We (also referred to as 'We', 'Us', or 'Our') remain fully committed to protecting your Personal Data and safeguarding your privacy.
This Privacy Policy is intended to inform you about how we collect and store the information you provide on the Gaingate website (the 'Website').
We adhere to the following principles:

We are committed to transparency 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 various 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 deliver them promptly and at the appropriate time. Should you have any questions, we are happy to clarify matters related to legal requirements. To contact us, please email us at info@blue-orion.com

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

You will find that we collect and process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining, provisioning, and delivering the Services, ensuring full compliance with legal and regulatory requirements, and performing 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.

Obtaining access to vital resources to more effectively protect your rights with respect to Personal Data

We are committed to helping you make well‑informed decisions about how we handle your data. That commitment is why we created this website. To support it, we use a range of methods and procedures to ensure you receive clear, accurate, and up‑to‑date information about the use of your Personal Data on an ongoing basis. When specific details are required, we will provide them at the appropriate time. If you have questions about our process, we are happy to offer answers and clarifications, all in line with applicable legal requirements. To learn more, contact us at info@blue-orion.com

Keep Your Personal Information Secure and Private

While we cannot guarantee the absolute security of your Personal Data—no organization can—we remain fully committed to employing multiple, industry-standard safeguards and practices to protect your Personal Data. Our Privacy and Security Policy addresses all the most essential areas, helping ensure your long-term safety.

Scope?

In this Policy, we outline the types of Personal Data our Company collects from customers, along with the purposes and methods for processing it, sharing it with third parties, and safeguarding that data. This Policy covers information about an identified or identifiable individual—someone we can recognize directly or indirectly when combined with additional information in our possession or data we can access. For the purposes of this Policy, “processing” refers to any operation involving Personal Data, including its collection, recording, organization, structuring, storage, adaptation, retrieval, use, management, disclosure by transmission or otherwise making it available, and deletion. Our services are intended for a general audience; however, they are not available to anyone under the age of 18. We do not authorize individuals under this age to use our services, and we do not knowingly collect information from anyone under 18. Accordingly, minors should not use the services or submit any information to us. If we become aware of any collection of data relating to a person under 18, we will promptly delete such information.

2. What Personal Information Do We Collect from You?

By using our services or associated channels, or by browsing our website, you consent to our collection and use of your personal data. In some cases, we may request this information from you directly through forms or other inputs. We may also obtain it by analyzing your interactions with our services or channels, or through our third-party partners

3. You are not obligated to submit your personal information to our company or address any consequences of doing so

Sharing your personal data with us is optional. Unfortunately, in certain cases, choosing not to provide this personal data may affect how we deliver our services to you, which could result in limited access to our website or limited use of specific features and functionalities.

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

The data we collect includes details such as your activity log, traffic data (including IP address and access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This usage data is non-personal, and we do not use it to identify you. Some of the Personal Data we obtain from you is the information you voluntarily provide when you connect to a third-party online trading platform through us. We may also receive from these platforms the personal details you submit to them, including 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 complies with applicable legal requirements.
We rely on a legal basis because, 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 on the Website for us to share with a third-party trading platform
• The Company or a third party may need to process this information because doing so supports their legitimate interests. Examples include enhancing our Services or protecting our rights by defending against potential legal claims.
• All processing on our website complies with applicable legal requirements, and we can confirm that it adheres to those standards.

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 for when and how we may use the personal information you provide 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 for purposes such as storage, hosting, IP address data processing, or user experience analysis.
We also honor requests from individuals who ask us to share specific Personal Data about themselves with third-party trading platforms. In such cases, we will transfer the Personal Data you provide to the platforms you designate. If you choose to do this, the use of your information will be governed by their privacy policies. In these cases, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners and affiliated entities. This allows us to access the resources needed to enhance and improve our customer offerings.
Where appropriate, 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 interested investors or buyers, or with lenders to the Company or its affiliates, typically in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or other related parties.

Online Tracking Notice

Our website may use third-party services, such as advertising networks or 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 learn about your preferences and browsing patterns so we can enhance the user experience, understand user interests, and design products and services based on customer needs. Cookies also help us compile statistics and conduct 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 and remain on your device even after you close your browser. These allow the website to recognize you as a returning visitor and retain your previously selected preferences.

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

Each cookie and its use may vary depending on its intended purpose.

Cookies have been blocked or cleared
You can manage your cookie preferences in your browser settings. Use the links below for assistance.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

Online Tracking Notice Please note that at this time, our service does not honor Do Not Track requests.
8. Learn More About How We Store Your Personal Information

Please be aware that Our Company will retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, and we may keep it for a longer period as permitted by applicable laws 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.
From time to time, we will review and evaluate the Personal Data we hold to confirm whether we still require it.

9. International Transfers 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 your Personal Data outside your home country or to international organizations. We take all necessary steps 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 rely on these protections and safeguards.

• In some instances, we may transfer your Personal Data to a third country or international organization that the European Commission has recognized 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 do so under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
• We carry out the transfer in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. For more details, you can review the official 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 use to protect your Personal Data when transferred to third-party countries or international organizations, please email us at info@wealthwaydigital.uk

10. Personal Information Protection

To protect your Personal Data, we have implemented robust, industry-standard security measures. These measures help prevent accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee error-free security of your Personal Data, nor can we be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, disclosures caused by transmission errors, unauthorized access by third parties, or other events beyond our control.
Where required by law, or due to other circumstances beyond our control, we may need to share your Personal Data with third parties such as public authorities. In such cases, we cannot control or manage the security practices of those third parties.
Please note that transmitting Personal Data over the internet is not completely secure and carries inherent risks. As a result, we cannot guarantee the security of Personal Data you send 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 governs activities on our website, it does not apply to third-party websites.
Before visiting any third-party website or app, please review its privacy policy before using its services. At the same time, carefully consider whether you wish to provide your Personal Data.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If changes are made, we will notify you via a notice on our website and display the updated Policy. For substantial changes to this Policy, we will communicate through the methods we consider most appropriate, including posting an announcement on our website. Unless we indicate otherwise, all amendments to this Policy will take effect immediately upon publication of the revised Policy.

Your Rights as They Relate to Your Personal Data

You have the right to request a review of the personal data we hold about you, to have it corrected, and to ask that we delete Personal Data in appropriate circumstances. You may also request that we restrict the types of data we collect. For residents of the EEA, please visit this page:
Anyone wishing to exercise their data rights may contact us at the email address below. Right of access
We will assess the accuracy of the Personal Data we process. If accurate, we will provide you 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 cannot infringe the rights and freedoms of others. If a request would adversely affect others’ rights, we may refuse to comply or limit our response. Right to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Right to erasure
Valid grounds may include: (a) we no longer need the Personal Data for the purposes for which it was collected; (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.
Restriction of processing
You may ask us to limit processing if you contest the accuracy of the data. While restricted, we may store the data and process it only with your consent, for the establishment, exercise, or defense of legal claims, to protect another person’s rights, or for important public interests of an EU Member State or the EU.
Right to data portability
For automated processing based on your consent or a contract, you have the right to receive your Personal Data that the Company processes and to obtain it in a structured, commonly used, machine-readable format.
You also have the right, where technically feasible, to have this data transmitted to another controller. Exercising your data portability right 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 a third party’s legitimate interests, including related profiling. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of 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 to 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 in your jurisdiction.
You may additionally request that a supervisory authority in a Member State safeguard your rights regarding Personal Data processing within the EU.
As outlined in this 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, with the possibility of extending this by two months due to complexity or volume. You will be informed within one month if an extension is needed and the reasons for it.
We will provide the information requested under section 13 free of charge unless a request is manifestly unfounded or excessive, particularly if repetitive. In such cases, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have reasonable doubts about your identity in connection with a request, the Company may request additional information to verify it.