We (referred to as 'We', 'Us', or 'Our') are committed to safeguarding your Personal Data and protecting your privacy.
This Privacy Policy is designed to inform you about 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 make informed choices about how your Personal Data is used and processed. Our commitment to transparency ensures you always have access to the necessary information. To support this, we’ve designed our website with a range of methods and procedures to provide clear, relevant information on data usage. If you need specific details, we will supply them promptly at the appropriate time. We are 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 specified in the Policy.

Personal Data may be processed by us for various purposes: to deliver and enhance the website, to connect you with third-party trading platforms (the 'Services'), to protect our rights and interests, to maintain and provide the Services, to comply with regulatory or legal obligations, and to conduct administrative and business activities. Personal Data is also processed by us to better understand your preferences and needs.

Use robust tools to safeguard your rights concerning your Personal Data:

We aim to enable you to make well-informed decisions about the collection, use, sharing, and processing of your personal data. That's why we've developed this website: to share comprehensive, up-to-date information on our data handling practices. We employ various methods and procedures to ensure you promptly receive all relevant details. If you require more specific information, we’ll provide it at the appropriate time. We’re also available to answer any questions and clarify any legal requirements or constraints. At every step, we remain committed to transparency in all our operations. You can contact us by email at info@blue-orion.com

Protect your personal data:

While we cannot guarantee the complete security of your Personal Data, we will continue to employ various methods 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 this information is processed, shared with third parties, and safeguarded. It applies to information relating to any identified or identifiable natural person. An identifiable natural person is someone who can be recognized—directly or indirectly—using that data alone or in combination with other information we hold or access. ‘Processing’ refers to any operation involving Personal Data, including its collection, organization, storage, and management. Our services are intended for general audiences and are not designed for individuals under 18. We do not knowingly collect personal information from minors under 18 or allow them to use our services. If we become aware of such data, we will delete it promptly.

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 explicitly request this information. In other cases, we gather data by analysing your use of our services or channels or by receiving information from our third-party partners.

3. You are not required to provide personal information to the company, and there are no consequences for not doing so.

You are not required to provide us with any Personal Data. However, in certain situations, choosing not to share your Personal Data may prevent us from delivering the Services or users from accessing the website.

4. What Personal Data Can We Collect? When you visit our website, we will collect the following personal information:

This includes information about your online activity log, traffic data (such as your IP address, access date and time), the language you used, software crash logs, browser type, and device details. These data are not considered private and cannot be used to identify you. Personal Data we receive from you consists of any personal information you voluntarily provide when connecting to a third-party online trading platform through Us. The personal information you share specifically with these platforms to facilitate trading includes your full name, mailing address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

Your Personal Data is processed by the Company for the purposes outlined in this section and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot process your Personal Data. The legal grounds on which the Company may process your Personal Data are:

• You have consented to the processing of your personal data for one or more purposes. This applies 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, this processing is required to enhance our services or defend legal claims.
• Processing must comply with legal obligations.

For more information about the processing necessary to safeguard our legitimate interests, please contact us by email.
Below is a list of the reasons and legal grounds on which we may use the information you provide. Personal Data.

6. Transfer of Personal Data to Third Parties

The Company may share Personal Data—including IP address data and user experience analytics—with third-party service providers, such as hosting and storage companies, to support, maintain, and optimize our services.
Upon your explicit request, we can transmit specific Personal Data you supply to us to third-party trading platforms. In these cases, your data will be handled by those platforms under their own privacy policies and may be shared with multiple trading partners.
Furthermore, the Company may disclose Personal Data to related entities or business partners, subject to appropriate confidentiality and security measures, to secure the resources needed to enhance and improve our products and services.
Where necessary to protect the rights or assets of third parties, the Company is permitted to disclose Personal Data to regulatory bodies, law enforcement, or other official authorities.
Finally, in the event of a merger, acquisition, restructuring, consolidation, asset sale, bankruptcy, or any similar corporate transaction involving the Company or any member of our group, we may share your Personal Data with potential investors, buyers, or lenders as required to complete the transaction.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be used. These providers may also employ cookies or similar technologies.
Cookies are small text files placed on your device each time you visit or use the website. They collect information about your preferences and browsing patterns to enhance your experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistical and analytical purposes.
We may use session cookies, which are temporarily downloaded to your device and expire when you close your browser. Other cookies are persistent, remaining on your device for a set period after your browser closes. These persistent cookies help the Website recognize you as a returning user and allow you to revisit the website.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To prevent or remove cookies, adjust your browser settings. Below are links to guide you through the process for a few of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please be aware that if this happens, some or all of the Website's functions and features may not function as expected.

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

The Company retains Personal Data about you for as long as necessary to fulfill the processing purposes described in this Policy, or for longer periods as permitted by law, regulation, policy, or applicable orders. We will share your information with third-party trading platforms for an initial 12-month period; if you agree, we will continue to share your data for an additional 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, jurisdictions, or international organizations—meaning it could be processed outside your country of residence. We take all necessary steps to safeguard the personal data you provide and ensure that you can assert your rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer of Personal Data to a third country or international organisation that the European Commission has deemed to provide adequate protection 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 authorities or bodies under Article 46(2)(a).
• The transfer was carried out in compliance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. These clauses can be viewed 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 details on the security measures we use to protect your Personal Data when it is transferred to third-party countries or international organisations. For more information, please email us at info@wealthwaydigital.uk

10. Safeguarding Personal Data

We have implemented organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee that the security of your Personal Data will be error-free, nor can we accept liability for any indirect, incidental, or consequential damages resulting from its use or disclosure. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or any circumstances beyond our control.
Where legal requirements or other obligations beyond our control arise, we may be required to disclose your Personal Data to third parties, such as public authorities. In such cases, we cannot ensure the security measures these third parties apply to your Personal Data.
No data transmission over the internet can be completely secure. Accordingly, the Company cannot guarantee the protection of any Personal Data you transmit to us online.

11. Hyperlinks to third-party websites

Links to third-party websites and applications on our site are not under the Company’s supervision. We are not responsible for the collection or processing of Personal Data by these external sites or apps. This Policy does not apply to any activities conducted through them.
Before accessing or using third-party sites or apps, we recommend that you review their privacy policies and share any Personal Data directly with them.

12. Updates to This Policy

This Policy may be updated at any time. When we revise this Policy, we will promptly post the updated version on our website to notify you. If we make significant modifications, we will also use the methods we consider appropriate and publish an announcement on our website. Unless explicitly specified, amendments become effective upon publication of the revised Policy.

Your rights in relation to your personal information

You are entitled to request that we verify the accuracy of any Personal Data we hold about you, correct any errors, and delete all Personal Data that we no longer require. You may also request that we restrict or suspend specific types of processing of your Personal Data. If you are a resident of the EEA, please refer to this page:
These rights apply to any information you have provided to us in relation to your Personal Data. To exercise any of these rights, please send an email to the address below. Access Rights
The Company will confirm whether we are processing your Personal Data and, if so, provide you with access to that data. At your request, we will supply an electronic copy of any Personal Data currently being processed. We may charge a reasonable fee for additional copies beyond the first. You will receive the data electronically unless you request otherwise.
Access may be refused or limited if fulfilling your request would infringe the rights and freedoms of others. Right to Rectification
You have the right to request correction of any inaccurate Personal Data we hold about you or to have incomplete data completed, taking into account the purposes of the processing. Upon receipt of your request, we will make the necessary amendments without undue delay. Right to Erasure
You may request the deletion of your Personal Data when one of the following grounds applies: (a) the Personal Data are no longer necessary for the purposes for which they were collected or processed; (b) you withdraw consent and no other legal basis for processing exists; (c) you object to processing based on our or a third party’s legitimate interests, on grounds relating to your particular situation; (d) the Personal Data have been unlawfully processed; or (e) erasure is required to comply with a legal obligation to which the Company is subject.
We will not erase your data if processing is necessary: (i) to comply with a legal obligation under European Union or Member State law; or (ii) to establish, exercise, or defend legal claims. Processing Restrictions
If you contest the accuracy of your Personal Data, you may ask us to restrict its processing. When processing is restricted, we will only store and use the data with your consent, to establish, exercise, or defend legal claims, to protect another individual’s rights, or for reasons of important public interest in the European Union or a Member State. Right to Data Portability
Where processing of your Personal Data is based on your consent or on a contract to which you are a party and is carried out by automated means, you have the right to receive your data in a structured, commonly used, and machine-readable format. You may also request transmission of that data directly to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure and must not adversely affect the rights and freedoms of others. Right to Object
You have the right to object at any time to the processing of your Personal Data when the processing is based on our legitimate interests or those of a third party, including profiling. If you object, we will no longer process the Personal Data unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
In relation to direct marketing, you have an absolute right to object to processing of Personal Data concerning you for marketing purposes at any time, free of charge and without providing any justification. Right to Withdraw Consent
You may withdraw your consent to our processing of your Personal Data at any time by contacting us via the details below. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Right to Lodge a Complaint
If you consider that our processing of your Personal Data infringes applicable data protection law, you have the right to lodge a complaint with a supervisory authority, particularly in the Member State of your habitual residence, place of work, or where the alleged infringement occurred. Applicable Law and Limitations
The laws of the European Union and Member States may limit your rights in relation to your Personal Data as described in this Section 13. We will respond to your valid request without undue delay and, in any event, within one month of receipt. That period may be extended by up to two further months if necessary, taking into account the complexity and number of requests. We will notify you of any extension within one month of receiving your request and explain the reasons for the delay. Fees
We will provide the requested information free of charge. However, where requests are manifestly unfounded, excessive, or repetitive, we may either charge a reasonable fee to cover administrative costs or refuse to comply with the request. Verification of Identity
If we have reasonable doubts concerning the identity of the person making a request, we may ask for additional information to confirm your identity before disclosing any Personal Data or taking any action.