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

We are committed to transparency about how we collect and use your personal information in your best interests:

By doing so, our goal is to help you make informed decisions about the collection and processing of Personal Data. To support this, our website uses several methods and procedures, such as notices and layered disclosures, to provide clear, relevant information on Personal Data use. If you require specific details about your information, we will make every effort to deliver them promptly and at an appropriate time. If you have any questions, we are happy to explain anything related to applicable legal constraints. To contact us, please send an email to info@blue-orion.com

We will use Personal Data only for the purposes set out in this Policy

We process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and legitimate interests, maintaining, provisioning, and supporting the Services, ensuring full compliance with applicable legal and regulatory requirements, and conducting administrative and business activities necessary to deliver and facilitate your use of the Services. We also process your Personal Data to better understand your preferences and needs.

Access the essential resources you need to safeguard your rights when it comes to Personal Data

Our goal is to help you make well-informed decisions about how we handle your data and the choices available to you. This commitment is why we built this website and invested the time to make our practices transparent. To support it, we use a range of methods and procedures to ensure you continue to receive the most relevant information about how your Personal Data is collected, used, and safeguarded. If you need specific details, we will provide them at the appropriate time and in the appropriate context. If you have questions about our process, we are happy to explain and clarify, all within applicable legal requirements and industry standards. To learn more, contact us by email at info@blue-orion.com

Keep Your Personal Information Safe and Secure

While we cannot guarantee the absolute security of Personal Data—no one can—we remain fully committed to employing a range of safeguards to protect your Personal Data. Our Privacy and Security Policy covers all essential areas to ensure your long-term safety.

Scope?

In this Policy, you will find an outline of the types of Personal Data our Company collects from customers, along with the methods and purposes for processing, sharing with third parties, and protecting that data. This Policy applies to information about an identified or identifiable individual, meaning a person can be recognized directly or indirectly through information we hold or have lawful access to. In this Policy, 'processing' means any operation performed on Personal Data throughout its lifecycle, including its collection, use, disclosure, and handling. This includes managing, organizing, storing, and otherwise maintaining Personal Data. Our services are intended for a general audience but are not available to anyone under 18 years of age. We do not authorize individuals under this age to use our services. We therefore do not knowingly collect information from anyone under 18, as they are not permitted to use our services. If we become aware that we have collected data about a person under 18, we will promptly delete it and take steps to prevent further collection.

2. What Personal Information Do We Collect from You?

By using our services and channels, or by browsing our website, you consent to our collection of personal information about you. In some cases, we may request this information from you directly. We may also gather it by analyzing your interactions with our services or channels, or obtain it through our trusted third-party partners

3. You are not required to provide your personal information to our company or deal with any implications of doing so

You are not required to share any personal information with us. However, in some cases, choosing not to provide this information may affect our ability to deliver services, which could result in limited access to our website or certain features.

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

The data we collect includes technical information such as activity log details, traffic data (including IP address, access date and time), the language you use on our site, software crash reports, browser type, and device specifications. This data is non-personal, and we do not use it to identify you. We also obtain Personal Data you voluntarily provide when you connect to a third-party online trading platform through us. Additionally, we collect the personal details you give directly to these platforms, including 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 outlined in this section and in compliance with applicable laws.
We require a valid legal basis; without one, 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, such as when you provide personal information through the Website for us to share with a third-party trading platform
• The Company or third parties may process this information to pursue their legitimate interests. This can include improving our Services or defending ourselves against potential legal claims.
• All processing activities on our website must comply with applicable legal requirements, and we confirm that they do.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we have outlined the reasons and legal bases for which we may use the personal information you provide to us. Personal Data

6. How We Disclose Your Personal Information to Third Parties

Depending on the circumstances, the Company may disclose Personal Data to third parties that provide services such as data storage, IP address hosting, or user experience analytics.
We also accommodate 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. If you choose this option, their privacy policies will govern how your information is used. 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. We do this to access the resources needed to enhance and continually 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 involving the Company or other parties associated with the Company.

Online Tracking Notice

You may encounter third-party services on our website, such as advertising providers or analytics companies. These providers may also use cookies and similar technologies to collect data.
When we say cookies, we mean small text files stored on your device each time you visit or access our website. We use cookies to remember your preferences and understand browsing patterns, with the goal of improving the user experience, tailoring products and services to customer interests, and supporting statistics and analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily stored on your device and expire when you close your browser. Other cookies are persistent, meaning they remain on your device after you close your browser. These cookies help the website recognize you as a returning visitor and retain the preferences you previously set.

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

Each cookie and its use may vary depending on its intended purpose.

Cookies have been blocked or deleted
You can manage your cookie preferences in your browser settings. Use the links below for help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that certain website features and functions may not work as intended if this occurs.

Online Tracking Notice Please note that, at this time, our service does not recognize Do Not Track requests.
8. Learning More About How Your Personal Information Is Stored

Please note that Our Company retains your Personal Data for as long as necessary to fulfill the purposes described in this Policy and to meet our legal and regulatory obligations, or for a longer period as permitted by applicable law and for orders where applicable. In certain cases, your information may 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 and appropriate.
We periodically review and assess the Personal Data we hold to confirm whether it remains necessary for the purposes stated, and delete or anonymize it when it is no longer required.

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

In certain circumstances, we may transfer your Personal Data to other countries, which means we may do so with your permission to a country other than your own or to international organizations. We take all necessary measures to safeguard your Personal Data and ensure you can exercise your rights and obtain effective legal remedies if needed.
All residents of the EEA (European Economic Area) can rely on these protections and safeguards.

• In certain cases, we may transfer your Personal Data to a third country or international organization that the European Commission recognizes 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 carry it out under a legally binding, enforceable agreement between public bodies or authorities in accordance with Article 46(2)(a)
• We carry out data transfers in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. For more information, 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’d like more information about these details and how they relate to the security measures we use to safeguard your Personal Data when it is transferred to third-party countries or international organizations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Information

To safeguard your Personal Data, we have implemented robust security measures. These measures help prevent accidental or unlawful destruction, loss, or alteration.
Even so, despite our precautions, we cannot guarantee that your Personal Data will always be maintained error-free, and we are not liable for any intangible, incidental, or consequential damages that result from its use or disclosure. This includes, without limitation, disclosures due to transmission errors, unauthorized access by third parties, or other causes beyond our control.
Where we are legally required, or due to other circumstances 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 security that these third parties provide.
Please note that transmitting Personal Data over the Internet cannot be made completely secure and carries risks. Because of these risks, we cannot guarantee the security of your Personal Data when you transmit it to us online.

11. About Links to Third-Party Websites

Our website may include links to external sites and applications that are outside our Company's control. Accordingly, we assume no responsibility for how these third-party websites collect or process your Personal Data. This Policy applies only to activities on our website and does not extend to third-party websites.
Before visiting any third-party website or app, please review their privacy policies prior to using their services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding Changes to Our Policy

We may update this Policy at any time. If we make changes, we will notify you on our website and provide the updated Policy. For significant updates, we will use the methods we deem most appropriate and will issue an announcement on our website. Unless stated otherwise, all amendments take effect immediately upon the release of the revised Policy.

Your Rights as They Relate to Your Personal Data

You have the right to request access to the personal data we collect about you, to rectify it, and to ask that we delete any Personal Data you do not wish us to retain. You may also restrict the types of data we collect. For those residing in the EEA, please visit this page:
Anyone who wishes to exercise their data rights may contact us using the email address below. Access rights
We will assess the accuracy of the Personal Data we process. If it is accurate, we will grant you access to your Personal Data and provide 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 cannot infringe on the rights of others. If a request would affect the rights of others, we may refuse to comply or limit our response. Your rights to rectification
If you wish to correct inaccurate Personal Data, you may ask us to rectify incomplete information. Your right to erasure
Valid reasons may include: (a) we no longer need the personal data for its original purpose; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (e) unlawful processing of Personal Data; or (f) erasure is required to comply with a legal obligation. You cannot exercise this right if 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 limit processing if you believe the data is inaccurate. While restricted, data may be retained or processed only with your consent, to protect another person’s rights, for the establishment, exercise, or defence of legal claims, or for important public interest of an EU or Member State.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to access the Personal Data the Company holds about you.
You also have the right to request that this data be transferred to another controller where technically feasible. Exercising your portability rights does not affect your right to erasure.
Right to object
You may object at any time to our processing of your Personal Data based on the Company’s or a third party’s legitimate interests, including related profiling. 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.
You have the right to object to processing for direct marketing at any time.
Right to withdraw consent
You may withdraw your consent to processing at any time without affecting the lawfulness of processing before withdrawal.
In addition, you have the right to lodge a complaint with the supervisory authority responsible for Personal Data rights.
You may also ask a supervisory authority in a Member State to 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. 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 required and the reasons.
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 refuse to act on the request.
If there is uncertainty about your identity in connection with a request, the Company may request additional information.