We (also known 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').
These principles will be upheld:

To ensure transparency in the processing and collection of your personal information:

We want you to make informed choices about how your Personal Data is used and processed. That’s why we created this website: to offer clear and relevant information on our Personal Data practices. We use a range of methods and procedures to ensure you have the insights you need. If you require specific details, we will provide them at the most appropriate time. Our aim is to support your understanding and confidence in how we handle your information. We welcome any questions and are happy to clarify any legal limitations. You can contact us by email at info@blue-orion.com

Personal data will be used solely for the purposes outlined in the Policy.

Personal Data may be processed by us for various purposes, including offering you access to the website, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, and facilitating the maintenance and delivery of the Services. We also process Personal Data in order to meet regulatory and legal obligations, conduct administrative and business activities that support the provision and use of the Services, and in order to better understand your preferences and needs.

Leverage powerful tools to protect your personal data rights:

We want you to make informed choices about how we use and process your Personal Data, which is why we created this website. Using various methods and procedures, we provide you with clear, relevant information on Personal Data usage. If you need specific details, we will supply them at the appropriate time. We welcome any questions and will clarify any limitations imposed by law. You can reach us via email at info@blue-orion.com

Safeguard Your Personal Data:

Although we cannot guarantee absolute security of your Personal Data, we will continue to implement a range of methods and techniques to safeguard it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy describes the types of personal data Company collects from natural persons, how we process and secure it, and whether we share it with third parties. It applies to information related to an identified or identifiable individual—someone who can be recognized directly or through additional data we hold or access. We define “processing” as any operation requiring the use or collection of 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 18. We do not knowingly collect information from, or allow use by, anyone under 18 years old. If we discover that we have collected information from a child, we will delete it as quickly as possible.

2. What Personal Data Do We Have About You?

When you access our services and channels or visit our website, we collect Personal Data. In some cases, we may request your Personal Data directly. In others, we gather it by analysing your use of our services and channels or by obtaining information from our third-party partners.

3. There is no obligation to disclose personal information to the company, and you will not face any consequences.

You are not required to provide Us with any Personal Data. However, in certain circumstances, withholding this information may prevent Us from offering the Services or prevent users from accessing the website.

4. What type of Personal Data can we collect? When you visit our website, we will collect the following Personal Data:

This includes your online activity log, traffic data (such as IP address, access date and time), selected language, software crash logs, browser type, and device details. This data is not private and cannot be used to identify you. Personal Data We Receive From You: any personal data you choose to provide when connecting to a third-party online trading platform through us. Personal Information You Provide to Third-Party Platforms to Facilitate Trading: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

Your personal data is processed by the Company 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 on which the Company processes your personal data are:

• You have consented to the processing of your personal data for one or more specific purposes. This occurs when you submit information through the Website so that we can forward it to a third-party trading platform.
• The Company or a third party may need to process data to pursue their legitimate interests, such as improving Our Services or defending legal claims.
• Processing must comply with legal obligations.

Contact us by email for further details on the processing required to protect our legitimate interests.
Below is a list of the purposes and legal bases for which we may use the personal data you provide.

6. Transfer of Personal Data to Third Parties

The Company may share Personal Data, including IP address information and user experience analysis, with third-party service providers such as hosting and storage companies.
You may request that we transfer specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you have provided with those platforms, which will use it in accordance with their own privacy policies. Your information may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities or business partners, enabling us to secure the resources needed to enhance and improve our products and services.
To protect the rights of third parties or safeguard assets, the Company is permitted to 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 affiliated company—in connection with a transaction (including the transfer or sale of assets) or as part of a merger, restructuring, consolidation, or bankruptcy involving the Company or any group entity.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be employed on our website. These providers might also use cookies and other tracking technologies. Cookies are small text files placed on your device each time you visit or use the site. They collect information about your browsing habits and preferences to enhance your experience, remember your settings, and personalise the products and services you see. Cookies also support statistical and analytical purposes. Some cookies are session-based: they are temporarily stored on your device and expire when you close your browser. Others are persistent, remaining on your device for a set period after your browser is closed. These persistent cookies help the site recognise you as a returning user and allow you to pick up where you left off.

7. Third-Party Cookies and Services

We may use them according to their purpose:

Cookies are blocked or removed
To prevent or remove cookies, adjust your browser settings. Below are links to help you with the process for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

ONLINE TRACKING NOTICE This service does not currently support do-not-track signals.
8. The retention of Your personal data

We retain your Personal Data for as long as necessary to achieve the processing purposes outlined in this Policy, or for longer when required by applicable laws, regulations, policies, or orders. We share your information with third-party trading platforms for an initial 12-month period. With your consent, we will extend this sharing for an additional 12 months.
We regularly review retained Personal Data to confirm that it is no longer required.

9. Transfers of Personal Information to Third Countries or International Organisations

Your personal information may be transferred to other countries—meaning a third country beyond your country of residence—or to international organizations or jurisdictions. Our company takes all appropriate measures to secure the personal data you provide, ensuring that data subjects can assert their rights and pursue effective legal recourse.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).

• Transfer of personal data to a third country or international organisation deemed by the European Commission to provide adequate protection under Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the 'GDPR')
• The transfer is made under a legally binding, enforceable agreement between public entities or authorities in accordance with Article 46(2)(a) of the viro.
• This transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. You can view the full text of these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You can request details of the security measures The Company uses to protect your Personal Data when it is transferred to third-party countries or international organisations. To learn more, email info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented robust organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee the absolute security of your Personal Data, 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, disclosures caused by transmission errors, unauthorised third-party access, or other factors beyond our control.
If required by law or other binding obligations, we may have to disclose your Personal Data to third parties, such as government authorities. In such cases, we cannot govern their handling or security of your data.
Since no method of internet transmission is completely secure, the Company cannot ensure the absolute protection of any Personal Data you transmit to us over the internet.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided on our website, but these services operate independently of the Company. We do not oversee their collection or processing of Personal Data, and this Policy does not apply to actions taken on those sites or apps.
Before accessing or using any third-party website or application, we recommend that you review its privacy policy and carefully consider any Personal Data you provide.

12. Updates to this Policy

This Policy may be revised at any time. If we update it, we will notify you by posting the updated Policy on our website. For significant changes, we will also use appropriate channels to inform you and will publish an announcement on our website. Unless explicitly stated otherwise, all amendments will take effect upon publication of the revised Policy.

Your Rights Regarding Your Personal Information

You have the right to request verification of the accuracy of any Personal Data we hold about you, to correct inaccuracies, and to delete any Personal Data we no longer require. You may also request restrictions on the types of processing we perform. If you are a resident of the EEA, please refer to this page:
These rights apply to all Personal Data you provide to us. To exercise any of these rights, please email us at the address below. Access rights
We will verify whether we are processing your Personal Data and, if so, provide you with access. Upon request, we will supply an electronic copy of the Personal Data currently processed; reasonable fees may apply for additional copies. If you prefer, we can provide the data electronically.
We will not refuse an access request unless it conflicts with the rights and freedoms of others. If fulfilling your request would adversely affect someone else’s rights, we may refuse or limit our response. Right to rectification
You may request that we correct any inaccurate or incomplete Personal Data concerning you, taking into account the purposes of processing. Right to erasure
You may request deletion of your Personal Data where: (a) it is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and we have no other lawful basis to process it; (c) you object, for reasons specific to your situation, to processing based on our legitimate interests (or those of a third party); (d) the data was unlawfully processed; or (e) we are required to erase it to comply with a legal obligation.
This right does not apply if processing is necessary to comply with EU or Member State law, or to establish, exercise, or defend legal claims. Processing restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict its processing. During the restriction period, we may only retain and process the data with your consent, to establish, exercise, or defend legal rights, to protect another individual’s rights, or for reasons of substantial public interest in the EU or a Member State. Right to data portability
If we process your Personal Data by automated means based on consent or a contract you have with us, you have the right to receive that data in a structured, commonly used, machine-readable format.
You may also request that we transfer your Personal Data directly to another controller where technically feasible. Exercising this right will not affect your right to erasure and will not infringe on the rights or freedoms of others. Right to object
You have the right to object at any time to processing of your Personal Data based on our legitimate interests or those of a third party, including profiling. We may continue processing if we can demonstrate compelling legitimate grounds that override your rights, or if processing is necessary to establish, exercise, or defend legal claims.
For direct marketing, you may opt out of processing your Personal Data for this purpose at any time. Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn. Right to lodge a complaint
You may lodge a complaint with the supervisory authority in your EEA Member State responsible for protecting individuals’ rights in relation to Personal Data processing.
EU and Member State law may limit these rights as detailed in Section 13 of this agreement. We will respond to requests under Section 13 within one month of receipt. This period may be extended by up to two months, depending on the nature and number of requests. We will inform you of any extension within one month of receiving your request, including the reasons.
We will provide the requested information free of charge unless your request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act. If we doubt the identity of the requester, we may request additional information to verify your identity.