We (referred to as 'we', 'us', or 'our') are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the 'Website').
We uphold the following principles:

To provide transparency about how we collect and process your personal information:

We want you to be able to make informed decisions about the use and processing of Personal Data. That is why we created this website. To achieve this, we use various methods and procedures to provide you with clear, relevant information about the use of Personal Data. If we believe you need specific details, we will provide them at the appropriate time. We are happy to answer any questions and will offer any clarifications you require, subject to any legal limitations. You can contact us by email at the following address: info@blue-orion.com

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

We may process Personal Data for a range of purposes, including providing the website to you and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, facilitating the maintenance and delivery of the Services, meeting regulatory and legal obligations, and conducting administrative and business activities to support the provision and use of the Services. We also process Personal Data to better understand your preferences and needs.

To access essential tools that help safeguard your rights in relation to Personal Data:

We want you to be able to make informed decisions about the use and processing of Personal Data. That’s why we created this website. To achieve this, we use various methods and procedures to provide you with relevant information about the use of Personal Data. If we believe you need specific details, we will share them at the appropriate date and time. We are happy to answer any questions and provide any clarifications you require, subject to any legal limitations. You can contact us via email at the address below: info@blue-orion.com

Protect your personal data:

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

1. The Scope?

This Policy explains the types of Personal Data the Company collects about individuals and how we process it, share it with third parties, and keep it secure. This Policy relates to information about an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, using information we hold or can access. The Policy defines 'processing' as any operation that involves the use or collection of Personal Data. This includes the management, organisation, structuring, and storage of Personal Data. Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from anyone under 18 years old, and we do not knowingly permit such persons to use our services. If we become aware that we have information about a child, we will erase it as quickly as possible.

2. What Personal Data Do We Hold About You?

When you use our services and channels, or visit our website, we collect Personal Data. In some situations, we may ask you to provide Personal Data. In others, we collect it by analysing how our Services and channels are used, or by receiving information about you from our third-party partners.

3. No obligation to disclose personal information to the company and the associated consequences.

You are not obliged to provide Us with any Personal Data. However, in certain circumstances, choosing not to do so may prevent Us from providing the Services or may limit users' access to the website.

4. What personal data may we collect? When you visit our website, we may collect the following personal information from you:

This includes details of your online activity log and traffic data (such as IP address, date and time of access), the language you use, software crash logs, browser type, and information about the device you use. The information we collect is non-personal and cannot be used to identify you. Personal data we receive from you: any personal data you voluntarily provide to us when you connect with a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading: this may include your full name, address, telephone number, and email address.

5. The Legal Basis and Purposes for the Processing of Personal Data

Your Personal Data is processed by the Company for the purposes set out in this section, in line with the applicable legal basis.
Without a valid legal basis, the Company cannot process your Personal Data. The legal grounds on which the Company may process your Personal Data are:

• You have consented to the processing of your Personal Data for one or more purposes. This applies when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
• The Company or a third party may need to carry out processing to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
• Processing must comply with a legal obligation.

Contact us via email for further details about the processing required to safeguard legitimate interests.
Below is a list of purposes and legal bases on which we may use the information you provide to us. Personal Data.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers that support us with hosting and storage, IP address management, and user experience analytics.
You may also request that we provide specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you provide to Us with those platforms. Their use of your Personal Data is governed by their own privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to access resources that help enhance and improve the products and services we provide to our customers.
Where necessary to protect the rights or property 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 or purchasers, or with lenders to the Company or any other group company, in connection with a relevant transaction (including the sale or transfer of assets of the Company or any other group company), or as part of any merger, restructuring, consolidation, or insolvency of the Company or any other business within the group.

ONLINE TRACKING NOTICE

We may use third-party services, such as advertising providers on our Website or analytics companies. These providers may also use cookies or other technologies.
Cookies are small text files placed on your device whenever you visit or access the Website. We use cookies to collect information about your preferences and browsing habits, improve your user experience, remember your settings, and customise the products and services you may enjoy. Cookies are also used for statistical and analytics purposes.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and make it easier for you to come back to the site.

7. Cookies and third-party services

We may use them depending on their purpose:

Cookies are blocked or have been removed
To block or remove cookies, adjust your browser settings. Below are links to guide you through the process for several 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 you expect if this occurs.

ONLINE TRACKING NOTICE This service does not currently recognise Do Not Track signals.
8. Retention of your personal data

The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and applicable orders. We will share your information with third-party trading platforms for a period of 12 months; with your consent, we will continue sharing your data for an additional 12 months.
We routinely review the Personal Data we hold to ensure it is not kept for longer than necessary.

9. Transfers of personal data to a third country or an international organisation

Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country—meaning a country other than the one in which you reside—or to international organisations or jurisdictions). The 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 recourse.
These protections and safeguards apply to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has determined ensures an adequate level of protection for personal data transferred to it 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 and enforceable agreement between public authorities or bodies under Article 46(2)(a).
• The transfer was carried out in accordance with the European Commission’s standard data protection clauses adopted under Article 46(2)(c) of the GDPR. The European Commission’s 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 provide details of the security measures it uses to protect your Personal Data when it is transferred to third countries or international organisations. To request this information, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented appropriate organisational and technical measures to protect Personal Data. These measures aim to prevent the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant the error-free security of your Personal Data. Nor can we be held liable for any intangible, incidental, or consequential losses arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure of Personal Data due to transmission errors, unauthorised third-party access, or other causes beyond our control.
In situations where legal or other obligations beyond our control apply, we may be required to provide your Personal Data to third parties, such as public authorities. We cannot control the level of security applied to your Personal Data by those third parties in such cases.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot ensure the security of Personal Data you send to us via the internet.

11. Hyperlinks to third-party websites

Links to third-party websites and applications are provided on our website. These websites and applications are not under the Company’s supervision or control. We are not responsible for the collection or processing of Personal Data by these third parties. This Policy does not apply to any activities carried out on such sites or apps.
When you visit any third-party website or app, we recommend that you carefully read their privacy policy before choosing to access or use it, and before providing any Personal Data to it.

12. Amendments to this Policy

This Policy may be updated at any time. If we make changes, we will notify you by posting the revised Policy on our website. For significant updates, we will also try to inform you through appropriate channels and will publish a notice on our website. Unless stated otherwise, any amendments will take effect once the revised Policy is published.

13. Your rights regarding your personal data

You are entitled to ask us to verify the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data we do not require. You may also restrict certain types of processing of your personal information. If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You may exercise your rights by emailing the address below. Access rights
The Company can verify the accuracy of the Personal Data processed about you. Where applicable, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you request it.
The right of access must not conflict with the rights and freedoms of others. If your request would adversely affect the rights and freedoms of another person, the Company may refuse to comply or limit its response. Right to rectification
The Company is entitled to rectify inaccurate Personal Data. You have the right to require that incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to erasure
The following reasons apply: (a) Personal Data are no longer necessary for the purposes for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, at any time and on grounds relating to your particular situation, to processing of your Personal Data based on legitimate interests pursued by us or by a third party; (e) Personal Data have been unlawfully processed; or (f) Personal Data must be erased to comply with a legal obligation of the Company. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise or defend legal claims.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where restriction is applied, Personal Data may be retained only with your consent, or for the establishment, exercise or defence of legal claims, to protect the rights of another natural person, or for reasons of important public interest in the European Union or a Member State.
Right to data portability
If processing is carried out by automated means and is based on your consent or a contract to which you are a party, you have the right to receive the Personal Data you have provided to the Company.
You may also request that your Personal Data be transmitted directly by the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.
Right to object
You may object at any time to the processing of Personal Data concerning you that is based on the legitimate interests of the Company or a third party, including profiling based on those interests. Unless we demonstrate compelling legitimate grounds for the processing 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.
Direct marketing You have the right to object at any time to the processing of your Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent for us to process your Personal Data at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
You are entitled to lodge a complaint with your supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to protect individuals’ fundamental rights in relation to the processing of Personal Data within the European Union.
The laws of the European Union and Member States may limit your rights regarding your Personal Data, as described in this Section 13. We will provide the information requested under your rights in Section 13 within one month of receiving your request. This period may be extended by up to two further months if necessary, depending on the complexity and number of requests. Within one month of receiving your request, we will inform you of any extension and the reasons for it.
Unless otherwise provided in Section 13, information provided under your rights in Section 13 will be made available free of charge. If a request is manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs of providing the information or taking the requested action, or we may refuse to act.
If we have doubts about the identity of the person making the request, the Company may ask for additional information.