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 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 being transparent about how we collect and use your personal information in your best interests:

In doing so, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website employs several methods and procedures to clearly provide relevant information about how Personal Data is collected, used, and processed. If you need specific details about your data, we will make every effort to deliver them promptly and at the appropriate time, in line with our obligations. If you have any questions, we are happy to clarify any applicable legal requirements and constraints. To contact us, please email us at info@blue-orion.com

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

We process Personal Data for a range of purposes, including making the website available to you, connecting you with third‑party trading platforms (the 'Services'), improving and optimizing the site, protecting our rights and legitimate interests, and operating, maintaining, and provisioning the Services. We also process data to ensure full compliance with legal and regulatory obligations, and to carry out the administrative and business activities necessary to enable the delivery and use of the Services. In addition, we use your Personal Data to better understand your preferences and needs.

Ensuring access to essential resources to effectively protect your Personal Data rights and freedoms

We have set a clear goal: to help you make well-informed choices about how we handle your data and to explain our practices clearly. That commitment is the reason we invested the time to develop this website. To support it, we use a range of methods and procedures, including notices, explanations, and updates, and regularly review them to ensure you continue to receive the most relevant information about our use of your Personal Data. If you require specific details, we will provide them at the appropriate time. If you have any questions about how this process works, we are ready to answer and clarify, always within applicable legal requirements and standards. If you wish to learn more, please contact us via email at: info@blue-orion.com

Keep Your Personal Data Safe and Secure

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

Scope?

Reviewing this Policy, you will find an overview of the types of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and keep it secure. Our Policy concerns information about an identified or identifiable individual, where a person can be recognized directly or by combining it with other information we hold or can access. For the purposes of this Policy, “processing” means any operation performed on Personal Data, including its use or handling. This covers activities such as the management, organization, and storage of Personal Data. Our services are intended for a general audience, but they are not available to anyone under 18 years of age. We do not permit individuals under this age to use our services. Accordingly, we do not knowingly collect information from anyone under 18, as they are not allowed to use our services. If we become aware that we have collected data about a person under 18, we will delete it promptly.

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 information directly. Alternatively, we may analyze your interactions with our services or channels to gather this information, or obtain it through our 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 personal data with us. However, if you choose not to provide certain personal data, it may affect our ability to deliver our services, which could result in limited access to our website or restricted use of certain features.

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

The Personal Data we collect includes information such as activity log details, traffic data (including IP address and access date and time), the language you use 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 you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we receive the personal details you submit directly to those platforms, which may include 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 described in this section and in compliance with applicable legal requirements.
We must rely on a lawful basis because, without one, our Company cannot process 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, including when you submit personal information through the Website for us to share with a third-party trading platform
• The Company or a third party may need to process this information to pursue their legitimate interests. Examples include improving our Services or defending against potential legal claims.
• All processing on our website must comply with applicable legal requirements, and we confirm that these requirements are met.

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 purposes and legal bases under which we may use the personal information you have provided to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

In certain circumstances, the Company may disclose Personal Data to third-party service providers, such as data storage, IP hosting, or user experience analytics.
We also honor 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. When this happens, the use of your data will be governed by their privacy policies. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may also share Personal Data with its business partners and affiliated entities. This allows us to access the resources we need to enhance and continually improve our customer offerings.
When necessary, 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 affiliated companies. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, 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 firms. These companies may also use cookies and 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 gather information about your preferences and browsing patterns to enhance the user experience, better understand your interests, and help us design products and services aligned with customer needs. Cookies also support our statistical and analytics efforts.
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 known as persistent cookies because they remain on your device even 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 are blocked or have been removed
You can manage your cookie preferences in your browser settings. Click the links below for help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be advised that some website functions and features may not perform as intended or work properly if this occurs.

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

Please note that Our Company will retain your Personal Data for as long as necessary to fulfill the purposes described in this Policy and, where applicable, to comply with legal or regulatory obligations and order‑fulfillment requirements, and may retain it longer where the law allows. In certain cases, your information may be shared with authorized third‑party trading platforms for up to 12 months. With your consent, we may extend this sharing for an additional 12 months if needed.
From time to time, we review and evaluate the Personal Data we hold to ensure we do not keep information we no longer require.

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

Under certain circumstances, we may transfer your Personal Data to other countries, meaning it could be sent to a country other than your own or to international organizations, with your consent where required by law. We take all necessary measures to safeguard your Personal Data and ensure you can exercise your rights and effectively access legal remedies if needed.
All residents of the EEA (European Economic Area) can 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 recognises as providing an adequate level of protection, 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 the transfer in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, 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 would like more information about these details and how they relate to the security measures we implement to safeguard your Personal Data when it is transferred to third-party countries or international organizations, please contact us at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented robust technical and organizational security measures. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
With that in mind, although we take extensive precautions, we cannot guarantee that your Personal Data will be maintained 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 resulting from transmission errors, unauthorized access by third parties, or other causes beyond our control.
Where we are legally obliged to do so, or due to other constraints 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 measures those third parties provide.
Please note that transferring Personal Data over the internet cannot be made entirely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of your Personal Data that you transmit to us online.

11. Information on Links to Third-Party Websites

Our website may link to external sites and applications that are beyond our Company's control. As such, we are not responsible for how those third-party websites collect or process your Personal Data. While our Policy explains what happens on our website, it does not apply to third-party websites.
Before visiting any third-party site or app, you should review its privacy policy before you begin using its services. You should also carefully consider whether you wish to share your Personal Data with them.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If changes occur, we will notify you on our website and display the revised Policy. For significant updates, we will communicate through the channels we deem most appropriate and publish an announcement on our website. Unless stated otherwise, all amendments take effect immediately upon publication of the updated 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 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 check out this page:
Anyone wishing to exercise their data rights may contact us using the email address below. Access rights
We will verify the accuracy of the Personal Data processed. 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. When requested, we will provide this data electronically.
Your right of access must not infringe on the rights of others. Where a request would affect others’ 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 include: (a) we no longer need the personal data for its original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to certain processing; (e) the Personal Data has been processed unlawfully; or (f) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with Member State or EU law or (b) to establish, exercise, or defend legal claims.
Restrictions on processing
You may ask us to limit processing if you believe the data is inaccurate. While restricted, data may be retained only with your consent, to protect another person’s rights, to establish, exercise, or defend legal claims, or for important public interest of a Member State or the EU.
Right to data portability
For automated processing based on consent or a contract, you have the right to obtain all Personal Data the Company processes about you.
You also have the right to request that the data be transferred to another controller where technically feasible. Exercising data portability 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 can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or we need the data to establish, exercise, or defend 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.
You also have the right to lodge a complaint with the authority supervising your Personal Data rights.
You may additionally 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. 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 to two months depending on the nature and number of requests. You will be notified within one month of any extension and the reasons.
We will provide information requested under section 13 free of charge unless a request is unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act.
If we have doubts about your identity in connection with a request, the Company may request additional information.