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 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:

Through these efforts, we aim to help you make informed decisions about the use and processing of your Personal Data. To support this, our website employs several methods and procedures to provide relevant information on Personal Data usage. If you need specific details about your data, we will work to provide them promptly and at the appropriate time. If you have any questions, we are happy to clarify any legal considerations. To get in touch, please email us at info@blue-orion.com

We will use Personal Data solely for the purposes outlined in this Policy

We process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (collectively, the 'Services'), enhancing the site, protecting our rights and interests, maintaining and provisioning the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities to enable the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Ensuring access to the essential resources you need to safeguard your rights concerning Personal Data

We are committed to helping you make well‑informed choices about how we manage your data. That commitment is why we created this website and the materials it contains. To support this, we follow established procedures and safeguards, using a range of tools to ensure you consistently receive the most relevant information about the use of your Personal Data. When specific details are required, we will provide them at the appropriate time. If you have any questions about our processes, we are happy to respond and offer clear explanations, all in line with applicable legal requirements. We also review and update our communications regularly so you stay informed. If you would like to learn more, please reach out to us via email at: info@blue-orion.com

Keep Your Personal Information Safe and Secure

While we cannot guarantee the absolute security of Personal Data, as no one can, we remain fully committed to employing multiple safeguards to protect your Personal Data. Our Privacy and Security Policy covers all key areas to help ensure your long-term safety.

Scope?

By reviewing this Policy, you will find an overview of the categories of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and safeguard it. Our Policy covers information about an identified or identifiable individual, whom we can recognise directly or through additional information we hold or can access. For the purposes of this Policy, ‘processing’ means any operation performed on Personal Data, including its management, organisation, and storage. Our services are intended for a general audience but are not available to anyone under 18 years of age. We do not authorise individuals under this age to use our services and, accordingly, do not knowingly collect information from them. If we become aware that we have collected data relating to a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

By using our services, channels, or browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you to provide this information directly. We may also collect it by analysing your interactions with our services or channels, or through our third-party partners

3. You are not required to share your personal information with our company or to address any implications arising from it

You are not required to share any personal data with us. However, in some situations, choosing not to provide certain personal information may affect our ability to deliver services, which could result in limited access to our website or specific features.

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

Information we collect includes details from your activity log, traffic data (such as IP address and date and time of access), the language you use on our site, software crash reports, browser type, and device specifications. This information is non-personal and is not used to identify you. We may also obtain Personal Data you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we receive personal details you submit directly to those 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, and does so in compliance with applicable laws, including data protection regulations.
We must rely on a lawful basis because, without one, our Company cannot process your Personal Data. The lawful grounds on which our Company processes 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 to be shared with a third-party trading platform
• The Company or a third party may need to process this information because it supports the pursuit of their legitimate interests. For example, this may include enhancing our Services or safeguarding us against potential legal claims.
• All processing on our website must comply with applicable legal requirements, and we confirm that it does comply with them.

If you would like more information about how we process Personal Data to protect our legitimate interests, please reach out to us by email.
Below, we have highlighted the purposes and legal bases under which you may see us using the personal information you have provided to us. Personal Data

6. How We Share Your Personal Information with Third Parties

Where appropriate, the Company may disclose Personal Data to third parties that provide services such as data storage, IP address hosting, or user experience analytics to support our operations.
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, and their privacy policies will govern how it is used. In these scenarios, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners or affiliated entities to access the resources needed to develop, enhance, and continuously improve our customer offerings.
When required, the Company may disclose Personal Data to regulatory, local, or other competent 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 affiliates. This typically occurs in the context of transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy involving the Company or parties associated with the Company.

Online Tracking Notice

You may encounter our use of third-party services on our website, such as ad networks and analytics providers. These companies may also use cookies and similar technologies to collect data.
When we say cookies, we mean small text files stored on your device each time you visit or access our website. We use cookies to gather information about your preferences and browsing patterns to improve the experience for our users, understand their preferences, and help us design products and services based on customer interests. Cookies also help us compile statistics and 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. Other cookies are persistent, meaning they remain on your device even after you close your browser. These cookies allow the website to recognise you as a returning visitor and retain the preferences you set earlier.

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

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

Cookies have been blocked or removed
You can manage your cookie preferences in your browser settings. Use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that some of the website's functions and features may not work as intended if this occurs.

Online Tracking Notice Please be aware that, at present, our service does not honour Do Not Track requests.
8. Learn More About How We Store Your Personal Information

Please note that Our Company will retain your Personal Data for as long as necessary to fulfil the purposes described in this Policy, and may retain it for a longer period as permitted by law and to comply with applicable orders. 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 evaluate the Personal Data we hold to confirm whether it is still required.

9. Transfer 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 data to a country other than your own, or to international organisations. We take every necessary step to safeguard 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) 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 execute it under a legally binding and enforceable instrument between public authorities or bodies in accordance with Article 46(2)(a)
• We conduct the transfer in line with the European Commission’s Standard Contractual Clauses for data protection, established 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 more information on these details and how they relate to the security measures we employ to protect your Personal Data when it is transferred to third-party countries or international organizations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented robust security measures designed to prevent accidental or unlawful destruction, loss, or alteration.
Even so, while we take extensive precautions, we cannot guarantee error-free security of your Personal Data, and we are not liable for 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 required by law, 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 govern the security practices of those third parties.
Please note that transferring Personal Data over the internet is not entirely secure and carries inherent risks. Owing to these risks, we cannot guarantee the security of Personal Data you transmit to us online.

11. Policy on Links to Third-Party Websites

Our website may include links to external sites and applications that are outside our Company's control. Accordingly, we do not accept responsibility for how such third-party websites collect or process your Personal Data. Our Policy applies only to activities on our website and does not extend to third-party websites.
Before visiting any third-party website or app via a link, please review their privacy policies before using their services. You should also carefully consider whether you wish to share 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 through a notice on our website and provide the updated Policy for your review. For significant changes, we will communicate through the methods we deem most appropriate and will also issue an announcement on our website. Unless stated otherwise, all amendments to this Policy take effect immediately upon the release of the revised Policy.

Your Rights in Relation to Your Personal Data

You have the right to request a review of the personal data we collect about you, to have it corrected, and to ask us to delete any Personal Data you do not wish us to retain. You may also request that we restrict the categories of data we collect. For residents of the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us at the email address below. Access rights
We will verify the accuracy of the Personal Data we process. If it is accurate, we will provide you with access to your Personal Data, including 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 must not adversely affect the rights and freedoms of others. If a request would compromise those rights, we may refuse to comply or limit our response. Your rights related to rectification
If you would like to correct inaccurate Personal Data, you may ask us to rectify inaccuracies or complete incomplete information. Your Right to Erasure
Legitimate grounds 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 ask us to limit processing if you believe the data is inaccurate. While restricted, data may be stored only with your consent, to protect the rights of others, to establish, exercise, or defend legal claims, or for important public interest of an EU Member State or the EU.
Right to data portability
Where processing is automated and 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 transmit the data to another controller where technically feasible. Exercising your data portability right will 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 comply unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is required to establish, exercise, or defend legal claims.
You may object at any time to the processing of Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent for processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data rights.
You may further request that a supervisory authority in a Member State protect your individual rights in relation to Personal Data processing within the EU.
As outlined in section 13, your Personal Data rights may be limited by EU and Member State laws. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request; we may extend this by two months depending on the complexity and number of requests. You will be notified within one month if an extension is applied and the reasons for it.
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 connection with a request, the Company may request additional information.