We (also referred to as 'We', 'Us' or 'Our') are committed to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the 'Website').
We uphold the following principles:

To be transparent about how we collect and process your personal information:

We want you to be able to make informed decisions about the use and processing of Personal Data. That is why we created this website. To that end, we use a range of methods and procedures to provide clear, relevant information on the processing of Personal Data. If we determine you require specific details, we will provide them at the appropriate time. We are happy to answer any questions and to clarify any limitations imposed by law. You can reach us by email at the address below: info@blue-orion.com

Personal Data will be used solely for the purposes described in the Policy.

Personal Data may be processed by us for various purposes, including providing the website to you and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, facilitating maintenance and delivery of the Services, complying with regulatory and legal obligations, and carrying out administrative and business activities to support the delivery and use of the Services. Personal Data are also processed to better understand your preferences and needs.

To access essential tools to safeguard your rights regarding Personal Data:

We want you to be able to make informed decisions about the use and processing of Personal Data. For that reason, we created this website. We use various methods and procedures to provide relevant information on how Personal Data is handled. If we determine you require specific details, we will provide them at the appropriate time. We welcome any questions and will clarify matters within the limits of the law. You can reach us by email at: info@blue-orion.com

Protect Your Personal Data:

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

1. The Scope?

This Policy describes the types of Personal Data the Company collects about natural persons and how that data is processed, shared with third parties, secured, and otherwise handled. This Policy covers information relating to an identified or identifiable natural person; an identifiable person is someone who can be identified directly or when combined with other information we hold or can access. The Policy defines "processing" as any operation involving Personal Data, including collection, management, organization, and storage. Our services are intended for a general audience and are not designed for use by anyone under 18 years of age; we do not knowingly seek, collect, or permit use by individuals under 18, and we will promptly delete any personal information we discover about a child if we become aware of it.

2. What personal data do we hold about you?

When you access our services or channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain situations. In other cases, we collect Personal Data by analysing how you use our services or channels, or by receiving information from our third-party partners.

3. You are not required to disclose personal information to the company, and there are no penalties for choosing not to.

You are not obliged to provide us with any personal data. However, in certain circumstances, refusing to supply required personal data may prevent us from providing the services or restrict users' access to the website.

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

This includes your online activity log and traffic data — for example, IP address, access date and time, language, browser type, software crash logs, and information about the device you used. These data are not private information and cannot be used to identify you. Personal Data We receive from you: any personal data you provide to Us voluntarily when you connect to a third‑party online trading platform through Us. Personal information you provide specifically to third‑party platforms to facilitate trade: 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 legal basis, the Company cannot process Personal Data concerning you. The legal grounds on which the Company relies to process Personal Data concerning you are:

• You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information via the Website so we can transfer it to a third-party trading platform.
• The Company or a third party may require processing to pursue legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
• Processing must comply with legal obligations.

Contact us by email for further details on the processing carried out to safeguard 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 disclose Personal Data to third-party service providers, such as hosting and storage providers, to supply IP address information and analysis of user experience.
You may request that we transfer specific Personal Data about you to third-party trading platforms. In such cases, we will provide the Personal Data you supplied to us to those trading platforms. Their use of your Personal Data is governed by their privacy policies, and your information may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to obtain the resources needed to enhance and improve the products and services it offers to customers.
Where necessary to safeguard the rights of third parties or protect assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data with potential investors, buyers, or lenders to the Company or other group companies in connection with contemplated or completed transactions (including transfers or sales of assets), or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any group company.

ONLINE TRACKING NOTICE

Third-party services, such as advertising networks or analytics providers, may be used on our website and may also employ cookies or other tracking technologies.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to enhance your experience, remember settings, and help tailor products and services you may find useful. Cookies are also used for statistical and analytical purposes.
Certain cookies we use are session cookies, which are downloaded temporarily to your device and expire when you close your browser. Other cookies are persistent and remain on your device after you close your browser to help the website recognize you as a returning user and make it easier to return to the website.

7. Third-party cookies and services

We may use them for their intended purpose:

Cookies are blocked or removed.
To prevent or remove cookies, adjust your browser's settings. Below are links to guides for several popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that some or all of the Website's functions and features may not work as you expect if this occurs.

ONLINE TRACKING NOTICE This service does not currently support Do Not Track (DNT) signals.
8. Retention of personal data about You

The Company will retain Personal Data about you for as long as necessary to fulfill the purposes of processing set out in this Policy, or for longer where required or permitted by law, regulation, policy, or applicable orders. We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue to share your data for an additional 12 months.
We regularly review retained Personal Data to ensure 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, for example to a third country (i.e., a country other than the one in which you reside) or to international organizations or jurisdictions. Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data users can assert their rights and access effective legal remedies.
These protections and safeguards are accessible to all those who reside in the EEA (European Economic Area).

• Transfer to a third country or to an international organisation that the European Commission has determined provides an adequate level of protection for Personal Data transferred to it 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')
• The transfer is made pursuant to a legally binding, enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
• The transfer was carried out in compliance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. These clauses can be viewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

The Company can provide details of the security measures it implements to safeguard your Personal Data when transferred to third countries or international organisations. To request this information, send an email to info@wealthwaydigital.uk.

10. Protection of Personal Data

We take appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration of Personal Data.
However, we cannot guarantee that the security of your Personal Data will be error-free, and we are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorized third‑party access, or other causes beyond our control.
If required by law or other circumstances beyond our control, we may be obliged to provide Personal Data about you to third parties, such as public authorities, and we cannot control the security measures those parties apply.
No transmission of Personal Data over the internet can be completely secure. The Company cannot guarantee the security of Personal Data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Links to third-party sites and applications are provided on the website. These applications and websites are not operated or controlled by the Company, and we are not responsible for their collection or processing of Personal Data. This Policy does not apply to actions taken on such sites or apps.
When you visit any third-party website or app, we recommend that you read their privacy policies before accessing or using them and carefully consider providing any Personal Data.

12. Updates to This Policy

This Policy may be amended at any time. When we make changes, we will notify you by posting the updated Policy on our website. For significant modifications, we will also endeavor to inform you through the methods we consider appropriate and will publish an announcement on our website. Unless explicitly stated otherwise, amendments take effect upon publication of the revised Policy.

13. Your rights regarding your personal information

You have the right to ask us to verify the accuracy of any Personal Data we hold about you, to correct any inaccuracies, and to delete Personal Data that we no longer need. You may also request restrictions on certain types of processing. If you are an EEA resident, please refer to this page:
These rights apply to the Personal Data you provide to us. To exercise any of these rights, send an email to the address below.Access rights
The Company can verify whether Personal Data about you are being processed. If they are, you may access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for additional copies. Data will be provided electronically if you request it.
The right of access must not conflict with the rights and freedoms of others. If your request would adversely affect another person’s rights and freedoms, the Company may refuse the request or limit its scope.Right to rectification
The Company will correct inaccurate Personal Data. You may request that incomplete Personal Data about you be completed, taking into account the purpose of processing.Right to erasure
You may request erasure of Personal Data where: (a) the data are no longer necessary for the purposes for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on our or a third party’s legitimate interests and there are no overriding legitimate grounds for the processing; (d) the data are unlawfully processed; or (e) erasure is required to comply with a legal obligation of the Company. This right does not apply where processing is necessary (a) to comply with a legal obligation under EU or Member State law; or (b) to establish, exercise, or defend legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may request that the Company restrict processing. While restricted, Personal Data may only be retained with your consent, to establish, exercise or defend legal claims, to protect the rights of another natural person, or where processing is necessary for reasons of significant public interest in the EU or a Member State.
Right to data portability
When processing is based on consent or on a contract and is carried out by automated means, you have the right to receive the Personal Data you have provided in a structured, commonly used, and machine-readable format. You may request that your Personal Data be transferred directly from the Company to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure, and this right must not adversely affect the rights and freedoms of others.
Right to challenge
You have the right to object at any time to processing of Personal Data about you that is based on legitimate interests pursued by the Company or a third party, including profiling based solely on those interests. If we can demonstrate compelling legitimate grounds for the processing that override your rights, or if processing is necessary for the establishment, exercise or defense of legal claims, we may continue processing.
Concerning direct marketing, you have the right to object at any time to processing of Personal Data for such purposes.
Right to withdraw consent
You may withdraw your consent to our processing of Personal Data at any time. Withdrawal will not affect the lawfulness of any processing carried out on the basis of consent before it was withdrawn.
You are entitled to lodge a complaint with the supervisory authority that oversees you.
You may appeal to the supervisory authority designated by a Member State to protect individuals’ fundamental rights in relation to Personal Data processing within the EU.
EU and Member State law may limit the rights described in this Section 13, as noted in this section. We will respond to requests made under Section 13 within one month of receipt. Where necessary because of the nature or number of requests, this period may be extended by up to two months; we will notify you of any extension and the reasons within one month of receiving your request.
Unless restricted by the provisions of Section 13, information you request under these rights will be provided free of charge. For manifestly unfounded or excessive requests, particularly if repeated, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have doubts about the identity of the person making a request, the Company may request additional information.