We (also referred to as ‘We’, ‘Us’ or ‘Our’) are dedicated to safeguarding your Personal Data and preserving your privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the ‘Website’).
We uphold the following principles:

To provide transparency in how your personal information is collected and processed:

Our goal is to empower you to make informed decisions about how your Personal Data is collected, used and processed. To support this, we have developed a comprehensive website featuring a range of methods and procedures designed to give you clear, relevant information on our Personal Data practices. This transparency ensures you fully understand your rights and our obligations under applicable laws. If you require specific details, we will provide them promptly at the appropriate time. We welcome any questions you may have and will clarify any legal limitations as needed. You can reach us via email at the address below: info@blue-orion.com

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

Personal Data may be processed by us for a variety of purposes, such as providing access to the website and connecting you with third-party trading platforms (the 'Services'), enhancing and securing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, complying with regulatory or legal requirements, and conducting administrative and business activities to support the delivery and use of the Services. Personal Data are also processed to better understand your preferences and needs.

Access essential tools to safeguard your personal data rights:

We want you to make informed decisions about how your Personal Data is collected, used and processed. Our goal is to help you understand your rights and how we protect your information. That’s why we created this website. Through a variety of methods and procedures, we provide clear, relevant information on data handling. Should you require further details, we will share them at the appropriate time. We’re available to answer any questions and clarify any legal constraints. Please contact us via email at: info@blue-orion.com

Safeguard Your Personal Data:

Although we cannot guarantee complete security of your Personal Data, we are committed to employing a variety of methods and techniques to keep your Personal Data protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy explains the categories of Personal Data that the Company collects from individuals and how it processes, shares, and secures that information. It covers data related to an identified or identifiable natural person—defined as someone who can be identified directly or through additional information we hold or may acquire. The policy defines “processing” as any operation involving the use or collection of Personal Data, including its management, organization, and storage. Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly collect information from or permit access by individuals under 18, and we will delete any such data as soon as we become aware of it.

2. What personal data do we hold about you?

If you access our Services, service channels or website, we collect Personal Data. In some cases, we will request this information directly. In others, we gather it by analysing your use of our Services and service channels, or by obtaining it from our third-party partners.

3. You are not required to disclose personal information to the company, and there are no consequences for choosing not to do so.

You are not required to provide us with any personal data. However, in certain circumstances, without this information we may be unable to provide our services or users may be unable to access the website.

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

This includes detailed records of your online activity, such as your activity log, traffic data (including IP address, date and time of access), geolocation details, language preference, software crash logs, browser type and version, operating system and version, network and device-specific information, and any other diagnostic data. The information we collect is considered non-personal and cannot be used to identify you. Personal Data We receive from you: any personal data you voluntarily provide when connecting through Us to a third-party online trading platform. Personal information you specifically supply to those platforms to facilitate transactions: your full name, postal address, telephone number, email address and any other data required to execute the trade that you provide.

5. Legal Basis and Reasons for Personal Data Processing

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

• You have given your consent to the processing of your Personal Data for one or more reasons. This occurs 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 information to meet their legitimate interests. For example, this is necessary to improve Our Services or defend legal claims.
• Processing must comply with legal obligations.

Contact us by email for more information on the processing required to safeguard our legitimate interests.
Below is a list of reasons and legal grounds on which we may use the personal data you provide us with.

6. Transfer of Personal Data to Third Parties

The Company may share Personal Data—including IP address information and user experience analyses—with third-party service providers such as hosting and storage vendors.
You may request that we disclose specific Personal Data about you to third-party trading platforms. In such cases, we will transfer the Personal Data you have provided to us to those platforms. Their use of your Personal Data is governed by their own privacy policies, and your data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners to access the resources required to enhance and improve the products and services offered to customers.
If necessary to protect the rights of third parties or Company assets, the Company is authorized to disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors, buyers, or lenders to the Company or any affiliated company in connection with such transactions (including the transfer or sale of assets belonging to the Company or any other group entity), or as part of a merger, restructuring, consolidation, or bankruptcy of the Company or any affiliated business.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be used on our website. These companies may also employ cookies or similar 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 might enjoy. Cookies also support statistics and analytics.
Some of the cookies we use are session cookies. These are downloaded temporarily to your device and expire when you close your browser. Other cookies are persistent, remaining on your device after you close the browser. They help the website recognise you as a returning user and allow you to revisit the website seamlessly.

7. Third-party cookies and services

We may use them according to their purpose:

Cookies are blocked or removed
To block or remove cookies, adjust your browser’s settings. Below are links to guides to help you through the process 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 perform as expected if this occurs.

ONLINE TRACKING NOTICE This service does not currently honour Do Not Track signals.
8. Retention of Your Personal Data

The Company will retain your Personal Data only for as long as necessary to fulfil the purposes described in this Policy or for longer periods as permitted by law, regulations, policies or applicable orders. We will share your information with third-party trading platforms for 12 months; if you agree, we will extend this sharing for an additional 12 months.
We regularly review the Personal Data we hold to ensure it is no longer needed.

9. Transfers of personal information to a third-party country or an international organisation

Your personal information may be transferred to other countries or international organisations (i.e. a third country outside your country of residence) or to international jurisdictions. We take all necessary steps to safeguard the personal data you provide and ensure you can exercise your rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the EU Commission has recognised as providing adequate 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')
• The transfer is made pursuant to a legally binding, enforceable agreement between public entities or authorities under Article 46(2)(a).
• The transfer was carried out in compliance with the Standard Contractual Clauses for data protection adopted by the European Commission 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.

The Company can provide details on the security measures it uses to safeguard your Personal Data when transferred to third-party countries or international organisations. Please email info@wealthwaydigital.uk

10. Safeguarding Personal Data

We have implemented appropriate organisational and technical safeguards to protect Personal Data, preventing accidental or unlawful destruction, loss or alteration of such information.
While we strive to maintain the security of your Personal Data, we cannot guarantee it will be error-free or accept liability for any indirect, incidental or consequential damages arising from its use or disclosure, including but not limited to transmission errors, unauthorised third-party access or other factors beyond our control.
If legal or other obligations beyond our control require disclosure of your Personal Data to third parties, such as public authorities, we cannot guarantee the security measures they apply.
No method of online transmission is entirely secure, and the Company cannot ensure the security of any Personal Data you transmit to us over the internet.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided on this website for your convenience. These websites and applications operate independently of the Company, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to activities conducted on these platforms.
Before accessing or using any third-party website or application, we recommend reviewing its privacy policy and carefully considering any Personal Data you choose to share.

12. Updates to this Policy

This Policy may be updated at any time. When we revise it, we will promptly post the updated version on our website. For significant modifications, we will also endeavour to notify you through methods we deem appropriate and publish a corresponding announcement on our site. Unless otherwise indicated, all amendments will take effect upon publication of the revised Policy.

Your Rights Regarding Your Personal Information

You have the right to request verification of your Personal Data, correct any inaccuracies and delete any data no longer required by us. You may also restrict certain types of processing. If you are an EEA resident, please refer to this page:
These rights apply to the Personal Data you provide. You may exercise them by emailing us at the address below.
Access rights
You may ask us to confirm whether we are processing your Personal Data and to provide you with an electronic copy. We may charge a reasonable fee for additional copies. You may request delivery in a suitable electronic format.
We will refuse or limit access only if doing so would infringe the rights and freedoms of others.
Right to rectification
You may request that we correct inaccurate or incomplete Personal Data, taking into account the purposes of processing.
Right to erasure
You have the right to have your Personal Data erased where: (a) it is no longer necessary for the purpose it was collected; (b) you withdraw consent and no other legal basis applies; (c) you object to processing based on our or a third party’s legitimate interests and there are no overriding grounds; (d) the data have been unlawfully processed; or (e) erasure is required by law.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under EU or Member State law; or (b) for the establishment, exercise or defence of legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict its processing. We will retain the data only with your consent, to establish, exercise or defend legal claims, to protect another individual’s rights or for reasons of significant public interest.
Right to data portability
If processing is based on consent or a contract and carried out by automated means, you may obtain your Personal Data in a structured, commonly used and machine-readable format. You may also request direct transfer to another controller, where technically feasible. Exercising this right will not affect your right to erasure, and does not infringe the rights and freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on legitimate interests, including profiling. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights or freedoms, or for the establishment, exercise or defence of legal claims.
Direct marketing
You have the right to object to the processing of your Personal Data for direct marketing at any time.
Right to withdraw consent
You may withdraw consent to any processing based on consent at any time. This will not affect the lawfulness of processing carried out before the withdrawal.
Right to lodge a complaint
You may lodge a complaint with your local supervisory authority if you believe your rights have been infringed.
EU and Member State law may limit these rights as set out in section 13. We will respond to requests under section 13 within one month of receipt, which may be extended by up to two months depending on the complexity and number of requests. We will notify you of any extension and the reasons within the initial one-month period.
Unless section 13 provides otherwise, information provided under this section is free of charge. We may charge a reasonable fee or refuse to act where requests are manifestly unfounded or excessive.
If we have doubts about the identity of the requester, we may request additional information.