We (also known as 'We', 'Us' or 'Our') are dedicated to safeguarding your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide on the Gaingate website (the 'Website').
The following principles govern our practices:

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

Our website is designed to empower you to make informed decisions regarding the use and processing of Personal Data. To support this, we use various methods and procedures to provide relevant information on Personal Data handling. If you require specific details, we'll furnish them at the appropriate time. We welcome any questions and will clarify any legal limitations that apply. You can reach us by email at info@blue-orion.com

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

Personal Data may be processed by us for a variety of purposes, such as providing access to the website, connecting you with third-party trading platforms (the 'Services'), enhancing and protecting the site and our interests, facilitating maintenance and provision of the Services, fulfilling legal or regulatory obligations, and conducting administrative and business activities to support delivery and use of the Services. Personal Data are also processed to better understand your preferences and needs.

Leverage powerful tools to safeguard your rights regarding Personal Data:

We aim to empower you to make informed decisions regarding the use and processing of your Personal Data. To support this, we’ve established this website and employ various methods and procedures to deliver relevant information about data handling. If you require specific details, we will provide them at the appropriate time. We welcome any questions and are happy to clarify any legal limitations. You can reach us by email at info@blue-orion.com

Safeguard Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we remain committed to employing a variety of methods and techniques to safeguard it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the types of personal data that the Company collects from individuals, how it processes and protects that data, and when it shares information with third parties. It applies to data relating to identified or identifiable natural persons—those who can be identified directly or through linked data we hold or access. The policy defines 'processing' as any operation involving the collection, management, organization, or storage of personal data. Our services are designed for a general audience and are not intended for anyone under 18. We do not knowingly collect information from minors under 18 or permit their use of our services, and we will promptly delete any such data if we become aware of it.

2. What personal data do we hold about you?

When you access our services, channels or website, we collect Personal Data. In some cases, we may request your Personal Data. In others, we gather it by analyzing your use of our services or channels, or by receiving 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 obligated to provide Us with Personal Data. However, in some cases, choosing not to supply this information may prevent Us from offering the Services or restrict users' access to the website.

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

This includes your online activity logs, traffic data (including IP address and access date and time), language settings, software crash reports, browser type, and device information. These data are not private and cannot identify you personally. We receive any personal data you provide at your own discretion when connecting through us to a third-party online trading platform. The personal information you submit to facilitate trades may include your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data

Your Personal Data is processed by the Company for the purposes outlined in this section, in line with the applicable legal basis.
Without such a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company may process your Personal Data are as follows:

• You have consented to processing 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 need to process information to pursue their legitimate interests, such as enhancing Our Services or defending legal claims.
• Processing must comply with legal obligations.

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

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data, including IP addresses and user experience analytics, with third-party service providers such as hosting and storage providers.
You may also request that we transfer your Personal Data to third-party trading platforms. In such cases, we will share the data you provided with those platforms, and its use will be subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with affiliated entities or business partners to enhance and improve the products and services it offers its customers.
Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders—or with any group company—in the event of a transaction (including a transfer or sale of assets) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other group business.

ONLINE TRACKING NOTICE

Third-party services, such as advertising providers or analytics companies, may be engaged on our website. These services may also use cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to enhance your experience, remember your settings, and customize the products and services you might enjoy. Cookies also support statistical and analytical purposes.
We use session cookies, which are temporary and are deleted when you close your browser. We also use persistent cookies, which remain on your device for a set period after you close your browser. These cookies help the website recognize you as a returning user and facilitate your return to the site.

7. Third-Party Cookies and Services

We may use them based on their intended purpose:

Cookies are being blocked or removed
To control or delete cookies, adjust your browser's settings. Below are direct links to guide you through the cookie management process on 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 work as expected if this occurs.

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

The Company retains your Personal Data for as long as necessary to fulfill the processing purposes described in this Policy, or longer if required by law, regulation, policy, or applicable orders. We will share your information with third-party trading platforms for 12 months, and with your consent will extend this sharing 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-party countries or international organisations

Your personal information may be transferred to other countries, meaning it could be sent to a third country (i.e., a country other than the one in which you reside) or to international organizations or jurisdictions. The Company takes all necessary steps to safeguard the personal data you provide and to ensure that you can exercise your rights and access effective legal remedies.
These protections and safeguards are available to everyone residing in the EEA (European Economic Area).

• Transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data, 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, enforceable agreement between public entities or authorities as set out in viro Article 46(2)(a).
• This transfer was conducted 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 provide details on the security measures it employs to safeguard your Personal Data when transferred to third-party countries or international organisations. Please email info@wealthwaydigital.uk

10. Personal Data Protection

We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee that the security of your Personal Data will be maintained without error, nor can we be held liable for any indirect, 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, or any cause beyond our control.
If legal or other obligations beyond our control require it, we may be compelled to provide your Personal Data to third parties, such as public authorities. In such cases, we cannot ensure how those parties will secure your information.
No method of transmitting Personal Data over the internet is completely secure. The Company cannot guarantee the safety of any Personal Data you send to us online.

11. Hyperlinks to Third-Party Websites

Our website includes links to third-party websites and applications that operate independently and are not under the Company’s supervision. We are not responsible for the collection or processing of Personal Data by these third-party sites or apps, and this Policy does not govern their activities.
When you visit any third-party site or app, we recommend reading its privacy policy before deciding to access or use it, and providing any Personal Data directly to that site or app.

12. Amendments to this Policy

This Policy may be revised at any time without prior notice. If changes occur, we will notify you by posting the updated Policy on our website to ensure you are informed. For significant revisions, we will also inform you through the methods we deem appropriate—such as email, in-app notifications, or other channels—and publish an announcement on our website. Unless explicitly stated otherwise, all amendments will take effect upon publication of the revised Policy.

Your Rights Concerning 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 necessary. You may also restrict the types of processing applied to your Personal Data. If you reside in the EEA, please refer to this page:
These rights apply to all Personal Data you provide. To exercise any of these rights, please send an email to the address below. Access rights
You may request confirmation of the Personal Data we process about you. If we process your Personal Data, you may access it and receive an electronic copy. We may charge a reasonable fee for additional copies. You may request to receive the data electronically.
The right of access must not conflict with the rights and freedoms of others. If fulfilling your request would adversely affect another individual’s rights, the Company may refuse or limit access. Right to rectification
You may request correction of any inaccurate or incomplete Personal Data we hold about you, taking into account the purpose of the processing. Right to erasure
You may request deletion of your Personal Data if: (a) it is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and no other legal basis applies; (c) you object to processing based on our or a third party’s legitimate interests and no overriding grounds exist; (d) your Personal Data has been unlawfully processed; or (e) erasure is necessary to comply with a legal obligation of the Company. This right does not apply where processing is required (a) to comply with a legal obligation under EU or Member State law; or (b) to establish, exercise, or defend legal claims. Processing restrictions
You may request that we restrict the processing of your Personal Data if you contest its accuracy. While processing is restricted, we may only store your Personal Data and process it (a) with your consent, (b) to establish, exercise, or defend legal claims, (c) to protect another individual’s rights, or (d) 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 carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format. You may also request that we transfer your Personal Data directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure, nor does it adversely affect others’ rights or freedoms.
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. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or processing is needed to establish, exercise, or defend 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 for processing of your Personal Data at any time. This will not affect the lawfulness of any processing carried out before the withdrawal.
You have the right to lodge a complaint with the supervisory authority in your jurisdiction. You may also appeal to any EU Member State supervisory authority responsible for protecting individuals’ rights related to Personal Data processing.
EU and Member State laws may limit the rights described in this Section 13. We will respond to your request 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 its reasons within the initial one-month period.
Unless prohibited by Section 13, we will provide the requested information free of charge. However, if your request is manifestly unfounded or excessive (especially if repetitive), we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have any doubt about the identity of the person making the request, the Company may ask for additional information.