We (also referred to as “We”, “Us” or “Our”) are committed to safeguarding your personal data and privacy.
This Privacy Policy explains how we collect and store information you provide through the Gaingate website (the “Website”).
These principles will be upheld:

To ensure transparency in the collection and processing of your personal information:

We want you to be able to make informed choices regarding the use and processing of Personal Data. That's why we've created this website—to provide clear, relevant information about our Personal Data practices. To accomplish this, we employ a variety of methods and procedures that ensure you have the relevant information. If you require more specific details, we will supply them promptly. We welcome any questions you may have and will clarify any legal limitations. You can reach us by email at info@blue-orion.com

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

Personal Data may be processed by us for various purposes: providing the website to you and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, facilitating maintenance and delivery of the Services, meeting regulatory or legal obligations, and conducting administrative and business activities to support the Services. We also process Personal Data to better understand your preferences and needs.

Access essential tools to safeguard your rights regarding personal data:

We want you to make informed decisions about the use and processing of your Personal Data. To support this, we’ve created our website and use various methods and procedures to provide you with relevant information. Should you need further details, we will supply them at the appropriate time. We welcome any questions and will clarify any legal limitations that apply. You can reach us at info@blue-orion.com

Safeguard your Personal Data:

Although we cannot guarantee complete security for your Personal Data, we will continue to employ a variety of methods and techniques to ensure that it remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy describes the types of personal data the Company collects from natural persons and how it processes, shares with third parties, and secures that data. It applies to information related to identified or identifiable natural persons—individuals who can be directly identified or linked through additional information we hold or access. We define ‘processing’ as any operation involving personal data, including its use, collection, management, structuring, and storage. Our services are intended for general audiences and are not designed for anyone under 18. We do not knowingly collect information from persons under 18, nor do we permit them to use our services. If we discover any data about children, we will delete it as promptly as possible.

2. What Personal Data Do We Have About You?

When you access our services and channels or visit our 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 channels or through information provided by our third-party partners.

3. There is no obligation to disclose personal information to the company, nor are there any penalties.

You are not required to provide Us with any Personal Data. However, in certain circumstances, choosing not to supply Us with Personal Data may prevent Us from delivering the Services or limit users’ access to the website.

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

This includes your online activity logs; traffic data (including IP address, date and time of access); language settings; software crash logs; browser type; and device information. This information is not private and cannot be used to identify you. Personal Data We Receive from You: any personal data you voluntarily provide when connecting to a third-party online trading platform through Us. Personal information you provide specifically to third-party platforms to facilitate trade: your full name, 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 set out in this section, in accordance with the applicable legal basis.
Without such a basis, the Company cannot use any Personal Data relating to you. The legal grounds that enable the Company to 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 through the Website so that we may transfer it to a third-party trading platform.
• The Company or a third party may need to process data to meet their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
• Processing must comply with legal obligations.

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

6. Transfer of Personal Data to Third Parties

The Company may also share your Personal Data—such as IP address details and user experience analytics—with third-party service providers, including hosting and storage vendors.
You can request that we submit specific Personal Data to third-party trading platforms. In these cases, we will transfer the information you provide to us to those platforms, whose handling of your Personal Data is governed by their own privacy policies. Your data may be shared across multiple platforms.
The Company may also disclose Personal Data to affiliates or business partners to support the enhancement and improvement of our products and services.
When necessary to protect third-party rights or assets, the Company may share Personal Data with regulatory bodies or other official authorities.
Additionally, we may share your Personal Data with potential investors, buyers, or lenders—or with any member of our corporate group—in connection with a proposed or actual transaction (including the transfer or sale of Company assets), or as part of any merger, restructuring, consolidation, or bankruptcy proceeding involving the Company or any group entity.

ONLINE TRACKING NOTICE

We may engage third-party services, such as advertising or analytics providers, who may also employ cookies or similar technologies.
Cookies are small text files stored on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your user experience, remember your settings, and customise products and services you may enjoy. Cookies are also used for statistical and analytical purposes.
Some cookies are session cookies, which are temporarily downloaded to your device and deleted when you close your browser. Others are persistent cookies, which remain on your device for a period after you close your browser, enabling the website to recognise you as a returning user and restore your preferences.

7. Third-Party Cookies and Services

We may use them in accordance with their purpose:

Cookies are blocked or removed
To block or delete cookies, update your browser settings. Below you’ll find links to guides for several popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that if this happens, some or all of the Website’s functions and features may not work as expected.

ONLINE TRACKING NOTICE This service does not currently honour Do-Not-Track signals.
8. The retention of your personal data

The Company will retain your Personal Data for as long as needed to fulfil the purposes of processing your Personal Data described in this Policy, or for extended periods as permitted by applicable law, regulations, internal policies, or relevant orders. The Company will share your information with third-party trading platforms for an initial period of 12 months and, with your consent, will continue to do so for an additional 12 months.
The Company regularly reviews all retained Personal Data to ensure it is no longer required.

9. Transfers of personal information to a third party in country_name or to an international organisation

Your personal information may be transferred securely to other countries around the world, including to a third country (i.e. a country other than your country of residence), or disclosed to international organizations or jurisdictions, in full compliance with relevant data protection regulations. We implement all appropriate organizational, technical, and legal measures to safeguard the personal data you provide, ensuring you and other data subjects can assert your rights and access effective legal recourse under applicable laws.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).

• Transfer to a third-country_name country_name or to an international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it in accordance with Article 45(3) of Regulation 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 and enforceable agreement between public entities or authorities under Article 46(2)(a).
• The transfer was carried out in compliance with the EU Commission’s standard data protection clauses adopted 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.

The Company can provide information on the security measures it uses to safeguard your Personal Data when transferring it to third-party countries or international organisations. To request this information, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented robust organizational and technical safeguards to protect Personal Data. These measures help prevent accidental or unlawful destruction, loss, or alteration of your information.
However, we cannot guarantee error-free or uninterrupted security of your Personal Data, nor can we be liable for any indirect, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, any Personal Data disclosed due to transmission errors, unauthorized third-party access, or other circumstances beyond our control.
Should legal or other obligations beyond our control require it, we may need to disclose your Personal Data to third parties, including public authorities. We are unable to dictate the security measures they apply to your information.
Transmitting Personal Data over the internet can never be completely secure. The Company cannot guarantee the security of any Personal Data you transmit to us online.

11. Hyperlinks to Websites Owned by Third Parties

Our website includes links to third-party sites and applications. These sites and applications are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by these sites or apps. This Policy does not apply to actions you take on those sites or apps.
When you visit a third-party site or app, we recommend that you read its privacy policy before accessing or using it. We also recommend that you provide any Personal Data directly to them.

12. Updates to This Policy

This Policy may be revised at any time. If we update it, we will post the revised version on our website. For any significant modifications, we will use appropriate methods to notify you and publish an announcement on our website. Unless explicitly stated otherwise, amendments will become effective upon publication of the updated Policy.

Your Rights Regarding Your Personal Information

You have the right to request verification of the accuracy of any Personal Data we collect about you, correct any errors, and delete any Personal Data no longer required by us. You may also restrict the types of processing applied to your data. If you reside in the EEA, please refer to this page:
These rights apply to the Personal Data you provide. To exercise them, send an email to the address below. Access rights
We will confirm whether we are processing your Personal Data. If so, you may request access to it. We will provide an electronic copy of the data currently processed, and may charge a reasonable fee for additional copies. Upon request, data will be delivered electronically.
The right of access does not infringe the rights and freedoms of others. If fulfilling your request would adversely affect another’s rights, we may refuse or limit our response. Right to rectification
We will correct any inaccurate Personal Data. You may also request completion of any incomplete data, taking into account the purpose of processing. Right to erasure
You may request deletion of your Personal Data if: (a) it is no longer necessary for its original purpose; (b) you withdraw consent and we have no other legal basis to process; (c) you object to processing based on our legitimate interests or those of a third party; (d) the data has been unlawfully processed; or (e) deletion is required to comply with a legal obligation.
This right does not apply if processing is necessary (a) to comply with a legal requirement under EU or Member State law; or (b) to establish, exercise, or defend legal claims. Processing restrictions
If you contest the accuracy of your Personal Data, you may request that processing be limited. During this restriction, we may only retain your data with your consent, or to establish, exercise, or defend legal rights, protect another individual’s rights, or for a significant public interest in the EU or a Member State. Right to data portability
If processing is automated and based on your consent or a contract, you may request a copy of your Personal Data. You also have the right to ask us to transfer your data directly to another controller, where technically feasible. Exercising this right does not affect your rights under the right to erasure and must not infringe on others’ rights or freedoms. Right to object
You may object at any time to the processing of your Personal Data based on our or a third party’s legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, or processing is needed to establish, exercise, or defend legal claims.
For direct marketing, you have the right to object to any processing of your Personal Data for marketing purposes at any time. Right to withdraw consent
You may withdraw your consent to processing at any time. This will not affect the lawfulness of processing carried out before your withdrawal.
You also have the right to lodge a complaint with the relevant supervisory authority. You may appeal to a supervisory authority in your Member State responsible for safeguarding individuals’ fundamental rights in relation to Personal Data processing within the EU.
EU and Member State law may limit your rights regarding your Personal Data as described in this section. We will respond to your request under section 13 within one month of receipt. This period may be extended by two further months if necessary, depending on the request’s complexity and volume. We will notify you of any extension and its reasons within one month of receiving your request.
Unless prohibited by section 13, requested information will be provided free of charge. For manifestly unfounded or excessive requests, particularly repeat requests, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have doubts about the identity of the person making the request, we may ask for additional information.