We (also referred to as 'We', 'Us', or 'Our') are fully committed to protecting your Personal Data and safeguarding your privacy.
Our Privacy Policy is intended to inform you, the consumer, 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 transparency about how we collect and process your personal information to serve your best interests:

By doing so, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website uses several methods and procedures to provide relevant information about how Personal Data is used. If you require specific details about your data, we will make every effort to deliver them promptly and at the appropriate time. If 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 solely for the purposes outlined 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, ensuring full compliance with legal and regulatory requirements, and carrying out administrative and business activities that enable the provision and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Ensuring access to essential resources as a means to effectively safeguard your rights in relation to Personal Data

We are committed to helping you make well‑informed choices about how we handle your data. That commitment explains why we built this website. To support this, we use a range of methods and procedures to ensure you receive the most relevant information about our use of your personal data. When specific details are needed, we will provide them at the appropriate time. If you have questions about how this process works, we are happy to answer and clarify, all within applicable legal requirements. To learn more, contact us via email at: info@blue-orion.com

Keep Your Personal Data Safe and Secure

While no one can guarantee the absolute security of Personal Data, we are fully committed to safeguarding your Personal Data through a range of robust protective measures. Our Privacy and Security Policy addresses all key areas to help ensure your long‑term safety.

Scope?

In this Policy, you will find an overview of 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. This Policy covers information about an identified or identifiable person, whom we can recognize directly or indirectly using additional information we hold or can access. In this Policy, 'processing' means any operation involving the use or handling of Personal Data, including the management, organization, and storage of such data. Our services are intended for general audiences, but are not available to anyone under the age of 18. We do not authorize individuals under this age to use our services and do not knowingly collect information from anyone under 18. If we become aware that we have collected data relating to a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

By using our services, our channels, or browsing our website, you acknowledge that we may collect personal data about you. In some cases, we may ask you to provide this information directly. Alternatively, we may analyse how you interact with our services or channels to obtain it, or receive it from our trusted third-party partners

3. There is no obligation to provide your personal information to our company or to deal with 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 this personal data, it may affect how we deliver our services to you, which could mean limited access to our website or restricted use of certain features.

4. What Types of Personal Data Do We Collect? When you visit our website, you can expect that we may collect the following personal information:

The Personal Data we collect includes information such as activity log details, traffic data (including 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-personally identifying, and we do not use it to identify you. Some of the Personal Data we obtain from you includes any personal information you voluntarily provide when you connect to a third-party online trading platform through us. We also collect the personal details you submit directly to these platforms, which may 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 outlined in this section and in accordance with applicable data protection laws.
We require a legal basis; without one, 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 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 your information when necessary to pursue their legitimate interests. This may include enhancing our Services or defending our legal rights in the event of a dispute.
• All processing on our website must comply with applicable legal requirements, and we confirm that it does.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us via email.
Below we outline the reasons and legal bases for the ways we may use the personal information you have provided to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Where appropriate, the Company may disclose Personal Data to third parties that provide services such as data storage, hosting of IP address data, or user experience analytics.
We also process requests from individuals who ask us to share certain Personal Data with third-party trading platforms. In such cases, we will transfer the Personal Data you provide to the platforms you specify. Once shared, their privacy policies will govern its use. Depending on your request, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners or affiliated entities. This enables us to access the resources needed to enhance and continually 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 purchasers, 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

Our website may use third-party services, such as advertising networks and analytics providers. These partners may also use cookies and similar technologies to collect data.
By cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies to learn about your preferences and browsing patterns so we can enhance your experience, understand user needs, and design products and services aligned with customer interests. Cookies also help us gather information for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Other cookies are persistent, meaning they remain on your device even after you close your browser. These 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 how it's used may vary depending on its intended purpose.

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

• 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 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 a longer period as permitted by applicable laws and for orders where required. 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 an additional 12 months if needed.
We periodically review and assess the Personal Data we hold to confirm whether it remains necessary.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send this Personal Data outside your home country, or to share it with international organizations. We take every necessary measure to safeguard your Personal Data and ensure that you can exercise your rights and have effective access to 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 line with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the 'GDPR')
• When the transfer occurs, we carry it out under a legally binding, 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, as adopted pursuant to Article 46(2)(c) of the GDPR. For those who wish to learn more, you can 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

For more information about these details and how they relate to the security measures we implement to protect your Personal Data when 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 appropriate security measures designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee that your Personal Data will always be maintained without error, and we are not liable for intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by transmission errors, unauthorized third-party access, or other events beyond our control.
Where we are legally required, or in other circumstances 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 is never fully secure and carries inherent risks. As a result, we cannot guarantee the security of Personal Data you send to us online.

11. Regarding Links to Third-Party Websites

Our website may contain links to external sites and applications that are outside our Company's control. As such, 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 you follow a link to any third-party website or app, you should review their privacy policies before you start to use their services. At the same time, you should carefully consider whether you want to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We may update this Policy at any time. If we make changes, we will notify you on our website and provide the updated Policy. For significant updates, we will use the communication methods we consider most appropriate and will also post an announcement on our website. Unless stated otherwise, all updates 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 deletion of Personal Data in certain circumstances. You also have the right to restrict certain types of processing. For those residing in the EEA, please check out this page:
If you wish to exercise any of your data rights, please contact us using the email address below. Access rights
We will verify the accuracy of the Personal Data we process. If accurate, we will provide you access to your Personal Data and an electronic copy of the processed data. 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 of access may not adversely affect the rights and freedoms of others. Where a request would do so, we may refuse to comply or limit our response. Your rights related to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Your right to erasure
Valid grounds may include: (a) we no longer need the Personal Data for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (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) to establish, exercise, or defend legal claims.
Processing restrictions
You may ask us to limit processing if you believe the data is inaccurate. Where processing is restricted, we will store the data but will only process it with your consent, for the establishment or defense 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 this data be transmitted 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 legitimate interests pursued by the Company or third parties, including related profiling. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is 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 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 ask the supervisory authority in a Member State to protect your individual rights concerning Personal Data processing within the EU.
As outlined in section 13, your Personal Data rights may be limited by EU and Member State laws. We will provide the information referred to in section 13 within one month of receiving your request, and 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 requested under section 13 free of charge, unless a request is manifestly unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act.
If we have reasonable doubts about your identity in relation to a request, the Company may request additional information.