We (also referred to as 'We', 'Us', or 'Our') are fully committed to protecting your Personal Data and safeguarding your privacy.
This Privacy Policy is intended to inform you 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 information in your best interests:

Our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website employs several methods and procedures, including clear notices, explanations, and FAQs, to provide comprehensive, relevant information about how Personal Data is used and for what purposes. If you require specific details regarding your data, we will make every effort to deliver them promptly and at the appropriate time. Should you have any questions, we are happy to clarify anything related to legal constraints. To contact us, please email us at info@blue-orion.com

We will use Personal Data exclusively for the purposes described in this Policy

You will find that 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 provisioning the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities to enable delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Ensuring access to vital resources to safeguard your rights when it comes to Personal Data

Our goal is to help you make well-informed decisions about how we handle your data. This is why we developed this website. To support this, we use a range of methods and procedures to ensure you continue to receive the most relevant information about our use of your Personal Data. When specific details are required, we will provide them at the appropriate time. If you have questions about how this process works, we are happy to answer and offer clarifications within the bounds of legal requirements. To learn more, contact us by email at: info@blue-orion.com

Keep Your Personal Information Secure and Protected

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

Scope?

In this Policy, you will find an overview of the types of Personal Data our Company collects from customers, as well as the ways we process it, share it with third parties, and protect it. Our Policy applies to information about an identified or identifiable individual, where a person can be recognised directly or indirectly through additional information in our possession or that we can access. For the purposes of this Policy, 'processing' means any operation performed on Personal Data, including the management, organisation, and storage of such data. Our services are intended for a general audience; however, they are prohibited for anyone under the age of 18. We do not authorise individuals under this age to use our services and do not knowingly collect their information. If we become aware of any data collected relating to a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

By using our services or channels, or by browsing our website, you consent to our collection of your personal data. In some cases, we may request your personal data directly. Alternatively, we may analyze your interactions with our services or channels, or work with third-party partners to gather this information

3. You are not required to provide your personal information to our company or manage any consequences arising from doing so

You are not required to share any personal data with us. However, in some situations, choosing not to provide certain personal data may affect our ability to deliver our services to you, which could result in restricted access to parts of our website or limited functionality of specific features.

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

The Personal Data we collect includes details from your activity log, traffic data (including IP address, access date and time), the language you use on our site, software crash reports, browser type, and device specifications. We treat this information as non-personal and do not use it to identify you. We may also obtain Personal Data that you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we receive personal details you submit directly to these platforms, such as your full name, email address, phone number, and postal address.

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

Our Company processes your personal data for the purposes outlined in this section and in accordance with applicable legal requirements.
We rely on a valid legal basis, as without it our Company cannot process your personal data. The legal grounds 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 provide personal information through the Website for us to share with a third-party trading platform
• The Company or a third party may need to process information to pursue their legitimate interests. For example, this may include improving our Services or protecting our rights in the event of legal claims.
• All processing carried out on our website complies with applicable legal requirements, and we can confirm that it adheres to those requirements.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email for further details and assistance.
Below, we outline the reasons and legal bases on 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 analysis.
We also accept requests from individuals who want us to share specific Personal Data with third-party trading platforms. In such cases, we transfer the Personal Data you provide to the platforms you designate. Once shared, their privacy policies will govern its use. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners and affiliated entities to access the resources needed to enhance and continually improve our customer offerings.
Where appropriate, the Company may disclose Personal Data to regulatory, local, or other competent authorities to protect the rights or property of others.
We may also share your Personal Data with interested investors or buyers, or with lenders to the Company or affiliated companies. This typically occurs in the context of transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy involving the Company or other parties connected to the Company.

Online Tracking Notice

You may encounter third-party services on our website, such as advertising providers or analytics firms. These companies may also use cookies and similar technologies that collect data.
Cookies are small text files stored on your device whenever you visit or access our website. We use cookies to understand your preferences and browsing patterns, improve the user experience, and design products and services aligned with customer interests. Cookies also help us gather information for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device after you close your browser. These allow the website to recognize you as a returning visitor and retain the preferences you set before.

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

Each cookie's purpose and usage may vary depending on its intended function.

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

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

Online Tracking Notice Please note that, at present, our service does not recognise Do Not Track requests.
8. Learn More About How We Store 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 may retain it for a longer period as permitted by law and where applicable to orders. In certain 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.
From time to time, we will review and assess the Personal Data we hold to ensure that we no longer require it.

9. Transfer of Personal Data to Third Countries or International Organizations

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

• In certain cases, we may transfer your Personal Data to a third country or international organisation that the European Commission has recognised as providing adequate protection for Personal Data, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the 'GDPR')
• When a transfer occurs, we carry it out under a legally binding and enforceable agreement between public bodies or authorities in accordance with Article 46(2)(a)
• We carry out the transfer in compliance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, please consult the adopted 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 to learn more about these safeguards and how they relate to the security measures we use to protect your Personal Data when transferring it to third countries or international organisations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented robust security measures. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
Even so, while we take every reasonable precaution, we cannot guarantee that your Personal Data will always be maintained without error, nor can we be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures resulting from transmission errors, unauthorized third-party access, or other events 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 cases, we cannot control or guarantee the security measures those third parties apply.
Please note that transferring Personal Data over the internet cannot be made completely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website includes 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. While this Policy explains practices on our website, it does not apply to third-party websites.
Before following any link to a third-party website or app, you should review its privacy policy before you begin using its services. At the same time, carefully consider whether you wish to provide your Personal Data.

12. Understanding the Amendments to Our Policy

We may update this Policy at any time. If we make changes, we will notify you via our website, present a clear notice of the change, and make the updated Policy available for your review. For material updates, we will use the communication methods we consider most appropriate—such as a website announcement, in-product notice, or email—to inform you. Unless we state otherwise, all amendments take effect immediately upon publication 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 have inaccuracies corrected, and, in certain cases, to request deletion of your Personal Data. You may also ask us to restrict certain types of processing. For individuals residing in the EEA, please refer to 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. If accurate, we will grant you access to your Personal Data and provide an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies of your data. Upon request, we will provide this information electronically.
Your right of access must not infringe the rights and freedoms 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 request that we rectify or complete it. Your Right to Erasure
Legitimate grounds may include: (a) we no longer need the personal data for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (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. You cannot exercise this right where processing is necessary (a) to comply with EU or Member State laws or (b) to establish, exercise, or defend legal claims.
Processing restrictions
You may ask us to limit processing, for example if you contest the data’s accuracy. While processing is restricted, the data may be stored and processed only with your consent, for the establishment, exercise, or defense of legal claims, to protect another person’s rights, or for important public interest of a Member State or the EU.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive your Personal Data that the Company processes.
You also have the right to request transfer of the data to another controller where technically feasible. Exercising data portability will not affect your right to erasure.
Right to object
You may object at any time to our processing of your Personal Data based on legitimate interests pursued by the Company or third parties, 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 have the right to object at any time to the processing of Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
In addition, you have the right to lodge a complaint with the supervisory authority responsible for protecting your Personal Data.
You may also seek protection of your individual rights regarding Personal Data processing within the EU from a supervisory authority in a Member State.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request, and we may extend this by up to two months based on the complexity and number of requests. You will be informed within one month of any extension and the reasons for it.
Information requested under section 13 will be provided free of charge unless a 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 have reasonable doubts about your identity in relation to a request, the Company may request additional information.