We (also referred to as ‘We’, ‘Us’ or ‘Our’) are dedicated 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 provide transparency about how we collect and process your personal information:

We want you to make informed decisions about how your Personal Data is collected and processed. That is why we created this website. Through various methods and procedures, we deliver clear, relevant information on the handling of Personal Data. If you need specific details, we will provide them at the appropriate time. We welcome any questions you may have and will explain any legal limitations. You can reach us via email at info@blue-orion.com

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

Personal Data may be processed by us for various purposes, such as providing you with access to the website and connecting you with third-party trading platforms (the "Services"), enhancing and maintaining the site, protecting our rights and interests, fulfilling regulatory or legal obligations, and conducting administrative and business activities to support the delivery and use of the Services. We also process Personal Data to gain a better understanding of your preferences and needs.

Leverage powerful tools to safeguard your rights regarding Personal Data:

We want you to make informed choices about how your Personal Data is used and processed. That’s why we built this website. Here, we use various methods and procedures to deliver relevant information on Personal Data usage. If you need specific details, we’ll provide them at the appropriate time. We’re happy to answer any questions and clarify any legal limitations. You can reach us by email at info@blue-orion.com

Protect Your Personal Data:

While we cannot promise absolute security for your Personal Data, we will continue to use a range of methods and techniques to safeguard it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy describes the types of Personal Data the Company collects from natural persons, and how it processes, shares with third parties, and secures this information. This Policy applies to any data related to an identified or identifiable natural person. An identifiable natural person is someone whose identity can be determined directly or through a combination of additional information we hold or access. The Policy defines "processing" as any operation involving Personal Data, including its collection, use, management, structuring, and storage. Our services are intended for general audiences and are not designed for use by individuals under 18. We do not knowingly collect information from anyone under 18 or permit their use of our services. If we become aware that we have collected data from a child, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

When you access our services or channels, or visit our website, we collect Personal Data. In some cases, we may ask you to provide Personal Data; in others, we gather it by analyzing your use of our services and channels or by receiving information from our third-party partners.

3. You are not required to disclose personal information to the company, and there will be no consequences.

You are not required to provide us with any Personal Data. However, in certain circumstances, withholding Personal Data may prevent us from providing the Services or users from accessing the website.

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

This includes your online activity log, traffic data such as your IP address and date and time of access, language preferences, software crash logs, browser type and device details. This data is not private and cannot be used to identify you. Personal Data we receive from you: any information you choose to provide when connecting to a third-party online trading platform through us. Personal information you provide to facilitate trades on these platforms includes your full name, address, phone number and email address.

5. The 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 a valid legal basis, the Company cannot use your Personal Data. The legal grounds that allow the Company to process your Personal Data are:

• You have consented to the processing of your Personal Data for one or more purposes. This applies when you provide 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 perform processing to pursue their legitimate interests. For example, this processing may be necessary to enhance Our Services or defend legal claims.
• Processing must comply with legal obligations.

Contact us by email for more information on the processing necessary to safeguard our legitimate interests.
Below is a list of reasons and legal grounds for using the personal data you provide us. Personal Data.

6. Third-Party Transfers of Personal Data

The Company may also share Personal Data—including IP addresses and usage analytics—with professional third-party service providers, such as hosting and storage vendors that support our operations.
You can also request that we disclose specific Personal Data about you to third-party trading platforms. Upon receiving your request, we will share the relevant data you have provided with those platforms. Their handling of your Personal Data is governed by their privacy policies, and your information may be further shared among multiple trading platforms.
In addition, the Company may share Personal Data with related entities, subsidiaries, or business partners to access the resources and expertise needed to enhance, improve, and develop the products and services we offer our customers.
In the event it becomes necessary to safeguard the rights or property of third parties, or to comply with legal obligations, the Company is permitted to disclose Personal Data to regulatory bodies, law enforcement agencies, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any other group company in connection with a corporate transaction (including the transfer or sale of assets belonging to the Company or any group member), or as part of a merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics firms, may be engaged to support our website. These providers may also use cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or access the website. They gather information about your preferences and browsing habits to improve your user experience, retain your settings, and customize the products and services you may enjoy. Cookies are also employed for statistical and analytical purposes.
Some of these cookies are session cookies: they are downloaded temporarily to your device and expire when you close your browser. Others are persistent cookies, which remain on your device for a specified period after you close your browser. Persistent cookies enable the website to recognize you as a returning user and allow you to resume your experience with your preferences saved.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To block or remove cookies, adjust your browser’s settings. Below are links to help you with the process for some of the most 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 if this happens.

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

The Company retains your Personal Data for as long as necessary to fulfill the processing purposes described in this Policy, or for longer periods if required by applicable laws, regulations, policies, or orders. We will share your information with third-party trading platforms for an initial period of 12 months, and, with your consent, will continue sharing your data for an additional 12 months.
We regularly review retained Personal Data to confirm that it is no longer needed.

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

Your personal information may be transferred to other countries, meaning your personal data could be transmitted to third countries (i.e., jurisdictions other than your country of residence) or to international organizations. The Company implements all necessary measures to safeguard the personal data you provide and to ensure that users can assert their rights and access 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 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)
• The transfer is made under a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a).
• The transfer of personal data was conducted in strict compliance with the standard contractual data protection clauses for international data transfers, adopted by the European Commission under Article 46(2)(c) of the GDPR. The full text of these model clauses for transfers to third countries is available on the European Commission’s official website under ‘Model Contracts for the Transfer of Personal Data to Third Countries’: 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 detailed information on the security measures it employs to protect your Personal Data when transferred to third-party countries or international organisations. To request further details, please email info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented robust organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee error-free security of your Personal Data, nor can we be liable for any indirect, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorized third-party access, or any other circumstances beyond our control.
In cases where legal or other binding obligations beyond our control require it, we may need to disclose your Personal Data to third parties, such as public authorities. We have no control over the security measures those parties apply to your Personal Data.
No method of transmitting Personal Data over the web is entirely secure. Accordingly, the Company cannot ensure the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to websites owned by third parties

Links to third-party sites and applications are provided on the website. These external platforms operate independently of the Company, and we are not responsible for their collection or processing of Personal Data. Consequently, this Policy does not apply to any actions taken on those sites or within their apps.
Before visiting a third-party site or using its app, please review its privacy policy and carefully consider any Personal Data you choose to provide. We also recommend only providing the Personal Data required to access or use their services.

12. Amendments to this Policy

This Policy may be updated at any time. When changes occur, we will post the revised Policy on our website. For significant updates, we will also use appropriate notification methods and publish an announcement on our website. Unless otherwise specified, all amendments become effective upon publication of the revised Policy.

Your rights regarding your personal information

You may request us to verify the accuracy of your Personal Data, correct any errors, or delete any data we no longer need. You may also restrict certain types of data processing. If you reside in the EEA, please refer to this page:
These rights apply to any Personal Data you provide. To exercise them, send an email to the address below. Access rights
You have the right to confirm whether we are processing your Personal Data and to access it. We will provide an electronic copy of the Personal Data we process and may charge a reasonable fee for additional copies. The data will be supplied electronically upon request.
The right of access must not infringe upon the rights and freedoms of others. If your request adversely affects another’s rights, we may refuse or restrict our response. Right to rectification
You may request correction of any inaccurate or incomplete Personal Data concerning you, taking into account the purposes of processing. Right to erasure
You may request deletion of your Personal Data when: (a) it is no longer necessary for the purposes collected; (b) you withdraw consent and no other legal basis exists; (c) you object, for reasons specific to your situation, to processing based on legitimate interests; (d) the data has been unlawfully processed; or (e) erasure is required to comply with a legal obligation.
This right does not apply if processing is necessary: (a) to comply with a legal obligation under EU or Member State law; or (b) to establish, exercise, or defend legal claims. Processing restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict its processing. During the restriction period, we will only process the data 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 automated and based on your consent or a contract to which you are a party, you have the right to receive the Personal Data you provided in a structured, commonly used, machine-readable format.
You may also request that we transfer your Personal Data directly to another controller, if technically feasible. Exercising this right does not affect your right to erasure or infringe on others’ rights and freedoms. Right to challenge
You may challenge any processing of your Personal Data based on legitimate interests pursued by us or a third party, including profiling. We will cease the processing unless we demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or unless it is necessary for the establishment, exercise, or defense of legal claims.
Concerning direct marketing, you have the unconditional right to object to the processing of your Personal Data at any time. Right to refuse consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of processing carried out before the withdrawal.
You have the right to lodge a complaint with your supervisory authority. You may also appeal to a supervisory authority established by an EU Member State to safeguard individuals’ rights regarding Personal Data processing. The laws of the EU and its Member States may limit these rights as set out in Section 13. We will respond to your request under Section 13 within one month of receipt, extendable by up to two months depending on complexity and volume of requests. We will inform you of any extension and its reasons within one month.
Unless otherwise specified in Section 13, the information you request will be provided free of charge. We may charge a reasonable fee or refuse to act if requests are manifestly unfounded or excessive, particularly if repeated.
If we have doubts about the identity of the person making a request, we may ask for additional information.