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

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

In doing so, 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 the use of Personal Data. If you need specific details about your data, we will work to ensure you receive them promptly and at the right time. If you have any questions, we are happy to clarify matters related to legal requirements. To contact us, please email us at info@blue-orion.com

We will use Personal Data solely for the purposes described in this Policy

We process Personal Data for a variety of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and provisioning the Services, ensuring full compliance with legal and regulatory requirements, and carrying out administrative and business activities that enable the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Access essential resources to help safeguard your rights regarding Personal Data

We are committed to helping you make a well-informed decision about how we handle your data. That commitment is why we invested the time to develop this website. We communicate through clear notices, timely updates, and accessible explanations. To support this, we use a range of methods and procedures to ensure you consistently receive the most relevant, up-to-date information about our use of your personal data. If you require specific details, we will provide them at the appropriate time. If you have any questions about how this process works, we are pleased to respond and offer clarifications, all within the bounds of applicable laws and regulations. If you would like to learn more, please contact us via email at: info@blue-orion.com

Keep Your Personal Data Safe and Secure

While no one can guarantee the absolute security of Personal Data, we remain fully committed to employing multiple, industry‑standard safeguards to protect your Personal Data. Our Privacy and Security Policy covers all key areas to support your long-term safety.

Scope?

This Policy outlines the categories of Personal Data our Company collects from customers and explains how we process it, share it with third parties, and protect it. Our Policy covers information about an identified or identifiable individual, whom we can recognize directly or indirectly through a combination of information already in our possession and other data we can lawfully access. Under this Policy, “processing” means any operation involving the use or handling of Personal Data, including its management, organization, and storage. Our services are intended for a general audience but are prohibited for anyone under the age of 18, and we do not permit individuals under this age to use them. In line with this, we do not knowingly collect information from anyone under 18. If we become aware that we have collected data about a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

If you use our services or their channels, or browse our website, you agree that we may collect personal data about you. In some cases, we may ask you to provide this data directly. We may also collect it by analysing 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 to accept any related implications

You are not required to share personal data with us. However, if you choose not to provide certain information, it may affect our ability to deliver our services, which could result in limited access to our website or restricted use of some features.

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

We collect technical information such as activity log details, traffic data (including IP address and dates and times of access), 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. We also obtain certain Personal Data from you, including any personal information you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we may receive from these platforms the personal details you submit to them, such as your full name, email address, phone number, and address.

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

Our Company processes your personal data for the purposes described in this section and in compliance with the applicable legal framework.
This legal basis is necessary; without an appropriate legal basis, our Company cannot use 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 provide 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 this information because doing so serves their legitimate interests. Examples of this may include enhancing our Services or defending ourselves against potential legal claims.
• All processing carried out on our website must comply with applicable legal requirements, and we can confirm that it does.

To learn more about how we process Personal Data in support of our legitimate interests, please send us an email to contact our team.
Below, we have outlined the purposes and legal bases under which you may see us using the personal information you have provided to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Depending on the 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 accept requests 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. Once shared, 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 to access resources that help us enhance and improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or official 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 connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy relating to the Company or other parties involved with the Company.

Online Tracking Notice

You may encounter our use of third-party services on our website, such as advertising networks or analytics providers. These companies may also use cookies and similar technologies to 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 patterns to improve the user experience, understand user interests, and design products and services that better meet customer needs. Cookies also help us compile statistics and perform analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily placed on your device and expire when you close your browser. Others are persistent cookies, which remain on your device after you close your browser. These cookies allow the website to recognise you as a returning visitor and retain the preferences you previously set.

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

Each cookie's purpose and usage may vary depending on its intended function.

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

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that certain website functions and features may not work as expected 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, and we may keep it for a longer period where permitted by law and for applicable orders. Your information may, in some 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.
From time to time, we will 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 to international organisations. Where this occurs, we rely on your permission or another lawful basis and apply all necessary safeguards to protect your Personal Data, ensure you can exercise your rights, and provide effective access to legal remedies if 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 rely on a legally binding and enforceable instrument between public authorities or bodies under Article 46(2)(a)
• We conduct transfers 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, you can 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 more information 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 organisations, please email us at: info@wealthwaydigital.uk

10. Protection of Personal Data

To safeguard your Personal Data, we have implemented robust security measures. These measures help prevent accidental or unlawful destruction, loss, or alteration.
However, despite these precautions, we cannot guarantee that your Personal Data will always be securely maintained without error, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, any disclosures caused by transmission errors, unauthorised access by third parties, or other circumstances beyond our control.
In situations where we are legally obliged, 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 the level of security those third parties provide.
Please note that transferring Personal Data over the internet cannot be completely secure. It carries inherent risks. Accordingly, we cannot guarantee the security of Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website includes links to external sites and applications that are beyond the control of our Company. Accordingly, we accept no responsibility or liability for how these third-party websites collect, use, or process your Personal Data. While this Policy governs activities on our website and services, it does not apply to any third-party websites or applications.
Before visiting any third-party website or app, please review its privacy policy and terms before using its services. You should also carefully consider whether you wish to share or otherwise disclose your Personal Data to them.

12. Understanding the 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 significant updates, we will use the communication methods we consider most appropriate and will also post an announcement on our website. Unless stated otherwise, all changes to this Policy take effect immediately upon publication of the revised Policy.

Your Rights with Respect 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 any Personal Data you do not want us to process. You also have the right to restrict the types of data we may process. For individuals residing in the EEA, please refer to this page:
Anyone wishing to exercise their data rights may contact us at the email address below. Access rights
We will verify the Personal Data we process and 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 of your data. Upon request, we will provide this data electronically.
Your right of access must not infringe the rights of others. Where a request would adversely affect others, we may refuse to comply or limit our response. Your rights related to rectification
If you would like to correct inaccurate Personal Data, you may ask us to rectify incomplete or incorrect information. 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 for specific reasons; (e) the processing is unlawful; or (f) 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 restrict processing if you believe the data is inaccurate. While restricted, the data may be stored and processed only with your consent, to protect another person’s rights, or where there is an important public interest of a Member State or the EU.
Right to data portability
For automated processing based on consent or a contract, you have the right to obtain all Personal Data the Company holds about you.
You also have the right to request that the data be transferred to another controller where technically feasible. Exercising your right to data portability does not affect your right to erasure.
Right to object
You may object at any time to our use of your Personal Data based on legitimate interests pursued by the Company or third parties, including related profiling. We will cease processing unless we demonstrate compelling legitimate grounds that override your rights and freedoms or where processing is necessary for legal claims.
You have the right to object at any time to the processing of Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing carried out before withdrawal.
You also have the right to lodge a complaint with the authority supervising your Personal Data rights.
You may request that a supervisory authority in a Member State protect your individual rights regarding Personal Data processing within the EU.
As outlined in section 13, your Personal Data rights may be limited by EU and Member State laws. In line with these rights, 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 depending on the complexity and number of requests. You will be notified within one month if an extension is applied and the reasons for it.
We will make the information you request under section 13 available free of charge unless the request is unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act on the request.
If we have any doubts about your identity in connection with a request, the Company may ask for additional information.