We ('we', 'us', or 'our') remain fully committed to safeguarding your Personal Data and protecting your privacy.
Our Privacy Policy is designed to inform you 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 information 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 employs several methods and procedures to provide clear, relevant information about Personal Data usage. If you require specific details about your data, we will work diligently to ensure you receive them promptly and at the appropriate time. Should you have any questions, we are happy to clarify any applicable legal constraints. To contact us, please send us an email at info@blue-orion.com

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

You will find that we process Personal Data for multiple purposes: to provide the website to you; to connect you with third-party trading platforms (the 'Services'); to improve the site and your experience; to protect our rights and interests; to maintain and provision the Services; to ensure full compliance with legal and regulatory obligations; and to carry out the administrative and business operations necessary to enable 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 safeguard your rights concerning Personal Data

Our goal is to help you make well-informed choices about how we handle your Personal Data. This commitment is why we built this website. To support it, we use a range of methods and procedures to ensure you continue receiving the most relevant, up-to-date information about our use of your Personal Data. If you need specific details, we will provide them at the appropriate time. If you have any questions about how this process works, we are happy to answer and clarify, always within applicable legal requirements. To learn more, contact us via email at: info@blue-orion.com

Keep Your Personal Information Private and Secure

Unfortunately, we cannot guarantee the absolute security of Personal Data, as no one can; however, we remain fully committed to using a range of measures to protect your Personal Data. Our Privacy and Security Policy addresses all key areas to support your long-term safety.

Scope?

In this Policy, we describe the categories of Personal Data our Company collects from customers, as well as how we process it, share it with third parties, and protect it. This Policy covers information about an identified or identifiable individual, including situations where a person can be recognized directly or indirectly using other information we hold or can access. For purposes of this Policy, “processing” means any operation performed on Personal Data. This includes, for example, the management, organization, and storage of such data. Our services are intended for a general audience but are strictly not available to individuals under 18. We do not authorize anyone under this age to use our services. Accordingly, we do not knowingly collect information from persons under 18, as they are not permitted to use our services. If we become aware that we have collected data from someone under 18, we will delete it promptly.

2. What Personal Information Do We Collect from You?

By using our services or channels, or by browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you to provide personal data directly. Alternatively, we may collect this information 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 be subject to any associated implications

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 access to our website or certain features.

4. What Are Examples of Personal Data We Collect? When you visit our website, we may gather the following personal information:

The Personal Data we collect includes information such as details from your activity log, traffic data (including IP address, access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This information is non-identifiable, and we do not use it to identify you. We may also obtain Personal Data from you—namely, any personal information you voluntarily provide when connecting to a third-party online trading platform through us. In addition, we may receive the personal details you submit directly to these platforms, which may include your full name, email address, phone number, and postal 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, in compliance with the applicable legal framework.
We require a lawful basis; without such a basis, our Company cannot use your Personal Data. The lawful 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 submit 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 this information to pursue their legitimate interests. For example, this may involve enhancing our Services or protecting our rights in potential legal proceedings.
• All processing conducted on our website must comply with all applicable laws and regulations, and we can confirm that it does so.

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 on which we may use 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-party service providers, such as for storage, hosting, IP address data processing, or user experience analytics.
We also accommodate 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 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 share Personal Data with its business partners or affiliated entities. We do this to access the resources needed to enhance our customer offerings while continually improving them.
Where appropriate, the Company may disclose Personal Data to regulatory, local, or official authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or buyers, or with lenders to the Company or its affiliated companies. This typically occurs in connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy involving the Company or other parties associated with the Company.

Online Tracking Notice

We may use third-party services on our website, such as advertising providers and analytics firms. These partners may also use cookies and similar technologies to collect data.
When we refer to cookies, we mean small text files stored on your device when you visit or access our website. We use cookies to collect information about your preferences and browsing patterns so we can improve the user experience, better understand your interests, and design products and services aligned with customer needs. Cookies also help us generate statistics and perform analytics.
Some of the cookies we use are session cookies. These are temporarily placed 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. 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 the way it is used may differ, depending on its purpose.

Cookies have been blocked or removed
You can adjust your cookie preferences in your browser settings. You can click the links below for instructions on how to do this.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that some website functions and features may not operate as intended if this occurs.

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

Please note that Our Company retains your Personal Data for as long as necessary to fulfill the purposes described in this Policy and may retain it longer where permitted by law and for order-related requirements, where applicable. 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.
We periodically review and assess the Personal Data we hold to ensure we do not retain it longer than necessary.

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 you permit us to send this data to a country other than your own, and we may also transfer it to international organizations. We take all necessary measures to protect and defend your Personal Data and to ensure that you can exercise your rights and effectively access legal remedies when needed.
All residents of the EEA (European Economic Area) can benefit from these protections and safeguards.

• In certain cases, we may transfer your Personal Data to a third country or an 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 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 these transfers in accordance with the European Commission’s Standard Contractual Clauses for data protection, issued under Article 46(2)(c) of the GDPR. To learn more, you can review 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 to learn more about these details and how they relate to the security measures we implement to protect 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 appropriate technical and organizational security measures. These measures are designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
Nevertheless, despite all reasonable precautions, we cannot guarantee that your Personal Data will be maintained without error, and we cannot be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures resulting from transmission errors, unauthorized access by third parties, or other events beyond our control.
Where we are legally obliged, or in other circumstances beyond our control, we may be required to share your Personal Data with third parties such as public authorities. In such cases, we cannot oversee or guarantee the security measures those third parties apply.
Please note that transmitting Personal Data over the internet cannot be made completely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website may include links to external sites and applications that are outside our Company’s control. Accordingly, we assume no responsibility for how these third-party websites collect or process your Personal Data. While our Policy applies to what happens on our website, it does not cover what occurs on third-party websites.
Before visiting any third-party website or app, please review its privacy policy before using their services. You should also carefully consider whether you want to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We may update this Policy at any time to reflect changes in our practices or legal requirements. If we make changes, we will notify you via a notice on our website and provide access to the updated Policy. For material changes to this Policy, we will make reasonable efforts to inform you through the channels we consider most appropriate, including a prominent announcement on our website and, where applicable, additional notices. Unless we indicate otherwise, all updates to this Policy take effect immediately upon publication of the revised version.

Your Rights as They Relate to Your Personal Data

You have the right to request a review of the personal data we collect about you, to have inaccuracies corrected, and to ask that we delete your Personal Data where appropriate. You may also restrict certain types of data processing. For residents of the EEA, please visit 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 and, where applicable, provide you with access to it, including an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies of your data. Upon request, we will supply this information electronically.
Your right of access must not infringe the rights and freedoms of others. Where a request would adversely affect others’ rights, we may refuse to comply or limit our response. Your rights related to rectification
If you wish to correct inaccurate or incomplete Personal Data, you may ask us to rectify it. Your Right to Erasure
Legitimate grounds for erasure 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) the Personal Data has been processed unlawfully; or (f) erasure is required to comply with a legal obligation. This right does not apply 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 believe the data is inaccurate. While processing is restricted, we may store the data but will only process it with your consent, to establish, exercise, or defend legal claims, to protect the rights of another person, or for reasons of important public interest of the EU or a Member State.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive the Personal Data you have provided to the Company and to review it.
You also have the right to request that the data be transmitted to another controller where technically feasible. Exercising your 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 legitimate interests of the Company or third parties, including related profiling. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests and rights, or the processing is needed for the establishment, exercise, or defense of 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 its withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for the protection of your Personal Data.
You may additionally request that a supervisory authority in a Member State protect your individual rights regarding Personal Data processing within the EU.
As noted in this section 13, your Personal Data rights may be limited by EU and Member State law. We will respond to requests made under section 13 within one month of receipt; where necessary due to complexity or volume, we may extend this by up to two further months. You will be informed of any extension and the reasons for it within one month.
Information provided under section 13 will be supplied 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 on the request.
If we have reasonable doubts about your identity in connection with a request, the Company may request additional information.