We (also 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 the following principles:

We aim to be transparent about how we collect and manage your personal information in your best interests:

Our goal is to help you make informed decisions about the use and processing of Personal Data. To achieve this, our website employs several methods and procedures to provide relevant information on Personal Data usage. If you need specific details about your data, we will make every effort to provide 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 only for the purposes described in this Policy

You will find that we process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and provisioning the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities necessary to deliver and enable use of the Services. In addition, we process your Personal Data to help us better understand your preferences and needs.

Gaining access to essential resources to protect your rights regarding Personal Data

Our goal is to help you make well‑informed choices about how we handle your data and how it affects you. That commitment is the reason we invested the time to develop this website. To support transparency, we apply a range of methods and procedures so you consistently receive the most relevant and up‑to‑date information about our use of your Personal Data. If you require specific details, we will provide them when appropriate or upon request. If you have any questions about how this process works, we are glad to answer and clarify, always within the applicable legal requirements. If you would like to learn more, please contact us by email at: info@blue-orion.com

Keep Your Personal Data Safe and Secure

While we cannot guarantee the absolute security of your Personal Data—as no one can—we remain fully committed to protecting it through a wide range of safeguards. Our Privacy and Security Policy covers the essential areas to help ensure your long-term safety.

Scope?

In this Policy, you will find an overview of the categories of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and protect it through appropriate safeguards. This Policy covers information about an identified or identifiable individual, meaning data that allows us to recognize a person directly or when combined with additional information in our possession or that we can access. For the purposes of this Policy, 'processing' means any operation performed on Personal Data, such as its collection, recording, use, management, organization, storage, retention, sharing with third parties, or other handling. Our services are designed for a general audience; however, they are not available to anyone under the age of 18, and we do not authorize individuals under this age to use them. Accordingly, we do not knowingly collect information from persons under 18, as they are not permitted to use our services. If we learn that we have collected any 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 or channels, or by browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you to provide personal data directly. Alternatively, we may analyze your interactions with our services or channels to gather this information, or obtain it through our third-party partners

3. You are not required to provide your personal data to our company or face any implications arising from it

You are not required to share any personal data with us. However, in certain instances, choosing not to provide this information may affect our ability to deliver services to you, which could result in limited access to our website or restricted use of specific features.

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

The Personal Data we collect includes information such as details from your activity log, traffic data (including IP address, access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This usage data is non-personal, and we do not use it to identify you. We also obtain Personal Data you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we may receive the personal details you submit directly to those platforms, including your full name, email address, phone number, and address.

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

Our Company processes your personal data for the purposes outlined in this section and complies with the applicable legal framework.
We require this legal basis because, without it, our Company cannot use 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 via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process this information to pursue their legitimate interests. Examples include improving our Services or defending against potential legal claims that may arise.
• All processing activities on our website must comply with applicable legal requirements, and we hereby 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 have outlined the reasons and legal bases explaining how we may use the Personal Data 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 providing services such as data storage, IP address hosting, or user experience analytics.
We also accommodate 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 select. Once transferred, its use will be governed by their privacy policies. 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 to access resources that help us 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 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 relating to the Company or other parties associated with the Company.

Online Tracking Notice

On our website, we may work with third-party services, such as advertising providers and analytics firms. These companies may also set cookies and use similar technologies to collect data about your interactions with our site.
When we refer to cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies to gather information about your preferences and browsing patterns so we can improve the user experience, better understand our audience, and design products and services aligned with customer interests. Cookies also help us compile statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire once you close your browser. Other cookies are persistent and remain on your device after you close your browser. They allow the website to recognize you as a returning visitor and keep the preferences you previously set.

7. How We Use Cookies and Third-Party Services

Each cookie and its use may vary, depending on its intended purpose.

Cookies are blocked or have been deleted
You can adjust your cookie preferences in your browser settings. For guidance, you can use the links below.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that certain website functions and features may not operate 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 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, and we may keep it for a longer period as permitted by law and for applicable 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 an additional 12 months, if needed.
From time to time, we will review and assess the Personal Data we hold to confirm whether it remains necessary.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send this personal data to a country other than your own, or to international organisations. We take all necessary measures to protect and defend your Personal Data and ensure that you can exercise your rights while effectively accessing legal remedies if needed.
All residents of the EEA (European Economic Area) can take advantage of 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 a transfer occurs, we carry it out under a legally binding, enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
• We transfer data in compliance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. 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

If you would like more information about these details and how they relate to the security measures we apply to protect your Personal Data when it is 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 robust security measures designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take every reasonable precaution, we cannot guarantee that your Personal Data will be maintained without error, 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, unauthorised access by third parties, or other events beyond our control.
Where required by law, 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 oversee or ensure the security measures those third parties apply.
Please note that transmitting Personal Data over the internet is not entirely secure and carries inherent risks. Accordingly, we cannot guarantee the security of Personal Data you send to us online.

11. Regarding Links to Third-Party Websites

Our website may include links to external sites and applications that are beyond our company’s control. Accordingly, we cannot accept responsibility for how these third-party websites collect or process your Personal Data. Our Policy applies only to our website and does not extend to third-party sites.
Before accessing any third-party website or app, please review its privacy policy before using its services. You should also carefully consider whether you wish to share your Personal Data with them.

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 present the updated Policy. For significant updates, we will use the communication methods we deem most appropriate and will also post an announcement on our website. Unless stated otherwise, all amendments take effect immediately upon publication of the revised Policy.

Your Rights Regarding Your Personal Data

You have the right to request access to the personal data we collect about you, to have it corrected, and to request deletion of Personal Data in certain circumstances. You may also ask us to restrict certain types of processing. For residents of the EEA, please see this page:
Anyone wishing to exercise their data rights can contact us at the email address below. Access rights
We may review the accuracy of the Personal Data processed. If it is accurate, we will provide you with access to your Personal Data and, upon request, an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies. Where requested, we will provide this information electronically.
Your right of access must not infringe the rights of others. If a request would affect the rights of others, we may refuse to comply or limit our response. Your rights related to rectification
If you wish to correct inaccurate Personal Data, you may request that we rectify and complete any incomplete information. Your Right to Erasure
Legitimate grounds may include: (a) we no longer need the personal data for the purposes for which it was collected; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object to processing and there are no overriding legitimate grounds; (d) the processing is unlawful; 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 laws or (b) to establish, exercise, or defend legal claims.
Processing restrictions
You may ask us to restrict processing, for example if you contest the accuracy of the data. While restricted, the data will be stored but 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 an EU 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 provided to the Company.
You also have the right to request that the data be transferred to another controller, where technically feasible. Exercising your right to 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 legitimate interests of the Company or third parties, 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 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 before withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data rights.
You may additionally request protection of your individual rights from a supervisory authority in a Member State regarding Personal Data processing within the EU.
As described 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 to two months depending on the complexity and number of requests. You will be notified within one month of any extension and the reasons.
We will provide information requested under Section 13 free of charge unless a request is 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 connection with a request, the Company may request additional information.