Privacy Policy

GiniAI OÜ · AutoGain · Last updated 18 September 2026

This page says what personal data we collect through autogain.markets, why we collect it, and what you can ask us to do about it.

Who we are

AutoGain is operated by GiniAI OÜ, a private limited company registered in Estonia. GiniAI OÜ decides why and how the data described here is used — in the words of the GDPR, we are the controller.

GiniAI OÜ
Estonian registry code 17571706
Ruunaoja tn 3, 11415 Tallinn, Estonia
cc@autogain.markets

Where the service is today

AutoGain is being built as a regulated investment service. It is not open. No agent is on sale, we hold no client money and no client assets, and we have no customer accounts. We will not accept a client, take a subscription or handle client money until we hold the authorisation required in that person's country. Until then this website is informational, and this policy covers the website and our correspondence — nothing more.

This site sets no cookies

autogain.markets loads no scripts, sets no cookies, and runs no analytics, advertising or tracking code of any kind. There is nothing here to consent to and nothing to opt out of. If that changes we will say so on this page, and ask for your consent first where the law requires it.

What we collect

• Server logs. Our web server records each request it receives: the IP address it came from, the time, the page asked for, and the browser's user agent. This is how the site is kept running and defended against abuse.
• Messages you send us. If you email us we keep the message and your address so we can reply and so we have a record of what was agreed.
• Staff sign-in. Our internal operator console is restricted to our own staff and uses Google sign-in with two-factor authentication. For those accounts we receive the name, email address and account identifier held by the Google account signing in. This does not apply to visitors.

We do not collect special categories of personal data — health, beliefs, biometrics and the like — and this site is not directed at children.

Advertising, and the Google Ads API

We advertise AutoGain on Google. We use the Google Ads API only to run and measure our own campaigns — our first-party advertising. We do not run advertising for anyone else, we do not offer an advertising service, and we do not sell, rent or share data about you with advertisers.

When the service opens we intend to measure which ads bring people who go on to sign up. That would mean sending Google a record that a signup happened, matched to the advertising click that led to it. It is not running today. Before it runs, this page will say exactly what is sent, and we will ask for consent where the law requires it.

Why we use your data, and our legal basis

• Running and securing the website and our systems — our legitimate interests (GDPR Article 6(1)(f)) in keeping the service available and defending it against abuse.
• Replying to you — our legitimate interests in answering you, or the steps before a contract (Article 6(1)(b)) if you are asking about becoming a client.
• Measuring our own advertising — our legitimate interests, and your consent (Article 6(1)(a)) where the law requires it.
• Meeting obligations that apply to us — legal obligation (Article 6(1)(c)).

Who else sees it

We use service providers who process data on our instructions and for nothing else: our hosting and infrastructure providers, for the servers this site and our systems run on; Google, for advertising and for staff sign-in; and our email provider, for correspondence. We do not sell personal data. We give data to an authority only where the law obliges us to.

Sending data outside the EEA

Our own systems run in the European Union. Some of our providers — Google in particular — may process data outside the EEA. Where that happens we rely on the safeguards the GDPR allows: an adequacy decision for the country concerned, or the European Commission's standard contractual clauses.

How long we keep it

• Server logs — a short operational period, then deleted.
• Correspondence — while it is useful, and for as long as any legal obligation requires.
• Staff account records — while the account exists.

Your rights

You can ask us for a copy of your data, to correct it, to delete it, to restrict what we do with it, or to send it to you in a portable form. You can object to our using data on the basis of legitimate interests. Where we rely on consent you can withdraw it at any time, and withdrawing it does not affect what we did beforehand.

Write to cc@autogain.markets and we will answer within one month.

If you are not satisfied with our answer you can complain to a data protection authority. Ours is the Estonian Data Protection Inspectorate, Andmekaitse Inspektsioon (www.aki.ee). You may also complain to the authority in the country where you live.

Changes to this policy

If we change this policy we update the date at the top of this page. If the change is a significant one we will say what changed.

Contact

GiniAI OÜ — Ruunaoja tn 3, 11415 Tallinn, Estonia
cc@autogain.markets