We (referred to as 'we', 'us' or 'our') are committed to protecting your personal data and your privacy.
This Privacy Policy is designed to explain how we collect and store the information you provide through the Gaingate website (the 'Website').
We adhere to the following principles:

To ensure transparency about how your personal information is collected and processed:

We want you to be able to make informed choices about the collection and processing of Personal Data. That is why we created this website. To achieve this, we use various methods and procedures to give you relevant information about how Personal Data is used. If we believe you need specific details, we will provide them at the appropriate date and time. We are happy to answer any questions and will offer any clarifications you require, subject to any legal limitations. You can contact us by email at: info@blue-orion.com

Personal Data will be used solely for the purposes set out in this Policy.

Personal Data may be processed by us for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, meeting regulatory or legal obligations, and carrying out administrative and business activities to support the delivery and use of the Services. Personal Data are also processed by us to better understand your preferences and needs.

To access essential tools to safeguard your rights in relation to Personal Data:

We want you to be able to make informed choices about the use and processing of your Personal Data. That is why we created this website. To achieve this, we use various methods and procedures to provide you with relevant information about the use of Personal Data. If we believe you need specific details, we will provide them at the appropriate time. We are happy to answer any questions and offer any clarifications you require, subject to any legal limitations. You can reach us by email at: info@blue-orion.com

Protect Your Personal Data:

While we cannot guarantee the complete security of your Personal Data, we assure you that we will continue to employ a range of methods and techniques to ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy describes the types of Personal Data the Company collects about natural persons and how we process it, share it with third parties, and protect it. It applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including through additional information we hold or can access. The Policy defines 'processing' as any operation that involves the use of Personal Data, including the collection, management, organisation, and storage of such data. Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly seek or collect information from individuals under 18, and we do not knowingly permit them to use our services. If we become aware that we hold information about a child, we will delete it as quickly as possible.

2. What personal data do we hold about you?

When you use our services and channels or visit our website, we collect Personal Data. In some cases, we may ask you to provide Personal Data. In others, we collect it by analysing how our Services and channels are used, or by receiving information from our third-party partners.

3. No obligation to provide personal information to the company and potential consequences.

However, you are not required to provide Us with any Personal Data. In some situations, you may choose not to share Personal Data with Us. This may prevent Us from delivering the Services or restrict users’ access to the website.

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

This includes details of your online activity log and traffic data (including IP address, and the date and time of access), the language you use, software crash logs, the type of browser used, as well as information about the device you use. The information we collect is non-personal and cannot be used to identify you. Personal data we receive from you: any personal data you choose to provide to us when you connect to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading: this may include your full name, address, telephone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

Your Personal Data is processed by the Company for the purposes set out in this section, in line with the applicable legal basis.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company may process your Personal Data are:

• You have provided your consent to the processing of your Personal Data for one or more reasons. This applies, for example, when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
• The Company or a third party may need to process data to pursue their legitimate interests. For example, processing may be necessary to improve Our Services or to defend legal claims
• Processing is required to meet a legal obligation.

Please contact us by email for more information about the processing required to protect our legitimate interests.
Below is a list of purposes and legal bases for which we may use the information you provide to us. Personal Data.

6. Transfers of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers, such as hosting and storage providers, and with partners who process IP address information and conduct user experience analysis.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In such cases, we will provide the Personal Data you supply to us to those third-party trading platforms. Their use of your Personal Data is governed by their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners. This provides the Company with the resources needed to enhance and improve the products and services it offers to customers.
Where necessary to safeguard the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors or purchasers, or with lenders to the Company or any other company within the group, in connection with a relevant transaction (including the transfer or sale of assets of the Company or any other group company), or as part of any merger, restructuring, consolidation, or insolvency of the Company or any other business within the group.

ONLINE TRACKING NOTICE

We may use third-party services, such as advertising providers and analytics companies. These providers may also use cookies and similar technologies to deliver their services.
Cookies are small text files placed on your device when you visit or access our website. They help collect information about your preferences and browsing habits to improve your experience, remember your settings, and customise the products and services you may enjoy. Cookies are also used for statistics and analytics to help us understand how the site is used.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and remain only for a short time, ending when you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a set period after you close your browser. They help the website recognise you as a returning user and make it easier for you to return to the site.

7. Use of third-party cookies and services

We may use them for their intended purposes:

Cookies are blocked or have been removed
To block or delete cookies, you will need to adjust your browser settings. Below are links to help you through the process for several 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 operate as expected if this occurs.

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

The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer where permitted by applicable laws, regulations, policies, or orders. We will share your information with third-party trading platforms for 12 months. If you consent, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is not kept longer than necessary.

9. Transfers of personal data to a third country or to an international organisation

Your personal information may be transferred to other countries (i.e. transmitted to a third country—meaning a country other than the one in which you reside—or to international organisations or jurisdictions). The Company takes all necessary steps to safeguard the personal data you provide and ensures that individuals can assert their 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 ensures an adequate level of protection for personal data transferred to it, 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 authorities or bodies in accordance with Article 46(2)(a).
• The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. You can view the European Commission’s clauses at 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 details of the security measures it uses to protect your Personal Data when it is transferred to third countries or international organisations. Please email info@wealthwaydigital.uk to request this information

10. Personal Data Security

We have taken appropriate organisational and technical measures to safeguard Personal Data. These measures include preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held liable for any non-material, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorised access by a third party, or any other cause beyond our control.
In the event of legal requirements or other obligations beyond our control, we may be required to provide Personal Data about you to third parties, such as public authorities. We cannot control the level of protection those third parties give to your Personal Data in such cases.
Personal Data cannot be transferred over the internet in a completely secure manner. The Company cannot ensure the security of 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. These websites and apps are not under the Company’s supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any third‑party website or app, we recommend reading its privacy policy before deciding to access or use it. We also suggest that you only provide any Personal Data to them after doing so.

12. Changes to this Policy

This Policy may be updated at any time. If we make changes to this Policy, we will notify you by posting the updated version on our website. In addition, when we make significant modifications to this Policy, we will seek to inform you through methods we consider appropriate, and we will also publish a notice on our website. Unless expressly stated otherwise, any amendments will take effect upon publication of the revised Policy.

13. Your rights in relation to your personal information

You are entitled to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we no longer require. You may also ask us to limit certain types of processing of your personal information. If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You can exercise them by emailing the address below. Access rights
The Company can verify whether Personal Data about you is being processed. If it is, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be supplied electronically if you request it.
Your right of access must not adversely affect the rights and freedoms of others. Where a request would prejudice another person’s rights and freedoms, the Company may refuse to comply or may restrict how it fulfils the request. Right to Rectification
The Company will correct inaccurate Personal Data. You have the right to require that incomplete Personal Data about you be completed, taking into account the purposes of the processing. Right to Erasure
You may request erasure where: (a) the Personal Data is no longer needed for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, to processing based on legitimate interests pursued by Us or a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be deleted to meet the Company’s legal obligations. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law; or (b) for the establishment, exercise, or defence of legal claims.
Restriction of Processing
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If restriction is applied, Personal Data may only be processed with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another natural person, or for reasons of important public interest in the European Union or a Member State.
Right to Data Portability
Where processing is carried out by automated means and based on your consent or on a contract to which you are party, you have the right to receive the Personal Data you have provided to the Company in a structured, commonly used, machine-readable format.
You may also request that your Personal Data be transmitted directly by the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. Data portability must not adversely affect the rights or freedoms of others.
Right to Object
You may object at any time to the processing of your Personal Data based on the legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is required for the establishment, exercise or defence of legal claims.
Direct Marketing
You have the right to object at any time to the processing of your Personal Data for direct marketing.
Right to Withdraw Consent
You may withdraw your consent for Us to process your Personal Data at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
You also have the right to lodge a complaint with your supervisory authority.
You may complain to a supervisory authority established by a Member State to protect individuals’ fundamental rights in relation to the processing of Personal Data within the European Union.
The laws of the European Union and Member States may limit your rights in relation to your Personal Data, as described in section 13. We will provide information in response to your requests under section 13 of this agreement within one month of receipt. This period may be extended by up to two further months where necessary, taking into account the complexity and number of requests. We will notify you within one month of receiving your request if an extension is required and explain the reasons.
Unless section 13 provides otherwise, information provided in response to your rights under section 13 will be supplied free of charge. If a request is manifestly unfounded or excessive, in particular because it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or we may refuse to act.
If we have doubts about the identity of the individual making the request, the Company may ask for additional information.