We (referred to as 'We', 'Us', or 'Our') are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the 'Website').
We will uphold the following principles:

For transparency about how we collect and process your personal information:

We want you to be able to make informed decisions about how your Personal Data is used and processed. That's why we've developed this website. To support this, we use a range of methods and procedures, including on-page notices and layered disclosures, to provide clear, relevant information about the use of Personal Data. Where specific details are needed, we will provide them at the appropriate time. We are happy to answer any questions you may have and to clarify any legal limitations. You can contact us by email at the following address: info@blue-orion.com

Personal Data will be used solely for the purposes outlined in the Policy.

We may process Personal Data for various purposes, including providing our website to you, connecting you with third-party trading platforms (the “Services”), enhancing the site, protecting our rights and interests, supporting the maintenance and delivery of the Services, complying with legal or regulatory obligations, and carrying out administrative and business activities to support the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs

Use essential tools to protect your rights regarding Personal Data

Our goal is to help you make informed decisions about how your Personal Data is used and processed. This website was created for that purpose. We apply a range of methods and procedures to provide you with relevant information on the use of Personal Data. When specific details are needed, we will share them at the appropriate time. We’re available to answer any questions and will offer any clarifications you need, subject to applicable legal restrictions. You can reach us via email at the address below: info@blue-orion.com

Safeguard Your Personal Data

While we cannot guarantee the absolute security of your Personal Data, we assure you that we will continue to employ a range of measures and technologies to ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive

Scope?

This Policy explains the types of Personal Data the Company collects about natural persons and how we process it, share it with third parties, secure it, and related matters. It covers information linked to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information we hold or can access. The Policy defines “processing” as any operation that involves using or collecting Personal Data, including its management, structuring, and storage. Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly seek or collect information from anyone under 18 years of age. We also do not knowingly permit such individuals to use our services. If we become aware of any information about children, we will delete it as quickly as possible

2. What Personal Information Do We Hold About You?

When you use our Services or channels, or visit our website, we collect Personal Data. We may ask for your Personal Data in specific situations. We also collect Personal Data by analyzing how you use our Services and channels, or by receiving information from our third-party partners

3. No obligation to provide personal information to the Company and the potential consequences

However, you are not obligated to provide Us with any Personal Data. In certain situations, you may not need to share any Personal Data with Us. This may limit Our ability to provide the Services or restrict users from accessing the website

4. What types of Personal Data do we collect? When you visit our website, we may collect the following personal information

This includes details about your online activity log, traffic data (including IP address and the date and time of access), the language you use, software crash logs, the type of browser, and information about the device you use. The information we collect is not personal information and cannot be used to identify you. Personal data we receive from you: any personal data you voluntarily provide to us when you connect through us to a third-party online trading platform. Personal information you provide directly to third-party platforms to facilitate trading: this information includes your full name, address, phone number, and email address

5. The legal bases and purposes for processing personal data

The Company processes your personal data for the purposes set out in this section, in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot use your personal data. The legal grounds on which the Company may process your personal data are:

• You have consented to the processing of your Personal Data for one or more purposes. This includes instances where you provide personal information via the Website so we can transfer it to a third-party trading platform
• The Company or a third party may process data to pursue legitimate interests; for example, to improve our Services or to defend against legal claims.
• Processing must comply with a legal requirement

Please contact us by email for further details about processing activities necessary to protect our legitimate interests.
Below is a list of purposes and legal bases we may rely on when using the information you provide. Personal Data

6. Disclosure of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers that support us with services such as hosting and storage, IP address information, and user experience analytics.
You may also request that we provide certain Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you give us with those platforms. Their use of your Personal Data is governed by their privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its affiliated entities or business partners. This helps provide the Company with the resources needed to enhance and improve the products and services it offers its customers.
Where necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company in the group in connection with such transactions (including the transfer or sale of assets of the Company or any other company in the group) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business in the group

Online Tracking Notice

Third-party services—such as advertising partners or analytics providers—may be used. These partners may also deploy cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or access the website. They collect information about your preferences and browsing behaviour to enhance your experience, remember settings, and customise the products and services you may find relevant. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. They are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device for a set period after your browser is closed. They help the Website recognise you as a returning user and make it easier to come back to the website

7. Cookies and Third-Party Services

We may use them depending on their intended purpose:

Cookies are blocked or have been deleted
To block or delete cookies, change your browser settings. The links below will guide you through the process for several popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that if this occurs, some or all of the Website's functions and features may not operate as expected

Online Tracking Notice This service does not currently support Do Not Track (DNT) signals.
8. Retention of personal data about You

The Company will retain your Personal Data for as long as necessary to fulfill the purposes of processing described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, and 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 retained Personal Data to ensure it is not kept longer than necessary

9. Transfers of personal information to a third country or an international organisation

Your personal information may be transferred to other countries (for example, to a third country—any country other than the one where you live) or to international organizations or jurisdictions. The Company takes all necessary steps to safeguard the Personal Data you provide and ensures that individuals can exercise their rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area)

• Transfer to a third country or international organization that the European Commission has determined provides an adequate level of protection for Personal Data transferred to it, 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')
• The transfer is carried out pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a)
• The transfer was carried out in accordance with the EU Commission’s Standard Contractual Clauses for data protection under Article 46(2)(c) of the GDPR. The Commission’s adopted clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

The Company can provide details of the security measures it uses to protect your Personal Data when it is transferred to third countries or international organizations. Please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented appropriate organizational and technical safeguards to protect Personal Data, including measures to prevent its accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be entirely error-free, nor can we be responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, any disclosure resulting from transmission errors, unauthorized third-party access, or other causes beyond our control.
In the event of legal or other obligations beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. In these circumstances, we cannot control the level of security those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company therefore cannot ensure the security of Personal Data you send to us via the internet

11. Hyperlinks to Websites Operated by Third Parties

Links to third-party sites and apps may be available on our website. These sites and apps are not controlled by the Company. We are not responsible for how they collect or process Personal Data. This Policy does not govern activities conducted on those sites or apps.
When visiting any third-party site or app, please review its privacy policy before deciding to access or use it. We also recommend exercising caution before sharing any Personal Data with them

12. Updates to this Policy

This Policy may change at any time. If we update it, we will post the revised Policy on our website and notify you accordingly. For significant changes, we will attempt to inform you through channels we deem appropriate and will also publish a notice on our website. Unless expressly stated otherwise, amendments will take effect upon publication of the revised Policy.

Your rights concerning your personal information

You have the right to ask us to verify the accuracy of the Personal Data we collect about you, correct any errors, and delete any Personal Data we do not require. You may also limit certain types of processing of your personal information. If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. You can exercise your rights by emailing the address below. Right of access
The Company can verify the accuracy of the Personal Data processed about you. Where accurate, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. Upon request, the data will be provided electronically.
The right of access must not infringe the rights and freedoms of others. If a request adversely affects another’s rights and freedoms, the Company may refuse to comply or limit its response. Right to rectification
The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to erasure
You may request deletion of your Personal Data where: (a) it is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, to processing based on legitimate interests pursued by us or a third party; (e) the data has been processed unlawfully; or (f) deletion is required to comply with the Company’s legal obligations. 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.
Restriction of processing
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where processing is restricted, the data may be stored only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or for reasons of important public interest in 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 on a contract to which you are a party, you have the right to receive the Personal Data you provided to the Company.
You also have the right, where technically feasible, to request the direct transfer of your Personal Data from the Company to another controller. Exercising your right to data portability does not affect your right to erasure. Data portability must not adversely affect the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of your Personal Data based on the Company’s or a third party’s legitimate interests, including profiling based solely on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing, we may continue unless you show that your rights, freedoms, or interests prevail, or where processing is required for the establishment, exercise, or defense of legal claims.
For direct marketing purposes, you may object at any time to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with the supervisory authority responsible for you.
You may submit a complaint to a supervisory authority established by a Member State to protect individuals’ fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights regarding your Personal Data as described in this section 13. We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. Where necessary, this period may be extended by up to two additional months depending on the complexity and number of requests. We will notify you within one month of receipt if an extension is required and explain why.
Unless otherwise provided under section 13 of the law, information provided in response to your requests under section 13 will be supplied free of charge. If a request is manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs or decline to act.
If we have reasonable doubts about the identity of the person making the request, the Company may request additional information.