We (also referred to as 'We', 'Us' or 'Our') are committed to safeguarding your Personal Data and privacy.
This Privacy Policy outlines how we collect and store any information you provide through the Gaingate website (the 'Website').
We uphold the following principles:

To maintain transparency in how we collect and process your personal information:

We are committed to helping you make informed decisions about the use and processing of your Personal Data. That’s why we’ve created this website. We use a range of methods and procedures to provide you with clear, relevant information on Personal Data handling. If you require specific details, we will supply them at the appropriate time. We are happy to answer your questions and clarify any legally imposed limitations. You can contact us via email at info@blue-orion.com

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

Personal Data may be processed by us for various purposes, including providing access to the website, connecting you with third-party trading platforms (the ‘Services’), enhancing the site, protecting our rights and interests, maintaining and delivering the Services, fulfilling legal or regulatory obligations, and conducting administrative and business activities. We also process Personal Data to better understand your preferences and needs.

To leverage essential tools to safeguard your rights regarding Personal Data:

We want you to make informed decisions about the collection and processing of your Personal Data. That is why we created this website—to offer transparent, up-to-date information. We employ a variety of methods and procedures to ensure you have relevant guidance on how your data is used. If you require additional specifics, we will provide them at the appropriate time. We continuously review and update this content to reflect any changes in data protection practices. We are available to answer any questions you may have and to clarify any legal limitations. Please feel free to contact us by email at the address below: info@blue-orion.com

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we are committed to continually deploying a diverse array of methods and techniques to protect it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the Personal Data the Company collects from individuals, and how we process, share, and secure that information. It applies to data related to identified or identifiable natural persons. An identifiable natural person is anyone who can be directly identified or distinguished using information we hold or have access to. In this policy, “processing” refers to any operation involving Personal Data, including collection, organization, storage, and management. Our services are designed for general audiences and are not intended for use by individuals under 18. We do not knowingly collect data from or permit access by minors. If we discover any information collected from a child, we will promptly delete it.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or website, we collect Personal Data. In certain cases, we may request your Personal Data directly. Otherwise, we collect it by analysing your use of our services or channels, or by receiving it from our third-party partners.

3. You are not required to disclose personal information to the company, and there will be no consequences.

You are not obliged to provide us with any personal data. However, in certain cases, withholding personal data may prevent us from providing the Services or restrict users from accessing the website.

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

This includes details of your online activity log, traffic data (including IP address, date and time of access), language preferences, software crash reports, browser type, and device information. These records are not private and cannot be used to identify you. Personal Data We receive from you: any personal data you voluntarily provide when you connect to a third-party online trading platform through us. Personal information you provide specifically to third-party platforms to facilitate trade: 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 described in this section and in accordance with the applicable legal basis.
Without a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company relies to process your Personal Data are:

• You have consented to the processing of your personal data for one or more purposes. This consent covers instances where you submit personal information through the Website so that we can forward it to a third-party trading platform.
• The Company or a third party may require processing to pursue their legitimate interests. For example, this may be necessary to improve Our Services or defend legal claims.
• Processing must comply with legal obligations.

Contact us via email for more information on the processing required to protect our legitimate interests.
Below is a list of the purposes and legal bases on which we may use your 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 providers such as hosting and storage companies.
You may also request that we disclose certain Personal Data about you to third-party trading platforms. In such cases, we will transfer the Personal Data you supply to those platforms. Their privacy policies govern the use of your information, and your data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to obtain the resources necessary to enhance and improve the products and services we offer.
To protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders to the Company or any group company in connection with a proposed or completed transaction (including the transfer or sale of assets), or as part of a merger, restructuring, consolidation, or bankruptcy of the Company or any group business.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be used. These services may also utilize cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to enhance the user experience, remember your settings, and personalize the products and services you receive. Cookies also support statistical and analytical purposes.
Some cookies are session cookies, temporarily downloaded to your device and expiring when you close your browser. Other cookies are persistent, remaining on your device for a set period after you close your browser. They help the Website recognize you as a returning user and allow you to revisit the Website.

7. Third-Party Cookies and Services

We may use them according to their purpose:

Cookies are blocked or removed
To block or delete cookies, adjust 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 work as expected if this occurs.

ONLINE TRACKING NOTICE Our service does not currently honor do-not-track signals.
8. Retention of Your Personal Data

The Company will retain your Personal Data for as long as necessary to fulfill the processing purposes described in this Policy or for any extended period required by law, regulation, policy, or order. We will share your information with third-party trading platforms for 12 months and, with your consent, for an additional 12 months.
We regularly review retained Personal Data to ensure it is no longer needed.

9. Transfers of personal information to a third country, country_name, or to an international organisation

Your personal information may be transferred to other countries (e.g. a third country beyond your place of residence) or to international organisations or jurisdictions. Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that you can assert your rights and pursue effective legal recourse.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third-country or international organisation that provides adequate security for Personal Data and has been recognised by the EU Commission under Article 45(3) of Regulation 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 and enforceable agreement between public entities or authorities under viro Article 46(2)(a).
• The transfer was carried out in accordance with the European Commission’s standard contractual clauses for data protection under Article 46(2)(c) of the GDPR. These clauses are available 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 provide details of the security measures it employs to safeguard your Personal Data when transferred to third-party countries or international organisations. Please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organizational and technical safeguards—such as encryption, access controls, and secure server environments—to protect Personal Data from accidental or unlawful destruction, loss, or modification.
However, we cannot guarantee or warrant that your Personal Data will be kept entirely error-free or immune to unauthorized access. We also disclaim liability for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, exposure due to transmission errors, unauthorized third-party access, or any other factors beyond our control.
In certain circumstances—such as compliance with legal or regulatory requirements—we may be compelled to disclose your Personal Data to third parties, including public authorities. We cannot control the security measures those parties implement.
Please note that no method of transmitting data over the Internet is completely secure; accordingly, the Company cannot ensure the absolute protection of any Personal Data you send to us online.

11. Links to third-party websites

Links to third-party websites and applications are provided on the website. These services operate independently and are not supervised by the Company. We are not responsible for the collection or processing of Personal Data by these sites or apps. This Policy does not apply to activities on these external platforms.
Before visiting or using any third-party website or app, we recommend that you read its privacy policy and consider carefully the disclosure of your Personal Data.

12. Amendments to this Policy

This Policy may be amended at any time. When we update it, we will notify you by posting the revised Policy on our website. For significant revisions, we will also attempt to inform you through appropriate channels—such as email, in-app notifications, or website banners—and prominently publish an announcement on our site. Unless explicitly stated otherwise, any amendments will take effect upon the publication of the updated Policy.

Your rights regarding your personal information

You have the right to ask us to verify the accuracy of any Personal Data we collect about you, correct any errors, or delete any data that we no longer need. You may also limit the types of processing we perform on your Personal Information. If you are an EEA resident, please refer to this page:
These rights apply to the Personal Data you provide to us. You can exercise them by sending an email to the address below.
Access rights
You can verify the Personal Data we process about you and request access to those records. We will provide an electronic copy of your Personal Data, and we may charge a reasonable fee for additional copies. Upon request, the data will be delivered electronically.
Your right of access must not infringe the rights and freedoms of others. If fulfilling your request would harm another person’s rights, we may refuse or limit our response.
Right to rectification
We will correct any inaccurate Personal Data about you. You may also request that incomplete data be completed, considering the purpose of processing.
Right to erasure
You may request that we erase your Personal Data for any of these reasons: (a) the data are no longer necessary for the purposes for which they were collected; (b) you withdraw consent and no other legal basis for processing exists; (c) you object, for reasons specific to your situation, to processing based on our or a third party’s legitimate interests; (d) the data have been unlawfully processed; or (e) erasure is required to comply with our legal obligations.
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 defense of legal claims.
Processing restrictions
If you dispute the accuracy of your Personal Data, you can request that we restrict its processing. Once restricted, we may only retain the data with your consent, to establish, exercise or defend legal claims, to protect another individual’s rights, or for reasons of substantial public interest under EU or Member State law.
Right to data portability
If we process your Personal Data by automated means based on your consent or a contract, you have the right to receive a copy of that data.
You may also request that we transmit your Personal Data directly to another controller, where technically feasible. Exercising your right to portability does not affect your right to erasure, and it must not infringe on the rights or freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on our or a third party’s legitimate interests, including profiling. If we demonstrate compelling legitimate grounds for processing that override your interests, rights and freedoms, or if processing is necessary for legal claims, we may continue.
Regarding direct marketing, you have the right to object to any processing of your Personal Data for this purpose at any time.
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 any processing carried out prior to withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may also appeal to any data protection authority established in the EU to safeguard individuals’ rights regarding Personal Data processing.
EU and Member State laws may limit your rights as outlined in Section 13. We will respond to your request under Section 13 within one month of receipt. If necessary, we may extend this period by up to two further months, depending on the complexity and number of requests. We will inform you of any extension and the reasons within the initial one-month period.
We will provide the requested information free of charge, unless requests are manifestly unfounded or excessive. In that case, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we doubt the identity of the requestor, we may request additional information to confirm your identity.