We (“we”, “us” or “our”) are dedicated to protecting your Personal Data and respecting your privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the “Website”).
We uphold the following principles:

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

Our goal is to enable you to make informed choices about how your Personal Data is collected, used, and processed. That’s why we’ve built this website—to offer clear, relevant information on Personal Data practices. We utilize a variety of methods and procedures to present the details you need. If you require specific information, we will provide it at the appropriate time. We’re available to answer your questions and clarify any limitations imposed by law. For any inquiries, simply send us a message and we will respond promptly. You can reach us by email at info@blue-orion.com

Personal Data is used solely for the purposes specified in the Policy.

We may process Personal Data for various purposes: to provide the website and connect you with third-party trading platforms (the “Services”), to improve and secure the site, to protect our rights and interests, to maintain and deliver the Services, to comply with legal and regulatory obligations, and to support related administrative and business operations. We also process Personal Data to better understand your preferences and needs.

Use a range of essential tools to protect your rights with respect to Personal Data:

We want you to be empowered to make informed decisions about the collection and processing of Personal Data. For this reason, we’ve developed our website to deliver clear and comprehensive information on our Personal Data practices. By employing various methods and procedures, we ensure you have access to relevant insights. If you need more specific details, we’ll provide them at the appropriate time. We are pleased to answer any questions you may have and clarify any legally required limitations. You can reach us by email at the address below: info@blue-orion.com

Safeguard Your Personal Data:

Although we cannot guarantee absolute security for your Personal Data, we remain committed to deploying a variety of methods and techniques to ensure it is fully protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy outlines the categories of Personal Data the Company collects from natural persons and explains how we process, share, and secure that data. It covers information related to identified or identifiable natural persons—those who can be directly recognized or whose identity can be inferred from additional data we hold or access. We define 'processing' as any operation involving the use or collection of Personal Data, including its management, organization, and storage. Our services are intended for a general audience and are not designed for use by anyone under the age of 18. We do not knowingly collect information from individuals under 18 or permit them to use our services. If we discover that we have inadvertently collected information about a child, we will delete it as soon as possible.

2. What Personal Data Do We Hold About You?

Whenever you access our services or channels, or visit our website, we collect Personal Data. In certain situations, we may request this information directly. In other cases, we obtain Personal Data by analyzing your use of our services or channels, or by receiving it from our third-party partners.

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

You are not required to provide Us with any Personal Data. However, in certain cases, declining to do so may prevent Us from delivering the Services or 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 details of your online activity log, traffic data (including IP address, date and time of access), language preferences, software crash logs, browser type, and device information. These details are not considered private and cannot be used to identify you. Personal Data We receive from you: any personal data you voluntarily provide when you connect to a third-party online trading platform through Us. Personal information you provide specifically to third-party platforms to facilitate trade includes 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 outlined in this section and in accordance with the applicable legal basis.
Without a legal basis, the Company cannot use your Personal Data. The legal bases 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 applies when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
• The Company or a third-party may require processing to meet their legitimate interests. For example, it may be necessary to improve Our Services or to defend legal claims.
• Processing must comply with legal obligations.

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

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data, including IP address information and user experience analysis, with third-party service providers such as hosting and storage vendors.
You can request that we transfer specific Personal Data about you to third-party trading platforms. In these instances, we will provide the Personal Data you supply directly to those platforms, subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to enhance and improve the products and services we offer our customers.
When necessary to protect the rights of third parties or assets, the Company is permitted to disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors, buyers, or lenders of the Company or any other group company in connection with a 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 group business.

ONLINE TRACKING NOTICE

Third-party services, such as ad networks and analytics providers, may be employed on our website and may use cookies or similar tracking technologies to collect information.
Cookies are small text files placed on your device each time you visit or access the website. They collect data about your preferences and browsing habits to improve the user experience, remember your settings, and tailor products and services you may find useful. Cookies also support site functionality, security measures, and statistical analysis.
Some cookies, known as session cookies, are downloaded temporarily and expire when you close your browser. Other cookies, called persistent cookies, remain on your device for a predefined period after you close the browser. These cookies help the website recognize you as a returning user and provide a seamless experience on subsequent visits to the site.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies have been blocked or removed
To prevent or remove cookies, adjust your browser settings. Below are links to instructions for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that some or all of the Website's functions and features may not operate as expected if this occurs.

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

The Company will keep your Personal Data only as long as necessary to fulfill the purposes of processing described in this Policy, or longer if required by law, regulations, policies, or applicable orders. We will share your information with third-party trading platforms for an initial period of 12 months. If you agree to this, we will continue sharing your data for an additional 12 months.
We regularly review retained Personal Data 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—an additional country outside your place of residence—or to international organizations or jurisdictions). The Company takes all necessary measures to safeguard the personal data you provide and ensures you can exercise your rights and access effective legal remedies.
These protections and safeguards apply to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the EU Commission has recognised as providing adequate protection for personal data under 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, enforceable agreement between public entities or authorities under Article 46(2)(a).
• The transfer was carried out in compliance with the EU Commission’s standard data protection clauses under Article 46(2)(c) of the GDPR. You can view 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.

The Company can provide details of the security measures it employs to safeguard your Personal Data when transferred to third-party countries or international organisations. For more information, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organizational and technical measures to protect Personal Data, including preventing its accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee that the security of your Personal Data will be flawless. We are not liable for any indirect, incidental, or consequential damages resulting from the use or disclosure of Personal Data. This includes, but is not limited to, disclosures caused by transmission errors, unauthorized third-party access, or any factors beyond our control.
If required by law or other binding obligations, we may be compelled to disclose Personal Data about you to third parties, such as public authorities. We cannot control the security measures these third parties employ.
No data transmission over the internet is entirely risk-free. The Company cannot guarantee the security of any Personal Data you transmit to us online.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided on this site for your convenience. These sites and apps operate independently of the Company, and we do not oversee how they collect or process Personal Data. This Policy does not apply to activities on those external platforms.
Before accessing or using any third-party services, we recommend that you review their privacy policies. You should also determine how they handle Personal Data before submitting any information.

12. Updates to this Policy

This Policy is subject to change at any time. When we make changes, we will post the revised Policy on our website to notify you. In addition, if we implement significant modifications, we will attempt to inform you through the methods we deem appropriate and publish an announcement on our website. Unless explicitly stated otherwise, any amendments will become effective upon publication of the updated Policy.

Your rights regarding your personal information

You have the right to request that we verify the accuracy of any Personal Data we collect about you, correct any errors, and delete any Personal Data that is no longer necessary. You may also request restrictions on certain processing activities. If you are an EEA resident, please refer to this page:
These rights apply to the Personal Data you provide and can be exercised by emailing the address below.
Access rights
The Company will confirm whether we are processing your Personal Data and, if so, provide you with access. We will supply an electronic copy of the data currently being processed and may charge a reasonable fee for additional copies. If you request the data electronically, we will deliver it in a suitable electronic format.
We will not disclose Personal Data if doing so would infringe the rights and freedoms of others. In such cases, we may refuse or limit your request.
Right to rectification
You may ask us to correct any inaccurate or incomplete Personal Data we hold about you, taking into account the purposes of processing.
Right to Erasure
You may request deletion of your Personal Data when: (a) it is no longer necessary for the purpose 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 our or a third party’s legitimate interests; (d) the data has been unlawfully processed; or (e) removal is required to comply with a legal obligation.
This right does not apply to processing that is necessary (a) to fulfill 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. While restricted, we will only process your data with your consent, to exercise or defend legal claims, to protect another individual’s rights, or for reasons of significant public interest in the EU or a Member State.
Right to data portability
When processing is carried out by automated means and based on your consent or a contract to which you are a party, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format. You may also request direct transfer of your data to another controller, where technically feasible. Exercising this right will not affect your right to erasure and will not infringe the rights or freedoms of others.
Right to Challenge
You have the right to object at any time to processing of your Personal Data based on legitimate interests pursued by us or a third party, including profiling. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
Right to object to direct marketing
You may object at any time to processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to any processing of your Personal Data at any time. This will not affect the lawfulness of processing carried out prior to your withdrawal.
You have the right to lodge a complaint with your local supervisory authority, which protects individuals’ fundamental rights in relation to Personal Data processing within the European Union.
EU and Member State laws may limit the rights detailed in this Section 13. We will respond to your request under this section within one month of receipt. If necessary, we may extend this period by up to two additional months, depending on the complexity and number of requests. We will inform you of any extension and the reasons within one month of receiving your request.
We will provide the requested information free of charge unless your request is unfounded or excessive, particularly if it is repetitive. In such cases, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have doubts about the identity of the person making the request, we may request additional information to verify your identity.