We (referred to as 'we', 'us', or 'our') are fully committed to safeguarding your Personal Data and protecting 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 follow and uphold the following principles:

We are committed to being transparent about how we collect and use your personal information in your best interests:

By doing so, we aim to help you make informed decisions about the use and processing of Personal Data. To support this, our website employs several methods and procedures to provide clear, relevant information about how Personal Data is used. If you require specific details about your data, we will make every effort to provide them promptly and at the appropriate time. If you have any questions, we are happy to explain anything related to legal requirements and constraints. To contact us, please email us at info@blue-orion.com

We will use Personal Data solely for the purposes set out in this Policy

We process Personal Data for various purposes, including providing the website, connecting you with third-party trading platforms (the "Services"), improving the site, protecting our rights and interests, maintaining and delivering the Services, complying with legal and regulatory obligations, and carrying out administrative and business operations 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 the essential resources you need to protect your rights in relation to Personal Data

Our goal is to help you make well‑informed decisions about how we handle your data. This is why we invested the time to develop this website. To support that aim, we use a range of methods and procedures to ensure you consistently receive the most relevant information about how your Personal Data is used. If you need specific details, we will provide them at the appropriate time. If you have questions about the process, we are happy to explain and clarify within the bounds of legal requirements. To learn more, please contact us at: info@blue-orion.com

Keep Your Personal Information Secure and Protected

Although we cannot guarantee the absolute security of Personal Data—no one can—we remain fully committed to employing a broad range of safeguards to protect your Personal Data. Our Privacy and Security Policy covers all essential areas to ensure your long-term safety.

Scope?

When reviewing this Policy, you will find an outline of the types of Personal Data our Company collects from customers, together with the methods we use to process it, share it with third parties, and keep it secure. This Policy applies to information relating to an identified or identifiable individual, where a person can be recognised directly or indirectly through a combination of additional information we hold or can access. For the purposes of this Policy, “processing” refers to any operation performed on Personal Data, including the collection, management, organisation, and storage of that data. Our services are intended for general audiences but are strictly prohibited for anyone under the age of 18. We do not authorise individuals under this age to use our services. Consistent with this, we do not knowingly collect information from anyone under 18, as they are not permitted to use our services. If we become aware of any data collection relating to persons under 18, we will delete it promptly.

2. What Personal Information Do We Collect from You?

If you use our services, access 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 this information directly. We may also analyze your interactions with our services or channels, or obtain this information through our third-party partners

3. You are not required to provide your personal information to our company or accept the implications of doing so

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

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

Personal Data we collect includes details from your activity log; traffic data (such as IP address and 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. Some of the Personal Data we obtain from you includes any information you voluntarily provide when you connect to a third-party online trading platform through us. We may also receive personal details you submit directly to those platforms, which can include your full name, email address, phone number, and postal address.

5. What Are Our Legal Bases and Justifications for Processing Personal Data

Our Company processes your personal data for the purposes we will outline in this section and in compliance with the applicable legal framework.
We require a valid legal basis; without one, our Company cannot process your personal data. The legal grounds 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 submit Personal Data through the Website for sharing with a third-party trading platform
• The Company or a third party may need to process this information where doing so serves their legitimate interests. Examples of this include enhancing our Services or defending against litigation that may arise.
• All processing activities on our website must comply with applicable legal requirements, and we confirm that they do.

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 provide 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 data storage, IP address hosting, 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 choose. When this occurs, the platforms’ 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. This enables us to access the resources needed to enhance and continuously improve our customer offerings.
Where appropriate, the Company may disclose Personal Data to regulatory, local, or other competent 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 related parties.

Online Tracking Notice

We use third-party services, such as advertising partners and analytics providers, on our website. 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 whenever you visit or access our website. We use cookies because they help us gather information about your preferences and browsing patterns to improve the user experience, understand your preferences, and design products and services aligned with customer interests. In addition, cookies help us compile statistics and conduct analytics.
With some of the cookies we use, they are session cookies. Session cookies are temporarily stored 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

The function and usage of each cookie may vary depending on its intended purpose.

Cookies are blocked or have been removed
You can manage your cookie settings in your browser's preferences. Use the links below for assistance.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that some of the website’s functions and features may not operate as intended if this occurs.

Online Tracking Notice Please note that our service currently does not recognise Do Not Track requests.
8. Learn More About Storing 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, or for a longer period where permitted or required by law, including for order-related obligations. 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 a further 12 months if needed.
We periodically review and assess the Personal Data we hold to ensure it is not retained longer than necessary.

9. Transfer of Personal Data to a Third Country or an International Organisation

In certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send this data to a country other than your own, or 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) benefit from these protections and safeguards.

• In certain cases, we may transfer your Personal Data to a third country or an 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 agreement between public entities or authorities, in accordance with Article 46(2)(a)
• We carry out data transfers in line with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) GDPR. To learn more, 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

To learn more about these details and how they relate to the security measures we implement to protect your Personal Data during transfers 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 measures are designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take every reasonable precaution, we cannot guarantee that your Personal Data will always be kept error-free and secure, nor can we be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures resulting from 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 cases, we cannot control the security measures those third parties implement.
Please note that transmitting Personal Data over the internet cannot be made completely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of your Personal Data that you transmit to us online.

11. About Links to Third-Party Websites

Our website contains links to external sites and applications that are outside our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. While our Policy covers activities on our website, it does not apply to third-party websites.
Before visiting any third-party website or app, you should review their privacy policies prior to using their services. You should also carefully consider whether you want to provide your Personal Data.

12. Understanding the Changes to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will notify you via a notice on our website and provide access to the updated Policy. For material updates, we will communicate through the channels we deem most appropriate, including a prominent announcement on our website. Unless we state otherwise, all changes to this Policy 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 to ask for the deletion of your Personal Data in appropriate circumstances. You may also request that we restrict certain types of processing. For individuals residing in the EEA, please refer to this page:
Anyone wishing to exercise their data rights may contact us using the email address below. Access rights
We will verify the accuracy of the Personal Data we process. If it is accurate, we will provide you with access to your Personal Data and supply an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, we will provide this data electronically.
Your right to access this information must not infringe on the rights and freedoms of others. Where a request would affect others’ rights, we may refuse to comply or limit our response. Rights related to rectification
If you wish to correct inaccurate Personal Data, you may request that we rectify or complete the information. Your Right to Erasure
Valid grounds may include: (a) we no longer need the personal data for its original purpose; (b) you withdraw your consent and no other legal basis applies; (c) you object to processing and there are no overriding legitimate grounds; (d) the Personal Data has been processed unlawfully; or (e) erasure is required to comply with a legal obligation. You cannot exercise this right 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 ask us to limit processing if you believe the data is inaccurate. While processing is restricted, the data may be stored but will be processed only with your consent, for the establishment, exercise or defense of legal claims, to protect another person’s rights, or for important public interest of a Member State or the EU.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive your Personal Data that the Company holds in a structured, commonly used, machine-readable format.
You also have the right to request the transfer of this data to another controller where technically feasible. Exercising data portability 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 third parties’ legitimate interests, including related profiling. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed for the establishment, exercise, or defense of legal claims.
You have the right to object at any time to the 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 carried out before withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for your Personal Data rights.
You may also seek protection from a supervisory authority in a Member State concerning the processing of Personal Data within the EU.
As noted in this section 13, your Personal Data rights may be limited by EU and Member State laws. We will provide the information requested under section 13 within one month of receiving your request, but we may extend this by up to two months depending on the complexity and number of requests. You will be notified within one month of any extension and the reasons for it.
We will provide the information you request under section 13 free of charge unless the request is unfounded or excessive, especially if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act on the request.
If we have doubts about your identity in relation to a request, the Company may request additional information.