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 clearly explain how we collect and process your personal data:

We want you to make informed choices about the use and processing of your Personal Data. To support this, we have designed our website to deliver clear, accessible content about how Personal Data is handled. We use a range of methods, notices, and procedures to provide you with relevant, up-to-date information. Whenever more detailed information is necessary, we will present it to you at the appropriate moment. We are also happy to answer any questions and to offer clarifications, including with respect 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 outlined in this Policy.

We may process Personal Data for various purposes, such as operating the website, connecting you with third-party trading platforms (the 'Services'), improving the site, safeguarding our rights and interests, supporting the maintenance and provision of the Services, complying with legal or regulatory obligations, and performing administrative and business activities that enable the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs

Access essential tools to protect your rights regarding Personal Data

We want you to make informed decisions about the use and processing of Personal Data. That’s why we created this website. To support this, we use a range of measures and procedures to deliver clear, relevant information about how Personal Data is handled. If we believe you need more specific details, we’ll provide them at the appropriate time. We’re happy to answer your questions and will offer any clarifications we can, subject to applicable legal restrictions. You can reach us by email at the address below: info@blue-orion.com

Safeguard Your Personal Data

Although we cannot guarantee the absolute security of your Personal Data, we will continue to implement a range of measures and safeguards to protect it. Our Privacy and Security Policy is comprehensive

Scope?

This Policy explains the types of Personal Data the Company collects about natural persons and how we process it, share it with third parties, secure it, and otherwise handle it. This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly in combination with additional information we hold or can access. The Policy defines 'processing' as any operation requiring the use or collection of Personal Data. This includes the management, organization, adaptation, structuring, and storage of Personal Data. Our services are intended for a general audience and are not designed for individuals 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 individuals to use our services. If we become aware that we have collected information about children, we will delete it as quickly as we can

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 it. In others, we obtain Personal Data by analyzing how you use our Services and channels, or from information supplied by our third-party partners

3. No obligation to provide personal data to the Company and the consequences thereof

However, you are not obligated to provide Us with any Personal Data. In some instances, you may not need to submit any Personal Data to Us. This may limit Us in delivering the Services or restrict users from accessing the website

4. What types of Personal Data do we collect? When you visit our website, we may collect the following Personal Data

This includes your online activity log, traffic data (including IP address, access date and time), the language you use, software crash logs, the browser type, and details 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 information you voluntarily provide when you connect to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading includes your full name, address, phone number, and email address

5. The legal grounds and purposes for processing personal data

The Company processes your personal data for the purposes outlined in this section, in line with the applicable legal basis.
Without such a basis, the Company cannot process your personal data. The legal grounds that permit the Company to process your personal data are:

• You have consented to the processing of your Personal Data for one or more purposes. This includes cases where you provide Personal Data through the Website so that we can transfer it to a third-party trading platform
• The Company or third parties may need to process data to pursue legitimate interests; for example, to improve our Services or to defend legal claims.
• Processing must comply with a legal obligation

Contact us by email for more details about the processing necessary to protect our legitimate interests.
Below is a list of purposes and legal bases we may rely on when handling the information you provide. Personal Data

6. Disclosure of Personal Data to Third Parties

The Company may also share Personal Data with third parties that support our operations, including hosting and storage providers, as well as vendors that analyze user experiences or process IP address information.
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 secure the resources needed to enhance and improve the products and services it offers its 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 prospective investors or purchasers, or with lenders to the Company or any other company in the group, in connection with such transactions (including the transfer or sale of assets of the Company or any other company in the group) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business in the group

Online Tracking Notice

Third-party services, such as ad providers on our website or analytics companies, may be used. These partners may also use 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 your experience, remember settings, and tailor 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 stored on 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 recognize you as a returning user and make it easier to come back to the site

7. Cookies and Third-Party Services

We may use them according to their intended purpose:

Cookies are blocked or have been deleted
To block or delete cookies, adjust your browser settings. Here are links to guide you through the process for several popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that if this occurs, some or all of the website's functions and features may not operate as expected

Online Tracking Notice This service does not currently recognize Do Not Track (DNT) signals.
8. Retention of Your Personal Data

We will retain your Personal Data for as long as necessary to fulfill the processing purposes described in this Policy, or longer where permitted by applicable laws, regulations, policies, and orders. We will share your information with third-party trading platforms for 12 months. With your consent, we will continue to share your data for an additional 12 months.
We routinely review the Personal Data we hold to confirm it is no longer needed

9. Transfers of personal data to third countries or international organizations

Your personal information may be transferred to other countries (i.e., your personal data may be sent to a third country (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 ensures that data subjects can assert their rights and access effective legal remedies.
These protections and safeguards apply to all individuals residing in the EEA (European Economic Area)

• Transfer to a third country or international organization that the European Commission has determined ensures adequate protection for Personal Data transferred to it, in accordance with Article 45(3) of Regulation 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, enforceable agreement between public bodies or authorities pursuant to Article 46(2)(a)
• The transfer was carried out in accordance with the EU Commission's Standard Contractual Clauses for data protection under Article 46(2)(c) of the GDPR. The clauses adopted by the EU Commission 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 on the security measures it uses to protect your Personal Data when transferred to third countries or international organisations. To request this information, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

We have implemented appropriate organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
We cannot guarantee that the security of your Personal Data will be error-free, nor can we be responsible for intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, disclosures resulting from transmission errors, unauthorized access by third parties, or other causes beyond our control.
In the event of legal requirements or other obligations beyond our control, 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 apply to your Personal Data in such situations.
Personal Data cannot be transmitted over the internet with complete security, and the Company cannot ensure the security of Personal Data you send to us online

11. Links to websites owned by third parties

The website may contain links to third-party websites and applications. These websites and apps are not under the Company's control. We are not responsible for the collection or processing of Personal Data by those websites or apps. This Policy does not apply to activities carried out through such sites or apps.
When you visit any third-party website or app, we recommend reviewing their privacy policies before deciding to access or use them. We also suggest that you carefully consider any Personal Data you choose to provide to them

12. Updates to this Policy

We may update this Policy at any time. When we do, we will notify you by posting the updated Policy on our website and outlining the changes. If the updates are significant, we will also seek to inform you through methods we consider appropriate and will publish a notice on our website. Unless explicitly stated otherwise, any amendments will take effect once the revised Policy is published on our website.

Your rights in relation to your personal data

You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data we do not require. You may also limit 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 can exercise them by sending an email to the address below. Access rights
The Company will verify the accuracy of the Personal Data processed about you. If it is accurate, 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. If you request, the data will be made available electronically.
The right of access must not conflict with the rights and freedoms of others. If a request would adversely affect another’s rights and freedoms, the Company may refuse to comply or limit its ability to do so. Right to rectification
The Company may correct inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be completed, taking into account the purpose of processing. Right to erasure
The following grounds apply: (a) the Personal Data is no longer necessary for the purposes for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object, for reasons related to your particular situation, to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be erased to comply with the Company’s legal obligation. This right does not apply if processing is necessary (a) to fulfill a legal obligation under European Union or Member State law or (b) for the establishment, exercise, or defense of legal claims.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If restriction is applied, the data may be stored only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or for reasons of important public interest within the European Union or a Member State.
Right to data portability
Where processing is carried out by automated means and is based on consent or a contract to which you are a party, you have the right to receive the Personal Data you provided to the Company in a structured, commonly used, machine-readable format.
You also have the right to request that your Personal Data be transmitted directly by the Company to another controller, where technically feasible. Exercising the right to portability does not affect the right to erasure and must not infringe the rights or freedoms of others.
Right to object
You may object at any time to the processing of your Personal Data based on the legitimate interests of the Company or a third party, including profiling based on those interests. We will stop processing unless we can demonstrate compelling legitimate grounds that override your rights, freedoms, or interests, or the processing is necessary for the establishment, exercise, or defense of legal claims.
For direct marketing purposes, 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 will not affect the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with the 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.
European Union and Member State laws may limit your rights regarding your Personal Data, as described in this section 13. We will provide information requested under your rights in section 13 of this agreement within one month of receiving your request. Where necessary, due to the nature or number of requests, this period may be extended by up to two months. We will notify you within one month of any extension and the reasons for it.
Unless otherwise provided in section 13 of the law, the information you request under section 13 will be provided free of charge. If a request is manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover the administrative costs of providing the information or taking the requested action, or we may decline to act.
If we have doubts about the identity of the person submitting the request, the Company may ask for additional information.