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

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

We want you to make informed decisions about how your Personal Data is collected, used and processed. We update this information regularly to reflect changes in our practices or legal requirements. That’s why we created this website—to present clear, up-to-date information about our data practices. By employing a range of methods and procedures, we strive to supply the details you need. When more specific information is required, we will provide it at the appropriate time. We’re also happy to answer your questions and clarify any legal limitations. You can reach us by email at info@blue-orion.com

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

We may process Personal Data for a variety of purposes, including offering you the website, connecting you with third-party trading platforms (the 'Services'), improving and securing the site, protecting our rights and interests, facilitating maintenance and delivery of the Services, complying with legal and regulatory obligations, and conducting administrative and commercial activities to support the Services. We also process Personal Data to better understand your preferences and needs.

To leverage key tools designed to safeguard your rights regarding Personal Data:

We want you to make informed decisions about the collection and processing of your Personal Data. That’s why we’ve developed this website—to share clear, relevant information about how we handle Personal Data. Through various methods and procedures, we ensure you receive the details you need. If you require more specific information, we will provide it promptly at the appropriate time. We welcome your questions and will clarify any matters within the bounds of applicable law. You can contact us by email at info@blue-orion.com

Protect Your Personal Data:

While we cannot guarantee complete security of your Personal Data, we will continue employing a variety of proven methods and techniques to keep it protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy describes the types of Personal Data the Company collects from natural persons and how it processes, shares, and secures that information. It covers data related to an identified or identifiable individual—someone who can be recognized directly or through other information we hold or access. The Policy defines ‘processing’ as any operation involving Personal Data, including collection, management, organization, and storage. Our services are intended for general audiences and are not designed for users under 18. We do not knowingly collect information from anyone under 18 or allow such individuals to use our services. If we learn we have collected data about a child, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

When you access our services and channels, or visit our website, we collect Personal Data. We may ask you to provide Personal Data in specific situations. Alternatively, we gather your Personal Data by analyzing how you use our services and channels or by obtaining information from our third-party partners.

3. You are not required to disclose personal information to the company, and there are no consequences.

You are not required to provide us with any personal data. However, in certain circumstances, withholding such information may prevent us from delivering our Services or restrict users from accessing the website.

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

This includes your online activity log, traffic data (including IP address, date and time of access), chosen language, software crash logs, browser type, and information about your device. This data 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 specifically supply to third-party platforms to facilitate trades: your full name, address, phone 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 described in this section and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot use any Personal Data about you. The legal grounds on which the Company relies to process your Personal Data are:

• You have consented to the processing of your personal data for one or more purposes. This applies whenever 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 personal data to pursue their legitimate interests. For example, this processing can be essential for improving Our Services or defending legal claims.
• Processing must comply with legal requirements.

Contact us via email for more information on the processing necessary to safeguard our legitimate interests.
Below is a list of reasons and legal grounds for which we may use the personal data you provide.

6. Transfer of Personal Data to Third Parties

The Company may share Personal Data, such as IP address information and user experience analytics, with third-party service providers like hosting and storage companies.
Upon your request, we can provide specific Personal Data to third-party trading platforms. Any data you authorize us to share will be transmitted to these platforms, and its use will be governed by their respective privacy policies, which may vary.
We may also share Personal Data with our affiliates or business partners to support the enhancement and improvement of our products and services.
If necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors, buyers, or lenders in connection with any transaction—such as the transfer or sale of assets, or any merger, restructuring, consolidation, or bankruptcy—affecting the Company or any other business within our group.

ONLINE TRACKING NOTICE

We may use third‐party services, such as advertisers or analytics firms, to support our website. These parties may also employ cookies or similar technologies for various purposes.
Cookies are small text files placed on your device each time you visit or access our website. They collect information about your preferences and browsing habits to enhance your user experience, remember settings, and tailor products and services you might enjoy. Cookies are also used for statistical and analytical purposes.
Some cookies are session cookies. These are temporary and are deleted from your device when you close your browser. Other cookies are persistent: they remain on your device for a set period after you close your browser. They help the website recognize you as a returning user and allow you to return to the site seamlessly.

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, update your browser settings. Below are links to guide you through this process for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please be aware that some or all of the Website’s functions and features may not work as expected in such cases.

ONLINE TRACKING NOTICE This service does not currently honor Do-Not-Track signals.
8. Retention of Your Personal Data

The Company will retain your Personal Data only as long as necessary to fulfil the processing purposes set out in this Policy, or longer if permitted by law, regulations, policies or applicable orders. We will share your information with third-party trading platforms for 12 months. If you agree, we will extend this sharing for an additional 12 months.
We regularly review retained Personal Data to confirm it is no longer needed.

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

Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third-country, meaning a country other than the one in which you reside) or to international organizations or jurisdictions. Our company takes all necessary steps to safeguard the personal data you provide and ensure that data subjects can assert their 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 EU Commission has determined, under Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, provides an adequate level of protection for the Personal Data transferred to it. (the 'GDPR')
• The transfer is made pursuant to a legally binding, enforceable agreement between public authorities or bodies under Article 46(2)(a).
• 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. You can review these clauses 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 about the security measures we employ to safeguard your Personal Data when it’s transferred to third-party countries or international organisations. To request this information, email us at info@wealthwaydigital.uk

10. Personal Data Security

We have implemented comprehensive organizational and technical measures to safeguard Personal Data, including preventing its accidental or unlawful destruction, loss or unauthorized modification.
However, we cannot guarantee or warrant that the security of your Personal Data will remain error-free, nor can we be held responsible for any intangible, incidental or consequential damages arising from its use or disclosure. This includes, but is not limited to, any Personal Data disclosed due to transmission errors, unauthorized third-party access, system failures or other causes beyond our control.
If we are required by law or other binding obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities or legal entities. We have no control over, and cannot assume liability for, the security practices these third parties apply to your data.
Data transmission over the internet cannot be guaranteed entirely secure. The Company cannot ensure the confidentiality or integrity of any Personal Data you transmit to us online.

11. Hyperlinks to Websites Operated by Third Parties

Links to third-party websites and applications are included on this website for your convenience. These external sites and apps operate entirely independently of the Company, and we are not involved in or liable for their collection or processing of personal data. Therefore, this Policy does not cover any activities you conduct on those platforms.
Before visiting or using any third-party website or application, please read its privacy policy. We also recommend that you carefully consider any personal data you choose to disclose to these entities.

12. Changes to this Policy

This Policy may be updated at any time. When we do, we will notify you by posting the revised Policy on our website. For significant changes, we will also endeavor to inform you through the methods we deem appropriate and post an announcement on our site. Unless otherwise specified, any amendments will take effect upon publication of the updated Policy.

Your rights regarding your personal information

You have the right to ask us to verify the accuracy of any Personal Data we collect about you, correct errors, and delete any Personal Data that is no longer necessary for our purposes. You may also request restrictions on certain types of processing of your personal information. If you reside in the EEA, 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
You have the right to verify the accuracy of any Personal Data we process about you and to access that data. We will provide you with an electronic copy of the Personal Data we process. We may charge a reasonable fee for additional copies, which will also be provided electronically upon request.
Your right to access Personal Data must not infringe on the rights and freedoms of others. If your request adversely affects another person’s rights, we may refuse or limit our response. Right to Rectification
We will correct any inaccurate Personal Data we hold about you. You may also request that incomplete data be completed, considering the purpose of processing. Right to Erasure
You may request that we erase your Personal Data when: (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 to processing based on legitimate interests, and there are no overriding legitimate grounds for us or third parties; (d) the data have been unlawfully processed; or (e) we must erase the data to comply with a legal obligation. 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.
Processing Restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict its processing. During any restriction, we will only retain the data with your consent, to establish, exercise, or defend legal claims, to protect another natural person’s rights, or for reasons of substantial public interest in the EU or a Member State.
Right to Data Portability
If 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 to us in a structured, commonly used, and machine-readable format.
You may also request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising this right will not affect your rights to erasure, nor will it infringe on the rights or freedoms of others.
Right to Object
You have the right to object at any time to processing of your Personal Data based on our or a third party’s legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights and freedoms or for the establishment, exercise, or defense of legal claims.
Direct Marketing
You have the right to object at any time to the processing of your Personal Data for direct marketing purposes.
Right to Withdraw Consent
You may withdraw your consent for us to process your Personal Data at any time. This will not affect the lawfulness of processing carried out based on consent before its withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
You may appeal to a supervisory body established by your Member State to protect individuals’ rights regarding Personal Data processing in the EU.
EU or Member State laws may further limit your rights regarding your Personal Data as described in Section 13. We will respond to your request under Section 13 within one month of receipt. If necessary, we may extend this period by up to two months, depending on the complexity and number of requests. We will inform you of any extension and the reasons for the delay within the initial one-month period.
Unless prohibited by Section 13, we will provide the requested information free of charge. However, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, particularly if they are repetitive.
If we have any doubt about your identity when you submit a request, we may ask for additional information to confirm it.