We (also referred to as 'We', 'Us', or 'Our') are fully committed to protecting your Personal Data and safeguarding your privacy.
This Privacy Policy is designed to inform you 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 process your personal data in your best interests:

Through these efforts, our goal is to help you make informed choices about the use and processing of Personal Data. To achieve this, our website uses a range of methods and procedures to share relevant information about Personal Data usage. If you require specific details about your data, we will work diligently to provide them promptly and at the appropriate time. Should you have any questions, we are happy to clarify anything regarding legal requirements. To contact us, please email us at info@blue-orion.com

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

We process Personal Data for various purposes, including providing the website, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, fully complying with legal and regulatory requirements, and performing administrative and business activities that enable the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Ensuring access to vital resources as a means to effectively protect your rights concerning Personal Data

Our goal is to help you make well‑informed choices about how we handle your data, and this website was created with that purpose in mind. To support this, we apply a range of methods and procedures to ensure you consistently receive the most relevant and accurate information about the use of your Personal Data. We also review and update our materials regularly to keep them current and useful. When specific details are needed, we will provide them to you at the appropriate time. If you have any questions about how this process works, we are happy to answer them and offer clear explanations, always within applicable legal requirements. If you would like to learn more, please contact us via email at: info@blue-orion.com

Ensure Your Personal Data Remains Secure and Protected

While no one can guarantee the absolute security of Personal Data, we remain fully committed to employing a wide range of measures to protect your Personal Data. Our Privacy and Security Policy covers all essential areas to help ensure your long-term safety.

Scope?

In this Policy, you will find an overview of the types of Personal Data our Company collects from customers, as well as how we process it, share it with third parties, and keep it secure. Our Policy covers information about an identified or identifiable individual, meaning we can recognize a person directly or indirectly using additional information in our possession or accessible to us. For the purposes of this Policy, “processing” means any operation performed on Personal Data, including its management, organization, and storage. Our services are intended for a general audience but are not available to anyone under 18, and we do not permit use by individuals under this age. Accordingly, we do not knowingly collect information from anyone under 18. If we become aware that we have collected data about a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

By using our services and channels or browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you to provide this data directly. Alternatively, we may analyze your interactions with our services or channels, or work with third-party partners, to obtain this information

3. You are not obligated to provide your personal information to our company or to accept the implications of doing so

You are not required to share personal data with us. However, in some cases, choosing not to provide this information may affect our ability to deliver services to you, which could result in 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 technical information such as activity log details, traffic data (including IP address, access dates and times), the language you use on our site, software crash reports, browser type, and device specifications. This information is non-personal, and we do not use it to identify you. We may also obtain Personal Data from you, namely any information you voluntarily provide when connecting to a third-party online trading platform through us. In addition, we receive the personal details you submit directly to those 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 set out in this section and in compliance with applicable law.
A valid legal basis is required; without it, our Company cannot process your Personal Data. The legal grounds we rely on 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 provide personal information via the Website so we can share it with a third-party trading platform
• The Company or a third party may need to process the information to pursue their legitimate interests. Examples include improving our Services or defending against potential litigation.
• All processing activities on our website must comply with all applicable laws and regulations, and we confirm that they do.

For more information about how we process Personal Data to protect our legitimate interests, please reach out to us via email at any time for assistance.
Below, we have set out the reasons and legal bases for which we may use the personal information you have provided 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, hosting, IP address processing, or user experience analysis.
We also process 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 choose. Their privacy policies will then govern its use. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may also 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 appropriate, the Company may disclose Personal Data to regulatory, local, or other competent authorities to protect the rights or property of others.
We may likewise share your Personal Data with prospective investors or buyers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy involving the Company or related parties.

Online Tracking Notice

On our website, we may use third-party services, such as advertising partners or analytics providers. These companies may also use cookies and similar technologies that collect data.
By cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies to learn about your preferences and browsing patterns, with the aim of improving the user experience, understanding interests, and designing products and services based on customer interests. Cookies also help us gather information for statistics and analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily downloaded to your device and expire when you close your browser. Others are persistent cookies, which remain on your device after you close your browser. These cookies allow the website to 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 how it is used may vary depending on its intended purpose.

Cookies may be blocked or have been removed
You can manage your cookie settings via your browser options. You can use the links below for guidance with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that certain website features and functions may not work as expected if this occurs.

Online Tracking Notice Please be aware that, at present, our service does not recognise Do Not Track requests.
8. Learn More About How Your Personal Information Is Stored

Please note that Our Company will retain your Personal Data for as long as necessary to fulfill the purposes set out in this Policy, and, where permitted by law, we may keep it longer to meet legal requirements and applicable orders. In some 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.
We periodically review and assess the Personal Data we hold to ensure it is still required.

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

In certain circumstances, we may transfer your Personal Data to other countries or to international organizations, which means we have your permission to send this data outside your country. We take all necessary measures to protect and defend your Personal Data and ensure that you can exercise your rights and effectively access legal remedies if needed.
All residents of the EEA (European Economic Area) can take advantage of these protections and safeguards.

• In certain cases, we may transfer your Personal Data to a third country or an international organisation that the European Commission recognises 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 the transfer occurs, we execute it under a legally binding, enforceable agreement between public entities or authorities pursuant to Article 46(2)(a)
• We carry out the transfer in compliance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. For those who wish to learn more, 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 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 countries or international organisations, please email us at: info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented appropriate technical and organisational security measures. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take extensive precautions, we cannot guarantee that your Personal Data will be maintained securely without error, nor can we be held liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by transmission errors, unauthorised access by third parties, or other events 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 oversee the security measures those third parties provide.
Please note that transmitting Personal Data over the internet cannot be made completely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of the Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website may contain 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. Our Policy explains what happens on our website but does not extend to third-party websites.
Before following any link to a third-party website or app, you should review their privacy policies before using their services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding the Changes to Our Policy

We reserve the right to update or modify this Policy at any time. If changes are made, we will notify you on our website and present the updated Policy for your review. For material updates, we will use the communication methods we deem most appropriate and will post an announcement on our website, and where relevant, via other channels, to alert you. Unless we indicate otherwise, all amendments to this Policy take effect immediately upon the release and publication of the revised Policy.

Your Rights Regarding Your Personal Data

You have the right to request access to the personal data we collect about you, to have it rectified, and to ask us to delete any Personal Data you do not wish us to retain. You also have the right to restrict certain types of data we may process. For those residing in the EEA, please check out this page:
Anyone who wishes to exercise their data rights may contact us using the email address below. Access rights
We will verify the accuracy of the Personal Data we process. If accurate, we will grant you access to your Personal Data and provide an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, we will provide this data electronically.
Your right of access must not infringe the rights and freedoms of others. If a request would impact those rights, we may refuse to comply or limit our response. Your rights related to rectification
If you wish to correct inaccurate Personal Data, you may request that we rectify incomplete or incorrect information. Your Right to Erasure
Legitimate grounds may include: (a) we no longer need the personal data for its original purpose; (b) you withdrew consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (e) the Personal Data was processed unlawfully; 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 laws 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. Where processing is restricted, we may store the data but will only process it with your consent, for the establishment, exercise, or defense of legal claims, to protect another person’s rights, or for important public interest of the EU or a Member State.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive the Personal Data you provided to the Company.
You also have the right to request that this data be transferred to another controller where technically feasible. Exercising your right to data portability 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 the legitimate interests of the Company or third parties, including related profiling. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is required for the establishment, exercise, or defense of legal claims.
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 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 a Member State to protect your individual rights regarding Personal Data processing within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request, with a possible extension of 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 decline to act on the request.
If we have doubts about your identity in connection with a request, the Company may ask for additional information.