We (referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide on the Gaingate website (the "Website").
We adhere to the following principles:

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

We want you to be empowered to make informed choices about the collection, use and processing of your Personal Data. Our goal is to ensure transparency and to maintain your confidence in our data-handling practices. That is why we have created this website: to explain our methods, procedures and practices in providing clear, accurate and relevant information. If we determine you require more specific details, we will supply them at the appropriate time. We are always happy to answer any questions you may have and will clarify any legal limitations that apply. You can reach us at any time via email at info@blue-orion.com

Personal Data will be used solely for the purposes set out in the Policy.

We may process Personal Data for various purposes, such as offering the website to you, connecting you with third-party trading platforms (the ‘Services’), enhancing the site, protecting our rights and interests, facilitating maintenance and delivery of the Services, meeting regulatory or legal obligations, and conducting administrative and business activities to support the Services. We also process Personal Data to better understand your preferences and needs.

To access powerful tools designed to safeguard your rights over Personal Data:

Our website has been created to enable you to make informed choices about the use and processing of Personal Data. We use a range of methods and procedures to provide clear, relevant information on our data practices. If you require specific details, we will supply them at the appropriate time. We are happy to answer any questions and clarify any points within the limitations imposed by law. You can contact us by email at info@blue-orion.com

Safeguard Your Personal Data:

Although we cannot guarantee absolute security of your Personal Data, we will continue to employ a range of methods and techniques to ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy explains the categories of Personal Data that Company collects from natural persons and describes how we process it, share it with third parties, service providers and affiliates, secure it and manage it across our operations. It applies to any information relating to an identified or identifiable natural person—someone who can be recognised directly or in combination with additional details we hold or can access. We define 'processing' as any operation conducted on Personal Data, including collection, use, disclosure, organisation, structuring, retention, storage, alteration or erasure. This Policy forms part of our commitment to protecting individual privacy and complies with applicable data protection laws. Our services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly seek or gather information from anyone under 18, nor do we knowingly permit children to use our services, and we will promptly erase any such data if we become aware of it.

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 ask you to provide this directly; in others, we collect it by analysing your use of our services and channels or obtain it from our third-party partners.

3. You are under no obligation to share personal information with the company or face any penalties.

You are not required to provide us with any personal data. However, in some circumstances, declining to do so may prevent us from offering certain services or hinder users from accessing the website.

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

This includes details from your online activity log, traffic data (including your IP address, date and time of access), the language you used, software crash reports, your browser type and information about the device you used. The data we collect is not private and cannot be used to identify you. Personal data we receive from you: any personal information you voluntarily provide when connecting to a third-party online trading platform through our service. Personal information you provide to third-party platforms to facilitate trades: 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 and in accordance with the relevant legal basis.
Without a legal basis, the Company cannot use your personal data. The legal grounds on which the Company may process your personal data are:

• You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information via the Website to enable its transfer 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 include enhancing Our Services or defending legal claims.
• Processing must comply with a legal obligation.

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

6. Transfer of Personal Data to Third Parties

The Company may share Personal Data, including IP addresses and user experience analytics, with third-party service providers—such as hosting and storage partners—under strict confidentiality obligations.
Upon your request, the Company can transfer specific Personal Data about you to third-party trading platforms. Any data you ask us to provide will be shared in accordance with their privacy policies and may be disclosed to multiple platforms.
The Company may also share Personal Data with its affiliates or business partners within the group to support and enhance the products and services it offers, always under appropriate contractual safeguards.
Where necessary to protect third-party rights or assets or to comply with legal obligations, the Company may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, the Company may share Personal Data with potential investors, buyers, or lenders in connection with any sale or transfer of assets, merger, restructuring, consolidation, due diligence, or bankruptcy involving the Company or its group companies.

ONLINE TRACKING NOTICE

Third-party services, such as advertising networks or analytics providers, may be engaged. These partners might also use cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or access the website. They collect information about your preferences and browsing habits to enhance your user experience, remember your settings, and personalise the products and services you see. Cookies are also used for statistical and analytical purposes.
Certain cookies, known as session cookies, are downloaded temporarily to your device and expire when you close your browser. Other cookies, called persistent cookies, remain on your device for a set period after you close your browser. These help the website recognise you as a returning user and allow you to revisit the site with ease.

7. Third-party cookies and services

We may use them for their intended purpose:

Cookies are currently blocked or removed
To block or remove cookies, please update your browser settings. Below are links to guides 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 currently does not support Do Not Track signals.
8. The retention of Your personal data

The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing set out in this Policy, or longer if required by law, regulations, policies or applicable orders. We share your information with third-party trading platforms for 12 months; if you consent, we will extend this for a further 12 months.
We regularly review retained Personal Data to ensure it is no longer needed.

9. Transfers of personal information to a third-party country (country_name) or an international organisation

Your personal information may be transferred to other countries, such as a third country (i.e. a country other than your country of residence), or to international organisations or jurisdictions. Company takes all necessary steps to safeguard the personal data you provide and to ensure that data subjects can exercise their rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has determined provides adequate 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')
• The transfer is made pursuant to a legally binding, enforceable agreement between public entities or authorities under Article 46(2)(a).
• The data transfer was carried out in compliance with the EU Commission’s standard data protection clauses adopted 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 outline the security measures it employs to protect your Personal Data when it is transferred to third-party countries or international organisations. For further information, please email us at info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organisational 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 maintained without error, nor can we accept liability 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, unauthorised third-party access or any other cause beyond our control.
Where we are legally or contractually required to disclose Personal Data, for example to public authorities, we cannot control the security measures applied by those third parties.
No method of transmitting Personal Data over the web is completely secure, and the Company cannot ensure the security of any Personal Data you transmit to us online.

11. Links to third-party websites

Links to third-party websites and applications are provided for your convenience; these platforms operate independently and are not managed by the Company. We do not oversee their collection or processing of Personal Data, and this Policy does not apply to actions you take on those sites or apps.
Before accessing or using any third-party website or app, we recommend reviewing its privacy policy and exercising discretion when sharing your Personal Data.

12. Updates to this Policy

This Policy is subject to change at any time. If we update this Policy, we will notify you by posting the revised version on our website. For significant modifications, we will also use the methods we consider appropriate to inform you and publish an announcement on our site. Unless otherwise specified, any amendments will take effect upon publication of the updated Policy.

Your rights in relation to your personal information

You are entitled to request that we verify the accuracy of any Personal Data we hold about you, rectify mistakes and erase any data no longer needed. You may also limit the scope of how your Personal Data is processed. If you reside in the EEA, please refer to this page:
These rights apply to all Personal Data you have provided. To exercise them, please email us at the address below.
Access rights
We can confirm whether we are processing your Personal Data and, if so, provide you with a copy. We will supply an electronic copy of your data and may charge a reasonable fee for additional copies. If you request it, the data will be provided electronically.
Your right to access is subject to the rights and freedoms of others. We may refuse or restrict access if fulfilling your request would adversely affect another individual.
Right to rectification
You may require us to correct any inaccurate or incomplete Personal Data concerning you, taking into account the purposes for which the data is processed.
Right to erasure
You may request the 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 there is no other legal basis for processing; (c) you object to processing based on legitimate interests and there are no overriding grounds for processing; (d) it has been unlawfully processed; or (e) it must be erased to comply with a legal obligation.
This right does not apply if processing is necessary: (a) to comply with a legal obligation under EU or Member State law; or (b) for the establishment, exercise or defence of legal claims.
Processing restrictions
If you question the accuracy of your Personal Data, you may request a restriction on its processing. While restricted, we may only retain your data with your consent or for the establishment, exercise or defence of legal rights, to protect another individual’s rights, or for reasons of significant public interest under EU or Member State law.
Right to data portability
Where processing is performed by automated means and based on your consent or a contract with you, 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 and must not infringe the rights and freedoms of others.
Right to object
You may object at any time to processing of your Personal Data based on our or a third party’s legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights or freedoms, or for the establishment, exercise or defence of legal claims.
Direct marketing
You have the right to object at any time to processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This will not affect the lawfulness of processing carried out before your withdrawal.
You are entitled to lodge a complaint with your supervisory authority. You may appeal to a Member State supervisory authority responsible for protecting individuals’ rights regarding Personal Data processing within the EU.
EU and Member State laws may limit your rights as described in this section 13. We will respond to your request within one month, extendable by up to two months for complex or multiple requests. We will inform you of any extension and its reasons within the initial one-month period.
We will provide the requested information free of charge unless requests are unfounded or excessive, in particular if repetitive. In such cases, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have doubts about the identity of the requester, we may ask for additional information.