We (also referred to as 'We', 'Us', or 'Our') are committed to safeguarding your Personal Data and privacy.
This Privacy Policy is designed to explain how we collect and store the information you provide through the Gaingate website (the 'Website').
These principles will be upheld:

To clearly explain how we collect and process your personal information:

Our goal is to empower you to make informed decisions about the collection and processing of personal data. To support this, we have developed our website using a range of methods and procedures to deliver relevant information on personal data use. If you require additional details, we will provide them at the appropriate time. We are happy to answer any questions and clarify any legal limitations. You can contact us via email at info@blue-orion.com

We will use Personal Data solely for the purposes outlined 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"), enhancing and maintaining the site, protecting our rights and interests, fulfilling regulatory or legal obligations, and performing administrative and business activities to support delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.

Utilize a comprehensive set of tools to effectively safeguard your personal data rights:

We created this website to help you make informed decisions about the use and processing of your Personal Data. To accomplish this, we implement a variety of best practices, techniques, and procedures to deliver clear, relevant information on how your Personal Data is collected, used, and protected. If we determine you need specific details, we will provide them at the appropriate time. We welcome your questions and are prepared to clarify any legal constraints. You can reach us by email at info@blue-orion.com

Safeguard 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 keep it protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy outlines the categories of Personal Data the Company collects from individuals and how it processes, shares, and secures that information. It covers data related to an identified or identifiable natural person—defined as someone directly identifiable or identifiable through additional information we hold or access. The Policy defines “processing” as any operation involving the use or collection of Personal Data, including its management, organization, and storage. Our services are designed for general audiences and are not intended for use by individuals under 18. We do not knowingly collect data from anyone under 18 or permit their use of our services, and if we become aware of personal data from minors, we will delete it promptly.

2. What Personal Data Do We Have About You?

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

3. You are not required to disclose personal information to the company, nor will there be any consequences.

You are under no obligation to provide us with personal data. However, in certain circumstances, if you choose not to share this information, we may be unable to deliver our services or you may be prevented from accessing the website.

4. What personal data can we collect? When you visit our website, we will collect the following personal information:

This information includes your online activity log and traffic details—such as IP address, access date and time—plus the language you used, software crash logs, browser type, and device information. This information is not private and cannot identify you. Personal Data We Receive from You: any personal data you voluntarily provide when connecting to a third-party online trading platform through our service. Personal Information You Share with Third-Party Platforms to Facilitate Trades: your full name, address, phone number, and email address.

5. The Legal Basis and the 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 relevant legal basis.
Absent a legal basis, the Company cannot use any Personal Data relating to you. The legal grounds on which the Company may process your Personal Data are:

• You have consented to the processing of your personal data for one or more purposes. This applies when you submit personal information through the Website so that 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 interests. For example, processing may be required to improve Our Services or defend legal claims.
• Processing must adhere to all legal obligations.

Contact us via email for more details about the processing required to protect our legitimate interests.
Below is a list of reasons and legal grounds on which we may use the information you provide us. Personal Data.

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, for purposes including IP address collection and user experience analysis.
You may request that we provide specific Personal Data to third-party trading platforms. In these cases, we will share the Personal Data you supply to us, and their use of your Personal Data will be governed by their privacy policies. Your Personal Data may be disclosed to multiple trading platforms.
The Company may share Personal Data with related entities or business partners to secure the resources needed to enhance and improve the products and services offered to customers.
If necessary to protect the rights of third parties or Company assets, we may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors, buyers, or lenders (including parties within our corporate group) in connection with transactions such as the transfer or sale of Company assets, or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any other group entity.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be utilized. These partners may also employ cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. They gather information about your preferences and browsing habits to enhance your user experience, remember your preferences, and tailor products and services to your interests. Cookies are also used for statistical and analytical purposes.
We 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 set period after your browser is closed. These cookies help the website recognize you as a returning user and provide a seamless experience.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To disable or delete 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 be aware 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 honor Do Not Track signals.
8. Retention of Your Personal Data

The Company will retain your Personal Data, which we collect, store, and process, for as long as necessary to fulfill the purposes described in this Policy, or for longer periods if required by applicable laws, regulations, policies, or orders. We will share your information with third-party trading platforms for a period of 12 months and, with your consent, will continue sharing your data for an additional 12 months.
We conduct regular reviews of the Personal Data we hold to confirm 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 (for example, to a third country beyond your residence) or to international organizations or jurisdictions. The Company takes all necessary measures to safeguard your Personal Data and ensure 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 determined provides adequate protection for Personal Data transferred 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 the viro Article 46(2)(a).
• The transfer was carried out in compliance with the standard contractual 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.

If you would like information on the security measures we employ to protect your Personal Data transferred to third-party countries or international organisations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented appropriate organizational and technical measures to protect Personal Data, including preventing accidental or unlawful destruction, loss, or alteration of such data.
However, we cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held liable for any indirect, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, any disclosures of Personal Data due to transmission errors, unauthorized third-party access, or other circumstances beyond our control.
In certain situations—such as legal requirements or obligations beyond our control—we may be required to disclose your Personal Data to third parties, including public authorities. We cannot ensure its security once transferred.
No method of transmission over the Internet is completely secure. The Company cannot guarantee the protection of any Personal Data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Links to third-party websites and applications are provided on the website. These external sites and apps operate independently of the Company, and we are not responsible for their collection or processing of Personal Data. Therefore, this Policy does not apply to any activities on these platforms.
When you visit a third-party website or application, we recommend reading its privacy policy before use. We also advise exercising discretion when sharing Personal Data with them.

12. Updates to this Policy

This Policy may be revised at any time. When we make changes, we will notify you by posting the updated Policy on our website. For significant modifications, we’ll use appropriate methods to inform you and publish an announcement on our website. Unless otherwise specified, all 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 your Personal Data, correct any errors, or delete any unnecessary Personal Data. You may also limit the types of processing of your personal information. If you reside in the EEA, please refer to this page:
These rights apply to the information you provide as Personal Data. To exercise your rights, email us at the address below. Access rights
The Company can verify the accuracy of the Personal Data we process about you. You may access your Personal Data, and we will supply you with an electronic copy upon request. We may charge a reasonable fee for additional copies. If you prefer, we will provide the data electronically.
The right to access Personal Data must not conflict with the rights and freedoms of others. If fulfilling your request would infringe on another person’s rights, the Company may refuse the request or limit its scope. Right to rectification
The Company will correct any inaccurate Personal Data. You may require us to complete any incomplete data, considering the purposes of processing. Right to erasure
You may request deletion of your Personal Data in the following cases: (a) the data are no longer necessary for the purposes for which they were collected or processed; (b) you withdraw consent and no other legal basis exists; (c) you object to processing based on legitimate interests, for reasons specific to your situation; (d) the data are unlawfully processed; or (e) deletion is required to comply with a legal obligation. This right does not apply if processing is necessary (i) to fulfill a legal obligation under EU or Member State law, or (ii) 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. Restricted data may only be retained with your consent, to establish, exercise, or defend legal rights, to protect another natural person, or for reasons of substantial public interest under EU or Member State law.
Right to data portability
If processing is automated and based on your consent or a contract, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format. You may also request direct transfer of your data to another controller, where technically feasible. Exercising this right does not affect your right to erasure and must not infringe on the rights or freedoms of others.
Right to object
You may object at any time to processing of your Personal Data based on legitimate interests pursued by the Company or a third party, including profiling. We may continue processing only if we demonstrate compelling legitimate grounds that override your interests, or for the establishment, exercise, or defense of legal claims.
Direct marketing
You have the right to object at any time to processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to any processing of your Personal Data at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.
Complaints
You have the right to lodge a complaint with the supervisory authority in your jurisdiction. You may also appeal to a supervisory authority established by an EU Member State to protect individuals’ rights in relation to Personal Data processing.
EU law limitations
EU and Member State laws may limit these rights in certain circumstances, as described in Section 13.
Response timeframe
We will respond to your request under Section 13 within one month of receipt. This period may be extended by up to two additional months, depending on the complexity and number of requests. We will notify you of any extension and the reasons within one month of receiving your request.
Fees
Unless prohibited by Section 13, we will provide the requested information free of charge. However, we may charge a reasonable fee for manifestly unfounded or excessive requests, especially if they are repetitive, to cover administrative costs, or we may refuse to act.
Identity verification
If we have any doubts about the identity of the requester, the Company may request additional information.