We (also referred to as 'We', 'Us' or 'Our') are committed to safeguarding your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the 'Website').
We uphold the following principles:

To ensure full transparency in our collection and processing of your personal information:

We want you to be in a position to make informed choices regarding the use and processing of Personal Data. This is why we created our website. To achieve this, we use a range of methods and procedures to provide you with relevant information about how Personal Data is handled. If we believe you need specific details, we will supply them at the appropriate date and time. We are happy to answer any questions you may have and to clarify any legal limitations. We can be reached via email at the address below: info@blue-orion.com

Personal Data will be used solely for the purposes set out in the Policy.

We may process Personal Data for a range of purposes, including providing the website and connecting you with third-party trading platforms (the 'Services'), enhancing and securing the site, facilitating the maintenance and delivery of the Services, protecting our rights and interests, meeting regulatory or legal obligations, and conducting administrative and business activities to support the Services. We also process Personal Data to gain a better understanding of your preferences and needs.

To leverage essential tools to safeguard your rights regarding Personal Data:

We want you to make informed choices about the use and processing of Personal Data. That’s why we’ve created this website and employ a range of methods and procedures to provide comprehensive, up-to-date information on our data handling practices. Through the site, you can easily access our privacy policies, guidelines and best practices to understand how we protect your information. If we believe you require specific details, we’ll supply them at the appropriate time. We’re happy to answer any questions you have and clarify any limitations imposed by law. You can reach us via email at info@blue-orion.com

Protect your Personal Data:

While we cannot guarantee complete security of your Personal Data, we remain committed to employing a variety of methods and techniques to ensure it is protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy outlines the categories of Personal Data the Company collects about individuals and explains how that data is processed, shared with third parties, secured and otherwise managed. It covers personal information that identifies or could identify a living individual; an identifiable person is someone who can be recognised directly or in combination with additional information we hold or have access to. The Policy defines 'processing' as any operation involving the collection, use, organisation, structuring or storage of Personal Data. Our services are intended for a general audience and are not designed for use by anyone under the age of 18. We do not knowingly collect information from, or permit access to, individuals under 18, and will promptly delete any such data if discovered.

2. What personal data do we hold about you?

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

3. You have no obligation to provide personal information to the company, and there are no consequences if you don’t.

You are not required to provide us with any personal data. However, in certain circumstances, withholding this information may prevent us from delivering our services or 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 your online activity log, traffic data (including IP address, date and time of access), chosen language, software crash logs, browser type and device information. None of this data is personal information and cannot be used to identify you. Personal Data we receive from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through us. Personal information you provide to third parties to facilitate trades includes your full name, address, phone number and email address.

5. Legal Basis and 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 applicable legal basis.
Without such a basis, the Company cannot use your Personal Data. The legal grounds on which the Company may process your Personal Data are as follows:

• You have provided your consent for 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 serve their legitimate interests. For example, this includes enhancing Our Services or defending legal claims.
• Processing must comply with legal obligations.

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

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data, such as IP address information and user experience analysis, with third-party service providers like hosting and storage companies.
You may request that we transfer specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you have provided with these platforms, subject to their privacy policies. Please note that your data may be shared with multiple trading platforms.
We may also share Personal Data with our affiliates or business partners to access the resources needed to enhance and improve the products and services we offer to customers.
Where necessary to protect third-party rights or assets, the Company may disclose Personal Data to regulatory, local or other official authorities.
We may also share your Personal Data with potential investors, buyers or lenders in connection with any corporate transaction—such as the transfer or sale of assets, a merger, restructuring, consolidation or bankruptcy—affecting the Company or any member of its corporate group.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be used on our website. These partners may also use cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to enhance your user experience, track your settings, and personalise the products and services you receive. Cookies also support statistics and analytics.
We may use session cookies, which are temporary and expire when you close your browser. We also use persistent cookies, which remain on your device for a set period after you close your browser. These cookies help the website recognise you as a returning user and enable you to return to the site more easily.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or deleted
To disable or delete cookies, adjust your browser's settings. Below are links to guides for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that if this happens, some or all of the Website’s functions and features may not work as you expect.

ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention of your personal data

The Company will retain your Personal Data only as long as necessary to fulfil the processing purposes set out in this Policy or for longer periods as required by law, regulation, policy or court order. We’ll share your information with third-party trading platforms for 12 months; if you consent, we’ll extend this sharing for a further 12 months.
We regularly review stored Personal Data to ensure it is no longer needed.

9. Transfers of personal information to third countries or international organisations

Your personal information may be transferred to third countries (that is, nations outside your country of residence) or to international organizations or jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide and ensures that you can assert your rights and access effective legal remedies.
These protections and safeguards apply to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation which the European Commission has determined provides an adequate level of protection for personal data under 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 and enforceable agreement between public entities or authorities under Article 46(2)(a).
• The transfer was completed in compliance with the EU Commission’s standard data protection clauses adopted 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.

The Company can provide details on the security measures it employs to safeguard your Personal Data when transferred to third-party countries or international organisations. For more information, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented suitable organisational and technical safeguards to protect Personal Data. These measures include prevention of accidental or unlawful destruction, loss or unauthorised alteration of your Personal Data.
However, we cannot guarantee or warrant that the security of your Personal Data will be flawless at all times, nor accept liability for any intangible, indirect, incidental or consequential damages arising from its use or disclosure in any form. This includes, but is not limited to, any Personal Data being exposed or improperly disclosed due to transmission errors, unauthorised third-party access or any other cause beyond our control.
In the event of legal or other obligations beyond our control, we may be required to provide Personal Data concerning you to third parties, such as public authorities. We cannot control how these parties protect your data.
Online transmission cannot be completely secure; therefore, the Company cannot guarantee the security of Personal Data you transmit via the internet.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided on this website. These sites and apps operate independently and are not governed by the Company. We are not responsible for the collection or processing of Personal Data by these third parties. This Policy does not apply to activities carried out on those sites or apps.
When you visit any third-party website or app, we recommend that you review its privacy policy before accessing or using it. We also suggest that you only submit Personal Data directly to them.

12. Amendments to this Policy

This Policy may be updated at any time. If we do so, we will notify you by posting the revised Policy on our website. For significant changes, we will also seek to inform you through the most appropriate channels and will publish an announcement on our site. Unless otherwise specified, any amendments take effect upon publication of the updated Policy.

Your rights in relation to your personal information

You are entitled to request that we verify the accuracy of any Personal Data we hold about you, correct any errors and delete any Personal Data that is no longer necessary. You may also restrict the types of processing of your Personal Data. If you are an EEA resident, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. To exercise any of these rights, please email us at the address below.
Access rights
You may request confirmation of whether we are processing any of your Personal Data and, if so, you may access it. We will supply an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. Upon request, the data will be provided electronically.
The right of access must not conflict with the rights and freedoms of others. If your request adversely affects another person’s rights, we may refuse to comply or limit our response.
Right to rectification
We will rectify any inaccurate Personal Data concerning you. You also have the right to request that any incomplete Personal Data be completed, taking into account the purposes of processing.
Right to Erasure
You may request the deletion of your Personal Data if: (a) it is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal ground for processing; (c) you object, for reasons specific to your situation, to the processing of your Personal Data based on our or a third party’s legitimate interests; (d) it has been unlawfully processed; or (e) it must be erased to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with a legal obligation under EU or Member State law; or (b) for the establishment, exercise or defence of legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict its processing. In such cases, we may only retain your data with your consent, to establish, exercise or defend legal claims, to protect another individual’s rights, or for reasons of significant public interest under EU or Member State law.
Right to data portability
Where processing is carried out by automated means and based on your consent or the performance of a contract, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format. You may also request that we transmit your Personal Data directly to another controller where technically feasible. Exercising this right does not affect your right to erasure and must not prejudice the rights or freedoms of others.
Right to object
You have the right at any time to object to the processing of Personal Data concerning you that is based on our or a third party’s legitimate interests. This includes profiling carried out on that basis. We may continue processing only if we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
Concerning direct marketing
You have the right at any time to object to the processing of Personal Data for direct marketing purposes.
Right to withdraw consent
You may revoke your consent for us to process your Personal Data at any time. This will not affect the lawfulness of any processing carried out prior to the withdrawal.
You are entitled to lodge a complaint with the supervisory authority in your jurisdiction. You may also appeal to any EU Member State supervisory authority responsible for protecting individuals’ fundamental rights in relation to Personal Data processing.
EU and Member State law may limit your rights as outlined in this section 13. We will respond to your request under section 13 within one month of receipt. We may extend this by up to two months where necessary, depending on the complexity and number of requests. We will inform you of any extension and our reasons within one month of receiving your request.
Unless prohibited by section 13, the information provided in response to your request will be free of charge. We may charge a reasonable fee to cover administrative costs for requests that are manifestly unfounded, excessive or repeated, or we may refuse to act on such requests.
If we have any doubts about the identity of the person making the request, we may ask for additional information.