We (also referred to as 'We', 'Us', or 'Our') are fully committed to safeguarding your Personal Data and protecting your privacy.
Our Privacy Policy explains how we collect, use, 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 use 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 various methods and procedures to provide relevant information on Personal Data usage. If you require specific details about your data, we will work diligently to provide 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 process Personal Data solely for the purposes outlined in this Policy

You will find that we process Personal Data for several purposes, including providing the website, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business operations to support the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Accessing essential resources to protect your rights regarding Personal Data

Our goal is to help you make well-informed decisions about how we handle your data. That purpose guided the time we invested in creating this website. To support this, we use a range of methods and procedures to ensure you continue receiving the most relevant information about the use of your Personal Data. If you need specific details, we will provide them at the appropriate time. If you have any questions about how this process works, we are more than willing to respond and offer clarifications, all within applicable legal requirements. To learn more, reach us via email at: info@blue-orion.com

Keep Your Personal Information Secure and Protected

Unfortunately, we cannot guarantee the absolute security of Personal Data—no one can—but we remain fully committed to using a wide 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?

In this Policy, you will find an overview of the types of Personal Data our Company collects from our customers, as well as the ways we process it, share it with third parties, and protect it. This Policy covers information about an identified or identifiable individual, whom we can recognize directly or indirectly using additional information in our possession or data we can access. For the purposes of this Policy, “processing” refers to any operation performed on Personal Data, including its collection, management, organization, and storage. Our services are intended for a general audience and are not available to anyone under 18. Accordingly, we do not authorize individuals under this age to use our services. In line with this, we do not knowingly collect information from anyone under 18, as they are not permitted to use our services. If we become aware that we have collected data relating to a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

For anyone who uses our services, channels, or browses our website, you acknowledge that we may collect personal data about you. In some cases, we may ask you for this information directly. We may also collect it by analyzing your interactions with our services or channels, or through our third-party partners

3. You are not required to provide your personal information to our company or accept 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 this personal data, it may affect how we deliver our services to you, which could result in limited access to our website or restricted use of certain features.

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

The data we collect includes details from your activity log, traffic data (including IP address, access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This information is non-personal, and we do not use it to identify you. Some of the Personal Data we obtain from you includes personal information you voluntarily provide when you connect to a third-party online trading platform through us. We may also receive personal details you provide directly to those platforms, such as your full name, email address, phone number, and address.

5. What Are Our Lawful Bases and Justifications for Processing Personal Data

Our Company processes your Personal Data for the purposes outlined in this section and in accordance with the applicable legal framework.
We rely on lawful bases because, without them, our Company cannot process your Personal Data. The legal bases under which our Company processes 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 for us to share with a third-party trading platform
• The Company or a third party may need to process information when necessary to pursue legitimate interests. Examples include improving our Services or defending against potential litigation.
• All processing on our website is required to comply with all applicable laws and regulations, and we confirm that it does.

If you would like more information on how we process Personal Data to protect our legitimate interests, please contact us by email at your convenience.
Below, we provide a detailed overview of the reasons and legal bases explaining when and how we use the personal information you provide to us. Personal Data

6. How We Share Your Personal Information with Third Parties

Depending on the circumstances, the Company may disclose Personal Data to third parties that provide services such as data storage, IP address hosting, or user experience analytics.
We also accept requests from users who want 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 proceed, 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 also share Personal Data with its business partners or affiliated entities. This allows us to access resources that help enhance and continuously 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 affiliated companies. This typically occurs in the context of transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or related parties.

Online Tracking Notice

We use third-party services on our website, such as advertising partners and analytics providers. These companies may also use cookies and similar technologies that collect information.
When we refer to cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies to learn about your preferences and browsing behavior so we can improve your experience, understand what our users value, and design products and services aligned with customer interests. Cookies also help us gather data for statistics and analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily stored on your device and expire once you close your browser. Other cookies are persistent, meaning they remain on your device even after you close your browser. These 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 and its use may vary, depending on its intended purpose.

Cookies are blocked or have been removed
You can manage your cookie settings in your browser preferences. You can also use the links below for step-by-step guidance.

• 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 this time, our service does not recognize Do Not Track requests.
8. Learn More About How Your Personal Information Is Stored

Please note that Our Company will retain your Personal Data for as long as needed to fulfill the purposes outlined in this Policy, and may keep it for a longer period as permitted by applicable laws and for relevant orders. 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 necessary.
We periodically review and evaluate the Personal Data we hold to determine whether it is still required.

9. Cross-Border Transfers of Personal Data to Third Countries or International Organizations

In certain circumstances, we may transfer your Personal Data to other countries or international organizations, which may involve sending your data outside your country of residence and, where required by law, obtaining your consent. We take all necessary measures to protect your Personal Data and ensure that you can exercise your rights and access effective legal remedies when needed.
All residents of the EEA (European Economic Area) benefit from these protections and safeguards.

• 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 conduct it under a legally binding and enforceable agreement between public bodies or authorities in accordance with Article 46(2)(a)
• We conduct the transfer in compliance with the European Commission’s Standard Contractual Clauses for data protection, issued under Article 46(2)(c) of the GDPR. To learn more, you may 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 organizations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

In order to protect your Personal Data, we have implemented robust security measures. These include preventing accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee that your Personal Data will be maintained without errors or fully secured, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, disclosures caused by transmission errors, unauthorized third-party access, or other events beyond our control.
Where we are legally required, or due to other circumstances 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 implement.
Please note that transmitting Personal Data over the internet can never be entirely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of any Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website contains links to external sites and applications that are beyond our Company's control. As a result, we are not responsible for how these third-party websites collect or process your Personal Data. While our Policy covers activity on our website, it does not apply to third-party websites.
Before visiting any third-party website or app, review the applicable privacy policy and terms. At the same time, carefully consider whether you want to share your Personal Data with them.

12. Understanding 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 major updates, we will use the methods we consider most appropriate and issue an announcement on our website. Unless stated otherwise, all amendments take effect immediately upon publication of the updated Policy.

Your Rights in Relation to Your Personal Data

You have the right to review the personal data we collect about you, to have it corrected, and to ask us to delete any Personal Data you no longer wish us to process. You may also restrict the types of data we collect. 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 assess the accuracy of the Personal Data processed. If it is 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. Upon request, this data will be provided electronically.
Your right of access must not infringe the rights 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 rectify or complete it. Right to erasure
Valid grounds include: (a) we no longer need the personal data for its intended purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (d) the Personal Data has been processed unlawfully; or (e) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with EU or Member State law 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. For data under restriction, it may only be retained with your lawful consent, to protect the rights of others, or where there is an important public interest of an EU Member State or the EU. Right to data portability
For automated processing based on consent or contract, you have the right to receive all Personal Data the Company holds about you.
You also have the right to request that the data be transmitted 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 may continue only where we can demonstrate compelling legitimate grounds that override your rights and freedoms, or for the establishment, exercise, or defense of legal claims.
You may object to processing for direct marketing at any time. 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 authority that supervises Personal Data rights.
You may request that a supervisory authority in a Member State protect your individual rights in relation to Personal Data processing within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State law. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request; however, we may extend this to two months depending on the complexity and number of requests. You will be notified within one month if an extension is applied, including the reasons.
Information provided under section 13 will be supplied free of charge unless a request is unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs, or we may decline to act on the request.
If we have doubts about your identity in connection with a request, the Company may ask for additional information.