We (also referred to as “we”, “us” or “our”) are committed to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the “Website”).
We commit to the following principles:

To ensure complete transparency in the collection and processing of your personal information:

We aim to empower you to make informed decisions about how your Personal Data is used and processed. To achieve this, our website offers clear guidance and comprehensive information on our data handling practices. If you require further details, we will provide them promptly at the appropriate time. We welcome any questions and are happy to clarify any legal limitations that may apply. You can reach us by email at the following address: info@blue-orion.com

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

Personal Data may be processed by us for a variety of purposes, including providing access to the website, connecting you with third-party trading platforms (the 'Services'), enhancing and securing the site, safeguarding our rights and interests, facilitating the maintenance and delivery of the Services, fulfilling regulatory or legal obligations, and performing administrative and business operations. Personal Data are also processed to gain deeper insights into your preferences and needs.

To access essential tools to safeguard your rights regarding Personal Data:

We want you to make informed choices about the use and processing of your Personal Data. That’s why we’ve developed this website: to provide comprehensive, accessible information on our data practices and policies. Through a range of methods and procedures, we strive to present the details that matter to you. If you require further specifics, we will share them with you in a timely and appropriate manner. We welcome any questions and will clarify legal limitations that may apply. Our goal is transparency: empowering you with the knowledge to manage and protect your information. You can reach us by email at info@blue-orion.com

Protect Your Personal Data:

Although we cannot guarantee the absolute security of your Personal Data, we will continue to employ a variety of methods and techniques to ensure it remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy outlines the types of personal data the Company collects from natural persons and how it processes, shares with third parties, and secures that data. It applies to information related to an identified or identifiable individual—a person who can be directly identified or whose identity can be determined using additional information we hold or access. The Policy defines “processing” as any operation involving the collection, use, management, organization, or storage of personal data. Our services are intended for general audiences and not for anyone under 18 years of age. We do not knowingly collect information from minors under 18 or permit them to use our services. If we become aware that we have collected data from a child, we will delete it promptly.

2. What personal data do we have about you?

When you access our services, channels, or visit our website, we collect your Personal Data. In some cases, we may ask you to provide it directly. In other instances, we collect your Personal Data by analysing your use of our services and channels or by receiving information from our third-party partners.

3. You are not required to disclose personal information to the company, nor are there any consequences for withholding it.

You are not obliged to provide us with any personal data. However, in certain circumstances, choosing not to supply personal data may hinder our ability to offer services or prevent users from accessing the website.

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

This includes information about your online activity log, traffic data (including IP address, date and time of access), language preference, software crash logs, browser type, and device details. This information is non-personal and cannot be used to identify you. Personal Data We receive from you: any personal data you voluntarily provide when connecting with a third-party online trading platform through us. Personal information you provide specifically to third-party platforms to facilitate trade: complete 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 and based on its applicable legal grounds.
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:

• You have provided consent to the processing of your personal data for one or more purposes. This applies when you submit personal information through the Website, so that we can transfer it to a third-party trading platform.
• The Company or a third party may need to process information to pursue their legitimate interests. For example, this may be required 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 we undertake to protect our legitimate interests.
Below is a list of the reasons and legal grounds on which we may use the personal data you provide.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data, including IP address information and user experience analytics, with third-party service providers such as hosting and storage partners.
You may request that we share specific Personal Data with third-party trading platforms. In such cases, we will transfer the information you provide to the requested platforms, and its use will be governed by their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to secure the resources necessary for enhancing and improving the products and services we offer.
If it becomes necessary to protect the rights or property of third parties, 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 company in connection with a transaction (including the transfer or sale of assets of the Company or any group company), or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any group entity.

ONLINE TRACKING NOTICE

Third-party services, such as ad providers or analytics companies, may be employed. 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 enhance the user experience, remember your settings, and tailor products and services to your interests. Cookies are also used for statistical and analytical purposes.
Some of the cookies we use are session cookies. These temporary files are downloaded to your device and are deleted when you close your browser. Other cookies are persistent, remaining on your device after you close your browser. They help the website recognize you as a returning user and streamline your subsequent visits.

7. Third-Party Cookies and Services

We may use them according to their purpose:

Cookies are blocked or removed
To block or remove cookies, adjust your browser's settings. You'll find links below to guide you through this process for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that some or all of the Website's features and functions may not operate as you expect if this occurs.

ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. Retention period for your personal data

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

9. Cross-border transfers of personal information to third countries or international organisations

Your personal information may be transferred to third countries (countries other than your country of residence) or to international organizations or jurisdictions. The Company takes all necessary measures to safeguard Personal Data you provide and ensures that you can assert your rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has determined provides adequate security for Personal Data transferred under Article 45(3) of Regulation (EU) 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 and enforceable agreement between public entities or authorities under Article 46(2)(a).
• The transfer was performed in accordance with the EU Commission’s standard data protection clauses adopted under Article 46(2)(c) of the GDPR. These clauses are available for review at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

We can provide information on the security measures we use to protect your Personal Data when it is transferred to third-party countries or international organisations. For more details, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented appropriate organizational and technical measures to safeguard Personal Data. These precautions help prevent accidental or unlawful destruction, loss, or modification of your information.
Despite these safeguards, we cannot guarantee or warrant that your Personal Data will remain completely secure or error-free. We are not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures due to transmission errors, unauthorized third-party access, or any other circumstances beyond our control.
In certain situations—such as legal obligations or other requirements beyond our control—we may be required to disclose your Personal Data to third parties, including public authorities. We cannot guarantee the security measures these third parties use to protect your information.
No method of transmitting Personal Data over the internet can be entirely secure. The Company cannot ensure the security of any Personal Data you transmit to us online.

11. Hyperlinks to third-party websites

Links to third-party sites and applications are provided on our website for your reference, but these services operate independently of the Company. We have no oversight of and assume no liability for how these third-party sites or apps collect, use or process Personal Data. Accordingly, this Policy does not govern their activities.
Before accessing or using any third-party website or application, we recommend that you carefully review its privacy policy. We also encourage you to manage and share any Personal Data directly with these external providers.

12. Revisions to this Policy

This Policy is subject to change at any time. Whenever we update this Policy, we will notify you by posting the revised version on our website and, where practicable, through other suitable channels. In addition, if we implement significant modifications, we will attempt to inform you using the methods we consider most appropriate and will publish an announcement on our site. Unless explicitly specified otherwise, all amendments take effect upon publication of the updated Policy.

Your Rights Regarding Your Personal Information

You have the right to ask us to confirm whether we are processing your Personal Data, correct any inaccuracies, and erase any Personal Data we no longer need. You may also restrict certain types of processing. If you are an EEA resident, please refer to this page:
These rights apply to the Personal Data you provide. To exercise any right, email us at the address below. Access rights
The Company can verify whether we are processing your Personal Data. If so, you may access it. We will provide an electronic copy of your data and may charge a reasonable fee for additional copies. Data will be delivered electronically upon request.
Your right of access must not infringe on the rights and freedoms of others. If fulfilling your request would harm another individual’s rights, we reserve the right to refuse or limit the request. Right to rectification
The Company will correct any inaccurate Personal Data. You may request the completion of incomplete data, taking into account the processing purpose. Right to erasure
You may request deletion of your Personal Data when: (a) it is no longer necessary for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests; (d) the data has been processed unlawfully; or (e) erasure is required by law. This right does not apply if processing is necessary: (a) to comply with a legal obligation under EU or Member State law; or (b) to establish, exercise, or defend legal claims.
Restriction of processing
If you question the accuracy of your Personal Data, you may request that we restrict its processing. Restricted data may only be retained with your consent, to establish or defend legal claims, to protect another individual’s rights, or for reasons of significant public interest in the EU or a Member State.
Right to data portability
When processing is automated and based on your consent or a contract, you have the right to receive the Personal Data you provided in a structured, commonly used, and machine-readable format. You may also request direct transfer of your data to another controller, where technically feasible. This right does not affect your right to erasure and must not infringe on others’ rights or freedoms.
Right to object
You may object at any time to processing of your Personal Data based on legitimate interests, including profiling. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, or for the establishment, exercise, or defense of legal claims.
Direct marketing
You have the right to object at any time to processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent for Personal Data processing at any time. This will not affect the lawfulness of processing carried out before your withdrawal.
You also have the right to lodge a complaint with your supervisory authority.
You may appeal to a supervisory authority established by an EU Member State to protect individuals’ rights regarding Personal Data processing.
EU and Member State laws may limit these rights as described in this section. We will respond to your request under Section 13 of this agreement within one month of receipt. We may extend this by up to two months, if necessary, based on the request’s complexity and number. We will inform you of any extension and reasons within one month of receiving your request.
Unless Section 13 provides otherwise, the information you request will be free of charge. If your request is unfounded or excessive—especially if repetitive—we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have doubts about the identity of the person making the request, the Company may ask for additional information.