We (also referred to as 'We', 'Us', or 'Our') remain fully committed to protecting your Personal Data and safeguarding your privacy.
This Privacy Policy is intended to inform you, as a user, about how we collect and store the information you provide on the Gaingate website (the 'Website').
We uphold the following principles:

We are committed to being transparent about how we collect and use your personal information in your best interests:

By doing so, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website uses several methods and procedures to provide relevant information about how Personal Data is handled. For example, if you require specific details about your data, we will work diligently to ensure you receive them promptly and at the appropriate time. Should you have any questions, we are happy to clarify any legal constraints. To contact us, please email us at info@blue-orion.com

We will use Personal Data solely for the purposes described in the Policy

You will find that we process Personal Data for several purposes; these include providing the website to you, connecting you with third-party platforms for trading (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, ensuring full compliance with legal and regulatory requirements, and carrying out administrative and business activities that enable the provision and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Securing access to essential resources to protect and uphold your rights in relation to Personal Data

Our goal is to help you make well-informed decisions about how we handle your data. This commitment explains why we built this website. To support it, we use a range of methods and procedures to ensure you consistently receive the most relevant information regarding the use of your Personal Data. When specific details are required, we will provide them at the appropriate time. If you have questions about how this process works, we are happy to respond and offer clarifications, all within applicable legal requirements. To learn more, please contact us at info@blue-orion.com

Keep Your Personal Information Safe and Secure

Although absolute security of Personal Data cannot be guaranteed by anyone, we remain fully committed to protecting your Personal Data through a broad set of technical and organizational safeguards. Our Privacy and Security Policy covers all key areas to help ensure your long-term safety.

Scope?

By reviewing this Policy, you will find a clear overview of the types of Personal Data our Company collects from customers, together with the purposes and methods for processing, sharing with third parties, and safeguarding that data. This Policy applies to information about an identified or identifiable natural person, where an individual can be recognized directly or indirectly through additional information we hold or can lawfully access. For the purposes of this Policy, 'processing' refers to any operation performed on Personal Data, including its collection, recording, use, management, organization, storage, retrieval, disclosure, and deletion. This includes, by way of example, the management, organization, and storage of Personal Data. Our services are intended for a general audience and are available only to individuals 18 years of age or older. We do not authorize the use of our services by anyone under this age and do not knowingly collect information from minors. If we become aware that we have collected any data relating to a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

If you use our services or channels, or browse our website, you agree that we may collect personal data about you. In some cases, we may ask you to provide this information directly. We may also collect it by analyzing your interactions with our services or channels, or through our third-party partners

3. You are not required to provide your personal information to our company or deal with any consequences 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 certain features.

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

The data we collect includes details from your activity log; traffic data (such as IP address and the date and time of access); 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. Some of the Personal Data we obtain comes from information you voluntarily provide when you connect to a third-party online trading platform through us. We also collect the personal details you provide 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 does so in accordance with the applicable legal framework.
We require a valid legal basis because, without it, Our Company cannot process personal data relating to you. The lawful 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 provide personal information via the Website for us to share with a third-party trading platform
• The Company or a third party may, from time to time, need to process this information to pursue their legitimate interests. Examples include enhancing our Services or defending against potential legal claims.
• All processing activities on our website are required to comply with applicable legal requirements, and we can confirm that they do comply with these requirements.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email for further details.
Below, we’ve outlined the reasons and legal bases on 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 parties that provide services such as data storage, IP address processing, 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 occurs, those platforms’ privacy policies will govern how your data is used. 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. We do this to access the resources needed to enhance and continuously improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or other authorities to protect the rights or property of others.
We may likewise share your Personal Data with interested investors or buyers, or with lenders to the Company or its affiliated companies. This typically takes place in the context of transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or other parties connected to the Company.

Online Tracking Notice

We may use third-party services, such as advertising providers or analytics firms, on our website. These companies may also use cookies and similar technologies that collect data.
When we say cookies, we’re referring to 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 with the goal of improving the user experience, understanding those preferences, and developing products and services aligned with customer interests. Additionally, cookies help us compile data 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. 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 keep 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 have been blocked or deleted
You can manage your cookie preferences in your browser settings. You can use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that certain functions and features of this website may not work as intended 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 We Store Your Personal Information

Please note that Our Company will retain your Personal Data for as long as necessary to fulfill the purposes outlined in this Policy, or for a longer period as permitted by applicable regulations and for relevant 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 another 12 months, if needed.
We periodically review and evaluate the Personal Data we hold to ensure it is still required.

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

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

• In some cases, we may transfer your Personal Data to a third country or international organization that the European Commission recognizes 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 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 compliance 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 our practices and how they align with the security measures we use to protect your Personal Data when transferred to third countries or international organizations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

To protect your Personal Data, we have implemented robust security measures. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
While we take every precaution, we cannot guarantee that your Personal Data will always be securely maintained without error, nor can we be held liable for intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by transmission errors, unauthorized third-party access, or other events beyond our control.
Where we are legally required—or in 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 control the security practices of those third parties.
Please note that transmitting Personal Data over the internet is never completely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of Personal Data you send to us online.

11. Regarding Links to Third-Party Websites

Our website includes 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 covers activity on our website only and does not extend to third-party websites.
Before visiting any third-party website or app, review its privacy policy prior to using its services. You should also carefully consider whether you wish to share your Personal Data with them.

12. Understanding Amendments to Our Policy

We may update this Policy at any time. If we make changes, we will notify you on our website and display the updated Policy for your review. For significant updates, we will use the communication methods we consider most appropriate, and we will also publish an announcement on our website to ensure you are informed. Unless we state otherwise, all updates to this Policy will take effect immediately upon publication of the revised Policy on our website.

Your Rights as They Relate to Your Personal Data

Your rights allow you to request a review of the personal data we collect about you, to have it corrected, 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. If you reside in the EEA, please refer to this page:
Anyone who wishes to exercise their data rights may contact us using the email address below. Access rights
We will assess the accuracy of the Personal Data processed. If 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. Upon request, we will deliver this information electronically.
Your right of access must not infringe the rights of others. If a request would compromise the rights of others, we may refuse to comply or limit our response. Your rights related to rectification
If you wish to correct inaccurate Personal Data, you may ask us to 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 withdraw consent and there is no other legal basis for processing; (c) you object to certain processing; (e) unlawful processing of Personal Data; or (f) compliance with a legal obligation. This right does not apply where processing is necessary (a) to comply with EU or Member State law 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. While restricted, the data may be stored and processed only with your consent, to protect another’s rights, to establish, exercise, or defend legal claims, or for important public interest of the EU or a Member State.
Right to data portability
For automated processing based on consent or contract, you have the right to receive all Personal Data the Company processes about you.
You also have the right to request that we transfer the data 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 use of your Personal Data based on legitimate interests pursued by the Company or third parties, including related profiling. We will proceed only where we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
You may 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 prior to withdrawal.
You also have the right to lodge a complaint with the authority supervising your Personal Data rights.
You may likewise 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, but we may extend this to two months depending on the complexity and number of requests. We will notify you within one month of receipt of any extension and the reasons.
We will provide information requested under section 13 free of charge unless a request is manifestly 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 reasonable doubts about your identity in connection with a request, the Company may request additional information.