Privacy Policy

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

We want you to have the information needed to make informed decisions about how your Personal Data is used and processed. Our website is designed with that goal in mind, and we use various methods to keep you informed about how your Personal Data is handled.
Where specific details are relevant to you, we will provide them at the appropriate time.
If you have questions or need clarification on any applicable legal limitations, we're happy to help. You can reach us by email at: info@truegainery.com

Your personal data will only be used for the purposes outlined 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; to 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 related to the Services. We also process your personal data to better understand your preferences and needs.

To exercise your rights over 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 it, restrict its use for specific or general purposes, or transfer it to you or a third party. We're committed to accommodating your requests.

Protect Your Personal Data:

While we cannot guarantee absolute security of your personal data, we are committed to employing a range of methods and techniques to keep it protected.
This concludes our Privacy and Security Policy.

1. The Scope?

This Policy describes the types of personal data the Company collects about natural persons, and how that data is processed, 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 management, organization, and storage.
Our services are intended for general audiences aged 18 and above. We do not knowingly collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that personal data belonging to a minor has been collected, we will delete it promptly.

2. What Personal Data Do We Have on You?

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

You are not required to disclose personal information to us. However, withholding certain information may limit our ability to provide our Services or grant you access to the website.

You are not required to provide us with personal data. However, withholding it may prevent us from delivering our Services or granting you access to the website.

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

This includes data collected automatically during your use of our platform, such as your IP address, access dates and times, preferred language, browser type, software crash logs, and device information. This data is non-personal and cannot be used to identify you.
Personal Data you provide to us: any personal data you voluntarily share when connecting to a third-party online trading platform through us.
Personal information shared with third-party platforms to facilitate trade: 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 under the following circumstances: When required by law or regulatory obligation, we may disclose your personal data to government authorities, law enforcement agencies, or regulatory bodies. When necessary to deliver our Services, we may share your personal data with trusted service providers, partners, or contractors who process data on our behalf. These third parties are bound by confidentiality obligations and may only use your data for the purposes we specify. When you provide explicit consent, we may share your personal data with third parties beyond the scope described in this Policy. In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the relevant third party as part of that transaction. We will notify you in advance of any such transfer and of any changes to how your personal data is handled. We do not sell your personal data to third parties. Where personal data is transferred to third parties located outside the Philippines, we take appropriate measures to ensure that such transfers are conducted in accordance with applicable data protection requirements and that your data remains protected to the same standard applied within the Philippines.

We may share your Personal Data with third-party service providers that support our operations, including hosting and storage providers and user experience analytics services. Upon your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be disclosed to those platforms and used in accordance with their own privacy policies. Your Personal Data may be shared with more than one trading platform. We may share Personal Data with affiliated 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 competent authorities. We may also share your Personal Data with prospective investors, buyers, or lenders — whether in relation to the Company or any other entity within the group — in connection with a potential transaction, including the transfer or sale of assets, or any merger, restructuring, consolidation, or bankruptcy involving the Company or any group entity.

7. Cookies and Third-Party Services Our website uses cookies and similar tracking technologies from third parties. These may include analytics providers, advertising networks, and social media platforms that place cookies on your device when you visit our site. Third-party cookies allow these providers to collect information about your browsing activity across different websites. This data may be used to deliver targeted advertising, measure website performance, or enable social media features. You can manage or disable third-party cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of some features on our website. We do not control how third parties collect or use your data. We recommend reviewing the privacy policies of any third-party services you interact with through our platform.

We may work with third-party service providers, including advertising networks and analytics companies, to support our website. These providers may also use cookies or similar technologies. Cookies are small text files placed on your device when you visit the website. They are used to collect information about your browsing habits and preferences, improve your experience, and tailor the products and services presented to you. Cookies also support website statistics and analytics. We use two types of cookies. Session cookies are temporary and are deleted from your device once you close your browser. Persistent cookies remain on your device after your browser is closed and allow the website to recognize you as a returning user, enabling 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 fulfill the purposes described in this Policy, or for longer periods as permitted by applicable law, regulations, or orders.
We will share your information with third-party trading platforms for a period of 12 months. With your consent, we will continue sharing your data for an additional 12 months.
We regularly review the personal data we hold to confirm it is no longer needed.

Transfers of Personal Information to a Third-Party Country or to an International Organisation

10. Security of Personal Data We are committed to protecting your personal data and take reasonable steps to safeguard it against unauthorized access, loss, misuse, alteration, or disclosure. We implement security measures appropriate to the nature of the personal data we hold and the risks involved in its processing. While we apply industry-standard security practices, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your personal data. Access to your personal data is restricted to authorized personnel, service providers, and third parties who require it to perform their functions. All such parties are subject to confidentiality obligations. You are responsible for keeping your account credentials confidential. If you believe your account has been compromised, notify us immediately. In the event of a personal data breach that poses a risk to your rights, we will take appropriate steps in accordance with our obligations, including notifying affected individuals where required.

We have implemented appropriate organizational and technical measures to protect personal data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that personal data will be maintained with complete security at all times. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of personal data, including disclosures resulting from transmission errors, unauthorized 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 personal data to third parties, such as public authorities. In such cases, we cannot control the level of security those third parties apply to your personal data. Personal data cannot be transmitted over the internet with guaranteed security. We cannot ensure the security of personal data you transmit to us through the internet.

Links 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. We also advise exercising caution before sharing any Personal Data with them.

12. Modifications to this Policy We may update this Policy at any time. When changes are made, we will revise the effective date at the top of the document. For significant changes, we may notify you directly — by email or through a notice on our platform. Continued use of our services after any update takes effect constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of any changes.

Before accessing or using any third-party websites or apps, read their privacy policies carefully. Be selective about the personal data you share with them.

13. Your Rights Over Your Personal Information You have the following rights regarding your personal information, subject to applicable law: Right of Access — You may request a copy of the personal information we hold about you and details on how we use it. If you believe we hold more information than necessary, you may request we limit our use to what is required. Right to Rectification — You may request corrections to any personal information that is inaccurate or incomplete. Right to Erasure — You may request that we delete your personal information where we no longer have a lawful basis to retain it. We will take reasonable steps to inform any third parties holding your data of your request. Right to Restriction of Processing — You may request that we restrict how we process your personal information in certain circumstances — for example, while we verify its accuracy or assess an objection you have raised. Right to Data Portability — Where processing is based on your consent or a contract, and is carried out by automated means, you may request a copy of your personal information in a structured, machine-readable format. Right to Object — You may object to our processing of your personal information where we rely on legitimate interests as the legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms. Right to Withdraw Consent — Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Right to Lodge a Complaint — You have the right to lodge a complaint with the relevant data protection authority if you believe we have not handled your personal information in accordance with applicable law. To exercise any of these rights, contact us using the details provided in this policy. We may need to verify your identity before processing your request. We will respond within the timeframe required by applicable law. Please note that some rights are not absolute. In certain circumstances, we may be entitled to refuse a request — for example, where fulfilling it would adversely affect the rights of others, or where we are required by law to retain the information.

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 no longer need. You may also request that we limit the types or scope of processing applied to your Personal Data.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please submit a written request to the email address below.
Access Rights
We can confirm whether Personal Data about you is being processed. If it is, you may request access to that data.
We will provide an electronic copy of the Personal Data currently being processed. A reasonable fee may apply for additional copies. Data will be provided electronically upon request.
The right to access Personal Data must not infringe on the rights and freedoms of others. If a request would be detrimental to another person's rights or freedoms, we may refuse or limit our response accordingly.
Right to Rectification
You have the right to request correction of inaccurate Personal Data. Where Personal Data is incomplete, you may request that it be completed, taking into account the purpose for which it is processed.
Right to Erasure
This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (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) the Personal Data must be erased 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 request that we restrict its processing.
Where processing is restricted, Personal Data may only be retained with your consent, or to establish, exercise, or defend legal claims, to protect the rights of another individual, 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 us in a structured, machine-readable format.
You may also request that your Personal Data be transferred directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability does not override 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 where that processing is based on the legitimate interests of the Company or a third party, including profiling based on those interests. If we cannot demonstrate compelling legitimate grounds for processing that override your rights, freedoms, or interests, or that are necessary for the establishment, exercise, or defense of legal claims, we will cease processing.
Regarding direct marketing: you have the right to object at any time to the processing of your Personal Data for direct marketing purposes.
Right to Withdraw Consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may submit a complaint to 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 13 as they apply to your Personal Data.
We will respond to requests submitted under section 13 within one month of receipt. Where necessary, this period may be extended by up to two months, depending on the complexity and volume of requests. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.
Unless otherwise provided under section 13, information provided in response to your rights under section 13 will be supplied free of charge. Where requests are manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt about the identity of the person making a request, we may ask for additional information to confirm identity before proceeding.