We (referred to as 'We', 'Us', or 'Our') are fully committed to safeguarding your Personal Data and protecting your privacy.
Our Privacy Policy is designed to inform you, as a consumer, about how we collect and store the information you provide on the Gaingate website (the 'Website').
We uphold and adhere to the following principles:

We are committed to being transparent about how we collect and use your personal data in your best interests:

In doing so, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, we employ a range of methods and procedures on our website to provide comprehensive, clear, and accessible information about Personal Data usage. If you require specific details about your data, we will make every effort to deliver them promptly and at the appropriate time. If you have any questions, we are happy to clarify anything related to legal constraints and compliance obligations. To contact us, please email us at info@blue-orion.com

We will use Personal Data solely for the purposes set out in the Policy

We process Personal Data for various purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities that support the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Gaining access to essential resources to effectively protect your rights relating to Personal Data

We are committed to helping you make well-informed choices about how we handle your data. This commitment is why we developed this website. To support it, we apply a range of methods and procedures and review them regularly to ensure you consistently receive the most relevant, up-to-date information about our use of your Personal Data and the choices available to you. Whenever specific details are required, we will provide them to you at the appropriate time. If you have any questions about how this process works, we are happy to answer and clarify, always in line with legal requirements. Our goal is to be transparent, timely, and compliant in every interaction. If you would like to learn more, please contact us via email at: info@blue-orion.com

Keep Your Personal Data Safe and Secure

While we cannot guarantee the absolute security of Personal Data, as no one can, we remain fully committed to using a range of measures to protect your Personal Data. Our Privacy and Security Policy addresses all essential areas to help ensure your long-term safety.

Scope?

In this Policy, you will find an outline of the types of Personal Data our Company collects from our customers, together with the ways we process it, share it with third parties, and keep it secure. This Policy covers information about an identified or identifiable individual, whom we can recognise directly or indirectly by reference to additional information in our possession or to data we can access through lawful means. For the purposes of this Policy, 'processing' means any operation involving the use or handling of Personal Data, including its collection, management, organisation, storage, and other related activities across our online and offline services. Our services are intended for a general audience and are not directed to anyone under the age of 18. We do not permit individuals under this age to use our services, and, accordingly, we do not knowingly collect information from anyone under 18. Because persons under 18 are not allowed to use our services, we do not intentionally gather their information. If we become aware of any collection of data relating to a person under the age of 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

If you use our services or channels, or browse our website, you agree that we may collect your personal data. In some cases, we may ask you to provide it directly. Alternatively, we may analyse your interactions with our services or channels to gather this information, or collect it through our third-party partners

3. You are not required to submit your Personal Data to Our Company or bear any implications arising from it

You are not required to share personal data with us. However, if you choose not to provide certain personal data, it may affect how we deliver our services to you, which could result in limited access to our website or limited use of certain features.

4. What Types of Personal Data Do We Collect? When you visit our website, we may gather the following categories of personal information:

Personal Data we collect includes information such as activity log details, traffic data (including IP address and access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This collected data is non-personal, and we do not use it to identify you. Some of the Personal Data we obtain from you comprises any personal information you voluntarily provide when you connect to a third-party online trading platform through us. We also collect the personal details you submit directly to those platforms, which can include your full name, email address, phone number, and address.

5. What Are Our Legal Bases and Justifications for Processing Personal Data

Our Company processes your Personal Data for the purposes set out in this section and in accordance with the applicable legal framework.
We rely on these legal bases because, without them, Our Company cannot process your Personal Data. The legal bases that permit Our Company to process your Personal Data include:

• We have obtained your consent to process your Personal Data for one or more of the following purposes, including when you submit personal information via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process the information to pursue their legitimate interests. Examples include enhancing our Services or defending ourselves in potential legal proceedings.
• All processing on our website must comply with applicable legal requirements, and we confirm that it does.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we have highlighted the reasons and legal bases for which we may use the personal information you provide to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Depending on the circumstances, the Company may disclose Personal Data to third parties that provide services such as data storage, IP address hosting, or user experience analytics.
We also accept requests from individuals who ask us to share specific Personal Data with third-party trading platforms. In such cases, we will transfer the Personal Data you provide to the platforms you designate. If you proceed, their privacy policies will govern how your data is used. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners or affiliated entities. We do so to access the resources needed to enhance and continually improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or other authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or buyers, or with lenders to the Company or its affiliated companies. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or insolvency proceedings relating to the Company or other parties associated with the Company.

Online Tracking Notice

You may encounter our use of third-party services on our website, such as advertising providers or analytics firms. These partners may also use cookies and similar technologies to collect data.
When we refer to cookies, we mean small text files stored on your device each time you visit or access our website. We use cookies to learn about your preferences and browsing patterns so we can enhance the user experience, understand what our audience values, and design products and services aligned with customer interests. Cookies also help us compile statistics and conduct analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device even after you close your browser. These cookies allow the website to recognize you as a returning visitor and retain the preferences you previously set.

7. How We May Use Cookies and Third-Party Services

Each cookie and its usage may vary, depending on its intended purpose.

Cookies are blocked or have been removed
You can manage your cookie preferences in your browser settings. Click any of the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that certain website features and functions may not perform as expected if this occurs.

Online Tracking Notice Please note that our service does not currently recognise Do Not Track requests.
8. Learn More About Storing Your Personal Information

Please note that Our Company retains your Personal Data for as long as necessary to fulfil the purposes outlined in this Policy, and we may retain it for longer where permitted or required by applicable laws, regulations, and orders. In some cases, your information may be shared with third-party trading platforms for up to 12 months. With your consent, we may extend this sharing for an additional 12 months, if needed.
We periodically review and assess the Personal Data we hold to ensure it is not retained longer than necessary.

9. Transfer of Personal Data to a Third Country or an International Organisation

Under certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send this Personal Data outside your home country, or to international organizations. We take all necessary measures to protect and defend your Personal Data and ensure you can exercise your rights and effectively access legal remedies if needed.
All residents of the EEA (European Economic Area) can take advantage of these protections and safeguards.

• In certain circumstances, we may transfer your Personal Data to a third country or international organisation recognised by the European Commission as providing adequate protection for Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the 'GDPR')
• When the transfer occurs, it is carried out under a legally binding and enforceable agreement between public bodies or authorities in accordance with Article 46(2)(a)
• We carry out data transfers in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, please review the clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

If you would like more information about these details and how they relate to the security measures we use to safeguard your Personal Data when transferred to third-party countries or international organizations, please contact us at info@wealthwaydigital.uk

10. Protection of Personal Data

To safeguard your Personal Data, we have implemented robust security measures. These measures are designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take every reasonable precaution, we cannot guarantee that your Personal Data will remain completely secure or error-free, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures resulting from transmission errors, unauthorized access by third parties, or other causes beyond our control.
Where we are legally required, or due to other constraints beyond our control, we may need to share your Personal Data with third parties, such as public authorities. In such situations, we cannot control the security practices those third parties implement.
Please note that transmitting Personal Data over the internet cannot be made entirely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of the Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website contains links to external sites and applications that are outside our Company’s control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. Our Policy covers activities on our website but does not apply to third-party websites.
Before visiting any third-party website or app via a link, please review their privacy policies before you start using their services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding Amendments to Our Policy

We may update this Policy at any time. If we make changes, we will notify you via our website and display the updated Policy. For major updates, we will use the most appropriate channels and publish an announcement on our website. Unless stated otherwise, all changes take effect immediately upon release of the revised Policy.

Your Rights in Relation to Your Personal Data

You have the right to request access to the personal data we hold about you, to correct it, and to ask us to delete any Personal Data you do not want us to process. You may also restrict the types of data we collect. For individuals residing in the EEA, please see this page:
If you wish to exercise any of your data rights, please contact us using the email address below. Access rights
We will verify the accuracy of the Personal Data we process. Where appropriate, we will provide you with access to your Personal Data, including an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, we will provide this data electronically.
Your right of access must not infringe the rights of others. If a request would affect others’ rights, we may refuse to comply or limit our response. Your rights related to rectification
If your Personal Data is inaccurate or incomplete, you may ask us to rectify or update it. Your Right to Erasure
Legitimate grounds include: (a) we no longer need the personal data for its original purpose; (b) you withdraw consent and no other legal basis applies; (c) you object to processing for specific reasons; (e) the Personal Data has been processed unlawfully; or (f) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with EU or Member State law or (b) to establish, exercise, or defend legal claims.
Processing restrictions
You may ask us to limit processing if you believe the data is inaccurate. While restricted, the data may be stored and processed only with your consent, to protect another person’s rights, or for important public interest in an EU or Member State context.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to obtain your Personal Data that the Company holds.
You may also request that we transfer that data to another controller where technically feasible. Exercising portability does not affect your right to erasure.
Right to object
You may object at any time to our processing of your Personal Data based on the Company’s or a third party’s legitimate interests, including related profiling. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.
You may object to processing for direct marketing at any time.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing before withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data matters.
You may also request that a supervisory authority in a Member State protect your individual rights regarding Personal Data processing within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. We will provide the information requested under section 13 within one month of receiving your request, but we may extend this by up to two months depending on the complexity and number of requests. You will be notified within one month if an extension applies and the reasons.
We will provide the information you request under section 13 free of charge unless the request is unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act.
If we cannot verify your identity in connection with a request, the Company has the right to request additional information.