We (referred to as 'We', 'Us' or 'Our') are dedicated to protecting 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 will uphold the following principles:

To be transparent about how we collect and process your personal information:

We want you to be able to make informed choices about how we collect, use and process Personal Data. That’s why we’ve created this website: to provide clear, relevant information on Personal Data handling through various methods and procedures. If you need specific details, we’ll supply them at the appropriate time. We’re also happy to answer any questions and clarify any legal limitations. You can reach us via email at info@blue-orion.com

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

Personal Data may be processed by us for various purposes, including providing you with access to the website and connecting you to third-party trading platforms (the 'Services'), enhancing and securing the site, facilitating maintenance and delivery of the Services, protecting our rights and interests, complying with legal and regulatory requirements, and conducting administrative and business operations. Personal Data is also processed to better understand your preferences and needs.

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

Our goal is to empower you to make informed decisions about the collection and processing of your Personal Data. To achieve this, we have developed this website and employ various methods and procedures to provide clear, relevant information about how Personal Data is used. If you require more specific details, we will supply them at the appropriate time. Whether you have general inquiries or need detailed explanations, our team is ready to assist within the bounds of applicable law. You can contact us at any time by email: info@blue-orion.com

Safeguard Your Personal Data:

While we cannot guarantee absolute security for your Personal Data, you can trust that we will continuously implement a variety of safeguards and techniques to protect it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the types of Personal Data the Company collects from natural persons and explains how we process, share with third parties, secure, and manage it. It covers information relating to identified or identifiable natural persons. An identifiable natural person is someone who can be directly recognised or identified by combining the information we hold or can access. The policy defines “processing” as any operation involving the collection or use of Personal Data, including its organisation, structuring, and storage. Our services are intended for general audiences and are not designed for individuals under 18. We do not knowingly collect information from anyone under 18 or allow such persons to use our services. If we learn that we have information about children, we will erase it as quickly as possible.

2. What personal data do we hold about you?

When you access our services and channels or visit our website, we collect Personal Data. In some cases, we may request specific Personal Data from you. Otherwise, we collect your Personal Data by analysing your use of our services and channels or by obtaining it from third-party partners.

3. There is no obligation to disclose personal information to the company, nor will you face any consequences for choosing not to do so.

However, you are not obliged to provide Us with any Personal Data. In certain circumstances, choosing not to supply Us with Personal Data could prevent Us from offering the Services or hinder users from accessing the website.

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

This includes your online activity logs, traffic data (such as IP address, date and time of access), language preferences, software crash reports, browser type, and device details. The collected data is not private and cannot be used to personally identify you. Personal data we receive from you consists of any information you voluntarily provide when connecting to a third-party online trading platform via our service. Personal information you supply directly to third-party platforms to facilitate transactions 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 described 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 on which the Company relies to process your Personal Data:

• You have consented to the processing of your personal data for various purposes. This applies when you submit personal information via the website so we can transfer it to a third-party trading platform.
• The Company or a third party may need to process data to pursue legitimate interests. For instance, processing may be necessary to enhance Our Services or to defend legal claims.
• Processing must comply with legal obligations.

Contact us by email for more information on how we process data to protect our legitimate interests.
Below is a list of reasons and legal grounds under which we may use the information you provide to us. Personal Data.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers—such as hosting, storage, and IP address analytics providers—to support our services and analyze user experience.
You can request that we send specific Personal Data about you to third-party trading platforms. In these cases, we will transfer the information you provide to us in accordance with their privacy policies. Your data may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities or business partners to secure the resources necessary for enhancing and improving our products and services.
If required to protect third-party rights or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may additionally share your Personal Data with potential investors, buyers, or lenders—whether for the Company or any related group entity—in connection with a transaction (including a sale or transfer of company assets), merger, restructuring, consolidation, or bankruptcy of the Company or any other group business.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be used. These companies can also employ 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 experience, remember your settings and personalise the products and services you may enjoy. Cookies are also used for statistical and analytical purposes.
We use two main types of cookies: session and persistent. Session cookies are downloaded temporarily and expire when you close your browser. Persistent cookies remain on your device after you close your browser, helping the website recognise you as a returning user and facilitating your return visits.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies have been blocked or removed
To block or remove cookies, adjust your browser's settings. Below are links to guides 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 expected if this occurs.

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

We retain your personal data only as long as necessary to fulfil the purposes outlined in this Policy, or longer if required by applicable laws, regulations, policies or orders. We share your information with third-party trading platforms for 12 months. With your consent, we will extend this sharing for a further 12 months.
We regularly review retained personal data to ensure it is no longer needed.

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

Your personal information may be transferred to other countries, including third countries, international organisations or jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide and to ensure you can assert your rights and access effective legal remedies.
These protections and safeguards are available to all individuals residing in the EEA (European Economic Area).

• Transfer to a third country or international organisation that 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, enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
• The transfer was carried out in accordance with the EU Commission’s standard data protection clauses adopted under Article 46(2)(c) of the GDPR. You can view these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

We can provide information on the security measures we employ to safeguard your Personal Data when it is transferred to third-party countries or international organisations. Please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented appropriate organisational and technical safeguards to protect Personal Data, including measures to prevent its accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee that the security of your Personal Data will be flawless or error-free. We also cannot accept liability for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised third-party access, or other factors beyond our control.
Should legal or other obligations beyond our control require us to disclose Personal Data to third parties—such as public authorities—we cannot assure the same level of protection by those entities.
No method of transmitting Personal Data over the internet is entirely secure. Accordingly, the Company cannot guarantee the security of any Personal Data you transmit to us online.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided on the website for your convenience. These external sites and apps operate independently of the Company, and we are not responsible for their collection or processing of Personal Data. This Policy does not apply to any actions you take on those platforms.
Before accessing or using any third-party website or app, we recommend reading its privacy policy. We also suggest providing any Personal Data directly to them.

12. Changes to this Policy

This Policy may change at any time. If we revise it, we will notify you by posting the updated Policy on our website. For significant updates, we will endeavour to inform you through appropriate channels and publish an announcement on our website. Unless stated otherwise, any amendments take effect upon publication of the revised Policy.

Your rights regarding your personal information

You have the right to ask us to verify that your Personal Data is being collected accurately, to correct any errors, and to delete any unnecessary Personal Data. You may also restrict the types of processing of your information. If you are an EEA resident, please refer to this page:
These rights apply to the information you provide as Personal Data. To exercise them, please send an email to the address below.
Access rights
The Company can confirm whether your Personal Data is being processed and grant you access to it. We will provide an electronic copy of the Personal Data we process and may charge a reasonable fee for additional copies. Upon request, the data will be delivered electronically.
The right to access Personal Data must not conflict with the rights and freedoms of others. If fulfilling your request would adversely affect another individual’s rights or freedoms, the Company may refuse or limit the response.
Right to rectification
The Company will correct any inaccurate Personal Data. You may also request the completion of any incomplete Personal Data, taking into account the purpose of processing.
Right to Erasure
The right to erasure applies if: (a) Personal Data is no longer necessary for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on our or a third party’s legitimate interests, for reasons specific to your situation; (e) Personal Data has been unlawfully processed; or (f) Personal Data must be deleted to comply with a legal obligation. This right does not apply if processing is necessary to: (a) comply with a legal obligation under European Union or Member State law; or (b) establish, exercise, or defend legal claims.
Processing restrictions
If you question the accuracy of your Personal Data, you may ask the Company to restrict its processing. Restricted data may be retained only with your consent, to establish, exercise, or defend legal rights, to protect another individual’s rights, or for reasons of substantial public interest under EU or Member State law.
Right to data portability
When processing is carried out by automated means and based on your consent or on a contract to which you are a party, you have the right to receive your Personal Data in a structured, commonly used, and machine-readable format.
You may also request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure and must not infringe on others’ rights or freedoms.
Right to challenge
You have the right to object at any time to the processing of your Personal Data based on our or a third party’s legitimate interests, including profiling. If we demonstrate compelling legitimate grounds for processing that override your interests, freedoms, or rights, or if processing is needed to establish, exercise, or defend legal claims, we may continue processing.
Concerning direct marketing
You may object at any time to the processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to the processing of your Personal Data at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may also appeal to a supervisory authority established by a Member State to protect individuals’ fundamental rights regarding Personal Data processing within the European Union.
EU and Member State laws may further limit your rights concerning your Personal Data as described in this section 13. We will respond to requests under section 13 of this agreement within one month of receipt. If necessary, this period may be extended by up to two months, depending on the request’s complexity and volume. We will inform you of any extension and its reasons within one month of your request.
Subject to section 13, information provided in response to your request will be free of charge. If a request is unfounded or excessive, particularly if repeated, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have any doubts about the identity of the person making the request, the Company may request additional information.