We (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 website Gaingate (the 'Website').
We uphold the following principles:

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

Our aim is to empower you to make informed decisions about the collection and processing of your Personal Data. To this end, we’ve developed and launched this website. We employ a range of methods and procedures to ensure you consistently receive clear, relevant information on our use of Personal Data. If we believe you need specific details, we will provide them at the appropriate time. We are happy to answer any queries and will clarify any points within the constraints of applicable law. Please feel free to get in touch at any time for further assistance. You can reach us by email at: info@blue-orion.com

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

Personal Data may be processed by Us for a variety of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), enhancing the site, safeguarding our rights and interests, facilitating maintenance and delivery of the Services, complying with legal and regulatory requirements, and conducting administrative and business activities to support the Services. Personal Data are also processed by Us to better understand your preferences and needs.

To access essential tools designed to protect your personal data rights:

We want you to be able to make informed decisions about how your Personal Data is used and processed. To support this, we have developed our website with a range of methods and procedures to provide you with relevant information on the use of Personal Data. Should you require further details, we will supply them at the appropriate time. We welcome any questions and will clarify any legal constraints. Please contact us by email at info@blue-orion.com

Safeguard your personal data:

Although we cannot guarantee absolute security for your Personal Data, we remain committed to continuously employing a wide range of methods and techniques at all times to fully safeguard it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy explains the categories of Personal Data the Company collects from individuals and how it processes, shares with third parties, secures and manages that information. It applies to any data related to an identified or identifiable natural person—that is, someone who can be identified directly or in combination with other information we hold or access. For the purposes of this Policy, ‘processing’ means any operation involving the collection, organisation, storage or use of Personal Data. 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 children under 18, nor do we authorise their use of our services. Should we become aware of Personal Data belonging to a minor, we will promptly delete it.

2. What Personal Data Do We Hold About You?

If you access our services or channels, or visit our website, we collect Personal Data. We may ask you to provide Personal Data in certain circumstances. Otherwise, we collect your Personal Data by analysing your use of our services or channels, or by receiving it from our third-party partners.

3. Disclosing personal information to the company is voluntary and carries no consequences.

You are under no obligation to provide Us with any Personal Data. However, in certain circumstances, if you choose not to supply Us with this information, it may prevent Us from offering the Services or restrict users’ access to the website.

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

Data collected includes your online activity logs and traffic data — such as IP address, access dates and times — your language settings, software crash reports, browser type and device information. This information is not private and cannot be used to identify you. Personal Data We Receive From You: any personal data you voluntarily provide when connecting to a third-party online trading platform through Us. Personal Information You Provide to Third-Party Platforms to Facilitate Trade: your full name, address, telephone number and email address.

5. The Legal Basis and Reasons for Processing Personal Data

Your Personal Data is processed by the Company for the purposes set out in this section and under the relevant legal basis.
Without a valid legal basis, the Company cannot process any Personal Data relating to you. The legal grounds on which the Company may process your Personal Data:

• You have consented to the processing of your Personal Data for one or more purposes. For example, by submitting personal information via the Website, you enable us to transfer it to a third-party trading platform.
• The Company or a third party may need to process data to pursue their legitimate interests. For example, it may be necessary to improve Our Services or to defend legal claims.
• Processing must fulfil legal obligations.

Email us for details on the processing required to safeguard our legitimate interests.
Below is a list of reasons and legal grounds on which we may use your 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 and storage vendors, to process IP address information and analyse user experiences.
You may also request that we transfer specific Personal Data about you to third-party trading platforms. In those cases, we will provide the data you have supplied to the relevant platforms, and their privacy policies will govern its use. Your information may be shared across 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 we offer.
Where necessary to protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local or other official authorities.
We may also share Personal Data with potential investors or buyers, or with lenders to the Company or any other group company in connection with the same transaction (including the transfer or sale of assets belonging to the Company or any group company), or as part of any merger, restructuring, consolidation or bankruptcy of the Company or any other business within the group.

ONLINE TRACKING NOTICE

Third-party services, such as those providing advertising on our website or analytics insights, may be employed. These partners can also use cookies or similar technologies to enhance functionality.
Cookies are small text files placed on your device each time you visit or access the website. They gather information about your preferences and browsing habits to improve your user experience, remember your settings, and personalise the products and services you might enjoy. Cookies are also used for statistical analysis and analytics reporting.
We use session cookies, which are downloaded temporarily to your device and expire when you close your browser. We also employ persistent cookies that remain on your device for a set period after you close the browser. These cookies help our website recognise you as a returning user and streamline your future visits.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To prevent or remove cookies, you must adjust your browser settings. Below are links to guide you through the process for some of the most widely used browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

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

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

The Company will retain your Personal Data only as long as necessary to achieve the purposes outlined in this Policy, or for longer if required by applicable laws, regulations, policies or orders. We will share your information with third-party trading platforms for an initial period of 12 months. If you consent, we will extend this sharing for an additional 12 months.
We regularly review the Personal Data we hold to confirm it is no longer needed.

9. Transfers of Personal Information to Third Countries or International Organisations

Your personal information may be transferred to third countries (i.e., countries outside your place of residence) or to international organizations and jurisdictions. To protect this data, the Company implements all necessary technical, organizational and contractual safeguards in accordance with applicable data protection laws, ensuring confidentiality, integrity and availability of your information. We also ensure that you can assert your rights and access effective legal remedies.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area).

• Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it 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 and enforceable agreement between public entities or authorities under Article 46(2)(a) of the viro.
• The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission 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 supply details of the security measures it adopts to protect your Personal Data when transferred to third-party countries or international organisations. Please email us at info@wealthwaydigital.uk for more information

10. Personal Data Security

We have implemented appropriate organisational and technical measures to safeguard Personal Data, including preventing its accidental or unlawful destruction, loss or alteration.
However, we cannot guarantee that your Personal Data will remain error-free or that its security will be upheld without fail. We also disclaim any liability for intangible, 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, unauthorised third-party access or any event beyond our control.
If compelled by legal requirements or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. We cannot control the security measures these parties apply to your information.
No method of transmitting Personal Data over the internet is completely secure. The Company cannot ensure the security of any Personal Data you transmit to us online.

11. Hyperlinks to Third-Party Websites

Our website includes links to third-party sites and applications, which are managed independently of the Company. As such, we neither supervise nor control the collection or processing of Personal Data gathered by these external sites and apps, and this Policy does not apply to their practices.
When you navigate to any third-party site or app, we recommend that you carefully review its privacy policy and assess its data handling procedures before deciding to access or use its services. You should determine what Personal Data to share with these providers.

12. Amendments to this Policy

This Policy may be revised at any time. If we do so, we will post the updated Policy on our website to notify you of the changes. For significant revisions, we will also endeavour to inform you through appropriate channels and publish an announcement on our site. Unless 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 your Personal Data, correct any errors and delete any data that is no longer required. You may also limit how we process your Personal Data. If you reside in the EEA, please refer to this page:
These rights apply to any Personal Data you provide to us. To exercise your rights, please email us at the address below.
Access rights
The Company can confirm whether your Personal Data are being processed and grant you access to them. On request, we will supply an electronic copy of the Personal Data currently processed and may charge a reasonable fee for additional copies. The data will be provided electronically if you so request.
Your right to access does not override the rights and freedoms of others. If fulfilling your request would infringe those rights, the Company may refuse or limit its response.
Right to rectification
You may ask the Company to correct any inaccurate or incomplete Personal Data concerning you, taking into account the purpose of processing.
Right to Erasure
You have the right to request deletion of your Personal Data if: (a) the data are no longer required for the purpose for which they were collected; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests pursued by us or a third party and no overriding grounds exist; (d) the data have been unlawfully processed; or (e) deletion is necessary to comply with a legal obligation. This right does not apply where processing is necessary to: (a) comply with a legal obligation under EU or Member State law; or (b) establish, exercise or defend legal claims.
Processing restrictions
If you dispute the accuracy of your Personal Data, you may ask the Company to restrict processing. During the restriction period, we will only process the data with your consent, to establish, exercise or defend legal claims, to protect another individual’s rights, or for reasons of substantial public interest under EU or Member State law.
Right to data portability
Where processing is based on your consent or a contract and is carried out by automated means, you have the right to receive the Personal Data you provided in a structured, commonly used, machine-readable format. You may also request direct transfer of your Personal Data to another controller, if technically feasible. Exercising this right does not affect your right to Erasure and does not override the rights or freedoms of others.
Right to challenge
You may challenge at any time the processing of your Personal Data based on legitimate interests pursued by the Company or a third party, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights or freedoms, or for the establishment, exercise or defence of legal claims.
Concerning direct marketing
You have the right to object at any time to processing of your Personal Data for direct marketing purposes.
Right to refuse consent
You may withdraw your consent for our processing of your Personal Data at any time. This will not affect the lawfulness of any processing conducted prior to withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may appeal to a supervisory authority established by a Member State to safeguard individuals’ fundamental rights in relation to Personal Data processing within the EU.
EU and Member State laws may limit the rights described in this 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 notify you of any extension and its reasons within one month of receiving your request.
Unless Section 13 provides otherwise, we will supply the requested information free of charge. For manifestly unfounded or excessive requests, particularly repetitive ones, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we doubt the identity of the person making the request, the Company may ask for additional information.