We (also referred to as 'We', 'Us', or 'Our') remain fully committed to safeguarding your Personal Data and protecting your privacy.
Our Privacy Policy is designed to inform you about 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 to serve your best interests:

Through these efforts, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website employs several methods and procedures to provide clear, relevant information about Personal Data practices. If you need specific details about your data, we will make every effort to deliver them promptly and at the appropriate time. If you have any questions, we are happy to clarify any legal constraints. To contact us, please email info@blue-orion.com

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

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

Gaining access to essential resources to effectively protect your rights in relation to Personal Data

Our goal is to help you make well‑informed choices about how we handle your data. That purpose guided the time we invested in developing this website and the resources behind it. Our aim is to provide transparency and build trust at every step. To support this, we use a range of methods and procedures to ensure you consistently receive the most relevant information about the use of your Personal Data. We regularly review and update our practices and notices to keep you informed. When specific details are needed, we will provide them at the appropriate time, including at the point of collection. If you have questions about how this process works, we are happy to respond and offer clarifications, all within applicable legal requirements. Your feedback is welcome and helps us improve. To learn more, contact us via email at: info@blue-orion.com

Keep Your Personal Data Safe and Secure

Unfortunately, we cannot guarantee the absolute security of Personal Data—no one can—but we remain fully committed to using a wide range of measures to protect your Personal Data. Our Privacy and Security Policy addresses the most essential safeguards to help ensure your long-term safety.

Scope?

Within this Policy, you will find an overview of the types of Personal Data our Company collects from customers, as well as how we process it, share it with third parties, and safeguard it. This Policy covers information about an identified or identifiable individual, where a person can be recognized directly or indirectly using information we hold or can access. For the purposes of this Policy, "processing" means any operation performed on Personal Data, including its management, organization, and storage. Our services are intended for a general audience but are not permitted for individuals under the age of 18. We do not authorize anyone under this age to use our services and 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 or channels, or by browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you directly for certain personal data. Alternatively, we may analyze your interactions with our services or channels to gather this information, or obtain it through our third-party partners

3. You are not required to provide your personal information to our company or manage any consequences arising from doing so

You are not required to share personal data with us. However, if you choose not to provide certain information, it may affect how we deliver our services, which could result in limited access to our website or restricted use of some features.

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

The Personal Data we collect includes information such as activity log details, 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 information is non-personal, and we do not use it to identify you. We also obtain certain Personal Data from you, namely any personal information you voluntarily provide when connecting to a third-party online trading platform through us. In addition, we receive the 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 described in this section and in accordance with the applicable legal framework.
We rely on a lawful basis, as 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 Data through the Website for us to share with a third-party trading platform
• The Company or a third party may need to process this information to pursue legitimate interests. Examples include improving our Services or defending ourselves against potential litigation.
• All data processing on our website must fully comply with applicable legal requirements at all times, and we confirm that it does.

If you would like more information about how we process Personal Data to safeguard our legitimate interests, please contact us by email.
Below, we outline the purposes and legal bases under which 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 parties that provide services such as data storage, IP address hosting, or user experience analytics.
We also honor requests from users who ask us 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 designate. If you choose this option, their privacy policies will govern its use. Your Personal Data may be shared with multiple trading platforms in these situations.
The Company may share Personal Data with its business partners or affiliates. We do so to access the resources needed to enhance and improve our customer offerings.
Where required, 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 prospective investors or buyers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or related parties.

Online Tracking Notice

On our website, we work with third-party services, including advertising providers and analytics firms. These partners may also use cookies and similar technologies that collect data.
By “cookies,” we mean small text files stored on your device each time you visit or access our website. We use cookies to remember your preferences, maintain essential site functionality, and understand browsing patterns. This helps us enhance the user experience, better understand what our users value, and design products and services around customer interests. Cookies also support the compilation of statistics and analytics.
With some of the cookies we use, they are session cookies. Session cookies are temporarily placed on your device and expire when you close your browser. Other cookies are known as persistent cookies because they remain on your device even after you close your browser. These cookies allow the website to recognize you as a returning visitor and retain the preferences you previously set.

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 removed
You can manage your cookie preferences in your browser settings. You can use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that certain website functions and features may not perform as expected if this occurs.

Online Tracking Notice Please note that our service currently does not recognise Do Not Track requests.
8. Learn More About How Your Personal Information Is Stored

Please note that Our Company will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy, and may retain it for a longer period where permitted by law and for applicable orders. In certain cases, we may share your information 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 assess the Personal Data we hold to confirm whether it remains necessary.

9. 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 consent to send this data outside your country of residence, or to international organizations. We take every necessary measure to protect and defend your Personal Data and ensure you can exercise your rights and effectively access legal remedies when needed.
All residents of the EEA (European Economic Area) benefit from these protections and safeguards.

• In certain circumstances, we may transfer your Personal Data to a third country or international organisation that the European Commission recognises 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 carry it out under a legally binding and enforceable instrument between public authorities or bodies, 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 view 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 about these details and how they relate to the security measures we apply to protect your Personal Data during transfers to third 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. These measures are designed to prevent accidental or unlawful destruction, loss, or alteration.
However, despite taking extensive precautions, we cannot guarantee that your Personal Data will be kept completely secure or error-free, and we cannot 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 we are legally required, 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 control the level of security those third parties provide.
Please note that transmitting Personal Data over the internet cannot be made entirely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of the Personal Data you transmit to us online.

11. About Links to Third-Party Websites

Our website includes links to external sites and applications that are outside our Company's control. Accordingly, we are not responsible for the content, security, or practices of those third-party websites, including how they collect, use, or process your Personal Data. While our Policy governs activity on our website, it does not apply to third-party websites or applications.
Before visiting any third-party website or app, please review its privacy policy and terms before using its services. You should also carefully consider whether you wish to share your Personal Data with them.

12. Understanding the Amendments to Our Policy

We reserve the right to amend or update this Policy at any time. If changes are made, we will notify you via our website, where we will display and provide a link to the updated Policy. For material changes, we will communicate through the channels we consider most appropriate, including a notice posted on our website and, where relevant, additional announcements and communications. Unless we state otherwise, all amendments to this Policy take effect immediately upon publication of the revised Policy.

Your Rights with Respect 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 us to delete Personal Data in appropriate circumstances. You also have the right to restrict the types of data we may process. If you reside in the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us using the email address below. Right of access
We will verify the accuracy of the Personal Data processed. If accurate, we will provide you with access to your Personal Data, including an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies of your data. Upon request, we will provide this data electronically.
Your right of access must not adversely affect the rights of others. If a request would infringe the rights of others, we may refuse to comply or limit our response. Right to rectification
If you wish to correct inaccurate Personal Data, you may ask us to rectify or complete that information. Right to erasure
Valid grounds may include: (a) we no longer need the personal data for its original purpose; (b) you withdraw consent and there is no legal basis for processing; (c) you object to processing for specific reasons; (e) unlawful processing of Personal Data; or (f) compliance 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 believe the data is inaccurate. While restricted, the data may be stored but processed only with your consent, to protect another person’s rights, or for important public interests of the EU or a Member State.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive the Personal Data the Company holds about you.
You may also request its transfer to another controller where technically feasible. Exercising data portability does not affect your right to erasure.
Right to object
You may object at any time to our use of your Personal Data based on the Company’s or third parties’ legitimate interests, including related profiling. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests and rights, or processing is required to establish, exercise, or defend legal claims.
You may object to processing for direct marketing at any time.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing before withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data.
You may also ask a supervisory authority in a Member State to protect your individual rights regarding Personal Data processing within the EU.
As outlined in section 13, your Personal Data rights may be limited by EU and Member State law. We will provide the information requested under section 13 within one month of receiving your request, and may extend this by up to two months depending on the complexity and number of requests. We will notify you within one month if an extension is applied and explain the reasons.
Information requested under section 13 will be provided free of charge unless a request is 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 doubts about your identity in connection with a request, the Company may ask for additional information.