We (also referred to as 'we', 'us' or 'our') remain fully committed to protecting your Personal Data and safeguarding your privacy.
This Privacy Policy explains how we collect, use and store the information you provide as a user of the Gaingate website (the 'Website').
We adhere to the following principles:

We're committed to being transparent about how we collect and use your personal information in your best interests:

By doing so, our aim 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 provide them promptly and at the appropriate time. If you have any questions, we are happy to clarify anything related to legal constraints. To contact us, please email us at info@blue-orion.com

We will use Personal Data solely for the purposes set out in this Policy

We process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and provisioning the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities to support the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Accessing the essential resources you need to help safeguard your rights in relation to personal data

Our goal is to help you make well‑informed decisions about how we manage your data, and that objective is the reason we developed this website. To support this, we use a range of methods and procedures designed to ensure you continually receive the most relevant, up‑to‑date information about the use of your Personal Data. Where specific details are needed, we will provide clear, timely notices at the appropriate moment. If you have any questions about these practices or how the process works, we are more than happy to respond and offer any clarifications you require, always within our legal obligations. We review and refine our approach regularly so the guidance you see remains accurate and useful. If you would like to learn more or need assistance beyond what’s provided here, please get in touch with us by email at: info@blue-orion.com

Keep Your Personal Information Safe and Secure

Unfortunately, we cannot guarantee the absolute security of your Personal Data, as no one can, but we remain fully committed to employing a range of measures to protect your Personal Data. Our Privacy and Security Policy covers all essential bases to ensure your long-term safety.

Scope?

In this Policy, you will find an outline of the types of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and protect it. This Policy covers information about an identified or identifiable person, meaning data that allows us to recognise someone directly or indirectly when combined with other information we hold or can access. For the purposes of this Policy, 'processing' means any operation involving Personal Data, including its use, management, organisation, and storage. Our services are intended for general audiences but are prohibited for anyone under the age of 18, and we do not permit individuals under this age to use our services. Accordingly, we do not knowingly collect information from anyone under 18, as they are not allowed to use our services. If we become aware of any collection of data relating to a person under the age of 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

When you use our services or channels, or browse our website, you agree that we may collect personal information about you. In some cases, we may ask for your personal information directly. We may also collect it by analysing your interactions with our services or channels, or through our third-party partners

3. You are not required to provide your personal information to our company or deal with any related implications

You are not required to share personal information with us. However, in some circumstances, choosing not to provide this information may affect how we deliver our services to you and could result in limited access to our website or restricted use of certain features.

4. What Types of Personal Data Do We Collect? When you visit our website, we may gather the following personal information:

The Personal Data and usage information we collect include details from your activity log, traffic data (including IP address and the date and time of access), your chosen site language, software crash reports, browser type, and device specifications. This usage data is non-personal, and we do not use it to identify you. We also obtain Personal Data that you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we collect the personal details you submit directly to these platforms, including your full name, email address, phone number, and address.

5. What Are Our Legal Grounds and Justifications for Processing Personal Information

Our Company processes your personal data for the purposes outlined in this section and does so in line with the applicable legal framework.
We require this legal basis because, without it, 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 submit personal information through the Website for us to share with a third-party trading platform
• The Company or a third party may need to process your information to pursue their legitimate interests. This may include improving our Services or defending against potential legal claims.
• All processing carried out on our website must comply with legal requirements, and we confirm that it does.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we have outlined the reasons and legal bases for how 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 providing services such as data storage, IP address hosting, or user experience analytics.
We also accept requests from individuals 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 select. If you proceed, their privacy policies will govern its use. In these circumstances, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners or affiliated entities. This enables us 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 affiliated companies. This typically occurs in connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or insolvency proceedings involving the Company or other parties connected to the Company.

Online Tracking Notice

We may use third-party services on our website, such as advertising partners and analytics providers. These providers may also use cookies and other technologies that collect data.
When we refer to cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies to understand your preferences and browsing patterns, enhance the experience for our users, and develop products and services that reflect customer interests. In addition, cookies help us gather information for statistics and analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily stored 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 allow the website to recognise 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 how it is used, may vary depending on its purpose.

Cookies are blocked or have been removed
You can manage your cookie preferences through your browser settings. You can use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that certain website functions and features may not work as intended if this occurs.

Online Tracking Notice Please note that, at this time, our service does not recognise Do Not Track requests.
8. Learn More About How We Store Your Personal Information

Please note that our company will retain your Personal Data for as long as necessary to fulfil the purposes outlined in this Policy, or for a longer period as permitted by law and where required for applicable orders. Your information may, in some cases, be shared with third-party trading platforms for up to 12 months. With your consent, we may extend this sharing for a further 12 months if needed.
From time to time, we will review and assess the Personal Data we hold to ensure it is still required.

9. Transferring Personal Data to a Third Country or an International Organisation

In certain circumstances, we may transfer your Personal Data to other countries or to international organisations, with your permission. We take all necessary measures to safeguard your Personal Data and ensure you can exercise your rights and access effective legal remedies when needed.
These protections and safeguards apply to all residents of the EEA (European Economic Area).

• In some instances, 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 under 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 execute it under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a)
• We conduct these transfers in accordance with the European Commission's Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, you can review 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’d like to know more about the specifics and how they relate to the security measures we use to protect your Personal Data when it is transferred to third countries or international organisations, please email us at info@wealthwaydigital.uk

10. Personal Information Protection

To protect your Personal Data, we have implemented robust security measures. These measures are designed to prevent accidental or unlawful destruction, loss, or alteration.
Even so, while we take every reasonable precaution, we cannot guarantee that your Personal Data will be maintained without error, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures resulting from transmission errors, unauthorised access by third parties, or other causes 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 security measures those third parties implement.
Please note that transmitting Personal Data over the internet is not completely secure and carries inherent risks. As a result, we cannot guarantee the security of Personal Data you transmit to us online.

11. Links to Third-Party Websites

Our website includes links to external sites and applications that are outside our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. While our Policy applies to activity on our website, it does not extend to third-party websites.
Before visiting any third-party website or app via a link, you should review its privacy policy before using its services. You should also carefully consider whether you wish to provide your Personal Data.

12. Understanding Changes to Our Policy

We may update this Policy at any time. If we make changes, we will notify you via a notice on our website and make the updated Policy available for your review on the same page. For significant changes, we will use the methods we consider most appropriate to inform you, including email or an announcement on our website. Unless we state otherwise, all updates to this Policy take effect immediately upon publication of the revised Policy.

Your Rights as They Relate to Your Personal Data

You have the right to request access to the Personal Data we collect about you, to have inaccuracies corrected, and to ask us to delete Personal Data you do not wish us to retain. You may also request that we restrict certain types of processing. If you are located in the EEA, please refer to this page:
To exercise any of your data rights, please contact us at the email address below. Access rights
We will verify the accuracy of the Personal Data we process and, where appropriate, provide you with access, including an electronic copy of the data. We may charge a reasonable fee for additional copies. On request, we will supply the data electronically.
Your right of access must not adversely affect the rights and freedoms of others. Where a request would do so, we may refuse or restrict our response. Your rights related to rectification
If your Personal Data is inaccurate or incomplete, you may ask us to correct or update it. Your Right to Erasure
You may request deletion of your Personal Data where, for example: (a) it is no longer needed for the purpose collected; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing on specific grounds; (e) the Personal Data has been processed unlawfully; or (f) deletion is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with EU or Member State laws or (b) to establish, exercise, or defend legal claims.
Processing restrictions
You may ask us to restrict processing, for instance, while you contest the accuracy of the data. While restricted, we may store the data but will process it only with your consent, to protect the rights of another person, for the establishment, exercise or defence of legal claims, or for important public interest of a Member State or the EU.
Right to data portability
Where processing is automated and based on your consent or a contract, you have the right to receive the Personal Data you have provided to the Company.
You may also ask us to transmit this data to another controller where technically feasible. Exercising your data portability rights does not affect your right to erasure.
Right to object
You may object at any time to our processing of your Personal Data based on the Company’s or third parties’ legitimate interests, including related profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is needed to establish, exercise or defend legal claims.
You may object at any time to processing for direct marketing.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for data protection.
You may request assistance from a supervisory authority in any Member State to protect your 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 laws. We will respond to requests made under section 13 within one month of receipt; where necessary due to complexity or volume, we may extend this by a further two months and will notify you within one month with the reasons for any extension.
Information provided under section 13 will be supplied free of charge unless a request is manifestly unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have reasonable doubts about your identity in relation to a request, the Company may request additional information.