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, use, and store the information you provide on the Gaingate website (the 'Website').
We follow and uphold the following principles:

We are committed to being transparent about how we collect and use your personal information for your benefit:

By doing so, our goal is to help you make informed decisions about the use and processing of Personal Data. To this end, our website employs several methods and procedures to provide clear, relevant information about Personal Data usage. If you require specific details about your data, we will work diligently to ensure you receive 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

We process Personal Data for a variety of purposes, including providing the website to you, connecting you with third-party trading platforms (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 conducting administrative and business activities to support the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Securing access to vital resources that help protect and uphold your rights in relation to Personal Data

Our goal is to help you make well-informed decisions about how we handle your Personal Data. With that in mind, we created this website to explain our approach in a clear and transparent way. To support this, we use a range of methods and procedures to ensure you continue receiving the most relevant information about our 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. If you would like to learn more, please contact us by email at: info@blue-orion.com

Keep Your Personal Information Safe and Secure

While we cannot guarantee the absolute security of Personal Data—no one can—we remain fully committed to using 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?

Within this Policy, you will find a summary of the categories of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and keep it secure. Our Policy covers information relating to an identified or identifiable individual, where a person can be recognized directly or indirectly using information we hold or can access. For the purposes of this Policy, “processing” means any operation performed on Personal Data, including its management, organization, and storage. Our services are intended for a general audience but are not permitted for anyone under 18. We do not authorize individuals under this age to use our services. Accordingly, we do not knowingly collect information from persons under 18, as they are not allowed to use our services. If we become aware that we have collected data about anyone under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

If you use our services, engage with our channels, or browse our website, you acknowledge that we may collect personal data about you. In some 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. You are not obliged to provide your personal information to our company or deal with implications arising from it

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

4. What types of personal data do we collect? When you visit our website, we collect the following categories of 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. The data collected is technical and 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 the 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 set out in this section and does so in accordance with the applicable legal framework.
We require a lawful basis; without one, our Company cannot lawfully process Personal Data about you. 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 this information when necessary to pursue legitimate interests. For example, this could include enhancing our Services and operations or protecting us against potential legal claims.
• All processing on our website must comply with all applicable legal requirements, and we can confirm that these obligations are fully met.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we’ve outlined the reasons and legal bases on which we may use 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 data storage, 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. If you choose this, the platforms’ 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 or affiliated entities. We do so to access resources that help us enhance and continuously improve our customer offerings.
Where required, 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 buyers, or with lenders to the Company or its affiliated companies. 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

On our website, we may use third-party services, such as advertising providers and analytics firms. These companies may also use cookies and similar technologies to collect data.
Cookies are 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, improve the user experience, understand audience interests, and design products and services based on customer needs. In addition, cookies help us compile statistics and perform 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 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 currently blocked or have been deleted
You can manage your cookie preferences in your browser settings. You can use the links below for step-by-step guidance through this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

Online Tracking Notice Please note that, at this time, our service does not honour 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 fulfil the purposes outlined in this Policy, and we may keep it for a longer period as permitted by law and where required for applicable orders. Your information may, in some cases, be shared with third-party trading platforms for up to 12 months. With your consent, we may extend this sharing for a further 12 months if needed.
From time to time, we will review and assess the Personal Data we hold to confirm whether it is still required.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which may mean we have your permission to send this data to a country other than your own, or we may transfer it to international organizations. We take all necessary measures to protect and defend 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 certain cases, we may transfer your Personal Data to a third country or 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 ('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 accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, you can view the 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 use to safeguard your Personal Data when it is transferred 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 extensive precautions, we cannot guarantee that your Personal Data will always be maintained without error, nor can we be held liable for intangible, 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 cannot oversee or assure the security measures of those third parties.
Please note that transferring Personal Data over the internet cannot be made completely secure and carries inherent risks. Owing to these risks, we cannot guarantee the security of the Personal Data you transmit to us online.

11. Links to Third-Party Websites

Our website includes links to external sites and applications that are outside our Company’s control. For this reason, we accept no responsibility for how these third-party websites collect or process your Personal Data. While our Policy explains what happens 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 their privacy policy before you begin using their services. You should also carefully consider whether you wish 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 inform you through the channels we deem most appropriate and will post an announcement on our website. Unless stated otherwise, all amendments take effect immediately upon publication of the revised Policy.

Your Rights as They Relate to Your Personal Data

You have the right to request access to the Personal Data we collect about you, to have it corrected, and to request deletion of your Personal Data where appropriate. You also have the right to restrict certain types of data we process. For individuals residing in the EEA, please see this page:
If you wish to exercise any of your data rights, please contact us using the email address below. Right of access
We will verify the accuracy of the Personal Data we process. Where appropriate, we will grant you access to your Personal Data and provide an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies of your data. Upon request, we will supply this data electronically.
Your right of access must not adversely affect the rights and freedoms of others. If a request would infringe those rights, we may refuse to comply or limit our response. Right to rectification
If you wish to correct inaccurate Personal Data, you may ask us to rectify any incomplete or incorrect information. Right to erasure
You may request erasure where, for example: (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 for specific reasons; (d) the Personal 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 (a) to comply with EU or Member State law, or (b) for the establishment, exercise, or defence of legal claims.
Restriction of processing
You may ask us to restrict processing if you believe the data is inaccurate or in other circumstances provided by law. Where processing is restricted, we may store the data but will process it only with your consent, for the establishment, exercise, or defence of legal claims, to protect the rights of another person, or for important public interest of an EU or Member State.
Right to data portability
For automated processing based on your consent or a contract, you have the right to receive the Personal Data you have provided to the Company.
You also have the right to request that we transmit that data to another controller where technically feasible. Exercising your data portability rights does 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 profiling related to those interests. Unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defence of legal claims, we will cease such processing.
You have the right to object at any time to 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.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data in your jurisdiction.
You may request that the supervisory authority in any Member State protect your individual 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 laws. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request; we may extend this by up to two months, taking into account the complexity and number of requests. You will be notified of any extension and the reasons within one month of your request.
We will provide the information you request under section 13 free of charge unless a request is manifestly unfounded or excessive, especially if repetitive; in such cases, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have reasonable doubts about your identity in relation to a request, the Company may ask for additional information.