We ('We', 'Us', or 'Our') remain fully committed to protecting your Personal Data and safeguarding your privacy.
Our Privacy Policy is designed 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 to serve 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, our website uses various methods and procedures to provide relevant information about Personal Data usage. If you require specific details about your data, we will work diligently to deliver them promptly and at the appropriate time. Should you have any questions, we are happy to clarify anything related to legal requirements. To contact us, please email info@blue-orion.com

We will use Personal Data solely for the purposes described in this 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 trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and providing the Services, ensuring full compliance with legal and regulatory requirements, and performing administrative and business activities necessary to deliver and support your use of the Services. We also process your Personal Data to help us better understand your preferences and needs.

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

We are committed to helping you make well‑informed decisions about how we manage your data. That commitment is why we designed and built this website, to explain our practices clearly and transparently. It outlines what we do and why it matters to you. To support this goal, we apply a range of methods and procedures—technical, organizational, and operational—to ensure you consistently receive the most relevant information about how your Personal Data is collected, used, and protected. When specific information is required, we will provide it to you at the appropriate time and in the appropriate format. If you have any questions about these processes, we are ready to respond, offer clarifications, and guide you through the details, all within applicable legal requirements. Should you wish to learn more or request assistance, please contact us via email at: info@blue-orion.com

Keep Your Personal Information Safe and Secure

While no system 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 the most critical areas to help ensure your long-term safety.

Scope?

This Policy outlines the categories of Personal Data our Company collects from customers and describes how we process it, share it with third parties, and protect it. It applies to information about an identified or identifiable individual, meaning data that can be used to recognize someone directly or when combined with other information we hold or can access. For purposes of this Policy, “processing” means any operation performed on Personal Data. This includes activities such as the management, organization, and storage of Personal Data. Our services are designed for a general audience but are not available to anyone under 18. We do not authorize individuals under this age to use our services. Accordingly, we do not knowingly collect information from anyone under 18, as they are not permitted to use our services. If we become aware that we have collected data about a person under 18, we will delete it promptly.

2. What Personal Information Do We Collect from You?

If you use our services or channels, or browse our website, you acknowledge that we may collect your personal data. In some cases, we may request this information from you directly. We may also collect it by analyzing how you interact with our services or channels, or through our third-party partners

3. You are not obligated to provide your personal information to our company or manage any resulting implications

You are not required to share personal data with us. However, choosing not to provide certain personal data may affect how we deliver our services, potentially resulting in limited access to our website or restricted use of some features.

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

The information we collect includes details from your activity log, traffic data (such as IP address and the date and time of access), the language you use on our site, software crash reports, browser type, and device specifications. This usage data is non-personal, and we do not use it to identify you. We also obtain Personal Data that you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we may receive 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 outlined in this section and in compliance with applicable legal requirements.
This legal basis is essential, as without it our Company cannot use 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 via the Website for us to share with a third-party trading platform
• The Company or an external party may need to process this information because it serves their legitimate interests. Examples include improving our Services or defending ourselves against litigation that may arise from time to time.
• All processing carried out on our website must comply with applicable legal requirements, and we confirm that it does comply with them.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we outline the reasons and legal bases for our use of the personal information you have provided 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 storage, hosting, IP address logging, or user experience analytics.
We also honor 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 choose this option, their privacy policies will govern its use. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners or affiliated entities to access resources needed to enhance and improve our customer offerings.
Where appropriate, the Company may disclose Personal Data to regulatory, local, or other official authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or purchasers, or with lenders to the Company or its affiliates. This typically occurs in the context of transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or related parties.

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 to collect data.
When we say cookies, we mean small text files stored on your device each time you visit or access our website. We use cookies to gather information about your preferences and browsing patterns with the goal of enhancing your experience, understanding what our users prefer, and shaping products and services around customer interests. In addition, cookies help us collect more detailed information for statistics and analytics.
With some of the cookies we use, they are session cookies. Session cookies are temporarily downloaded to your device and expire once 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 enable 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 have been blocked or deleted
You can manage your cookie settings through your browser's settings menu. For help, click one of the links below.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be advised that some functions and features of the website may not operate as intended if this issue occurs.

Online Tracking Notice Please note that our service does not currently 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 fulfill the purposes outlined in this Policy, and may retain it for a longer period as permitted by law and for order-related requirements where applicable. 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 review and assess the Personal Data we hold to ensure we do not retain it longer than necessary.

9. Cross-Border Transfer of Personal Data to a Third Country or an International Organization

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

• In certain cases, we may transfer your Personal Data to a third country or international organisation that the European Commission has recognised 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 instrument between public authorities or bodies, in accordance with Article 46(2)(a)
• We conduct data transfers in accordance with the European Commission’s Standard Contractual Clauses (SCCs) for data protection, adopted under Article 46(2)(c) of the GDPR. For more information, 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'd like to learn more about these details and how they relate to the security measures we use to protect your Personal Data when transferred to third countries or international organizations, please email us at info@wealthwaydigital.uk

10. Personal Information Protection

To safeguard your Personal Data, we have implemented robust industry-standard security measures. These are designed to prevent accidental or unlawful destruction, loss, alteration, or unauthorized disclosure.
However, despite our best efforts, we cannot guarantee that your Personal Data will always remain secure and error-free, and we are not liable for any indirect, 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 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 do not control the security measures those third parties implement.
Please note that transmitting Personal Data over the internet is never completely secure and carries inherent risks. For this reason, we cannot guarantee the security of your Personal Data when you send it to us online.

11. Regarding Links to Third-Party Websites

Our website may include 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. While our Policy applies to activity on our website, it does not apply to third-party websites.
Before visiting any third-party website or app, please review their privacy policies before using their services. You should also carefully consider whether you wish to share your Personal Data with them.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will notify you via our website, where we will also provide the updated Policy for your review. For material changes, we will use the communication methods we deem most appropriate, post a dedicated announcement on our website, and may contact you through other channels where applicable. Unless we state otherwise, all updates to this Policy will take effect immediately upon the publication of the revised Policy.

Your Rights Regarding Your Personal Data

You have the right to review the personal data we hold about you, to have it corrected, and to request deletion of any Personal Data you do not wish us to retain. You may also restrict the categories of data we collect. For those residing in the EEA, please check out this page:
If you wish to exercise any of your data rights, please use the email address below to contact us. 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. We reserve the right to charge a reasonable fee for additional copies. Upon request, we will provide this data electronically.
Your right of access must not infringe the rights of others. If a request would do so, 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 correct or complete 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 on specific grounds; (e) the processing is unlawful; 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 request that we limit processing if you believe the data is inaccurate. While restricted, it may be retained only with your consent, to protect the rights of others, or where there is an important public interest under Member State or EU law.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive your Personal Data processed by the Company.
You may also request that we transfer this data to another controller where technically feasible. Exercising 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 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 necessary for the establishment, exercise, or defense of legal claims.
You may also object at any time to processing for direct marketing.
Right to withdraw consent
You may withdraw your consent for processing at any time without affecting the lawfulness of processing carried out before your withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data rights.
You may ask a supervisory authority in a Member State to protect your rights regarding Personal Data processing within the EU.
As outlined in section 13, your Personal Data rights may be limited by EU and Member State law. We will provide information requested under section 13 within one month of receiving your request, and we may extend this by up to two months depending on the nature and volume of requests. You will be notified within one month if an extension applies and the reasons for it.
We will provide information requested under section 13 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 doubts about your identity in relation to a request, the Company may request additional information.