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 about how we collect and store the information you provide on the Gaingate website (the 'Website').
We adhere to the following principles:

We are committed to being transparent about how we collect and use your personal data in your best interests:

By doing so, our goal is to help you make informed decisions about the use and processing of personal data. To support this, we use several tools and procedures on our website to provide relevant information about personal data usage. If you require specific details about your data, we will strive to deliver them promptly and at the appropriate time. If you have any questions, we are happy to clarify any applicable 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 the Policy

We process Personal Data for a range of purposes, including providing and operating the website, facilitating access to third-party trading platforms (the 'Services'), improving the site, safeguarding our rights and interests, carrying out the ongoing maintenance and provision of the Services, ensuring full compliance with legal and regulatory requirements, and performing administrative and business operations that support the delivery and use of the Services by users. We also process your Personal Data to help us better understand your preferences and needs.

Securing access to vital resources as a means of protecting your Personal Data rights

Our goal is to help you make well-informed choices about how we manage your data, and to be transparent about our practices. That objective explains why we invested time and care in developing this website. To support it, we use a range of methods and procedures, and we regularly review and update them, to ensure you consistently receive the most relevant information about our use of your Personal Data. When specific details are necessary for a decision or action, we will provide them to you at the appropriate time. If you have any questions about how this process works, we are happy to answer and offer clear explanations for you, always within the bounds of applicable legal requirements. If you would like to learn more or need assistance, please contact us by email at: info@blue-orion.com

Ensure Your Personal Data Stays Safe and Secure

While no one can guarantee the absolute security of Personal Data, we remain fully committed to protecting your Personal Data through a range of robust safeguards. Our Privacy and Security Policy addresses the most critical areas to help ensure your long-term safety.

Scope?

This Policy outlines the types of Personal Data our Company collects from customers, as well as how we process it, share it with third parties, and keep it secure. It applies to information about an identified or identifiable individual, whom we can recognize directly or indirectly using additional information we hold or can access. In this Policy, ‘processing’ means any operation performed on Personal Data. This includes, for example, the management, organization, and storage of such data. Our services are intended for a general audience, but they are not available to anyone under the age of 18. We do not authorize individuals under this age to use our services. Accordingly, we do not knowingly collect information from anyone under 18, as they are not permitted to use our services. If we become aware that we have collected data about a person under the age of 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

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

3. You are not required to provide your personal data to our company or address any associated implications

You are not required to share any personal data with us. However, in some situations, choosing not to provide this information may affect how we deliver our services, which 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 collect the following categories of personal information:

The data we collect includes information such as entries from your activity log, traffic data (including IP address, access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This technical data is non-personal and is not used to identify you. We may also obtain Personal Data you voluntarily provide when connecting to a third-party online trading platform through us. In addition, we receive the personal details you submit directly to these platforms, which may include 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 set out in this section and does so in accordance with applicable data protection laws.
We require a valid legal basis; without such a basis, our Company cannot lawfully process your personal data. The legal grounds that authorize 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 this information when necessary to pursue legitimate interests. For example, this may include enhancing our Services or protecting ourselves against potential legal claims.
• All processing on our website must comply with applicable legal requirements, and we confirm that it meets these requirements.

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 for how we 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, IP address data hosting, 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 choose this option, their privacy policies will govern how your data is used. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners or affiliated entities. We do this to access resources that help us enhance and improve our customer offerings.
Where appropriate, the Company may disclose Personal Data to regulatory, local, or official authorities to protect the rights or property of others.
We may also share your Personal Data with interested investors or buyers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy involving the Company or other parties connected to the Company.

Online Tracking Notice

You may encounter third-party services on our website, including advertising providers and analytics firms. These companies may also use cookies and similar technologies to collect data in connection with your use of the site.
When we refer to cookies, we mean small text files that are stored on your device each time you visit or access our website. We use cookies to learn about your preferences and browsing patterns so we can improve the experience for our users, better understand what our visitors value, and design products and services that reflect customer interests. Cookies also help us measure site performance, compile statistics, and conduct analytics that inform how we develop and enhance our services.
Some of the cookies we use are session cookies. Session cookies are temporarily downloaded to your device and expire as soon as you close your browser. Others are persistent cookies, which remain on your device even after the browser is closed. These cookies enable the website to recognize you as a returning visitor, remember settings such as language or display preferences, and keep the choices you previously set.

7. How We May Use Cookies and Third-Party Services

Each cookie and its usage can vary, depending on its intended purpose.

Cookies are blocked or have been removed
You can manage your cookie preferences in your browser settings. You can use the links below for guidance.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

Online Tracking Notice Please note that our service currently 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 fulfill the purposes outlined in this Policy, and we may keep it for a longer period as permitted by law and where required by applicable orders. In some cases, your information may be shared with third-party trading platforms for up to 12 months. With your consent, we may extend this sharing for an additional 12 months, if needed.
From time to time, we will review and assess the Personal Data we hold to determine whether it is still required.

9. Transfers of Personal Data to Third Countries or International Organisations

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

• In certain cases, we may transfer your Personal Data to a third country or an international organisation that the European Commission has recognised 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 the transfer occurs, we carry it out under a legally binding and enforceable agreement between public entities or authorities, in compliance with Article 46(2)(a)
• We transfer data in accordance with the European Commission’s Standard Contractual Clauses for data protection, set out under Article 46(2)(c) of the GDPR. To learn more, you can review the 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 more information about these details and how they relate to the security measures we apply to protect your Personal Data when transferred to third countries or international organizations, please contact us at info@wealthwaydigital.uk

10. Protection of Personal Data

To safeguard your Personal Data, we have implemented appropriate technical and organizational measures. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
Even with extensive precautions, we cannot guarantee that your Personal Data will always be maintained without error, and we are not liable for intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by transmission errors, unauthorized third-party access, or other events 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 safeguards those third parties implement.
Please note that transferring Personal Data over the internet cannot be made entirely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website includes links to external sites and applications that are outside our Company's control. Accordingly, we assume no responsibility for how these third-party websites collect or process your Personal Data. Our Policy, while it explains what happens on our website, does not cover what happens on third-party websites.
Before visiting any third-party website or app, review their privacy policies prior to using their services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will notify you via a notice posted on our website and provide access to the updated Policy document. For more substantial revisions, we will communicate through the channels we consider most appropriate, and we will also publish a clear announcement on our website. Unless we indicate otherwise, all updates to this Policy will take effect immediately upon the release and publication of the revised version.

Your Rights in Relation to Your Personal Data

You have the right to request access to the personal data we collect about you, to have it rectified, and to ask us to delete Personal Data in certain circumstances. You may also request that we restrict certain types of processing. For those residing in the EEA, please check out this page:
Anyone who wishes to exercise their data rights may contact us using the email address below. Access rights
You have the right to obtain confirmation of whether we process your Personal Data and to access it, including receiving an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies. When requested, we will provide this data electronically.
Your right of access must not adversely affect the rights and freedoms of others. Where a request would infringe the rights of others, we may refuse to comply or limit our response. Your rights related to rectification
If you wish to correct inaccurate Personal Data, you may request that we rectify it and complete any incomplete information. Your Right to Erasure
Legitimate grounds for erasure may include: (a) we no longer need the Personal Data for the purposes for which it was collected; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object to processing for specific reasons and there are no overriding legitimate grounds; (e) unlawful processing of Personal Data; or (f) compliance 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.
Processing restrictions
You may ask us to restrict processing, for example if you believe the data is inaccurate. While processing is restricted, we may store the data but may process it only with your consent, for the establishment, exercise or defence of legal claims, to protect another person’s rights, or for important public interest of the EU or a Member State.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive your Personal Data in a structured, commonly used, machine‑readable format.
You also have the right to request the transfer of your data to another controller where technically feasible. Exercising your 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 legitimate interests pursued by the Company or third parties, including related profiling. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is required for the establishment, exercise or defence of legal claims.
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 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 that a supervisory authority in a Member State protect your individual rights concerning Personal Data processing within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. 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 notified within one month if any extension is applied 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 refuse to act.
If we have reasonable doubts about your identity in connection with a request, the Company may ask for additional information.