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

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

By doing so, our goal is to help you make informed choices about the use and processing of Personal Data. To support this, our website uses several methods and procedures to provide relevant information about Personal Data usage. If you require specific details about your data, please let us know. We will work hard to ensure you receive 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 strictly for the purposes set out in this Policy

We process Personal Data for various 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, fully complying with legal and regulatory obligations, and carrying out administrative and business operations that enable delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Facilitating access to vital resources that protect and uphold your rights regarding Personal Data

Our goal is to help you make well‑informed decisions about how we handle your data. That is why we invested the time to develop this website. To support this, we use a range of methods and procedures to ensure you consistently receive the most relevant information about our use of your Personal Data. If you require specific details, we will provide them at the appropriate time. If you have any questions about how this process works, we are happy to answer and clarify, all within applicable legal requirements. To learn more, please reach us by email at: info@blue-orion.com

Keep Your Personal Information Private and Secure

While we cannot guarantee absolute security of Personal Data—no provider can—we remain fully committed to using multiple measures to protect your Personal Data. Our Privacy and Security Policy covers all essential areas to help ensure your long-term safety.

Scope?

By reviewing this Policy, you will find an overview of 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. Our Policy covers information about an identified or identifiable person, whom we can recognize directly or indirectly through additional information in our possession or data we can access. For the purposes of this Policy, “processing” means any operation involving the use or handling of Personal Data, including its management, organization, and storage. Our services are intended for a general audience but are not permitted for anyone under the age of 18. We do not authorize individuals under this age to use our services and do not knowingly collect information from them. If we become aware of any data collected about a person under 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 ask you to provide this information directly. Alternatively, we may analyze your interactions with our services or channels, or work with third-party partners, to collect this data

3. You are not required to provide your personal information to our company or manage any consequences of doing so

You are not required to share any personal data with us. However, in some cases, if you choose not to provide certain information, it may affect how we deliver our services, which could mean 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 personal information:

The Personal Data we collect includes details from your activity log, traffic data (including IP address and access date and time), the language used on our site, software crash reports, browser type, and device specifications. This collected data is non-personal, and we do not use it to identify you. Some of the Personal Data we obtain from you includes any personal information you voluntarily provide when you connect to a third-party online trading platform through us. We also collect the personal details you submit directly to these platforms, which may include your full name, email address, phone number, and 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 in accordance with applicable laws and regulatory standards.
An appropriate and valid legal basis is required; without such a basis, our Company cannot use your Personal Data in relation to you. 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 provide your 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 the information to pursue their legitimate interests. Examples include improving our Services or defending ourselves against legal claims that may arise.
• All processing on our website must comply with applicable laws and regulations, and we confirm that it fully adheres to those 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 have highlighted the reasons and legal bases for how we may use the personal information you have provided 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 data storage, IP address data hosting, or user experience analytics.
We also accommodate 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 choose. If you opt for this, 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. This enables us to access the resources needed to enhance and continually improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or other competent 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 its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy relating to the Company or other parties connected to the Company.

Online Tracking Notice

We may use third-party services on our website, such as advertising providers and analytics firms. These companies may also use cookies and similar technologies that collect data.
When we say cookies, we mean small text files 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 enhance the user experience, better understand what our users prefer, and design products and services aligned with customer interests. Cookies also help us gather information for statistics and analytics.
With some of the cookies we use, they 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 cookies allow the website to recognize you as a returning visitor and keep 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 intended purpose.

Cookies are blocked or have been removed
You can adjust your cookie preferences in your browser settings. Use the links below for assistance.

• 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 at present, our service does not recognise Do Not Track requests.
8. Learn More About How Your Personal Information Is Stored

Please note that Our Company retains your Personal Data for as long as necessary to fulfil the purposes outlined in this Policy, and may keep it longer as permitted by applicable laws and to comply with order-related requirements. 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.
We periodically review and assess the Personal Data we hold to ensure it is still required.

9. Transfers of Personal Data to Third Countries and International Organizations

In certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send your Personal Data to a country other than your own, or to provide it to international organizations. We take all necessary measures to protect and safeguard your Personal Data and ensure that you can exercise your rights and effectively access legal remedies if needed.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• In certain cases, we may transfer your Personal Data to a third country or an international organisation that the European Commission recognises as providing an adequate level of protection for Personal Data, in line 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 conduct these transfers in line with the European Commission’s Standard Contractual Clauses for data protection, established under GDPR Article 46(2)(c). To learn more, 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 security measures we implement 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 protect your Personal Data, we have implemented industry‑standard security measures. These measures aim to prevent accidental or unlawful destruction, loss, or alteration.
Even with these precautions, we cannot guarantee that your Personal Data will always be maintained without error, 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, unauthorized access by third parties, 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 measures those third parties provide.
Please note that transferring Personal Data over the internet cannot be made completely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of your 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 beyond our Company’s control. Accordingly, we do not accept responsibility for how these third-party websites collect or process your Personal Data. While our Policy applies to activities on our website, it does not extend to third-party websites.
Before visiting any third-party website or app, you should review their privacy policies before you start using their services. You should also carefully consider whether you want to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We may update this Policy at any time. If we make changes, we will notify you on our website and display the updated Policy. For significant updates, we will use the most appropriate channels, including a public announcement on our website. Unless stated otherwise, all amendments take effect immediately upon publication of the updated Policy.

Your Rights As They Relate to Your Personal Data

You have the right to request access to the Personal Data we hold about you, to have inaccuracies rectified, and to ask us to delete any Personal Data you no longer want us to process. You may also request that we restrict certain types of data processing. For those residing in the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us using the email address below. Right of access
We will verify the accuracy of the Personal Data processed. If accurate, we will provide you with access to your Personal Data and an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, we will provide this data electronically.
Your right of access must not infringe the rights of others. Where a request would do so, we may refuse to comply or limit our response. Your rights related to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Your right to erasure
Valid reasons may include: we no longer need the Personal Data for its original purpose; you withdraw consent and there is no other legal basis; you object to certain processing; the processing is unlawful; or erasure is required to meet a legal obligation. You cannot exercise this right where processing is necessary to comply with EU or Member State law or to establish, exercise, or defend legal claims. Processing restrictions
You may ask us to limit processing, for example if you believe the data is inaccurate. While restricted, the data may only be stored, processed with your consent, used to protect the rights of others or for the establishment or defence of legal claims, or processed for important public interests of an EU Member State or the EU. Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format.
You may also request that we transfer the data 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 our or third parties’ legitimate interests, including related profiling. We will stop unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or processing is required for the establishment, exercise or defence of legal claims.
You also have the right to 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 before withdrawal.
In addition, you have the right to lodge a complaint with the supervisory authority responsible for data protection.
You may also ask a supervisory authority in a Member State to protect your individual 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 provide the information requested under section 13 within one month of receiving your request, though we may extend this by up to two months depending on the complexity and number of requests. You will be notified within one month of any extension and the reasons.
We will provide information requested under section 13 free of charge unless a request is unfounded or excessive, especially 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 connection with a request, the Company may ask for additional information.