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

To be transparent about how we collect and process your personal information:

We want you to be able to make informed decisions about the collection, use, and processing of Personal Data. That’s why we created this website. To achieve this, we use a range of methods and procedures to provide you with timely, relevant information about how Personal Data is used. If we determine you need more specific details, we will share them with you at the appropriate time. We are happy to answer any questions and will provide any clarifications you need, subject to legal limitations. You can reach us by email at: info@blue-orion.com

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

Personal Data may be processed by Us for various purposes, including to provide the website to you, connect you with third-party trading platforms (the 'Services'), enhance the site, protect our rights and interests, facilitate the maintenance and provision of the Services, comply with regulatory and legal obligations, and conduct administrative and business activities that support the delivery and use of the Services. Personal Data are also processed by Us to better understand your preferences and needs.

To access essential tools that help protect your rights regarding Personal Data:

We want you to be able to make informed decisions about the collection and processing of your Personal Data. That’s why we created this website. To achieve this, we use various methods and procedures to provide relevant information about the use of Personal Data. If we believe you need specific details, we’ll provide them at the appropriate date and time. We’re happy to answer any questions and provide any clarifications you need, subject to applicable legal limits. You can reach us by email at: info@blue-orion.com

Protect your personal data:

While we cannot guarantee the complete security of your Personal Data, we are committed to continually employing a range of measures and techniques to help ensure it remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy outlines the types of Personal Data the Company collects about natural persons and how it is processed, shared with third parties, and secured. It applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including through a combination of additional information we hold or can access. The Policy defines “processing” as any operation involving the use or collection of Personal Data, including the management, organization, and storage of such data. Our services are intended for a general audience and are not designed for individuals under 18 years of age. We do not knowingly solicit or collect information from anyone under 18, nor do we knowingly permit such individuals to use our services. If we become aware that we have collected information about a child, we will delete it as promptly as possible.

2. What Personal Data Do We Hold About You?

When you use our services or channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain situations. In other cases, we collect your Personal Data by analysing how you use our services and channels, or by receiving your information from our third-party partners.

3. No requirement to disclose personal information to the company and the potential consequences.

You are not required to provide Us with Personal Data. However, in certain situations, if you choose not to, it may prevent Us from providing the Services or limit users' ability to access the website.

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

This includes details about your online activity log, traffic data (including IP address and the date and time of access), the language you use, software crash logs, the type of browser, and information about the device you use. The information we collect is not personal information and cannot be used to identify you. Personal data we receive from you: any personal data you choose to 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, 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 outlined in this section, and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot use your Personal Data. The legal grounds that permit the Company to process your Personal Data are:

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

Contact us via email for more details about processing necessary to safeguard legitimate interests.
Below is a list of purposes and legal bases for how we may use the information you provide (Personal Data).

6. Transfer of Personal Information to Third Parties

The Company may also share Personal Data with third-party service providers—such as hosting and storage providers—and with vendors that process IP address information and conduct 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 third-party trading platforms. Their use of your Personal Data is subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliates or business partners to secure resources that help enhance and improve the products and services we provide to customers.
Where necessary to safeguard the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, we may share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company in our corporate group if a transaction occurs (including the transfer or sale of assets of the Company or any other company within the group) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

ONLINE TRACKING NOTICE

We may use third-party services, including advertising providers and analytics companies. These partners may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the website. They collect information about your preferences and browsing habits to enhance your experience, remember your settings, and personalize products and services you may enjoy. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and last only for a short time, disappearing when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period after you close your browser. They help the Website recognize you as a returning user and make it easier to come back to the website.

7. Cookies and Services from Third Parties

We may use them based on their intended purpose:

Cookies are blocked or have been removed
To block or remove cookies, adjust your browser settings. The links below will 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 features and functions may not work as expected if this occurs.

ONLINE TRACKING NOTICE This service does not currently support 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 purposes described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders. We will share your information with third-party trading platforms for a period of 12 months. With your consent, we may continue to share your data for an additional 12 months.
We routinely review retained Personal Data to confirm that it is no longer needed.

9. Cross-border transfers of personal information to another country or to an international organization

Your personal information may be transferred to other countries (for example, to a third country—meaning a country other than the one where you reside—or to international organizations or jurisdictions). The Company takes all necessary measures to safeguard the Personal Data you provide and to ensure that individuals can exercise their rights and access effective legal remedies.
These protections and safeguards are available to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the European Commission has determined provides 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 carried out under a legally binding and enforceable agreement between public entities or authorities, in accordance with Article 46(2)(a).
• The transfer was carried out in accordance with the European Commission's Standard Contractual Clauses adopted 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 about the security measures it uses to protect your Personal Data when it is transferred to third countries or international organizations. To request this information, please email info@wealthwaydigital.uk

10. Personal Data Protection

We have implemented appropriate organizational and technical measures to protect Personal Data. These measures are intended to prevent the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant error-free security of your Personal Data. We are also not responsible for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, any disclosure caused by transmission errors, unauthorized access by a third party, or any other cause beyond our control.
In circumstances 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 protection those third parties provide to your Personal Data in such situations.
No method of transferring Personal Data over the internet is completely secure. The Company cannot ensure the security of Personal Data you transmit to Us online.

11. Hyperlinks to third-party websites

Our website may include links to third-party sites and applications. These sites and apps are not controlled or supervised by the Company. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to activities conducted on those sites or apps.
When you visit any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. We also suggest that you provide any Personal Data to them after doing so.

12. Changes 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. When significant modifications are made, we will also endeavour to inform you through methods we consider appropriate and will publish a notice on our website. Unless stated otherwise, any amendments take effect upon publication of the updated Policy.

13. Your rights regarding your personal information

You are entitled to ask us to verify the accuracy of the Personal Data collected about you, correct any errors, and delete any Personal Data that 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 we process 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 fulfilling your request would adversely affect another person’s rights or freedoms, the Company may refuse the request or limit our ability to fulfil it. Right to rectification
The Company may rectify inaccurate Personal Data. You may require that any incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to Erasure
The following grounds apply: (a) Personal Data are no longer needed 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, based on reasons related to your particular situation, to processing of your Personal Data based on legitimate interests pursued by us or a third party; (e) Personal Data have been processed unlawfully; 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 processing of your Personal Data. If processing is restricted, Personal Data may be stored and otherwise processed only with your consent, for the establishment, exercise, or defence of legal claims, to protect the rights of another natural person, or for reasons of important public interest of 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 on 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. Your right to erasure is not affected by exercising the right to data portability. The right to portability must not adversely affect the rights or freedoms of others.
Right to challenge
You may object at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those interests. Unless we demonstrate compelling legitimate grounds for processing that override your rights, freedoms, and interests, or for the establishment, exercise, or defence of legal claims, we will cease such processing.
For direct marketing, you have the right to object at any time to the processing of your Personal Data.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This does 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 regarding the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights regarding your Personal Data as described in section 13. We will provide the requested information in accordance with your rights under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two 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 under section 13, the information supplied pursuant to your rights under section 13 will be provided free of charge. If a request is unfounded or excessive, in particular due to repetition, we may charge a reasonable fee to cover administrative costs or refuse to act.
If we have doubts about the identity of the person making the request, the Company may request additional information.