We ('We', 'Us', or 'Our') are fully committed to protecting your Personal Data and safeguarding your privacy.
Our Privacy Policy explains how we collect and store the information you provide on the Gaingate website (the 'Website').
We uphold the following principles:

We aim to be transparent about how we collect and use your personal data in your best interests:

By doing so, our aim is to help you make informed choices about the use and processing of Personal Data. To support this, our website employs several methods and procedures to provide relevant information on how Personal Data is used. If you require specific details about your data, we will make every effort to ensure you receive them promptly and at the appropriate time. Should you have any questions, we will gladly clarify anything relating to legal requirements. To contact us, please email info@blue-orion.com

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

We process Personal Data for a range of purposes, including making the website available to you, linking you to third-party trading platforms (the 'Services'), improving the site, ensuring our rights and interests are safeguarded, carrying out ongoing maintenance and provisioning of the Services, ensuring full compliance with applicable legal and regulatory requirements, and undertaking administrative and business operations to facilitate the delivery and use of the Services, as well as supporting their effective operation. In addition, we process your Personal Data to help us better understand your preferences and needs.

Gaining access to essential resources to safeguard your Personal Data rights

Our goal is to help you make well‑informed choices about how we handle your data, and to be transparent at every step. This is the reason we developed this website and continue to improve it. To support that commitment, we use a range of methods and processes—such as clear notices, regular updates, and accessible guidance—to ensure you consistently receive the most relevant information about our use of your personal data. If you need specific details for a particular situation, we will provide them at the appropriate time. If you have any questions about how this works, we are happy to explain and clarify, always in line with applicable legal requirements and best practice. To learn more, please contact us at info@blue-orion.com

Keep Your Personal Information Secure and Protected

While we cannot guarantee the absolute security of Personal Data, as no system is completely secure, we remain fully committed to using a wide range of measures to protect your Personal Data. Our Privacy and Security Policy covers all key areas to help ensure your long-term safety.

Scope?

Within this Policy, you will find an outline of the types of Personal Data our Company collects from customers, together with the ways we process it, share it with third parties, and keep it secure. Our Policy covers information relating to an identified or identifiable individual, where a person can be recognised directly or by combining that data with other information we hold or can access. For the purposes of this Policy, 'processing' means any operation performed on Personal Data, including the collection, management, organisation, and storage of such data. Our services are intended for a general audience; however, they are prohibited for anyone under 18 years of age, and we do not permit individuals under this age to use our services. In line with this, we do not knowingly collect information from anyone under 18, as they are not allowed to use our services. If we become aware of any collection of data relating to persons under 18, we will take prompt steps to delete it.

2. What Personal Information Do We Collect from You?

By using our services or channels, or by browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you for your personal data directly. Alternatively, we may analyse your interactions with our services or channels to gather this information, or obtain it through our third-party partners

3. There Is No Requirement to Submit Your Personal Information to Our Company or Bear Any Implications Arising from Doing So

You are not required to share any personal data with us. However, in some cases, if you choose not to provide this personal data, it may affect how we deliver our services to you, which could lead to limited access to our website or restricted use of certain features.

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

The data we collect includes details from your activity log, traffic data (including IP address and the date and time of access), your language preferences on our site, software crash reports, browser type, and device specifications. This technical data is non-personal and we do not use it to identify you. We also obtain Personal Data that you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we collect from those platforms the personal details you provide to them, including your full name, email address, telephone number, and postal address.

5. What Are Our Lawful Bases and Justifications for Processing Personal Data

Our Company processes your personal data for the purposes outlined in this section and does so in accordance with the applicable legal framework.
We require a lawful basis, as without one Our Company cannot use your personal data in relation to you. The lawful 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, including when you submit Personal Data via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process information in order to pursue their legitimate interests. Examples of this include improving our Services or defending ourselves against potential litigation.
• All processing on our website must comply with applicable legal requirements, and we can confirm that it fully adheres to those requirements.

To learn more about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we’ve outlined the reasons and legal bases on which we may use the personal information you provide to us. Personal Data

6. How We Disclose Your Personal Data 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 accept requests from individuals who ask us 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 to proceed, the use of your data will be governed by those platforms' privacy policies. 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 to access the resources needed to enhance and improve our customer offerings.
Where appropriate, 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 purchasers, or with lenders to the Company or its affiliated companies. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or insolvency proceedings relating to the Company or parties associated with it.

Online Tracking Notice

You may encounter our use of third-party services on our website, such as advertising networks or analytics providers. These companies may also use cookies and similar technologies to collect data about how you use our services.
When we refer to cookies, we mean small text files stored on your device each time you visit or access our website. We use cookies to learn about your preferences and browsing behaviour so we can improve the user experience, better understand our audience, and design products and services aligned with customer interests. Cookies also help us gather information for statistical and analytical purposes.
Some of the cookies we use are session cookies. These are temporarily placed on your device and expire when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. These cookies allow the website to recognise 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 removed
You can manage your cookie settings via your browser's settings. You can also use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that some website functions and features may not perform as intended if this occurs.

Online Tracking Notice Please note that, at present, our service does not honour Do Not Track requests.
8. Learn More About How We Store Your Personal Information

Please note that Our Company retains your Personal Data for as long as necessary to meet the purposes set out in this Policy, and may keep it for longer where required or permitted by applicable laws, including for relevant orders, compliance obligations, and record-keeping and retention requirements. In certain circumstances and where relevant, your information may be shared with third-party trading platforms for up to 12 months. With your consent, we may extend such sharing for an additional 12 months, if it remains necessary.
We regularly review and evaluate the Personal Data we hold to confirm whether we still need it and to securely delete it when we do not.

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

Under certain circumstances, we may transfer your Personal Data to other countries, meaning that, with your permission, we could send this data to a country other than your own or to international organisations. We take all necessary measures to safeguard your Personal Data and to ensure you can exercise your rights and access effective legal remedies if needed.
All residents of the EEA (European Economic Area) benefit from these protections and safeguards.

• In certain cases, we may transfer your Personal Data to a third country or international organisation that the European Commission has recognised 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 and 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 view 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 would like further information on these details and how they relate to the security measures we apply to protect your Personal Data when it is transferred to third countries or international organisations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To safeguard your Personal Data, we have implemented comprehensive security measures. This includes preventing accidental or unlawful destruction, loss or alteration.
With this in mind, while we take every reasonable precaution, we cannot guarantee that your Personal Data will be maintained securely and free from errors, nor can we be held liable for any intangible, incidental or consequential losses arising from its use or disclosure. This includes, without limitation, disclosures resulting from transmission errors, unauthorised access by third parties, or other causes beyond our control.
In cases where we are legally obliged, or where other constraints beyond our control apply, we may need to share your Personal Data with third parties, such as public authorities. In such cases, we cannot control the security measures those third parties provide.
Please note that transmitting Personal Data over the internet can never be entirely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of any Personal Data you transmit to us online.

11. External Links to Third-Party Websites

Our website includes links to external sites and applications that are outside our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. While our Policy covers what happens on our website, it does not extend to third-party websites.
Before visiting any third-party website or app via a link, you should 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 Amendments to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will notify you on our website and display the updated Policy. For significant changes, we will notify you using the methods we consider most appropriate, including an announcement on our website. Unless stated otherwise, all amendments to this Policy take effect immediately upon publication of the revised Policy.

Your Rights in Relation to Your Personal Data

You have the right to request a review of the Personal Data we collect about you, to have it rectified, and to ask us to delete Personal Data you no longer wish us to process. You also have the right to restrict certain types of data we may collect or use. For those residing in the EEA, please refer to this page:
Anyone wishing to exercise their rights over their data may contact us using the email address below. Access rights
We will verify the accuracy of the Personal Data we process. Where appropriate, we will provide you with access to your Personal Data, including an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies of your data. Where requested, we will provide this information electronically.
Your right of access must not adversely affect the rights and freedoms of others. If a request would infringe the rights of others, we may refuse to comply or may need to limit our ability to fulfil your request. Your rights related to rectification
If you wish to correct inaccurate Personal Data, you may ask us to rectify any inaccuracies or complete incomplete information. Your Right to Erasure
Legitimate grounds may include: (a) we no longer need the Personal Data for its original purpose; (b) you have withdrawn consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (e) the Personal Data has been processed unlawfully; or (f) erasure is required to comply with the Company’s legal obligations. This right does not apply where processing is necessary (a) to comply with EU or Member State law or (b) for the establishment, exercise, or defence of legal claims.
Restriction of processing
You may ask us to limit processing if you believe the data is inaccurate. For data under restriction, we may only store it, or process it with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another person, 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 obtain the Personal Data the Company holds about you in a structured, commonly used and machine-readable format.
You also have the right to request that this data is transmitted to another controller where technically feasible. Exercising your data portability rights does not affect your right to erasure.
Right to object
You may object at any time to our use of your Personal Data based on legitimate interests pursued by the Company or third parties, including profiling related to those interests. Unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims, we will cease such processing.
You have the right to object at any time to the processing of Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing carried out before withdrawal.
In addition, you have the right to lodge a complaint with the supervisory authority responsible for your Personal Data rights.
You may also ask a supervisory authority in any Member State to protect your individual rights regarding the processing of Personal Data within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. We will provide the information referred to in section 13 within one month of receiving your request, but we may extend this by up to two months depending on the complexity and number of requests. You will be notified within one month of any extension and the reasons for it.
We will provide the information you request under section 13 free of charge unless the request is unfounded or excessive, particularly if repetitive. In such cases, we may charge a reasonable fee to cover administrative costs or may refuse to act on the request.
If we have doubts about your identity in relation to a request, the Company may request additional information.