (PII) is stored directly on-chain.

* Transactions are linked only to cryptographic wallet addresses, which ForeGate does not associate with real-world identities unless required by law.

* When possible, we apply pseudonymization or abstraction techniques to further decouple user identity from transaction records.

14.4 Right to Erasure in a Blockchain Context

While on-chain records are permanent, ForeGate fulfills erasure requests by:

* Deleting all related off-chain personal information.

* Unlinking any off-chain identifiers associated with on-chain wallet addresses.

* Retaining minimal on-chain links only as necessary to fulfill legal or security obligations.

14.5 User Rights Execution Pathway for On-Chain Users

For blockchain-based users:

* Rights requests can be submitted to [e-mail].

* You may be asked to verify wallet ownership (e.g., via signature) to confirm identity.

* ForeGate will confirm which data is stored on-chain vs off-chain and execute eligible requests accordingly.