We (also referred to as 'We', 'Us' or 'Our') are committed to safeguarding your Personal Data and protecting your privacy.
This Privacy Policy is designed to explain how we collect and store the information you provide through the Gaingate website (the 'Website').
We will uphold the following principles:

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

We want you to be able to make informed decisions about the use and processing of Personal Data. That’s why we created this website. To achieve this, we use a range of methods and procedures to share relevant information about how Personal Data is used. If we believe you need specific details, we’ll provide them at the appropriate time. We’re happy to answer any questions and will offer any clarifications you require, subject to legal limitations. You can reach us via email at: info@blue-orion.com

Personal data will be used solely for the purposes outlined in this Policy.

Personal Data may be processed by Us for various purposes, including providing the website to you and connecting you with third-party trading platforms (the 'Services'); enhancing the site; protecting our rights and interests; facilitating the maintenance and provision of the Services; complying with regulatory and legal obligations; and carrying out administrative and business activities that support the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.

Access key tools to effectively protect your rights in relation to your Personal Data:

We want you to be able to make informed decisions about the use and processing of Personal Data. That is why we have created this website. To do so, we use a range of methods and procedures to provide you with relevant information about how Personal Data is used. If we believe you need specific details, we will share them at the appropriate time. We are happy to answer any questions and will provide any clarifications you need, subject to legal limits. You can contact us via email at: info@blue-orion.com

Protect your personal data:

While we cannot guarantee the complete security of your Personal Data, we will continue to employ a range of measures and techniques to ensure your Personal Data is protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy describes the types of Personal Data the Company collects about natural persons and how we process it, share it with third parties, and protect it. This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified, or identified in combination with other information we hold or can access. The Policy defines ‘processing’ as any operation that involves the use or collection of Personal Data. It includes the management, organisation, structuring, and storage of Personal Data. Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly seek or collect information from anyone under 18 years of age, nor do we knowingly allow such persons to use our services. If we become aware of information about children, 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. In some cases, we may request Personal Data directly from you. In others, we collect it by analysing your use of our Services and channels, or from information provided by our third-party partners.

3. No obligation to disclose personal information to the company and the consequences of not doing so.

However, you are not required to provide Us with any Personal Data. In some circumstances, you may choose not to share Personal Data with Us. This may prevent Us from delivering the Services or restrict users' access to the website.

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

This includes your online activity logs and traffic data (such as IP address and the date and time of access), your language settings, software crash logs, the type of browser used, and details about the device you use. The information we collect is not personal information and cannot be used to identify you. Personal Data We receive from you: any personal data you choose to provide to Us when you connect with a third-party online trading platform through Us. Personal information you provide directly to third-party platforms to facilitate trade 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 set out in this section, and in line with the applicable legal basis.
Without a lawful basis, the Company cannot process Personal Data relating to you. The legal grounds that allow the Company to 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 we can 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, this may be necessary to improve Our Services or to defend against legal claims.
• Processing must satisfy a legal obligation.

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

6. Sharing Personal Data with Third Parties

The Company may also share Personal Data with third-party service providers that support us, such as hosting and storage providers, and partners that process IP address information or analyse user experience.
At your request, we can provide specific Personal Data about you to third-party trading platforms. In these cases, we will share the Personal Data you supply to us with those platforms. Their use of your Personal Data is governed by their own privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with related entities or business partners. This helps provide the resources needed for the Company to enhance and improve the products and services it offers to customers.
Where necessary to protect the rights or property of third parties, the Company may disclose Personal Data to regulatory, local, or other public authorities.
We may also share your Personal Data with potential investors, purchasers, or lenders of the Company or any other company in our corporate group in connection with a proposed or actual transaction (including the transfer or sale of assets of the Company or any other group company), or as part of any merger, restructuring, consolidation, or insolvency proceedings of the Company or any other business in the group.

ONLINE TRACKING NOTICE

Third-party services, such as providers that display advertisements on our website or analytics companies, may be engaged. These companies 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 are used to collect information about your preferences and browsing habits to enhance your experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and last for a short time until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and make it easier for you to return to the Website.

7. Cookies and Third-Party Services

We may use them according to their intended purpose:

Cookies are blocked or have been removed
To manage or remove cookies, update your browser settings. Below are links to guide you through the process for a range of 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 This service does not currently recognise Do Not Track signals.
8. Retention of your personal data

The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer where permitted by laws, regulations, policies, and applicable orders. We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold to confirm whether it is still required.

9. Transfers of personal information to a foreign country or an international organisation

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 organisations), as well as to international jurisdictions. Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that individuals can assert their rights and access effective legal remedies.
These protections and safeguards are available to all persons residing in the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has determined provides an adequate level of protection for Personal Data transferred to it, 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')
• The transfer is effected under a legally binding and enforceable agreement between public entities or authorities pursuant to Article 46(2)(a).
• The transfer was conducted in accordance with the European Commission’s Standard Contractual Clauses adopted under Article 46(2)(c) of the GDPR. The Commission’s adopted clauses are available 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 about the security measures it uses to protect your Personal Data when 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 appropriate organisational and technical measures to protect Personal Data, including preventing accidental or unlawful destruction, loss, or alteration.
While we strive to secure your Personal Data, we cannot guarantee error-free security and are not liable for any indirect, incidental, or consequential loss arising from its use or disclosure, including, without limitation, disclosure due to transmission errors, unauthorised third-party access, or other causes beyond our control.
Where required by law or by other obligations beyond our control, we may need to provide your Personal Data to third parties, such as public authorities, and we cannot control the safeguards those third parties apply to your information.
Because data transmitted over the internet cannot be completely secure, the Company cannot ensure the security of Personal Data you send to Us online.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided on this site. These applications and websites do not fall under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by those websites or apps. This Policy does not apply to actions taken through such sites or apps.
When you visit any third-party websites or apps, we recommend you read their privacy policies before deciding to access or use them. We also suggest doing so before you provide any Personal Data to them.

12. Amendments to this Policy

This Policy may be updated at any time. If we make changes to this Policy, we will notify you by posting the revised Policy on our website. In addition, when we make significant updates to this Policy, we will attempt to inform you through the methods we consider appropriate and will publish a notice on our website. Unless explicitly stated otherwise, any amendments take effect upon publication of the revised Policy.

Your rights in relation to your personal information

You are entitled to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete Personal Data that is not required by Us. You may also restrict the scope and types of processing of your personal information. If you are an EEA resident, please refer to this page:
These rights are available to you with respect to the information you provide regarding your Personal Data. You can request to exercise your rights by emailing the address below.Access rights
The Company can verify whether Personal Data about you is being processed. Where it is, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. If you request it, the data will be made available electronically.
Your right of access must not conflict with the rights and freedoms of others. If your request would adversely affect the rights or freedoms of another person, the Company may refuse to comply or limit its response.Right to rectification
The Company will rectify inaccurate Personal Data. You are entitled to require that any incomplete Personal Data concerning you be completed, taking into account the purposes of processing.Right to erasure
You may request erasure where: (a) the Personal Data 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, at any time and on grounds relating to your particular situation, to processing based on legitimate interests pursued by Us or a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased to comply with a legal obligation of the Company. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law, or (b) for the establishment, exercise, or defence of legal claims.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If processing is restricted, Personal Data may only be stored, or processed with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another natural person, or for reasons of important public interest of the European Union or a Member State.
Right to data portability
Where processing is carried out by automated means and is based on your consent or on a contract to which you are party, you have the right to receive the Personal Data you have provided to the Company.
You may also request that your Personal Data be transmitted directly from the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to portability must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time to the processing of Personal Data concerning you that is based on the legitimate interests of the Company or a third party, including profiling based on those interests. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.
For direct marketing, you have the right to object at any time to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent to Us processing your Personal Data at any time. This does not affect the lawfulness of processing carried out before your withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to protect the fundamental rights of individuals regarding the processing of Personal Data within the European Union.
European Union and Member State laws may restrict your rights relating to your Personal Data as described in section 13. We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. This period may be extended by up to two further months if necessary, considering the complexity and number of requests. Within one month of receiving your request, we will inform you of any extension and the reasons.
Unless otherwise provided under section 13, the information you request under your rights will be provided free of charge. If a request is manifestly unfounded or excessive, particularly due to repetition, we may charge a reasonable fee to cover administrative costs or may refuse to act.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information.