We (also referred to as 'We', 'Us', or 'Our') are fully committed to safeguarding your Personal Data and protecting your privacy.
This 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 transparency about how we collect and process your personal data to serve your best interests:

Through these efforts, 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 Personal Data usage. 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 anything related to legal constraints. To contact us, please email info@blue-orion.com

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

You will find that we process Personal Data for various purposes, including providing you access to the website, connecting you with third-party trading platforms (the “Services”), improving the site, protecting our rights and interests, maintaining and provisioning the Services, ensuring full compliance with legal and regulatory obligations, and conducting administrative and business activities to enable the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Gain timely access to essential resources designed to protect your rights and privacy regarding Personal Data

We are committed to helping you make informed choices about how we handle your personal data. This commitment explains why we created this website. To support it, we use a range of tools and procedures to ensure you receive the most relevant information about our use of your Personal Data. If you need specific details, we will provide them at the appropriate time. If you have questions about our process, we are happy to explain and clarify, always within legal requirements. To learn more, contact us at info@blue-orion.com

Keep Your Personal Information Secure and Private

While we cannot guarantee the absolute security of Personal Data, as no one can, we remain fully committed to using multiple safeguards and industry-standard practices to protect your Personal Data. Our Privacy and Security Policy covers all the essential bases to help ensure your long-term safety.

Scope?

By reviewing this Policy, you will find an overview of the types of Personal Data our Company collects from customers, as well as the methods we use to process it, share it with third parties, and keep it secure. This Policy applies to information about an identified or identifiable individual, meaning a person can be recognized directly or through other information we hold or can access. For the purposes of this Policy, “processing” covers any operation performed on Personal Data, including its collection, management, organization, and storage. Our services are designed for a general audience but are strictly unavailable to anyone under 18. We do not authorize use by individuals under this age and do not knowingly collect their information. If we become aware of any data relating to a person under 18, we will promptly delete it.

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 certain personal details directly. We may also gather this information by analyzing your interactions with our services or channels, or via our third-party partners

3. You are not required to provide your personal information to our company or to deal with any implications that may arise from doing so

You are not required to share personal data with us. However, if you choose not to provide certain details, it may affect our ability to deliver services to you, which could result in limited access to our website or restricted use of some features.

4. What 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, 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 may also obtain Personal Data that you voluntarily provide when connecting to a third-party online trading platform through us. In addition, we collect the personal details you submit directly to those platforms, such as 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 outlined in this section, and does so in accordance with the applicable legal framework at all times.
We require this legal basis because, without a valid legal basis, our Company cannot process your Personal Data. The legal grounds that allow 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 via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process information to support their legitimate interests. For example, this may include enhancing our Services, improving user experience, or protecting ourselves against potential legal claims that may arise.
• All processing activities on our website must comply with applicable legal requirements, and we can confirm that they do.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we outline the reasons and legal bases for our use of the personal information you have provided to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Depending on the circumstances, the Company may disclose Personal Data to third parties that provide services such as data storage, IP address hosting, or user experience analytics.
We also process 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. If you choose this option, their 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 share Personal Data with its business partners or affiliated entities. We do this to access the resources needed to enhance and continuously improve our customer offerings.
Where appropriate, the Company may disclose Personal Data to regulatory, local, or other competent authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or buyers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or bankruptcy involving the Company or other parties associated with the Company.

Online Tracking Notice

You may encounter our use of third-party services on our website, such as advertising networks and analytics providers. These companies may also use cookies and similar technologies to collect data.
When we refer to cookies, we mean small text files stored on your device whenever you visit or access our site. We use cookies to gather information about your preferences and browsing patterns with the aim of improving the user experience, understanding user preferences, and designing products and services based on customer interests. In addition, cookies help us compile statistics and conduct analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily placed on your device and expire when you close your browser. Others are persistent cookies, which remain on your device even after the browser is closed. These cookies allow the website to recognize you as a returning visitor and retain the preferences you set previously.

7. How We May Use Cookies and Third-Party Services

Each cookie and its usage 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 assist with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that some website features and functions may not operate as intended if this occurs.

Online Tracking Notice Please note that our service does not currently recognise Do Not Track requests.
8. Learn More About Storing Your Personal Information

Please note that Our Company will retain your Personal Data for as long as necessary to fulfill the purposes set out in this Policy, and, where permitted by applicable law or required for order processing and record-keeping obligations, for a longer period of time. In certain limited 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 an additional 12 months if needed.
We periodically review and assess the Personal Data we hold to ensure it is not retained longer than necessary and delete or anonymize it in accordance with our retention schedules and applicable regulations.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send your Personal Data outside your country of residence, or to international organizations. We take all necessary measures to protect 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 an international organization that the European Commission has recognized 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 rely on a legally binding and enforceable instrument between public authorities or bodies 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 protect your Personal Data when it is transferred to third countries or international organizations, please email us at: info@wealthwaydigital.uk

10. Protection of Personal Data

In order to safeguard your Personal Data, we have implemented robust security measures. These are designed to prevent accidental or unlawful destruction, loss, or alteration.
Even so, while we take every reasonable precaution, we cannot guarantee that your Personal Data will be kept completely secure or error-free, nor can you hold us liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by transmission errors, unauthorized access by third parties, or other events beyond our control.
Where we are legally required, or due to 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 measures those third parties implement.
Please note that transferring Personal Data over the internet cannot be entirely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of Personal Data you transmit to us online.

11. Regarding Links to Third-Party Websites

Our website contains links to external sites and applications that are outside our Company's control. As such, we accept no responsibility for how these third-party websites collect or process your Personal Data. While our Policy explains what happens on our website, it does not cover what occurs on third-party websites.
Before following any link to a third-party website or app, you should review their privacy policies before you start using their services. At the same time, carefully consider whether you want to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We may update this Policy at any time. If changes are made, we will notify you on our website, highlight the update prominently, and provide access to the revised Policy. For material updates, we will use the communication methods we consider most appropriate, which may include email or in-service notices, and will also issue a notice through an announcement on our website. Unless we state otherwise, all updates to this Policy take effect immediately upon publication of the amended Policy.

Your Rights in Relation to Your Personal Data

You have the right to request a review of the Personal Data we hold about you, to have it corrected, and to ask us to delete any Personal Data you no longer want us to process. You may also request that we limit the categories 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 assess the accuracy of the Personal Data processed. If accurate, we will provide you with access to your Personal Data and 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 the rights and freedoms of others. If a request would do so, we may refuse to comply or limit our response. Your rights related to rectification
If you want to correct inaccurate Personal Data, you may ask us to 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 processing for specific reasons; (e) unlawful processing of Personal Data; or (f) erasure is required to comply 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 restrict processing if you believe the data is inaccurate. While restricted, we will store the data but will process it only with your consent, to protect another person’s rights, to establish, exercise, or defend legal claims, or for important public interests of an EU Member State or the EU.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive your Personal Data that the Company processes.
You also have the right, where technically feasible, to request that the data be transmitted to another controller. Exercising your data portability rights 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 legitimate interests of the Company or third parties, including related profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defense of legal claims.
You have the right to object to processing for direct marketing at any time.
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 supervisory authority responsible for Personal Data in your jurisdiction.
You may ask a supervisory authority in a Member State to protect your individual rights regarding Personal Data processing within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. In accordance with your rights, we will provide the information requested under section 13 within one month of receiving your request; we may extend this by two months due to the complexity or number of requests. You will be notified within one month of any extension and the reasons for it.
Information requested under section 13 will be provided free of charge unless a request is unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable administrative fee 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.