We (also referred to as 'We', 'Us', or 'Our') are fully committed to protecting your Personal Data and safeguarding your privacy.
Our Privacy Policy is designed to inform you, as a consumer, how we collect and store the information you provide on the Gaingate website (the 'Website').
We maintain and uphold the following principles:

To act in your best interests, we remain transparent about how we collect and use your personal information:

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 uses a range of methods and procedures to provide clear, relevant information about how Personal Data is used. If you need specific details about your data, we will work diligently to ensure you receive them promptly and at the appropriate time. If you have any questions, we are happy to explain anything related to legal requirements and our obligations. To get in touch, 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, provisioning and delivering the Services, ensuring full compliance with regulatory and legal requirements, and undertaking administrative and business activities necessary for the provision and use of the Services. We also process your Personal Data to help us better understand your preferences and needs.

Accessing essential resources as part of safeguarding your rights in relation to Personal Data

Our goal is to help you make well-informed decisions about how we handle your data, which is why we have invested time in developing this website. To support that aim, we apply a combination of policies, technical measures and operational procedures so that you continue to receive timely, relevant information about our use of your Personal Data. Where specific, detailed information is needed, whether by law or to address a particular request, we will provide it at the appropriate time. If you have questions about any part of this process, we are ready to respond, explain our approach and offer clarification, all within the bounds of applicable legal requirements. We welcome enquiries, feedback and requests for further details, and will do our best to provide clear, accessible responses. If you would like to learn more or speak to us directly, please contact us via email at: info@blue-orion.com

Keep Your Personal Data Secure and Protected

While no one can guarantee the absolute security of Personal Data, we remain fully committed to employing a range of measures to protect your Personal Data. Our Privacy and Security Policy addresses all key areas to support your long-term safety.

Scope?

In this Policy, you will find details of the types of Personal Data our Company collects from customers, together with how we process it, share it with third parties, and keep it secure. Our Policy concerns information about an identified or identifiable individual, where someone can be recognised directly or indirectly using information we hold or can access. For the purposes of this Policy, ‘processing’ means any operation involving the use or handling of Personal Data. This includes the management, organisation, and storage of Personal Data. Our services are intended for a general audience but are prohibited for anyone under the age of 18. We do not authorise individuals under this age to use our services and do not knowingly collect their information. Accordingly, we do not intentionally gather data from anyone under the age of 18, as they are not permitted to use our services. If we become aware of any data collection relating to persons under the age of 18, we will promptly delete it.

2. What personal information do we collect from you?

By using our services or channels, or by browsing our website, you agree that we may collect personal data about you. In some cases, we may also ask you to provide this information directly. Alternatively, we may analyse your interactions with our services or channels to gather this information, or obtain it from our third-party partners

3. You are not required to provide your personal information to our company or address any implications arising from it

You are not required to share any personal data with us. However, if you choose not to provide certain information, it may affect how we deliver our services, which could result in restricted access to parts of our website or limited use of certain features.

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

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

5. What Are Our Legal Bases and Justifications for Processing Personal Data

Our Company processes your personal data for the purposes outlined in this section and complies with the applicable legal framework.
We require a lawful basis; without one, our Company cannot process your personal data. The lawful bases 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 via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process this information to pursue their legitimate interests. This may include improving our Services or protecting ourselves against potential legal claims.
• All processing carried out on our website must comply with all applicable legal requirements, and we can confirm that it does so.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we outline the reasons and legal bases on which 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 that provide services such as storage and hosting, IP address data processing, or user experience analytics.
We also accept requests from individuals who want 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 designate. If you proceed, the use of that data will be governed by their privacy policies. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners or affiliates. We do this to access resources that help us enhance and improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or other official authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or purchasers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or insolvency proceedings involving the Company or related parties.

Online Tracking Notice

On our website, we may use third-party services, such as advertising providers and analytics companies. These providers may also use cookies and similar technologies to collect data.
By cookies, we mean small text files stored on your device when you visit or access our website. We use cookies to collect information about your preferences and browsing behaviour so we can improve the user experience, understand what our visitors value, and design products and services based on customer interests. Cookies also help us compile statistics and analytics.
Some of the cookies we use are session cookies. These are stored temporarily on your device and expire when you close your browser. Others are persistent cookies, which remain on your device 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 Use Cookies and Third-Party Services

Each cookie and its use may vary, depending on its intended purpose.

Cookies are blocked or have been removed
You can manage your cookie preferences in your browser settings. 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 operate as intended if this occurs.

Online Tracking Notice Please be aware that our service currently does not recognise Do Not Track requests.
8. Learn More About Storing Your Personal Information

Please be advised that Our Company will retain your Personal Data for as long as necessary to fulfil the purposes set out in this Policy, and we may keep it for a longer period where permitted by applicable law and in connection with relevant orders. Your information may, in certain circumstances, be shared with third-party trading platforms for up to 12 months, subject to appropriate safeguards. With your consent, we may extend this sharing for a further 12 months if required.
From time to time, we will review, assess, and update the Personal Data we hold to confirm whether it is still required.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send this data outside your home country, or to international organisations. We take all necessary measures to protect and safeguard your Personal Data and to ensure you can exercise your rights and effectively access legal remedies if you need them.
All residents of the EEA (European Economic Area) benefit from these protections and safeguards.

• In some cases, we may transfer your Personal Data to a third country or international organisation where the European Commission recognises that country as providing an adequate level of 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')
• When a transfer occurs, we carry it out under a legally binding and enforceable instrument between public authorities or bodies in accordance with Article 46(2)(a)
• We carry out the transfer in compliance with the European Commission’s Standard Contractual Clauses for data protection, pursuant to Article 46(2)(c) of the GDPR. For further information, 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 would like to learn more about these details and how they relate to the safeguards we apply to protect your Personal Data when it is transferred to third countries or international organisations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To safeguard your Personal Data, we have implemented robust security measures. These measures help prevent accidental or unlawful destruction, loss, or alteration.
However, despite taking extensive precautions, we cannot guarantee that your Personal Data will always be kept error-free and secure, nor can we be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, any disclosures caused by transmission errors, unauthorised access by third parties, or other events beyond our control.
Where we are legally required, or due to other constraints outside our control, we may need to share your Personal Data with third parties, such as public authorities. In such cases, we cannot oversee or guarantee the security measures those third parties apply.
Please note that transmitting Personal Data over the internet cannot be made completely secure and carries inherent risks. For this reason, we cannot guarantee the security of Personal Data you send to us online.

11. Details on Links to Third-Party Websites

Our website includes links to external websites and applications that are outside our company’s control. As such, we accept no responsibility for how these third-party websites collect or process your Personal Data. While our policy explains what happens on our website, it does not apply to any third-party websites or services you access via our links.
Before visiting any third-party website or app, please review its privacy policy before you start using its services. You should also carefully consider whether you wish to provide your Personal Data.

12. Understanding Amendments to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will notify you on our website and display the updated Policy. For significant changes, we will use the methods we consider most appropriate and will issue an announcement on our website. Unless stated otherwise, all amendments take effect immediately upon publication of the revised Policy.

Your rights in relation to your personal data

You have the right to request a review of the Personal Data we hold about you, to have it rectified, and to ask us to delete Personal Data in appropriate circumstances. You may also restrict the categories of data we process. For those residing in the EEA, please check this page:
Anyone wishing to exercise their data rights may contact us using the email address below.
Access rights
We will assess the accuracy of the Personal Data we process. Where appropriate, we will grant you access to your Personal Data and provide an electronic copy. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, this information will be supplied electronically.
Your right of access must not infringe the rights of others. If a request would adversely affect another person’s rights, we may refuse to comply or limit our response.
Rights related to rectification
If your Personal Data is inaccurate or incomplete, you may ask us to correct or complete it.
Right to erasure
Legitimate grounds include: (a) we no longer need the Personal Data for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing; (d) the processing is unlawful; or (e) erasure 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 law, or (b) to establish, exercise, or defend legal claims.
Restriction of processing
You may ask us to limit processing if you contest the accuracy of the data. While restricted, data may be stored and processed only with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another person, or for important reasons of public interest of the EU or a Member State.
Right to data portability
For automated processing based on your consent or a contract, you have the right to receive your Personal Data held by the Company and to obtain an electronic copy.
You also have the right to request that the data be transmitted to another controller where technically feasible. Exercising data portability 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 a third party’s legitimate interests, including related profiling. Unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is for legal claims, we will stop processing.
You have the right to object to processing for direct marketing at any time.
Right to withdraw consent
You may withdraw your consent to processing at any time without affecting the lawfulness of processing carried out before withdrawal.
You also have the right to lodge a complaint with the authority supervising your Personal Data rights.
You may request that a supervisory authority in a Member State protects your individual rights in relation to Personal Data processing within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State law. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request, and we may extend this by up to two months depending on the complexity and number of requests. You will be informed within one month of any extension and the reasons for it.
We will provide the information requested under section 13 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 decline to act.
If we have doubts about your identity in relation to a request, the Company may ask for additional information.