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

We are committed to transparency about how we collect and use your personal data to serve your best interests:

By doing so, our goal is to help you make informed decisions about the collection, use, and processing of Personal Data. To support this, our website employs several methods and procedures to provide clear, relevant information about the use of Personal Data. If you require specific details about your data, we will work to ensure you receive them promptly and at the appropriate time. We also strive to deliver updates and notices in a timely and accessible manner. If you have any questions, we are happy to clarify any legal constraints and requirements. To contact us, please email info@blue-orion.com

We will use Personal Data solely for the purposes outlined in the Policy

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

Ensuring access to essential resources as a means of safeguarding your rights relating to Personal Data

Our goal is to help you make well‑informed choices about how we handle your Personal Data. This commitment explains why we invested the time to develop this website. To support it, we use a range of methods and procedures to ensure you continue receiving the most relevant and up‑to‑date information about the use of your Personal Data. If you require specific details, we will provide them at the appropriate time. If you have any questions about how this process works, we are happy to answer and offer clarifications, all within the bounds of legal requirements. To learn more, please contact us via email at info@blue-orion.com

Keep Your Personal Data Safe and Secure

While no one can guarantee the absolute security of Personal Data, we remain fully committed to employing a wide range of measures to protect your Personal Data. Our Privacy and Security Policy addresses all essential aspects to help ensure your long-term security.

Scope?

When reviewing this Policy, you will find an overview of the types of Personal Data our Company collects from customers, as well as how we process it, share it with third parties, and keep it secure. Our Policy applies to information about an identified or identifiable person, meaning we can recognise someone directly or by combining it with other information we hold or can access. For the purposes of this Policy, “processing” means any operation performed on Personal Data, including its management, organisation, and storage. Our services are intended for a general audience, but are not permitted for anyone under 18 years of age. We do not authorise individuals under this age to use our services and do not knowingly collect their information. If we become aware that we have collected data relating to anyone 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 certain cases, we may ask you to provide personal data directly. We may also collect this information by analyzing your interactions with our services or channels, or through our third-party partners

3. There is no obligation to provide your personal information to our company or to deal with any associated implications

You are not required to share personal data with us. However, if you choose not to provide certain information, it may affect our ability to deliver our services, which could result in limited access to our website or restricted use of certain 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 information such as activity log details, traffic data (including IP address, access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This technical data is non-personal, and we do not use it to identify you. We may also obtain Personal Data you voluntarily provide when connecting to a third-party online trading platform through us. In addition, we receive personal details you submit directly to those platforms, which may 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 outlined in this section and in accordance with applicable law.
We require a legal basis; without it, our Company cannot process your Personal Data. The legal bases that allow 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 via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process information to further their legitimate interests. This may include improving our Services or defending against potential legal claims.
• All processing on our website must comply with applicable laws and regulations, and we confirm that it does.

If you would like more information about how we process Personal Data under our legitimate interests, please contact us by email for further details.
Below, we outline the purposes and legal bases on which we may use the personal information you have provided to us, including the safeguards we apply. 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 want 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. When you do so, 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 this to access resources that help us 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 interested investors or buyers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving 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 companies may also use cookies and similar technologies to collect data.
When we refer to cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies because they help us gather information about your preferences and browsing patterns, with the goal of improving the user experience, understanding our audience, and designing products and services based on customer interests. In addition, cookies help us collect data for statistics and analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily placed on your device and expire when you close your browser. Other cookies are known as persistent cookies because they 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 use may vary depending on its intended purpose.

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

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some of the website's functions and features may not perform as intended 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 will retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, and we may keep it for a longer period as permitted by law and for applicable order-related requirements. 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.
We periodically review and assess the Personal Data we hold to ensure we only retain what is necessary.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send this data outside your home country, including to international organizations. We take all necessary measures to protect 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 benefit from these protections and safeguards.

• In some cases, we may transfer your Personal Data to a third country or an international organisation that the European Commission recognises as providing an adequate level of 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 a transfer occurs, we carry it out under a legally binding and enforceable agreement between public authorities or bodies 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 pursuant to Article 46(2)(c) of the GDPR. For more information, you can review 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 more information about these details and how they relate to the security measures we employ to safeguard your Personal Data when transferred to third countries or international organizations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented robust security measures designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee that your Personal Data will be maintained without error or that security will be flawless, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by 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 circumstances, we cannot control the security measures those third parties apply.
Please note that transmitting Personal Data over the internet can never be completely secure and carries inherent risks. Accordingly, we cannot guarantee the security of Personal Data you send 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 are not responsible for how these third-party websites collect or process your Personal Data. Our Policy covers activity on our website only and does not apply to third-party websites.
Before following any link to a third-party website or app, you should review their privacy policies before using their services. You should also carefully consider whether you want to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If changes are made, we will notify you on our website and display the updated Policy. For significant updates, we will use the communication methods we deem most appropriate, including an announcement on our website. Unless stated 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 circumstances, to ask us to delete your Personal Data. You may also request that we restrict certain types of processing. For those residing in the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us at the email address below. Right of access
We will confirm whether we process your Personal Data and, where we do, provide access along with an electronic copy of the data processed. We may charge a reasonable fee for additional copies. When requested, we will provide this data electronically.
Your right of access must not adversely affect the rights and freedoms of others. Where a request would do so, we may refuse to comply or limit our response. Right to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Right to erasure
You may request deletion where, for example: (a) the data is no longer needed for its original purpose; (b) you withdraw consent and no other legal basis applies; (c) you object to processing and there are no overriding legitimate grounds; (d) the data has been processed unlawfully; or (e) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary to comply with EU or Member State law or to establish, exercise, or defend legal claims.
Right to restrict processing
You may ask us to limit processing, for example if you contest the data’s accuracy or object to processing while we verify our grounds. Where processing is restricted, we will only store the data or process it with your consent, for legal claims, to protect others’ rights, or for important public interests of an EU Member State or the EU.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive the Personal Data you provided to us in a structured, commonly used, machine‑readable format.
You also have the right to request that we transmit this 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 processing of your Personal Data based on our 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 required 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 based on consent before its withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data.
You may submit a complaint to the supervisory authority in the EU Member State of your residence, place of work, or where the alleged infringement occurred.
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 information requested under section 13 within one month of receipt; we may extend this by up to two months depending on the complexity and number of requests. You will be informed of any extension and the reasons within one month of your request.
We will provide information requested under section 13 free of charge unless a request is manifestly 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 connection with a request, the Company may request additional information.