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

To be transparent about how we collect and process your personal information:

We want you to be well positioned to make informed decisions regarding the use and processing of your Personal Data. To that end, our website employs various methods and procedures to deliver clear and relevant information on how Personal Data is handled. Our goal is to ensure full transparency and to empower you to exercise control over your Personal Data. If we determine you need more specific details, we will provide them at the appropriate time. We welcome any questions and will clarify any legal limitations as required. You can reach us via email at 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 you with the website and connecting you to third-party trading platforms (the 'Services'), enhancing and maintaining the site, protecting our rights and interests, fulfilling regulatory or legal obligations, and performing administrative and business activities to facilitate the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.

Take advantage of powerful tools to safeguard your rights with respect to Personal Data:

Our goal is to empower you to make informed choices about how your Personal Data is used and processed. That is why we created this website. To achieve this, we employ various methods and procedures to deliver detailed, relevant information on our Personal Data practices. If you need further specifics, we will provide them promptly at the appropriate time. We welcome your questions and will clarify any legal constraints as needed. You can reach us by email at info@blue-orion.com

Safeguard Your Personal Data:

While we cannot guarantee absolute security of your Personal Data, we will continue to employ a variety of robust methods and techniques to ensure its protection. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the categories of Personal Data the Company collects from natural persons, how it processes and shares that data with third parties, and the measures it takes to secure it. It covers information related to an identified or identifiable natural person—someone who can be identified directly or through other information we hold or access. The policy defines “processing” as any operation involving Personal Data, including its management, organization, and storage. Our services are intended for a general audience and are not designed for use by anyone under the age of 18. We do not knowingly collect information from individuals under 18, nor do we permit them to use our services. If we become aware of Personal Data belonging to minors, we will delete it as soon as possible.

2. What Personal Data Do We Hold About You?

If you access our services, communication channels, or website, we collect Personal Data. In certain instances, we may ask you to provide this information directly. In other cases, we gather it by analyzing your interactions with our services or channels, or by receiving it from our authorized third-party partners.

3. There is no obligation to disclose personal information to the company, and no consequences for opting not to do so.

You are not required to provide us with any personal data. However, if you choose not to share certain personal data under specific circumstances, we may be unable to provide our services or allow users to access the website. This could affect your experience and restrict access for other users.

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

This includes your online activity logs, traffic data (including IP address, date of access and time of access), language preferences, software crash logs, browser type and device details. The collected information is not private and cannot identify you. Personal Data We receive from you: any personal data you voluntarily provide when connecting with a third-party online trading platform through us. Personal information you provide specifically to third-party platforms to facilitate trade: your full name, address, phone number and email address.

5. The Legal Basis and Rationale for the Processing of Personal Data

We process your Personal Data for the purposes described in this section and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot use your Personal Data. The legal grounds the Company relies on to process your Personal Data are:

• You have granted your consent to the processing of your Personal Data for one or more purposes. This occurs when you provide personal information through the Website so that we can forward it to a third-party trading platform.
• The Company or a third-party may require processing to meet their legitimate interests. For instance, this is necessary to improve Our Services or to defend legal claims.
• Processing must comply with legal obligations.

Contact us by email for more details about the processing required to protect our legitimate interests.
Below is a list of reasons and legal grounds on which we may use the personal data you provide. Personal Data.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, such as hosting and storage companies, including IP address information and user experience analytics.
You can request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will transmit the Personal Data you provide to us to those platforms. Their use of your Personal Data is governed by their privacy policies, and your information may be shared with multiple trading platforms.
The Company may share Personal Data with affiliates or business partners to secure the resources needed to enhance and improve the products and services we offer our customers.
To protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any group company in connection with a transaction (including the transfer or sale of assets) or as part of a merger, restructuring, consolidation, or bankruptcy of the Company or any related entity.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be used on our website. These services may also employ cookies or other technologies.
Cookies are small text files stored on your device each time you visit or access the website. They collect information about your preferences and browsing habits to enhance your user experience, maintain your settings, and personalize products and services. Cookies are also used for statistical and analytical purposes.
We use session cookies, which are temporarily downloaded to your device and expire when you close your browser. We also use persistent cookies, which remain on your device for a specified period after the browser is closed. These cookies help the website recognize you as a returning user and allow you to revisit the site seamlessly.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To prevent or remove cookies, adjust your browser settings. Here are links to guides for several popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that some or all of the Website's functions and features may not work as you expect if this happens.

ONLINE TRACKING NOTICE This service does not currently honor Do Not Track signals.
8. Retention of your personal data

We will retain your Personal Data as long as necessary to fulfill the processing purposes outlined in this Policy or for any extended period required by law, regulation, policy, or applicable orders. We'll share your information with third-party trading platforms for 12 months. If you consent, we'll continue sharing your data for an additional 12 months.
We regularly review the Personal Data we hold to ensure it is no longer necessary.

9. Transfers of personal data to third countries or international organisations

Your personal information may be transferred or transmitted to other countries—including third countries outside your country of residence—or to international organizations or jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that individuals can assert 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 organisation that the European Commission has determined provides adequate security for Personal Data under Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the ‘GDPR’)
• The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a) of viro.
• This transfer was executed in compliance with the EU Commission’s standard data protection clauses, adopted under Article 46(2)(c) of the GDPR. You can view these clauses on the EU Commission website at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

We can provide details on the security measures we employ to protect your personal data when it’s transferred to third-party countries or international organisations. To request this information, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organizational and technical measures to safeguard your Personal Data, including protections against accidental or unlawful destruction, loss, or modification. We regularly review these safeguards to ensure their ongoing effectiveness.
However, we cannot guarantee that your Personal Data will remain secure without error, nor can we accept liability for any indirect, incidental, or consequential damages resulting from its use or disclosure. This includes, but is not limited to, data disclosed due to transmission errors, unauthorized third-party access, or any circumstances beyond our control.
If compelled by law or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot govern the security measures those third parties may apply to your Personal Data.
No method of transferring Personal Data over the internet can be completely secure. The Company cannot guarantee the security of any Personal Data you transmit to Us online.

11. Hyperlinks to external websites operated by third parties

Our website includes links to third-party websites and applications. These external services operate independently and are not supervised by the Company. We are not responsible for their collection or processing of Personal Data. This Policy does not apply to actions taken on these sites or apps.
Before visiting any third-party site or app, we recommend reviewing its privacy policy and carefully considering any Personal Data you choose to provide.

12. Updates to This Policy

This Policy may be revised at any time. When we update it, we will notify you by posting the revised Policy on our website. For substantial changes, we will also inform you through appropriate channels and publish an announcement on our site. Unless explicitly stated otherwise, all amendments become effective upon publication of the updated Policy.

Your rights regarding 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 unnecessary Personal Data. You may also limit the types of processing we perform on your personal information. If you reside in the EEA, please refer to this page:
These rights apply to the information you provide as Personal Data. To exercise any of these rights, please email us at the address below. Access rights
The Company can verify whether your Personal Data is being processed. If so, you have the right to access it. We will provide an electronic copy of the processed data and may charge a reasonable fee for additional copies. Upon request, the data will be delivered electronically.
The right to access Personal Data must not infringe on the rights and freedoms of others. If your request conflicts with another person’s rights, the Company may refuse or partially fulfill it. Right to rectification
The Company will correct any inaccurate Personal Data. You may also request that incomplete Personal Data about you be updated in light of the processing purpose. Right to Erasure
You may request that your Personal Data be deleted when: (a) it is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on our or a third party’s legitimate interests for reasons specific to your situation; (d) the data have been unlawfully processed; or (e) the data must be erased to comply with a legal obligation. This right does not apply when processing is necessary (a) to comply with a legal requirement under EU or Member State law; or (b) to establish, exercise, or defend legal claims. Processing restrictions
If you question the accuracy of your Personal Data, you may request that the Company restrict processing. During this restriction, your data will only be retained with your consent, or to establish, exercise, or defend legal claims, to protect another individual’s rights, or for reasons of significant public interest under EU or Member State law.
Right to data portability
When processing is based on your consent or a contract and is carried out by automated means, you have the right to receive the Personal Data you provided to the Company in a structured, commonly used, and machine-readable format.
You may also request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising this right of portability does not affect your right to erasure and must not infringe on others’ rights or freedoms.
Right to challenge
You have the right at any time to object to the processing of your Personal Data that is based on the Company’s or a third party’s legitimate interests, including profiling. We may continue processing if we can demonstrate compelling legitimate grounds that override your rights, or if required to establish, exercise, or defend legal claims.
Concerning direct marketing
You have the right at any time to object to the processing of your Personal Data for direct marketing purposes.
Right to refuse consent
You may withdraw your consent for us to process your Personal Data at any time. This will not affect the lawfulness of any processing carried out before your withdrawal.
Complaint and supervisory authority
You have the right to lodge a complaint with your local data protection authority. You may also appeal to a supervisory authority established by an EU Member State to protect individuals’ fundamental rights in relation to Personal Data processing.
EU and Member State law may impose limits on the rights described in Section 13 of this Agreement. We will respond to your request under Section 13 of this Agreement within one month of receipt. If necessary, we may extend this period by up to two further months, depending on the complexity and number of requests. We will inform you within one month of receipt if an extension is required, along with the reasons.
Unless prohibited by Section 13 of the law, we will provide the requested information free of charge. However, if your request is manifestly unfounded or excessive—particularly if repeated—we may charge a reasonable administrative fee or refuse to act on the request.
Identity verification
If we have any doubts about your identity when processing a request, we may ask you to provide additional information to verify who you are.