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').
The following principles guide our practices:

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

We want you to make informed decisions about how your Personal Data is used and processed. That’s why we created this website. Using various methods and procedures, we provide you with relevant information on Personal Data usage. If you need specific details, we will supply them at the appropriate time. We welcome your questions and are ready to clarify any legal limitations. You can contact us by email at info@blue-orion.com

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

Personal Data may be processed by Us for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (‘Services’), enhancing and maintaining the site, safeguarding our rights and interests, facilitating the maintenance and provision of the Services, fulfilling regulatory or legal obligations, and conducting administrative and business activities to support the delivery and use of the Services. Personal Data are also processed by us to better understand your preferences and needs.

Leverage powerful tools to safeguard your rights regarding Personal Data:

We want you to make informed decisions about how your Personal Data is collected, used, and processed. That’s why we created this website. We employ a variety of methods and procedures to present you with clear, relevant information about Personal Data use. When you need additional details, we will provide them promptly and at the appropriate time. We are pleased to answer any questions and clarify any legal requirements. You can contact us by email at info@blue-orion.com

Safeguard Your Personal Data:

While we cannot guarantee complete security of your Personal Data, we will continue to employ a variety of methods and techniques to ensure that your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy describes the types of Personal Data the Company collects from natural individuals and explains how it processes, shares, and secures that data. It covers information related to an identified or identifiable natural person, defined as someone who can be recognized directly or through a combination of additional information we hold or access. The policy defines “processing” as any operation involving the use or collection of Personal Data, including its management, structuring, and storage. Our services are intended for general audiences and are not designed for use by anyone under 18. We do not knowingly seek or collect data from anyone younger than 18, nor allow such individuals to use our services. If we become aware of any personal data concerning children, we will remove it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or visit our website, we collect your Personal Data. In some cases, we will request this information directly. In others, we gather Personal Data by analyzing your use of our services and channels or by obtaining it from our third-party partners.

Providing personal information to the Company is not required and carries no consequences.

You are not required to provide us with any personal data. However, in certain circumstances, withholding personal data may restrict our ability to provide services or prevent users from accessing the website.

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

This includes information about your online activity log, such as traffic data (including IP address, date and time of access), language settings, software crash logs, browser type, and other details regarding the device you use (for example, model and operating system). The information we collect is not private and cannot be used to identify you. Personal Data We receive from you: any personal information you voluntarily provide to Us when you choose to connect with a third-party online trading platform through Us. Personal information you provide specifically to third-party platforms to facilitate trade: this information includes your full name, address, phone number, and email address.

5. The Legal Basis and Justification for the Processing of Personal Data

We process your Personal Data for the purposes detailed in this section, in accordance with the applicable legal grounds.
Without a legal basis, the Company cannot process your Personal Data. 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 via 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 legitimate interests, such as improving Our Services or defending legal claims.
• Processing must comply with legal obligations.

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

6. Transfer of Personal Data to Third Parties

The Company may share Personal Data—including IP address information and user experience analyses—with third-party service providers, such as hosting and storage providers.
You may request that we disclose specific Personal Data about you to third-party trading platforms. In such cases, we will transmit the Personal Data you provide to us to those platforms. Their use of your Personal Data will be governed by their privacy policies, and your information may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliates or business partners to access the resources necessary to enhance and improve the products and services the Company provides to its customers.
If required to protect the rights of third parties or property, The Company may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors, buyers, or lenders to The Company (or to any other group company) in connection with such transactions (including any transfer or sale of assets of The Company or any group company) or as part of any merger, restructuring, consolidation, or bankruptcy of The Company or any group entity.

ONLINE TRACKING NOTICE

Third-party services, such as advertisers and analytics providers, may be used on our website. These partners may employ cookies or other technologies.
Cookies are small text files placed on your device when you visit or access the website. They collect information about your preferences and browsing habits to enhance your experience, remember settings, and tailor products and services to your interests. Cookies also support statistical analysis and reporting.
We use session cookies, which are temporary and expire when you close your browser. We also use persistent cookies, which remain on your device after you close your browser to recognize you as a returning user and facilitate future visits.

7. Third-Party Cookies and Services

We may use them in accordance with their intended purpose:

Cookies are blocked or removed
To prevent or delete 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 in this case.

ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention of Your Personal Data

The Company will retain Personal Data about you as long as necessary to fulfill the processing purposes described in this Policy, or for any longer periods required by law, the applicable regulations, policies, or orders. We will share your information with third-party trading platforms for 12 months; if you consent, we will extend this sharing for 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 or international organizations (i.e., jurisdictions outside your country of residence). The Company takes all necessary steps to safeguard the Personal Data you provide, ensuring you can assert 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 recognised as providing adequate protection for Personal Data under Article 45(3) of Regulation 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 in virtue of Article 46(2)(a).
• The transfer was completed in accordance with the European Commission’s standard data protection clauses under Article 46(2)(c) of the GDPR. These clauses are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

We can provide information about the security measures we employ to safeguard your Personal Data when transferred 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 safeguards to protect Personal Data, preventing its accidental or unlawful destruction, loss, or alteration.
While we cannot guarantee that the security of your Personal Data will be maintained without error, we also cannot be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes—but is not limited to—Personal Data being exposed through transmission errors, unauthorized third-party access, or any other causes beyond our control.
When legal or other obligations beyond our control require it, we may need to share your Personal Data with third parties, such as public authorities. We cannot govern the security measures applied to your Personal Data by those third parties.
Since no method of online transmission is entirely secure, the Company cannot guarantee the protection of Personal Data you transmit to us via the internet.

11. Hyperlinks to websites that are owned by third parties

Links to third-party websites and applications are provided for your convenience. These sites and apps operate independently and are not overseen by the Company. We are not responsible for how they collect, use, or process Personal Data. This Policy does not cover actions taken on those sites or through their apps.
When you visit any third-party website or app, we recommend reviewing its privacy policy before accessing or using its services. We also advise carefully considering any Personal Data you decide to share with them.

12. Updates to this Policy

This Policy is subject to change at any time. If we update this Policy, we will inform you by posting the revised version on our website. Additionally, when we make significant changes to this Policy, we will use the methods we deem appropriate—such as email notifications—and publish an announcement on our website. Unless explicitly stated otherwise, any amendments will take effect once the revised Policy is published on our website.

Your Rights Regarding Your Personal Information

You have the right to ask us to verify that the Personal Data we collect about you is accurate, to correct any errors, and to delete any Personal Data that we no longer need. You may also request restrictions on certain types of data processing. If you reside in the EEA, please refer to this page:
These rights apply to the Personal Data you provide. To exercise any of these rights, please send an email to the address below.
Access rights
The Company can verify whether your Personal Data is being processed and, if so, grant you access to it. We will provide an electronic copy of the Personal Data currently in processing and may charge a reasonable fee for any additional copies. Upon request, the data will be delivered electronically.
Your right to access Personal Data must not infringe the rights and freedoms of others. If fulfilling your request would adversely affect another person’s rights, the Company may refuse or limit the request.
Right to rectification
The Company will correct any inaccurate Personal Data. You may also request that incomplete Personal Data about you be updated, considering the purpose of processing.
Right to erasure
You may request deletion of your Personal Data under the following circumstances: (a) the data are no longer necessary for the purposes for which they were collected or processed; (b) you withdraw consent and we have no other legal basis for processing; (c) you object to processing based on our or a third party’s legitimate interests, due to your particular situation; (d) the data have been unlawfully processed; or (e) the data must be erased to comply with a legal obligation of the Company.
This right does not apply if processing is necessary: (a) to comply with an obligation under EU or Member State law; or (b) for establishing, exercising, or defending legal claims.
Processing restrictions
If you question the accuracy of your Personal Data, you may request that the Company restrict its processing. While data is restricted, we may only retain it with your consent, to establish, exercise, or defend legal claims, to protect another natural person’s rights, or for reasons of substantial public interest in the EU or a Member State.
Right to data portability
If processing is carried out by automated means based on your consent or a contract to which you are party, you have the right to access the Personal Data you have provided.
You may also request that we transfer this data directly to another data controller, if technically feasible. Exercising your right to data portability does not affect your right to erasure and must not infringe the rights or freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on legitimate interests pursued by the Company or a third party, including profiling. If we demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims, we may continue processing your data.
Concerning direct marketing, you have the right to object to the processing of your Personal Data at any time.
Right to withdraw consent
You may withdraw your consent for the Company to process your Personal Data at any time. This will not affect the lawfulness of any processing carried out before your withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may file an appeal with any EU Member State supervisory authority responsible for protecting individuals’ fundamental rights in data processing.
EU and Member State laws may limit certain rights regarding your Personal Data, as described in Section 13. We will respond to your request under Section 13 within one month of receipt. This period may be extended by up to two months, depending on the request’s complexity and number. We will inform you of any extension and its reasons within the initial month.
Unless Section 13 dictates otherwise, the information you request will be provided free of charge. If your request is unfounded or excessive, particularly if repetitive, 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 the request, the Company may ask for additional information.