We (also referred to as 'We', 'Us' or 'Our') are dedicated to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide via the Gaingate website (the 'Website').
We uphold the following principles:

Providing transparency about how we collect and process your personal information:

We want you to make informed decisions about how we use and process Personal Data. That’s why we’ve created this website, offering clear, relevant information through various methods and procedures. If you require specific details, we’ll provide them promptly at the appropriate time. We welcome your questions and will clarify any legal limitations. You can reach us via email at info@blue-orion.com

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

We may process Personal Data for various purposes, such as providing the website to you and connecting you with third-party trading platforms (the Services), enhancing the site, protecting our rights and interests, facilitating maintenance and provision of the Services, fulfilling legal or regulatory obligations, and conducting administrative and business activities to support the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.

Use essential tools to safeguard your rights regarding Personal Data:

We want you to be in a position to make informed decisions about how your Personal Data is used and processed. That is why we created our website. To support this, we employ various methods and procedures to provide you with relevant information on Personal Data use. If you require specific details, we will provide the information to you at the appropriate date and time. We are happy to answer any questions you may have and will provide any clarifications you need regarding legal limitations. You can reach us via email at the address below: info@blue-orion.com

Safeguard Your Personal Data:

Although we cannot guarantee absolute security for your Personal Data, we are dedicated to employing a variety of methods and techniques to ensure its protection. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the types of personal data the Company collects from individuals and how we process, secure, and share that information with third parties and other recipients. We may transfer data to authorised third-party processors and affiliates under strict confidentiality and security standards. It covers information relating to identified or identifiable natural persons. An identifiable person is someone who can be recognised directly or through additional data we hold or can access. We define “processing” as any operation involving personal data, including its collection, management, organisation, structuring, and storage. We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, or disclosure. Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly collect information from anyone under 18, nor do we knowingly allow minors to use our services. If we become aware of any personal data about children, we will erase it promptly.

2. What personal data do we hold about you?

When you access our services, channels, or website, we collect Personal Data. In some cases, we may ask you to provide this information directly. In other cases, we gather it by analysing how you use our Services and channels or by receiving data from our third-party partners.

3. There is no requirement to disclose personal information to the company; however, doing so may have consequences.

You are not obliged to provide us with any personal data. However, in certain circumstances, withholding personal data may prevent us from offering the Services or prevent users from accessing the website.

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

This includes your online activity log, traffic data (including IP address, date and time of access), language preferences, software crash logs, browser type and device information. This data is not private and cannot be used to identify you. Personal data we receive from you: any information you choose to 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 outlined in this section, in accordance with the relevant legal basis.
Without a valid legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company relies 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 we can forward it to a third-party trading platform.
• The Company or a third party may require processing to pursue their legitimate interests. For example, this processing is necessary to improve Our Services or to defend legal claims.
• Processing must comply with legal obligations.

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

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data, including IP addresses and user experience analyses, with third-party service providers such as hosting and storage companies.
You can also request that we transfer specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you provide with those platforms. Their use of your Personal Data is governed by their own privacy policies, and your data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners to secure the resources needed to enhance and improve the products and services it offers to customers.
If required to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders of the Company or any group entity in connection with a transaction (including the transfer or sale of assets) or as part of any merger, restructuring, consolidation, or bankruptcy.

ONLINE TRACKING NOTICE

Third-party services, such as those providing advertisements on our website or analytics companies, may be used. These providers may also use cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve the user experience, remember your settings and tailor products and services to your interests. Cookies are also used for statistical and analytical purposes.
Some cookies we use are session cookies. These are temporary cookies downloaded to your device and last only until you close your browser. Other cookies are persistent, remaining on your device for a set period after you close your browser. They help the website recognise you as a returning user and streamline your return visits.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To block or remove cookies, you’ll need to adjust your browser’s settings. Below are links to step-by-step instructions for some of the most widely used browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

ONLINE TRACKING NOTICE This service does not currently support do-not-track signals.
8. Retention of Your personal data

We will retain your Personal Data for as long as necessary to fulfill the processing purposes described in this Policy or longer if required by applicable laws, regulations, policies, or orders. We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for an additional 12 months.
We regularly review the Personal Data we hold to ensure it is no longer needed.

9. Transfers of personal information to third-party countries or international organisations

Your personal information may be transferred to other countries (i.e. a third country outside your country of residence) or to international organizations or jurisdictions. Company takes all necessary steps to safeguard the personal data you provide and ensure you can exercise your rights and access effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer of Personal Data to a third country or an international organisation that the EU Commission has determined provides an adequate level of protection, 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, 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 implements to safeguard your Personal Data when transferred to third-party countries or international organisations. Send an email to the following address: info@wealthwaydigital.uk

10. Safeguarding Personal Data

We have implemented suitable organisational and technical measures to protect Personal Data, including preventing accidental or unlawful destruction, loss or alteration.
However, we cannot guarantee that the security of your Personal Data will be error-free, nor can we accept liability for any indirect, incidental or consequential damages arising from its use or disclosure. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised third-party access or any other cause beyond our control.
If required by law or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. We cannot govern how these parties secure your data.
As no method of transmitting Personal Data online is completely secure, the Company cannot ensure the safety of Personal Data you transmit to us over the internet.

11. Hyperlinks to external websites owned by third parties

Links to third-party websites and applications on our site are offered for your convenience and are not managed by the Company. We do not control how these sites or apps collect or process your Personal Data, and this Policy does not govern their activities.
When you visit any third-party website or application, we recommend reading their privacy policy before accessing or using their services. You should provide any Personal Data directly to them.

12. Updates to this Policy

This Policy is subject to change at any time. If we update it, we will notify you of the changes by posting the revised Policy on our website. In addition, for significant modifications, we will inform you through the methods we consider most appropriate and publish a separate announcement on our website. Unless explicitly stated otherwise, any amendments will take effect upon publication of the updated Policy.

Your rights regarding your personal information

You have the right to ask us to verify the accuracy of any Personal Data we collect about you, to correct any inaccuracies, and to delete any Personal Data that is no longer necessary. You may also request restrictions on certain types of processing of your Personal Data. If you reside in the EEA, please refer to this page:
These rights apply to all Personal Data you have provided. When contacting us, please include sufficient details to identify yourself and specify the rights you wish to exercise. Send your request by email to the address below. Access rights
Our Company will confirm whether we are processing your Personal Data and provide you with a copy of any such data, including the categories of data processed, the purposes of processing, and any third-party recipients. Upon request, we will supply this information in a structured, commonly used electronic format. We may charge a reasonable fee for any additional copies beyond the first. We will deliver the data electronically if you prefer.
Your right of access does not override the rights and freedoms of others. If fulfilling your request would adversely affect those rights or involve the disclosure of confidential information about another individual, we may refuse or limit our response. Right to rectification
You have the right to have any inaccurate Personal Data we hold about you corrected without undue delay. You may also request that we complete or update any incomplete or outdated Personal Data, taking into account the purposes of processing and any relevant documentation you submit. Right to erasure
You may request the deletion of your Personal Data when one of the following applies: (a) the data is no longer necessary for the purposes for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on our or a third party’s legitimate interests and there are no overriding grounds to continue; (d) the Personal Data has been unlawfully processed; or (e) the data must be erased to comply with a legal obligation. This right does not apply if processing is necessary to comply with EU or Member State law, or to establish, exercise or defend legal claims. Processing restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict its processing while we verify the data. When processing is restricted, we will only store your Personal Data and process it (i) with your consent; (ii) to establish, exercise or defend legal claims; (iii) to protect the rights of another natural person; or (iv) for reasons of significant public interest in the EU or a Member State.
Right to data portability
If our processing is based on your consent or on a contract and carried out by automated means, you have the right to receive the Personal Data you provided in a structured, commonly used and machine-readable format. You may also request that we transmit this data directly to another controller, where technically feasible. Exercising your right to portability will not affect your right to erasure and will not infringe on the rights and freedoms of others.
Right to object
You have the right to object at any time to processing of your Personal Data based on our or a third party’s legitimate interests, including profiling. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, or processing is necessary for establishing, exercising or defending legal claims.
Right to object to direct marketing
You have the right to object at any time, free of charge and without providing any justification, to the processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent for our processing of your Personal Data at any time. Withdrawal will not affect the lawfulness of any processing carried out prior to withdrawal.
Complaints
You have the right to lodge a complaint with the supervisory authority in your jurisdiction. If you reside in an EU Member State, you may appeal to the authority responsible for safeguarding data protection rights within the EU. EU and Member State laws may limit these rights as described in Section 13 of this agreement. We will respond to your request under Section 13 within one month of receipt. If necessary, we may extend this period by up to two additional months, taking into account the complexity and number of requests. We will inform you of any extension and the reasons for it within one month of receiving your request.
Subject to Section 13, we will provide the requested information free of charge. However, if your request is manifestly unfounded or excessive—particularly if it is repetitive—we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have any doubts regarding the identity of the person making the request, we may ask for additional information.