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

To ensure transparency in the collection and processing of your personal information:

We believe in transparency and want you to make informed decisions about how your Personal Data is collected, used, and processed. This website exists to provide clear, relevant information on our policies, methods, and procedures for collecting, processing, and safeguarding your Personal Data. If you require more detailed explanations, we will supply them at the appropriate time and in the most suitable and accessible format. We are happy to answer any questions you may have and clarify any legal requirements or limitations. Reach out to our dedicated support team by email at info@blue-orion.com

We will use Personal Data solely for the purposes specified in the Policy.

Personal Data may be processed by us for a variety of purposes, such as providing the website to you and connecting you with third-party trading platforms (the 'Services'), enhancing and maintaining the site, facilitating maintenance and improvements, protecting our rights and interests, facilitating the provision and use of the Services, meeting regulatory or legal obligations, and conducting administrative and business operations to support and deliver the Services. Personal Data is also processed to better understand your preferences, needs, and usage patterns.

Access essential tools to safeguard your Personal Data rights:

Our goal is to enable you to make informed choices regarding the collection, use, and processing of Personal Data. That is why we have developed this website—to offer an array of resources, methods, and procedures that present clear, relevant information on Personal Data handling practices. If you need further details or specific explanations, we will provide the required information at the appropriate time. We are also ready to address any questions you may have and clarify any legal limitations that apply. You can reach us via email at info@blue-orion.com

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we will continue utilizing a range of proven measures and techniques to keep it protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the types of Personal Data the Company collects from natural persons and explains how it processes, shares, and secures that data. It applies to information related to identified or identifiable individuals. An identifiable person is someone who can be recognized directly or through additional information we hold or can access. The Policy defines “processing” as any operation involving Personal Data, including its collection, management, organization, and storage. Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or collect information from individuals under 18, nor do we permit their use of our services. If we learn we have collected data about a child under 18, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

If you access our services and channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain instances. We also gather Personal Data by analysing how you use our services or channels, or by receiving it from our third-party partners.

3. You are under no obligation to disclose personal information to the company, nor will you face any consequences.

You are not required to provide us with any personal data. However, in some cases, withholding it may prevent us from providing our 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 details of your online activity log, traffic data (including IP address, date and time of access), the language you used, software crash logs, browser type, and device information. These details are not private and cannot be used to identify you. Personal Data We Receive From You: any personal data you provide to Us voluntarily when connecting to a third-party online trading platform through Us. Personal information you share specifically with third-party platforms to facilitate trade: your full name, address, phone number, and email address.

5. The Legal Basis and Reasons for Processing Personal Data

Your Personal Data is processed by the Company for the purposes outlined in this section and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot process your Personal Data. The legal grounds that permit the Company to process your Personal Data are:

• You have consented to the processing of your personal data for one or more purposes. This happens 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 need to process data to pursue their legitimate interest. For example, this processing may be required to enhance Our Services or to defend legal claims.
• Processing must comply with legal obligations.

Contact us by email for more information about the processing required to protect our legitimate interests.
Below is a list of the reasons and legal bases on which we may use the personal data you provide.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, to obtain IP address information and user experience analytics.
You can also request that we share your specific Personal Data with third-party trading platforms. In these cases, we will provide the information you supply to us directly to those platforms. Their use of your Personal Data is subject to their own privacy policies and may involve multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to access resources that help enhance and improve the products and services we offer to our customers.
If required to protect the rights of third parties or assets, The Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any group company in connection with a transaction (including the transfer or sale of assets) or as part of a merger, restructuring, consolidation, or bankruptcy of the Company or any group entity.

ONLINE TRACKING NOTICE

Third-party services, such as companies providing advertisements, analytics, or other website functionalities, may be engaged. These external partners might also deploy 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 user experience, remember your settings, and tailor products and services to your interests. Cookies also support statistical and analytical purposes, helping us understand how visitors use the site and where improvements can be made.
We may use session cookies, which are temporarily downloaded to your device and expire when you close your browser. We also use persistent cookies, which remain on your device for a specified period even after you close your browser. These cookies help recognize you as a returning user, maintain your session, and streamline future visits to the website.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are disabled or deleted
To manage cookies, adjust your browser settings. Below are links to guides for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention of your personal data

The Company retains Personal Data about you for as long as necessary to fulfill the processing purposes outlined in this Policy, or for any additional period required by law, regulation, policy, or applicable order. We share your information with third-party trading platforms for 12 months, and with your consent, we will extend this period by another 12 months.
We regularly review retained Personal Data to ensure it is no longer needed.

9. Transfers of Personal Information to Third-Party Countries or International Organisations

Your personal information may be transferred to other countries—i.e., to a third country (other than the one in which you reside) or to international organizations or jurisdictions. The Company takes all necessary steps to protect the personal data you provide, ensuring that you can exercise your rights and pursue effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has deemed to provide adequate 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 and enforceable agreement between public entities or authorities under Article 46(2)(a).
• The transfer was carried out in accordance with the EU Commission’s standard data protection clauses under Article 46(2)(c) of the GDPR. You can view these clauses 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 on the security measures we use to protect your Personal Data when transferring it to third-party countries or international organisations. Please email us at info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organizational and technical measures to safeguard Personal Data, including protections against accidental or unlawful destruction, loss, or modification.
However, we cannot guarantee error-free security or accept liability for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This covers, but is not limited to, incidents such as transmission errors, unauthorized third-party access, or other causes beyond our control.
If required by law or other binding obligations, we may be compelled to disclose your Personal Data to third parties, including public authorities, and cannot control the security measures they employ.
Because no online data transmission is completely secure, the Company cannot ensure the safety of Personal Data you send to us over the Internet.

11. Links to third-party websites

Links to third-party websites and apps are provided for your convenience. These platforms operate independently and are not managed by the Company. We are not responsible for how they collect or process Personal Data. This Policy does not apply to activities on these external sites or apps.
Before using any third-party website or app, we recommend reviewing its privacy policy. You should also determine whether to share any Personal Data with them.

12. Changes to this Policy

This Policy is subject to change at any time. If we revise it, we will notify you by posting the updated Policy on our website. When we implement significant modifications, we will use the methods we deem appropriate to inform you and publish an announcement on our website. Unless explicitly specified, any amendments take effect upon publication of the revised Policy.

Your Rights Regarding Your Personal Information

You have the right to request verification of the accuracy of any Personal Data we hold about you, to correct errors, and to delete any Personal Data no longer required by us. You may also limit certain types of processing of your Personal Data. If you are an EEA resident, please refer to this page:
These rights apply to all Personal Data you have provided. To exercise any of these rights, email us at the address below.
Access Rights
We can confirm whether we are processing your Personal Data. If we are, you may request access to that data. We will provide an electronic copy of the Personal Data currently under processing and may charge a reasonable fee for additional copies. Upon request, the data will be delivered electronically. Your right of access will not infringe upon the rights and freedoms of others; if fulfilling your request would adversely affect another person’s rights, we may refuse or limit our response.
Right to Rectification
We are obligated to correct any inaccurate Personal Data we hold about you. You may also request completion of any incomplete Personal Data, taking into account the purposes of processing.
Right to Erasure
You may request deletion of your Personal Data where one of the following applies: (a) it is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on our legitimate interests or those of a third party, due to reasons specific to your situation; (d) the data has been unlawfully processed; or (e) erasure is required to comply with a legal obligation. This right does not apply when processing is necessary (a) to comply with a legal requirement 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 we restrict its processing. While processing is restricted, we will only retain your Personal Data with your consent, to establish, exercise, or defend legal claims, to protect another individual’s rights, or for reasons of important public interest of the EU or a Member State.
Right to Data Portability
When processing is carried out by automated means based on your consent or a contract to which you are party, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format. You may also request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising this right will not affect your right to erasure, and it shall not adversely affect the rights or freedoms of others.
Right to Object
You have the right at any time to object to processing of your Personal Data based on our legitimate interests or those of a third party, including profiling. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless processing is necessary for the establishment, exercise, or defense of legal claims. You also have the right to object to processing for direct marketing purposes at any time.
Right to Withdraw Consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal will not affect the lawfulness of processing carried out prior to your withdrawal.
Complaints
You have the right to lodge a complaint with the supervisory authority in your jurisdiction. You may also appeal to any EU Member State supervisory authority responsible for safeguarding individuals’ rights in relation to Personal Data processing.
Limitations and Timeframes
EU and Member State laws may limit your rights as described in this Section 13. We will respond to your request under Section 13 within one month of receipt. If necessary due to the complexity or volume of requests, we may extend this period by up to two months. We will notify you within one month of any extension and explain the reasons.
Fees
Unless otherwise provided by Section 13, we will provide the requested information free of charge. If requests are manifestly unfounded or excessive—particularly because of their repetitive nature—we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
Identity Verification
If we have doubts regarding the identity of the individual making a request, we may ask for additional information to confirm your identity.