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

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

Through these efforts, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website employs several methods and procedures to provide relevant information about how Personal Data is used. If you require specific details about your data, we will work diligently to deliver them promptly and at the appropriate time. Should you have any questions, we are happy to clarify any 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 this Policy

You will find that we process Personal Data for a wide range of purposes, including operating the website for you, connecting you with third-party trading platforms (the 'Services'), improving the site and user experience, protecting our rights and interests, supporting the ongoing maintenance and provision of the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities that enable the effective delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Accessing essential resources to better safeguard and enforce your rights concerning the collection and use of your Personal Data

Our goal is to help you make well‑informed choices about how we handle your personal data. That purpose guided the time and effort we invested in creating this website. We aim to be transparent, consistent, and responsible in every interaction. To support this, we use a range of methods and procedures—and we regularly review them—to ensure you continue receiving the most relevant, up‑to‑date information about how your Personal Data is used. When specific information is needed, we will provide it at the appropriate time and in the appropriate context. If you have any questions about how this process works, we are happy to answer them and offer clear explanations, all in line with applicable legal requirements. If you would like to learn more or require additional details, please contact us by email at: info@blue-orion.com

Keep Your Personal Data Safe and Secure

While absolute security of Personal Data cannot be guaranteed by anyone, we remain fully committed to employing a range of measures to protect your Personal Data. Our Privacy and Security Policy covers the most essential areas to help ensure your long-term safety.

Scope?

This Policy outlines the types of Personal Data our Company collects from customers and explains how we process, share with third parties, and safeguard that data. Our Policy covers information about an identified or identifiable individual, whom we can recognize directly or indirectly using additional information in our possession or accessible to us. Under this Policy, 'processing' refers to any operation performed on Personal Data, including its management, organization, and storage. Our services are intended for general audiences but are prohibited for anyone under 18. We do not authorize individuals under this age to use our services and do not knowingly collect their information. If we become aware that we have collected data from a person under 18, we will promptly delete it.

2. What personal data do we collect from you?

By using our services, their channels, or browsing our website, you acknowledge that we may collect personal data about you. In some instances, we may ask you to provide personal data directly. We may also collect this information by analyzing how you interact with our services or channels, or via our third-party partners

3. You are under no obligation to submit your personal information to our company or address any implications that may arise

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

4. What Personal Data Do We Collect? When you visit our website, we may collect the following personal data:

The Personal Data we collect includes information such as activity log details, traffic data (including IP address and access date and time), your language preferences on our site, software crash reports, browser type, and device specifications. The data described above is non-identifying, and we do not use it to identify you. We may also obtain Personal Data from you—namely, any personal information you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we 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 the Legal Bases and Justifications for Our Processing of Personal Data

Our Company processes your personal data for the purposes outlined in this section and in accordance with the applicable legal framework.
We require a legal basis, as without one our Company cannot process your Personal Data. 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 submit personal information through the Website so we can share it with a third-party trading platform
• The Company or a third party may need to process information to pursue their legitimate interests. Examples include enhancing our Services or defending against potential legal claims.
• All processing on our website is required to comply with applicable legal requirements, and we can confirm that it fully complies with those obligations.

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 purposes 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

Under certain circumstances, the Company may disclose Personal Data to third parties that provide services such as storage, hosting of IP address data, or user experience analytics.
We also honor 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 designate. If you choose to proceed, their privacy policies will govern its use. 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 the resources needed to enhance and continually improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or other 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 involving the Company or related parties.

Online Tracking Notice

You may encounter third-party services on our website, such as advertising providers and analytics companies. These partners may also use cookies and similar technologies that collect data.
When we refer to cookies, we mean small text files stored on your device each time you visit or access our website. We use cookies to gather information about your preferences and browsing behavior with the aim of improving the user experience, understanding your interests, and shaping products and services around customer needs. Cookies also help us compile statistics and conduct analytics.
With some of the cookies we use, they are session cookies. Session cookies are temporarily placed on your device and expire when you close your browser. Other cookies are persistent, meaning they remain on your device even after you close your browser. These cookies allow the website to recognize you as a returning visitor and retain the preferences you previously set.

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

Each cookie may differ in purpose and use, depending on how it is applied.

Cookies are blocked or have been removed
You can manage your cookie settings in your browser options. You can use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some of the website's functions and features may not operate as intended 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 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, or for a longer period as permitted by applicable law and for orders where applicable. Your information may, in certain cases, 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. Transfer of Personal Data to Third Countries or International Organizations

Under certain circumstances, we may transfer your Personal Data to other countries or international organizations, which means we have your permission to send this Personal Data outside your country. We take all necessary measures to protect and safeguard your Personal Data and ensure that you can exercise your rights while effectively accessing 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 international organisation that the European Commission recognises 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 agreement between public bodies or authorities per Article 46(2)(a)
• We carry out the transfer in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, see the approved 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 implement to safeguard your Personal Data when it is transferred to third countries or international organizations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented appropriate technical and organisational security measures. These help prevent accidental or unlawful destruction, loss, or alteration.
Even so, despite taking extensive 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, 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 beyond our control, we may need to share your Personal Data with third parties, such as public authorities. In such cases, we cannot control or ensure the security measures those third parties apply.
Please note that transferring Personal Data over the internet cannot be made completely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of any Personal Data you transmit to us online.

11. About Links to Third-Party Websites

Our website may contain links to external sites and applications that are outside our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. Our Policy covers activities on our website only and does not extend to third-party websites.
Before visiting any third-party website or app via a link, you should review its privacy policy before using its 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 on our website and display the updated Policy. For material updates to this Policy, we will use the methods we deem most appropriate and will issue a notice through an announcement on our website. Unless we state otherwise, all amendments to this Policy take effect immediately upon publication of the updated Policy.

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 where appropriate. You also have the right to restrict certain types of data processing. For residents of the EEA, please refer to this page:
Anyone who wishes 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. Where appropriate, we will provide you with access to your Personal Data, including an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies. Upon request, we will provide this data electronically.
Your right of access must not infringe the rights and freedoms of others. If a request would adversely affect others’ rights, we may refuse to comply or limit our response. Right to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it. Your right to erasure
Legitimate grounds may 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 on specific grounds; (d) the Personal Data has been processed unlawfully; or (e) erasure is required to comply with a legal obligation. You cannot exercise this right if processing is necessary (a) to comply with EU or Member State laws or (b) to establish, exercise, or defend legal claims. Processing restrictions
You may ask us to limit processing if you believe the data is inaccurate, among other reasons. While restricted, we may store the data but process it only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another person, or for important reasons of public interest in the EU or a Member State. Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive the Personal Data you have provided to the Company. You may also request that we transfer this 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 the Company’s or a third party’s legitimate interests, including related profiling. We will stop processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is needed for the establishment, exercise, or defense 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. You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data protection. You may also seek protection of your rights from a supervisory authority in any Member State regarding the processing of Personal Data within the EU. As outlined in this section 13, your rights related to Personal Data 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 where necessary due to the complexity or number of requests. You will be notified within one month of any extension and the reasons.
Information requested under section 13 will be provided free of charge unless we consider the request unfounded or excessive, particularly if repetitive; in such cases, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have reasonable doubts about your identity in connection with a request, the Company may request additional information.