We (also referred to as 'We', 'Us', or 'Our') are fully committed to protecting your Personal Data and safeguarding your privacy.
This Privacy Policy is intended to inform you, the consumer, about how we collect and store the information you provide on the Gaingate website (the 'Website').
We uphold and adhere to the following principles:

We are committed to being transparent about how we collect and use your personal data in your best interests:

By doing so, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website uses several methods and procedures to provide relevant information about Personal Data usage. If you need specific details about your data, we will work diligently to ensure you receive them promptly and at the appropriate time. If you have any questions, we are happy to clarify anything related to legal constraints. To contact us, please email us at info@blue-orion.com

We will process Personal Data solely for the purposes described in this Policy

You will find that we process Personal Data for a variety 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 requirements, and carrying out administrative and business activities necessary for the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

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

Our goal is to help you make well-informed choices about how we handle your data. With that in mind, this explains why we invested the time to develop this website. To support this, we use a variety of methods and procedures to ensure you continue receiving the most relevant information about our use of your Personal Data. If you require specific information, we will provide it to you when needed. If you have any questions about how this process works, we are more than willing to answer and offer clear explanations, all within the bounds of legal requirements. If you would like to learn more, please contact us via email at info@blue-orion.com

Keep Your Personal Information Safe and Secure

While we cannot guarantee the absolute security of your Personal Data—no one can—we are fully committed to employing a wide range of measures to protect it. Our Privacy and Security Policy addresses all key areas to help ensure your long-term safety.

Scope?

This Policy outlines the types of Personal Data our Company collects from customers, along with the methods we use to process, share with third parties, and safeguard that data. It applies to information about an identified or identifiable individual—data that can identify a person directly or when combined with other information in our possession or to which we have access. For purposes of this Policy, “processing” means any operation performed on Personal Data, including the collection, management, organization, and storage of such data. Our services are intended for a general audience but are not available to individuals under 18, and we do not authorize anyone under this age to use them. Accordingly, we do not knowingly collect information from individuals under 18, as they are not permitted to use our services. If we become aware of any collection involving persons under 18, we will promptly delete the information.

2. What Personal Information Is Collected from You?

If you use our services or channels, or browse our website, you consent to our collection of your personal data. In some cases, we may ask you to provide personal data directly. Alternatively, we may gather it by analyzing your interactions with our services or channels, or through our third-party partners

3. You Are Not Required to Provide Your Personal Information to Our Company or Address Any Implications of Doing So

You are not required to share any personal data with us. However, in some cases, choosing not to provide this information may affect how we deliver our services and could result in limited website access or limited use of certain features.

4. What are examples of personal data 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 and access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This technical data is non-personal, and we do not use it to identify you. We also obtain Personal Data that you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we collect the personal details you submit directly to these platforms, which may include your full name, email address, phone number, and address.

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

Our Company processes your personal data for the purposes set out in this section, in accordance with applicable law.
We require a lawful basis; without one, our Company cannot process your personal data. The lawful bases on which we rely 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 through the Website for us to share with a third-party trading platform
• The Company or a third party may need to process information to pursue their legitimate interests. This may include enhancing our Services or protecting against potential legal claims.
• All processing activities on our website must comply with legal requirements, and we 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 under which 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 that provide services such as storage, IP address hosting, or user experience analytics.
We also accept 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 choose. If you proceed, their privacy policies will govern its use. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners or affiliated entities. We do this to access the resources needed to enhance and continuously improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or other official authorities to protect the rights or property of others.
We may additionally share your Personal Data with prospective investors or buyers, or with lenders to the Company or its affiliated companies. This typically occurs in the context of 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

You may encounter third-party services on our website, such as advertising networks or analytics providers. These companies may also use cookies and similar technologies that collect data.
When we say cookies, we mean small text files stored on your device each time you visit or access our site. We use cookies to learn about your preferences and browsing patterns so we can improve the user experience, better understand our audience, and design products and services that reflect customer interests. Cookies also help us compile statistics and conduct analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device after you close your browser. These cookies allow the website to recognize you as a returning visitor and retain the preferences you previously set.

7. How We May Use Cookies and Third-Party Services

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

Cookies have been blocked or cleared
Manage your cookie settings in your browser preferences. You can use the links below to help with this.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that certain website features and functions may not work as expected if this occurs.

Online Tracking Notice Please note that our service does not currently recognise Do Not Track requests.
8. Learn More About How Your Personal Information Is Stored

Please note that Our Company will retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, and may retain it longer as permitted by applicable laws and to comply with applicable orders where relevant. 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 determine whether we still require it.

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 information to a country other than your own, or to international organizations. We take all necessary measures to protect your Personal Data and ensure you can exercise your rights and effectively access legal remedies if needed.
All residents of the EEA (European Economic Area) benefit from these protections and safeguards.

• In certain cases, we may transfer your Personal Data to a third country or international organisation that the European Commission has recognised as providing an adequate level of protection for Personal Data, 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')
• When the transfer occurs, we carry it out under a legally binding and enforceable agreement between public authorities or bodies in accordance with Article 46(2)(a)
• We conduct such transfers in accordance with the European Commission’s Standard Contractual Clauses for data protection, issued under Article 46(2)(c) of the GDPR. For more information, you can view 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 implement to protect your Personal Data when it is transferred to third-party countries or international organizations, please contact us by email at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented robust security measures. These measures help prevent accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee that your Personal Data will always be maintained without errors, and we cannot be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by transmission errors, unauthorized access by third parties, or other events beyond our control.
Where we are legally obligated, 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 situations, we cannot control the security measures those third parties provide.
Please note that transmitting Personal Data over the internet cannot be made entirely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of the Personal Data you send to us online.

11. Regarding Links to Third-Party Websites

Our website includes links to external sites and applications that are outside our company’s control. As such, we accept no responsibility for how these third‑party websites collect or process your Personal Data. While our Policy covers what occurs on our website, it does not extend to third‑party websites.
Before visiting any third‑party website or app, review its privacy policy before you use its services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will notify you via our website and provide the updated Policy. For significant updates, we will use the methods we deem most appropriate to inform you, including posting an announcement on our website. Unless stated otherwise, all amendments to this Policy take effect immediately upon publication of the updated Policy.

Your Rights in Relation to Your Personal Data

You have the right to request access to the personal data we collect about you, to rectify it, and to ask that we delete your Personal Data where applicable. You may also request that we restrict certain types of data we process. For residents of the EEA, please see this page:
To exercise any of your data rights, please contact us at the email address below. Access rights
We will verify the accuracy of the Personal Data we process. If accurate, we will provide you access to your Personal Data and an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, we will provide this data electronically.
Your right of access may not adversely affect the rights and freedoms of others. If a request would infringe those rights, we may refuse or limit our response. Your rights related to rectification
If you wish to correct inaccurate Personal Data, you may ask us to rectify or complete the information. Your Right to Erasure
Legitimate grounds include: (a) we no longer need the Personal Data for the purposes for which it was collected; (b) you withdraw consent where processing is based on consent and there is no other legal basis; (c) you object to processing and there are no overriding legitimate grounds; (d) the Personal Data has been unlawfully processed; or (e) erasure is required to comply with a legal obligation. You cannot exercise this right where processing is necessary (a) to comply with EU or Member State law or (b) to establish, exercise, or defend legal claims.
Processing restrictions
You may request that we limit processing if you contest the accuracy of the data or in other circumstances provided by law. While restricted, we may process the data only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another person, or for important public interest of the EU or a Member State.
Right to data portability
For automated processing based on consent or contract, you have the right to receive the Personal Data you have provided to the Company.
You also have the right to request that this data be transmitted to another controller where technically feasible. Exercising data portability does not affect your right to erasure.
Right to object
You may object at any time to our use of your Personal Data based on legitimate interests pursued by the Company or third parties, including related profiling. Unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims, we will stop processing.
You also have the right to object at any time to processing 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 a supervisory authority regarding your Personal Data.
You may contact the supervisory authority in a Member State to protect your individual rights concerning Personal Data processing within the EU.
As outlined in section 13, your Personal Data rights may be limited by EU and Member State law. We will provide the information requested under section 13 within one month of receiving your request, and we may extend this by up to two additional months depending on the complexity and number of requests. You will be notified within one month of any extension and the reasons for it.
We will provide the information you request under section 13 free of charge unless a request is manifestly 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 doubts about your identity in connection with a request, the Company may ask for additional information.