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, use, 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 information in your best interests:

By doing so, our goal is to help you make informed choices about the use and processing of Personal Data. To achieve this, our website uses several methods and procedures to deliver clear, relevant information about how Personal Data is handled. If you need specific details about your data, we will work hard to provide them promptly and at the appropriate time. Should you have any questions, we are happy to explain any aspect, including applicable legal constraints. To contact us, please send us an email at info@blue-orion.com

We will only use Personal Data for the purposes set out in this Policy

You will find that we process Personal Data for a range of purposes, including providing and operating the website, connecting you with third-party trading platforms (referred to as 'Services'), enhancing the site and user experience, protecting our rights and legitimate interests, maintaining, supporting, and provisioning the Services, ensuring full compliance with legal and regulatory obligations, and performing administrative and business functions to facilitate the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Securing access to essential resources to better safeguard your rights in relation to Personal Data

Our goal is to help you make informed decisions about how we manage your data. This is why we created this website. To support this, we use a range of methods and processes to ensure you consistently receive the most relevant information about our use of your Personal Data. If you need specific details, we will provide them at the appropriate time. If you have questions about how this works, we are happy to offer explanations and clarifications, all within legal requirements. To learn more, contact us at: info@blue-orion.com

Keep Your Personal Information Secure and Protected

Unfortunately, we cannot guarantee the absolute security of Personal Data—as no one can—but we remain fully committed to using multiple measures to protect your Personal Data. Our Privacy and Security Policy covers all essential bases to help ensure your long-term safety.

Scope?

This Policy outlines the categories and sources of Personal Data our Company collects from customers, along with how we process it, share it with third parties, the purposes for which it is used, and the measures we take to keep it secure. It applies to information about an identified or identifiable individual, where a person can be recognised directly or indirectly by reference to data we hold, in our possession, or otherwise accessible to us, including in combination with other information. For the purposes of this Policy, ‘processing’ refers to any operation performed on Personal Data, such as its collection, use, management, organisation, storage, adaptation, disclosure, and disposal. Our services are designed for a general audience; however, they are not available to anyone under the age of 18. We do not authorise individuals under this age to use our services and do not knowingly collect information from persons under 18. If we become aware that data relating to someone under 18 has been collected, we will promptly delete it.

2. What Personal Information Do We Collect from You?

By using our services, channels, or browsing our website, you acknowledge that we may collect personal data about you. In some cases, we may ask you for your personal data directly. Alternatively, we may analyse your interactions with our services or channels to gather this information, or obtain it through our third-party partners

3. You are not obliged to submit your personal information to our company or to accept any implications arising from doing so

You are not obliged to share any personal data with us. However, if you choose not to provide it, this may affect how we deliver our services and could mean restricted access to our website or limited use of certain features.

4. What types of personal data do we collect? When you visit our website, we may collect the following personal information:

The information we collect includes details from your activity log, traffic data (such as IP address and access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This information is non-personal, and we do not use it to identify you. We may also obtain Personal Data that you voluntarily provide when connecting to a third-party online trading platform through us. In addition, we receive 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 outlined in this section and in accordance with applicable laws and regulations.
We require a legal basis; without one, 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 through the Website for sharing with a third-party trading platform
• The Company or third parties may, from time to time, need to process information where necessary to pursue their legitimate interests. This can include improving our Services, enhancing user experience, or protecting and defending against potential legal claims.
• All processing carried out on our website must comply with applicable laws and regulations, and we confirm that it does.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below is an overview of the reasons and legal bases for our use of the personal information you have provided 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 data storage, IP address hosting, or user experience analytics.
We also accept requests from individuals who want us 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 designate. When this occurs, their privacy policies will govern how your data is used. 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. We do so 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 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 insolvency or bankruptcy proceedings involving the Company or related parties.

Online Tracking Notice

Our website may use third-party services, such as advertising networks and analytics providers. These partners may also use cookies and similar technologies that collect information.
When we say cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies to remember your preferences and understand browsing patterns, so we can enhance the user experience, tailor products and services to customer interests, and conduct statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device even after you close your browser. Persistent cookies help the website recognise 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 how it is used may vary, depending on its intended purpose.

Cookies are currently blocked or have been removed
You can manage your cookie preferences in your browser settings. Click the links below for guidance.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some of the website's functions and features may not operate as intended if this occurs.

Online Tracking Notice Please note that, at present, our service does not recognise Do Not Track requests.
8. Learn More About Storing Your Personal Information

Please note that Our Company retains your Personal Data for as long as necessary to fulfil the purposes set out in this Policy, and we may also retain it for a longer period where permitted by law and where required for applicable orders and compliance obligations. In certain cases, we may share your information 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 and appropriate.
We periodically review and assess the Personal Data we hold to confirm whether it remains necessary and to securely delete or anonymise data that is no longer required.

9. Transfers of Personal Data to a Third Country or an International Organisation

Under certain circumstances, we may transfer your Personal Data to other countries with your permission, whether to a country that is not your own or to international organisations. We implement all necessary measures to protect and secure your Personal Data, ensuring you can exercise your rights and obtain effective legal remedies whenever required.
All residents of the EEA (European Economic Area) can take advantage of these protections and safeguards.

• In some cases, we may transfer your Personal Data to a third country or international organisation where the European Commission has recognised that country 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 and enforceable instrument between public authorities or bodies in accordance with Article 46(2)(a)
• We carry out the transfer in compliance with the European Commission’s Standard Contractual Clauses for data protection, which were adopted under Article 46(2)(c) of the GDPR. For more information, please see 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 safeguard 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. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee that your Personal Data will always be securely maintained without errors, nor can we 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, unauthorised access by third parties, or other circumstances beyond our control.
Where we are legally required, 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 control the security measures those third parties apply.
Please note that transmitting Personal Data over the internet is not entirely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of your Personal Data you send to us online.

11. Information on Links to Third-Party Websites

Our website includes links to external sites and applications that are beyond our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. Our Policy, while it governs what occurs on our website, does not extend to third-party websites.
Before visiting any third-party website or app via our links, you should review their privacy policies before using their services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding 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 make the updated Policy available for your review. For more substantial updates, we will use the channels we deem most appropriate to inform you, and we will also issue an announcement on our website. Unless we state otherwise, all amendments to this Policy take effect immediately upon the publication of the revised Policy.

Your Rights as They Relate to Your Personal Data

You have the right to request access to the personal data we hold about you, to have it rectified, and to ask us to delete any Personal Data you no longer wish us to process. You may also restrict the types of data we collect. For individuals residing in the EEA, please refer to this page:
Anyone wishing to exercise their data rights may contact us via the email address below. Access rights
We will verify the accuracy of the Personal Data we process. If accurate, we will grant you access to your Personal Data and provide an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies. Upon request, we will provide this data electronically.
Your right of access must not infringe the rights of others. Where a request would affect others’ rights, 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 incomplete or incorrect information. Your right to erasure
Legitimate reasons may include: (a) we no longer need the Personal Data for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (e) unlawful processing of Personal Data; or (f) compliance with a legal obligation. This right does not apply if processing is necessary (a) to comply with Member State or EU law, or (b) to establish, exercise, or defend legal claims.
Restrictions on processing
You may ask us to limit processing if you believe the data is inaccurate. Where processing is restricted, the data may only be stored with your consent, to establish or defend legal claims, to protect the rights of others, or for reasons of important public interest under Member State or EU law.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive all Personal Data the Company processes about you.
You also have the right to request that we transfer this data to another controller where technically feasible. Exercising your data portability rights 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 Company’s or third parties’ legitimate interests, including related profiling. We will proceed only where we have compelling legitimate grounds that override your rights and freedoms or where processing is required for legal claims.
You have the right to object at any time to the 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 carried out before withdrawal.
You also have the right to lodge a complaint with the authority supervising your Personal Data rights.
You may additionally request that a supervisory authority in a Member State protect your individual rights regarding Personal Data processing within the EU.
As outlined in 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, and we may extend this by up 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 the 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 on the request.
If we have doubts about your identity in relation to a request, the Company may request additional information.