About Us
Welcome to our Privacy Policy (“Privacy Policy”), which outlines how we handle and safeguard your personal data when you use our services (include our websites and applications) and our other communication means. These services are managed by Gaimin.AG and GAIMIN LDA, located at, respectively, GAIMIN AG, Baarerstrasse 12, 6300 Zug, Switzerland and GAIMIN LDA, R. João Saraiva 34 Loja 3, 1700-051 Lisboa, Portugal (referred to as “the Companies”, “we”, “our”, or “us”). The Companies are responsible for the data processing activities detailed in this policy and act as joint-controllers. Unless otherwise specified in this Privacy Policy, the terms used here have the same definitions as outlined in the European Union General Data Protection Regulation (“GDPR”).The Personal Data We Collect
Categories of personal data collected
We gather personal data for different purposes associated with our business operations as you utilize our services. In particular, we process:- Contact information (e.g. e-mail address)
- Online identifiers (e.g. IP address, cookie identifiers, device identifiers)
- Identification data (e.g. name)
- Communication data (e.g. messages sent through contact forms or social media accounts (including but not limited to Telegram, Discord, X, Instagram)
- Behavioural data (e.g. tracking data, logfiles)
- Professional information (e.g. qualifications, employment history, CV)
How we collect it
We acquire information about you as you engage with us. This includes:Direct collection
- When you submit your inquiries or feedback through our contact forms.
- When you register as a user for our application and/or services.
- When you communicate with us via email for customer support.
- When you apply for a vacancy with us through the recruitment form.
- From your interaction with our social media platforms.
Indirect collection
- When you interact with our website’s functionalities.
- When cookies and similar technologies are installed on your device or access information included therein.
- From our service providers.
- From public sources, public registers and internet searches.
Why Do We Collect Personal Data
Overview of our purposes for data processing
Our legal basis for collecting and processing personal data, as described in this Privacy Policy, depends on the category of personal data collected and the purposes for which it is collected.- Advertising and Personalisation: We use third‑party advertising partners to display personalised and non‑personalised advertisements within our platform. For this purpose, we may share certain categories of personal data, including device identifiers, IP address, approximate location, browsing behaviour, interaction data, and technical information about your device. The legal basis for personalised advertising is your consent. You may withdraw your consent at any time through our cookie settings or by contacting us.
- Contractual Obligations: We collect and process personal data to fulfil our contractual obligations or to take measures related to a contract to be concluded with you. In particular, we rely on contractual obligations to:
- Manage and respond to inquiries or communications submitted via our contact form or email.
- Recruit you for vacancies through our website.
- Ensure compliance with our terms of service.
- Consent: We may rely on your voluntary consent, provided when we collect your personal data. In particular, we rely on your consent to:
- Use non-essential cookies and similar tools which includes:
- Personalise advertising
- Profile you
- Share data with advertising partners
- Enable social media and third-party interaction features.
- Legitimate Interests: We use legitimate interests as a legal basis for processing your personal data, based on our assessment that the processing is necessary and proportionate and does not infringe on your interests or fundamental rights and freedoms. In particular, we rely on our legitimate interests to:
- Use essential cookies and similar technologies that are technically necessary for our website to function.
- Detect, prevent and address security threats, as well as to prevent fraud and general suspicious activities.
- Collect and analyse your feedback to improve our services and user experience.
- Legal Compliance: We process personal data when necessary to fulfil legal and regulatory obligations. In particular, we rely on the fulfilment of legal obligations to:
- Comply with applicable regulations and legislation.
- Legally enforcement of claims and rights.
- Fulfil our tax and accounting obligations.
Advertising and Personalisation
We display both personalised and non‑personalised advertising on our platform. To provide personalised advertising, we may process and share the following categories of personal data with our advertising partners:- Device identifiers
- IP address
- Approximate location
- Behavioural and interaction data
- Technical device information
- Cookie identifiers
- Display relevant advertisements
- Measure ad performance
- Prevent fraud
- Limit ad frequency
Profiling for Advertising Purposes
We create user profiles based on your interactions with our services to deliver personalised advertising. Profiling may include analysing your browsing behaviour, device characteristics, and interaction patterns. You have the right to:- Object to profiling
- Withdraw consent
- Request access to data used for profiling
Our data processing in detail
Our contact forms
You can use the contact form on our website or application to contact us for any request. We will process the personal data included therein, such as your name, e-mail address and any other information you choose to provide to us in your message only to answer your request. We do so to take steps at your request prior to entering a contract with you or to perform an already existing contract with you.Our vacancies
We may showcase our vacancies on our website, allowing you to apply for them. To that end, we collect the personal data you provide us within the application form, namely your identification details, your contact information, as well as your professional and educational details. We also store your personal data for a period of 6 months after your application in order to process it. We do so to take steps at your request before entering an employment contract with you.Links to third-party websites, apps and services
Our services contain links to websites, apps or services that are not operated by us. When you click on a third-party link, you will be directed to that third-party’s website or app. We have no control over the content, privacy policies, or practices of any third-party websites or services. We maintain an online presence on social networks to, among other things, communicate with customers and prospective customers and to provide information about our products and services. If you have an account on the same network, it is possible that your information and media made available there may be seen by us. In addition, the social network may allow us to contact you. As soon as we transfer personal data into our own system, we are responsible for this independently. This is then done to carry out pre-contractual measures and to fulfil a contract with you. For the legal basis of the processing carried out by the social media networks under their own responsibility, please refer to their data protection declarations. Below is a list of social media networks on which we have an online presence:- Telegram: Privacy Policy
- Facebook: Privacy Policy
- Instagram: Privacy Policy
- X: Privacy Policy
- YouTube: Privacy Policy
- LinkedIn: Privacy Policy
- Discord: Privacy Policy
- TikTok: Privacy Policy
Profiling for Advertising Purposes
We work with third‑party advertising networks, demand‑side platforms, and analytics providers (“Advertising Partners”). These partners may act as processors or joint controllers, depending on their role. We create user profiles based on your interactions with our platform in order to provide personalised advertising. Profiling involves analysing or predicting your preferences, interests, or behaviour. You have the right to object to profiling or withdraw your consent at any time.For how long do we store personal data
We retain personal data for the period necessary to fulfil the purposes for which it was collected, in accordance with the legal, regulatory and contractual obligations to which we are subject. Once this retention period is over, we delete the personal data or irreversibly anonymise it.With whom we share personal data
Our service providers
We collaborate with third-party entities (“service providers”) to support the functioning of our services. These service providers assist in various activities, such as analyzing service usage, facilitating payments, and providing IT infrastructure. They are granted access to your personal data solely to the extent required to carry out these tasks. Categories of service providers that can access your personal data:- Cloud service, hosting, and infrastructure providers
- Advertising partners and service providers
- Social media and content platforms
- Analytics and marketing service providers
- IT and cybersecurity service providers
- Legal and accounting service providers
Third-country transfers
Please note that we hire service providers located in countries outside the EU/EEA. These third countries may not offer a level of data protection equivalent to that of the EU/EEA. To ensure the security of your personal data during these transfers, we fulfil applicable legal obligations by adopting appropriate safeguards. These safeguards include:- Transfer of data to countries that have received an adequacy decision from the European Commission.
- Implementation of standard contractual clauses provided by the European Commission, in accordance with Commission Implementing Decision (EU) 2021/914 of 4 June 2021, as well as supplementary measures for the transfer, where we consider that such measures are necessary to guarantee a level of protection essentially equivalent to that of the EU.
- USA
- EU/EEA
- Switzerland
International Transfers for Advertising Services
In connection with the provision of personalised and non‑personalised advertising on our platform, we may transfer certain categories of personal data to our third‑party advertising partners (“Advertising Partners”). These partners may be located in countries outside the EU/EEA, including the United States, where data protection laws may not offer the same level of protection as those within the EU/EEA. When such transfers occur, we ensure that they are carried out in compliance with applicable data protection laws. In particular, we rely on one or more of the following safeguards:- Adequacy Decisions issued by the European Commission for countries that provide an adequate level of data protection.
- Standard Contractual Clauses (SCCs) adopted by the European Commission, together with supplementary measures where required, to ensure that the transferred data benefits from a level of protection essentially equivalent to that in the EU/EEA.
- Where applicable, transfers to U.S.‑based Advertising Partners certified under the EU–US Data Privacy Framework (DPF).
Data disclosure
We may disclose your personal data when we have a sincere belief that such disclosure is essential for the following purposes:- To fulfil a legal obligation, which includes cases where such disclosure is required by law or in response to lawful requests from public authorities, such as a court or a government agency.
- To safeguard the security of our services and safeguard our rights or property.
- To prevent or investigate potential unlawful conduct related to our operations.
Cookie and Tracking Technologies
We use cookies and similar technologies for website functionality, analytics and advertising. Non‑essential cookies, including advertising cookies, are used only with your consent. You may manage your cookie preferences at any time.How we keep personal data safe
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures are designed to ensure a level of security appropriate to the risks presented by the processing of your personal data. Our security measures include, where appropriate:- Encryption of data in transit and at rest
- Access controls and authentication procedures
- Network and infrastructure security measures
- Regular monitoring, testing, and evaluation of our security practices
- Secure development practices and vulnerability management
- Internal policies and staff training on data protection and confidentiality
Your Rights
You possess the following data protection rights. To exercise these rights, please reach out to us at the provided address or send an email to info@gaimin.io. Please be aware that we may ask you to verify your identity before addressing your requests.- Right to Access: You have the right to request a copy of your personal data, which we will furnish to you in an electronic format.
- Right to Correction: You can request us to rectify any inaccuracies or incompleteness in your data.
- Right to Withdraw Consent: If you’ve given your consent for the processing of your personal data, you have the right to withdraw it at any time, affecting future processing. This applies, for example, when you wish to opt out of marketing communications. Once we receive your withdrawal of consent, we will no longer process your information for the purpose(s) you initially consented to, unless there exists another legal basis for processing.
- Right to Erasure: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes it was collected, or if it was processed unlawfully.
- Right to Restrict Processing: You can request the limitation of our processing of your personal data in cases where you believe it to be inaccurate, processed unlawfully, or no longer needed for the original purpose, but cannot be deleted due to legal obligations or your own request.
- Right to Data Portability: You can request that we transmit your personal data to another data controller in a standard format (e.g., Excel), if you provided this data to us and we processed it based on your consent or to fulfill contractual obligations.
- Right to Object to Processing: If the legal basis for processing your personal data is our legitimate interest, you have the right to object to such processing based on your specific situation. We will respect your request, unless we have a compelling legal basis for the processing that outweighs your interests or if we need to continue processing the data for legal defense purposes.
- Right to File a Complaint with a Supervisory Authority: If you believe that the processing of your personal data violates data protection laws, you have the right to lodge a complaint with a data protection supervisory authority. In the EU and EEA, you can exercise this right by contacting a supervisory authority in your country of residence, workplace, or where you believe the infringement occurred. You can find a list of the relevant authorities here: https://edpb.europa.eu/about-edpb/about-edpb/members.
Advertising Transparency (Digital Services Act)
In accordance with the EU Digital Services Act (DSA):- We provide clear information about why a specific advertisement is shown to you.
- We do not use sensitive personal data for advertising.
- We do not target advertising to minors.
Changes To This Privacy Policy
Our Privacy Policy may be updated from time to time. We advise you to check this Privacy Policy periodically for any changes. Changes to this Privacy Policy take effect from the moment they are published on this page.Contact Us
If you have any inquiries or concerns regarding this Privacy Policy, please do not hesitate to contact us at:- Gaimin.AG (trading as Ovia Systems and GAIMIN) - Bahnhofstrasse 12, 6300 Zug, Switzerland
- GAIMIN LDA - R. João Saraiva 34 Loja 3, 1700-051 Lisboa, Portugal
- Email: info@gaimin.io