We (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 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 data in your best interests:

By doing so, our aim is to help you make informed decisions about the use and processing of Personal Data. To support this, our website employs various methods and procedures to provide relevant information on Personal Data usage. If you require specific details about your data, let us know. We will make every effort to ensure you receive them promptly and at the appropriate time. Should you have any questions, we are happy to clarify any legal constraints. To contact us, please email us at info@blue-orion.com

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

We process Personal Data for various purposes, which include making the website available to you, connecting you with third-party trading platforms (the 'Services'), improving and enhancing the site, protecting our rights and legitimate interests, maintaining, supporting, and provisioning the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative, operational, and business activities to enable the effective delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Providing access to essential resources to help protect your rights regarding Personal Data

We are committed to helping you make well‑informed choices about how we handle your data. That commitment is why we invested the time to develop this website and the resources behind it. To support this, we apply a range of methods and procedures to ensure you continue to receive clear, up‑to‑date, and relevant information about our use of your Personal Data. We also review and update our practices regularly to reflect changes in law and best practice. Where more specific details are required, we will provide them to you at the appropriate time and in the appropriate context. If you have any questions about how this process works, we are pleased to answer and offer clarifications, always within the bounds of applicable legal requirements. To learn more, please contact us by email at: info@blue-orion.com

Keep Your Personal Information Secure and Protected

While we cannot guarantee the absolute security of Personal Data—as no system can—we remain fully committed to employing a wide range of measures to protect your Personal Data. Our Privacy and Security Policy addresses the key essentials to help ensure your long-term safety.

Scope?

This Policy outlines the types of Personal Data our Company collects from customers, as well as how we process it, share it with third parties, and protect it. It covers information about an identified or identifiable individual, whom we can recognize directly or by combining that data with other information we hold or can access. For the purposes of this Policy, 'processing' means any operation performed on Personal Data, including its collection, management, organization, and storage. Our services are intended for a general audience but are not available to anyone under the age of 18. We do not authorize use by individuals under this age and do not knowingly collect information from anyone under 18. If we become aware that we have collected data about a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

By using our services and channels or browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you for this information directly. Alternatively, we may analyse your interactions with our services and channels, or obtain data through our third-party partners

3. You are under no obligation to provide your personal data to our company or accept any consequences arising from doing so

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

4. What are examples of personal data we collect? When you visit our website, you can expect us to collect the following personal information:

The data we collect may include details from your activity log, traffic information (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 information is non-identifying, and we do not use it to personally identify you. We may also obtain Personal Data you provide when connecting to a third-party online trading platform through us. In addition, we receive the personal details you submit to those platforms, which may include your full name, email address, telephone 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 complies with the applicable legal framework.
We require a legal basis because, without it, our Company cannot process 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 submit personal information through the Website so that we can share it with a third-party trading platform
• The Company or a third party may need to process this information because doing so supports their legitimate interests. Examples include improving our Services or protecting ourselves against litigation or legal claims that may arise.
• All processing activities on our website are required to comply with applicable legal requirements, and we confirm that they do.

If you would like more information on how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we provide an overview of 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 providing services such as data storage, hosting of IP address data, or user experience analytics.
We also accept requests 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. Once shared, their 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. This enables us to access the resources needed to enhance and improve our customer offerings.
Where required, 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 prospective investors or buyers, 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 insolvency proceedings involving the Company or related parties.

Online Tracking Notice

You may encounter third-party services on our website, such as advertising providers and analytics companies. These partners may also use cookies and similar technologies to collect data.
When we refer to cookies, we mean small text files stored on your device each time you visit or access our site. We use cookies to learn about your preferences and browsing patterns, so we can enhance your experience, better understand user needs, and design products and services aligned with customer interests. Cookies also support statistical and analytical reporting.
Some of the cookies we use are session cookies. Session cookies are temporarily placed on your device and expire when you close your browser. Other cookies are persistent, meaning they remain on your device 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 can vary, depending on its intended purpose.

Cookies have been blocked or deleted
You can manage your cookie settings in your browser. Use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that certain website functions and features may not perform 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 How Your Personal Information Is Stored

Please note that Our Company will retain your Personal Data for as long as necessary to fulfil the purposes outlined in this Policy, and may keep it for longer where permitted or required by law and for orders where applicable. In some 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 will review and assess the Personal Data we hold to ensure we do not retain it longer than necessary.

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

Under certain circumstances, we may transfer your Personal Data to other countries or to international organizations, with your permission where required. We take all necessary measures to protect your Personal Data and ensure you can exercise your rights and access effective 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 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, enforceable agreement between public bodies or authorities pursuant to Article 46(2)(a)
• We carry out these transfers in line with the European Commission’s Standard Contractual Clauses for data protection, issued under Article 46(2)(c) of the GDPR. For more details, you can view 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 would like to learn more about these details and how they relate to the security measures we implement to protect your Personal Data when it is transferred to third countries or international organisations, please contact us at info@wealthwaydigital.uk

10. Protection of Personal Data

To safeguard your Personal Data, we have implemented robust security measures. These measures are designed to prevent accidental or unlawful destruction, loss, or alteration.
Even so, while we take every reasonable precaution, we cannot guarantee that your Personal Data will always be maintained without error, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures due to transmission errors, unauthorized access by third parties, or other causes beyond our control.
Where we are legally required, or subject 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 guarantee the security measures those third parties provide.
Please note that transmitting Personal Data over the internet can never be completely secure and involves inherent risks. Because of 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 includes links to external sites and applications that are beyond our Company’s control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. Our Policy, while it governs activity on our website, does not extend to third-party websites.
Before visiting any third-party website or app, you should review their privacy policies before using their services. At the same time, carefully consider whether you wish to provide them with your Personal Data.

12. Understanding the Changes to Our Policy

We may update this Policy at any time. If we make changes, we will notify you on our website and make the updated Policy available for your review. For significant changes to this Policy, we will communicate through the methods we consider most appropriate, such as a prominent announcement on our website, and will provide clear access to the revised Policy. Unless we state otherwise, all amendments to this Policy take immediate effect upon publication of the amended Policy.

Your Rights as They Relate to Your Personal Data

You have the right to request access to the personal data we hold about you, to rectify inaccuracies, and to ask that we delete your Personal Data where applicable. You may also request restrictions on the types of data we process. For residents of the EEA, please refer to this page:
Anyone wishing to exercise their data rights may 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. Upon request, we will supply this data electronically.
Your right of access must not infringe the rights and freedoms of others. If a request would affect those rights, we may refuse to comply or limit our response. Your right to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Your right to erasure
You may request deletion of your Personal Data where, for example: (a) it is no longer needed for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing on specific grounds; (e) the Personal Data has been processed unlawfully; 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.
Restriction of processing
You may ask us to limit processing if you believe the data is inaccurate or in other circumstances provided by law. While processing is restricted, we may store the data but will process it only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another person, or for important reasons of public interest of a Member State or the EU.
Right to data portability
Where processing is automated and 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 this data be transmitted 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. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
You also have the right to object at any time to the processing of your 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 data protection.
You may further request protection of your individual rights from a supervisory authority in any Member State regarding the processing of Personal Data 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, and we may extend this by up to two additional months depending on the complexity and number of requests. You will be informed within one month if an extension is applied and the reasons for it.
Information provided under section 13 will be supplied free of charge unless a request is unfounded or excessive, particularly due to repetition, in which case 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 request additional information.