We (also referred to as "We", "Us" or "Our") are firmly committed to safeguarding your Personal Data and respecting your privacy.
This Privacy Policy is designed to explain the methods by which we collect, use and store the information you submit via the Gaingate website (the 'Website').
These principles are strictly upheld:

To be transparent about how we collect and process your personal information:

We want you to make informed choices about the use and processing of Personal Data. This website has been created to provide clear, relevant information on our Personal Data practices. We use various methods and procedures to ensure you see all pertinent details. If you require specific information, we will supply it at the appropriate time. We are happy to answer any questions and 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.

Personal Data may be processed for various purposes, such as providing you with access to our website and connecting you with third-party trading platforms (the “Services”); enhancing and maintaining the site; protecting our rights and interests; fulfilling any regulatory or legal obligations; and conducting the administrative and business activities required to deliver and support the Services. Personal Data is also processed to help us better understand your preferences and needs.

Access a suite of essential tools to safeguard your Personal Data rights:

We aim to empower you to make informed decisions about how your Personal Data is collected, used, and processed. To support this, we created this website to present clear, relevant information on our data practices, which we continually review and update. This approach ensures you stay informed about how we handle your data at every stage. We employ a range of methods and procedures to ensure you receive the guidance you need. If you require specific details, we will provide them at the appropriate time. We welcome any questions you may have and are happy to clarify any legal limitations. You can reach us by email at: info@blue-orion.com

Protect Your Personal Data:

Although we cannot guarantee absolute security of your Personal Data, we will continue to employ a range of methods and techniques to safeguard it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the categories of Personal Data that the Company collects from natural persons and explains how we process, share, and secure that information. It covers data related to identified or identifiable individuals—those who can be directly identified or recognized through additional information in our possession. We define ‘processing’ as any operation involving Personal Data, including its collection, organization, structuring, and storage. Our services are designed for a general audience and are not intended for use by anyone under the age of 18. We do not knowingly collect information from minors and do not permit them to use our services. If we become aware that we have inadvertently gathered data about a child, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access any of our services or channels, or visit our website, we collect your Personal Data. In specific cases, we may request your Personal Data; otherwise, we gather it by analysing your use of our services or channels, or by receiving data from our collaborating third-party partners.

3. There is no obligation to disclose personal information to the company, nor are there any adverse consequences.

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

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

This includes your online activity log, traffic data (including your IP address, date and time of access), chosen language, software crash logs, browser type, and device information. This data is not private and cannot identify you. Personal Data We receive from you: any personal information you choose to provide when connecting with a third-party online trading platform through Us. Personal information you provide specifically to third-party platforms to facilitate trading includes 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 and in accordance with the applicable legal grounds.
Without a valid legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company may process your Personal Data are:

• You have consented to the processing of your personal data for one or more purposes. This occurs when you submit personal information via the Website, enabling us to transfer it to a third-party trading platform.
• The Company or a third party may need to process data to pursue legitimate interests, such as enhancing Our Services or defending legal claims.
• Processing must comply with legal obligations.

Contact us by email for more details on the processing required to safeguard our legitimate interests.
Below is a list of the reasons and legal grounds on which we may use the personal data you provide. Personal Data.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers—such as hosting, storage and infrastructure vendors—to support our operations. This may include IP address information and analyses of user interactions and experiences, which help us monitor performance, detect issues and optimise service delivery.
Upon your request, we can transmit specific Personal Data about you to third-party trading platforms. In such cases, we will forward the data you have provided to Us to the designated platforms. Please note that these platforms will handle your information in accordance with their own privacy policies, and your data may be shared across multiple trading services.
The Company may also share Personal Data with our affiliates, subsidiaries, or business partners. Doing so enables us to obtain the necessary resources and expertise to develop, enhance and maintain the products, services and features we offer to our customers.
Where disclosure is necessary to safeguard the rights, property or safety of third parties or in compliance with legal obligations, the Company is authorised to provide Personal Data to regulatory bodies, law enforcement, courts or other official authorities.
Furthermore, we may share Personal Data about you with potential investors, acquirers or financiers (including those within our corporate group) in connection with a proposed or actual sale, merger, restructuring, consolidation, transfer of assets, financing arrangement or insolvency event involving the Company or any group entity.

ONLINE TRACKING NOTICE

Third-party services, such as those providing advertisements on our website or analytics companies, may be used. These providers may also employ 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 preferences and tailor products and services you might enjoy. Cookies are also used for statistical and analytical purposes.
Certain cookies we use are session cookies, which are temporarily downloaded to your device and last only until you close your browser. Other cookies are persistent: they remain on your device after you close your browser. They help the website recognise you as a returning user and enable you to return to the website.

7. Cookies and services provided by third parties

We may use them in accordance with their intended purpose:

Cookies are currently blocked or removed
To block or remove cookies, you need to update your browser settings. Below are links to guides for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, be aware that some or all of the Website's features and functions may not work as you expect if this occurs.

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

The Company retains Personal Data about you for as long as necessary to fulfil the purposes of processing outlined in this Policy, or for longer periods where required by law, regulation, policy or applicable orders. We’ll share your information with third-party trading platforms for 12 months, extending it for a further 12 months if you consent.
We regularly review Personal Data we hold to ensure it is no longer needed.

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

Your personal information may be transferred to other countries (for example, to a third country or to international organisations and jurisdictions). The Company takes all necessary steps to safeguard the Personal Data you provide and ensure 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 confirmed provides adequate safeguards 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')
• 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 carried out in accordance 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 details of the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. To request this information please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented robust organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss or alteration of your information.
However, we cannot guarantee error-free security of your Personal Data, nor accept liability for any indirect, incidental or consequential damages resulting from its use or disclosure. This includes, but is not limited to, data exposure due to transmission errors, unauthorised third-party access or any cause beyond our control.
Should legal or regulatory requirements compel us to disclose your Personal Data to third parties—such as public authorities—we cannot be responsible for how they secure that information.
As no method of internet transmission is entirely secure, the Company cannot guarantee the safety of Personal Data you send to us online.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided for your convenience. These platforms operate independently of the Company, so we are not responsible for how they collect or process Personal Data. This Policy does not apply to any activities conducted on these sites or apps.
Before accessing or using any third-party website or application, we recommend reviewing its privacy policy and carefully considering the Personal Data you choose to share with them.

12. Updates to this Policy

This Policy may be revised at any time at our discretion. If we make any changes, we will notify you by posting the updated Policy on our website. In addition, for significant revisions, we will inform you through the methods we deem most appropriate and publish an announcement on our website. Unless explicitly stated otherwise, any amendments will take effect upon publication of the revised Policy.

Your rights regarding your personal information

You have the right to request that we verify the accuracy of Personal Data we hold about you, correct any errors and delete any unnecessary Personal Data. You may also restrict certain types of processing of your personal information. If you are an EEA resident, please refer to this page:
These rights apply to the Personal Data you provide. To exercise them, please email us at the address below. Access rights
The Company will confirm whether Personal Data about you is being processed. If so, you may access that Personal Data. We will provide an electronic copy of the Personal Data currently processed and may charge a reasonable fee for any additional copies. The data will be supplied electronically upon request.
Your right to access Personal Data must not override the rights and freedoms of others. If fulfilling your request would adversely affect another individual’s rights, the Company may refuse the request or limit its scope Right to rectification
You may request the correction of inaccurate Personal Data concerning you, and we will update any incomplete information, taking into account the purposes of processing Right to erasure
You may request the deletion of your Personal Data where: (a) it is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, to processing based on legitimate interests; (d) the data has been unlawfully processed; or (e) it must be erased to comply with a legal obligation. This right does not apply if processing is necessary to comply with a legal obligation under 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 processing is restricted, we may only retain your data with your consent, for legal claims, to protect another person’s rights, or for substantial public interest within the EU or a Member State Right to data portability
Where processing is carried out by automated means and based on your 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 your Personal Data directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure and must not infringe on the rights or freedoms of others Right to object
You may object at any time to the processing of your Personal Data based on our or a third party’s legitimate interests, including profiling based on those interests. Unless we can demonstrate compelling legitimate grounds that override your interests, rights or freedoms, or for the establishment, exercise or defence of legal claims, we will cease processing.
For direct marketing, you have the right to object at any time to the processing of your Personal Data for such purposes Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out before your withdrawal You also have the right to lodge a complaint with the supervisory authority in your jurisdiction.
You may appeal to a supervisory authority designated by an EU Member State to safeguard individuals’ rights in relation to the processing of Personal Data.
EU and Member State law may further limit these rights as detailed in section 13. We will respond to your request under section 13 within one month of receipt. This period may be extended by up to two months, depending on the complexity and number of requests. We will inform you of any extension and the reasons within one month of your request.
Where not prohibited by section 13, the information provided under your rights will be free of charge. 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 doubts concerning the identity of the person making the request, the Company may request additional information.