We (also 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').
These principles will be upheld:

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

We want you to be able to make informed choices about the use and processing of Personal Data, which is why we created this website. We use a range of methods and procedures to provide clear, relevant information about how Personal Data is used. If we determine you need specific details, we will provide them at an appropriate time. We are happy to answer any questions and to clarify any legal limitations that may apply. You can contact us by email at the address below: info@blue-orion.com

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

Personal Data may be processed by us for a range of purposes, including to provide the website and connect you with third‑party trading platforms (the 'Services'), to improve and protect the site and our rights and interests, to facilitate maintenance and delivery of the Services, to meet regulatory or legal obligations, and to carry out administrative and business activities to support the use of the Services. Personal Data are also processed to help us better understand your preferences and needs.

To access key tools to safeguard your rights in relation to Personal Data:

We want you to be able to make informed choices about the use and processing of Personal Data. That is why we have created this website. To that end, we use a range of methods and procedures to provide clear, relevant information about how Personal Data is handled. If we determine you require specific details, we will provide them at the appropriate time. We are happy to answer any questions you may have and to clarify any legal limitations. You can contact us by email at info@blue-orion.com

Protect your personal data:

Although we cannot guarantee absolute security of your Personal Data, we will continue to use a range of measures and techniques to safeguard it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy explains the types of personal data the Company collects about natural persons and how we process, share, secure and otherwise handle that data. It covers information relating to identified or identifiable natural persons — that is, individuals who can be identified directly or by reference to other information we hold or can access. For the purposes of this policy, "processing" means any operation involving the collection or use of personal data, including its organisation, structuring and storage. Our services are intended for a general audience and are not directed at anyone under the age of 18. We do not knowingly seek to collect information from, or permit access by, persons under 18; if we become aware that we have collected personal data from a child under 18, we will delete it as soon as reasonably practicable.

2. What personal data do we hold about you?

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

3. You are not required to disclose personal information to the company, and there will be no adverse consequences for choosing not to do so.

You are not obliged to provide Us with any Personal Data. However, in certain circumstances, choosing not to supply Us with Personal Data may prevent Us from providing the Services or may prevent users from accessing the website.

4. What kinds of personal data can we collect? When you visit our website, we will gather the following personal information:

This includes your online activity log and traffic data (including IP address, date and time of access), the language used, software crash logs, browser type, and details about the device you used. This information is non-personal 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 trade includes your full name, address, telephone number and email address.

5. Legal basis and reasons for processing personal data

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

• You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information via the Website to enable us to transfer it to a third-party trading platform.
• The Company or a third party may process data to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
• Processing must comply with legal obligations.

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

6. Transfer of Personal Data to Third Parties

The Company may also disclose Personal Data to third‑party service providers, such as hosting and storage providers, including IP address information and user‑experience analytics.
You can also request that we transfer specific Personal Data about you to third‑party trading platforms. In such cases, we will provide the Personal Data you supply to those platforms; their use of your Personal Data will be subject to their privacy policies, and your data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to obtain the resources needed to enhance and improve the products and services it provides to its customers.
If required to protect the rights of third parties or the Company’s assets, the Company may disclose Personal Data to regulatory, local or other official authorities.
We may also share Personal Data about you with potential investors, purchasers or lenders, or with other companies in the group, in connection with a proposed or actual transaction (including the transfer or sale of assets belonging to 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

Third-party services, such as companies that provide advertisements on our website or analytics providers, may be used. These parties 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 improve your user experience, remember your settings and personalise the products and services you may enjoy. Cookies are also used for statistics and analytics.
Certain cookies we use are session cookies. These are downloaded temporarily to your device and last only for the duration of your browser session. Other cookies are persistent: they remain on your device for a period after you close your browser to help the website recognise you as a returning user and allow you to return to the site.

7. Third-party cookies and services

We may use them for their intended purpose:

Cookies are blocked or removed
To prevent or remove them, change your browser settings. Below are links to help you with the process for several commonly used browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please be aware 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 honour Do Not Track signals.
8. Retention of your personal data

The Company will retain Personal Data about you only for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer where required or permitted by law, regulation, policy or the applicable orders. We will share your information with third-party trading platforms for an initial period of 12 months; if you agree, we will continue to share your data for a further 12 months.
We regularly review Personal Data we hold to ensure it is no longer required.

9. Transfers of personal information to third countries or international organisations

Your personal information may be transferred to other countries (for example, to a third country — i.e. 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 remedies.
These protections and safeguards are available to residents of the EEA (European Economic Area).

• Transfer to a third country or to an 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 made pursuant to an enforceable agreement between public entities or authorities 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 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 applies to safeguard your Personal Data when transferred to third-party countries or international organisations. Please email info@wealthwaydigital.uk

10. Safeguarding Personal Data

We have taken appropriate organisational and technical precautions to safeguard Personal Data. This includes preventing the accidental or unlawful destruction, loss or alteration of Personal Data.
However, we cannot guarantee or warrant that the security of your Personal Data will be free from error. We also cannot be held liable for any indirect, incidental or consequential losses arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third‑party access or any other cause beyond our control.
If required by law or other circumstances beyond our control, we may be obliged to disclose Personal Data about you to third parties, including public authorities. In such cases, we cannot control the security measures those third parties apply to your Personal Data.
Personal Data cannot be transferred over the web in a completely secure manner. The Company cannot ensure the security of Personal Data you transmit to Us via the internet.

11. Hyperlinks to Third-Party Websites

Links to third-party websites and applications are provided on the website. These sites and applications are not under the supervision of the Company, and we are not responsible for the collection or processing of Personal Data by those third parties. This Policy does not apply to actions taken on such sites or apps.
When you visit any third-party website or app, we recommend that you read its privacy policy before accessing or using the service, and think carefully before providing any Personal Data to them.

12. Amendments to this Policy

This Policy is subject to change at any time. If we amend it, we will notify you by posting the updated Policy on our website. For significant changes, we will also endeavour to inform you by the methods we consider appropriate and will publish an announcement on our website. Unless otherwise specified, amendments will take effect upon publication of the revised Policy.

13. Your rights in relation to your personal information

You have the right to ask us to verify whether Personal Data relating to you is being collected, to correct any inaccuracies, and to delete Personal Data that we no longer need. You may also request limits on the types of processing of your Personal Data. If you are a resident of the EEA, please refer to this page. These rights apply to the information you provide as Personal Data. To exercise any of these rights, please email the address below. Access rights The Company can confirm whether Personal Data about you is being processed and, if so, you may access that Personal Data. The Company will provide an electronic copy of the Personal Data under processing and may charge a reasonable fee for additional copies. Where requested, the data will be supplied electronically. Access rights must not conflict with the rights and freedoms of others; if a request would prejudice another person’s rights or freedoms, the Company may refuse or limit compliance. Right to rectification The Company will correct inaccurate Personal Data. You may request that incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to erasure You may request erasure of your Personal Data where: (a) the 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, for reasons related to your particular situation, to processing based on the Company’s or a third party’s legitimate interests; (d) the Personal Data have been unlawfully processed; or (e) erasure is required to comply with a legal obligation of the Company. This right does not apply where processing is necessary: (i) to comply with a legal obligation under EU or Member State law, or (ii) to establish, exercise or defend legal claims. Processing restrictions If you contest the accuracy of your Personal Data, you may ask the Company to restrict processing. Where processing is restricted, Personal Data will only be retained with your consent, or for the establishment, exercise or defence of legal claims, to protect another natural person’s rights, or for reasons of substantial public interest in the EU or a Member State. Right to data portability Where 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 in a structured, commonly used, machine-readable format. You may also request that the Company transfer those data directly to another controller, where technically feasible. Exercising this right does not affect your right to erasure and must not adversely affect the rights and freedoms of others. Right to object You have the right to object at any time to processing of Personal Data about you that is based on the Company’s or a third party’s legitimate interests, including profiling based on those interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims. You also have the right to object at any time to processing for direct marketing purposes. Right to withdraw consent You may withdraw any consent you have given for the Company’s processing of your Personal Data at any time. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. Complaints You are entitled to lodge a complaint with the relevant supervisory authority in your Member State responsible for protecting individuals’ rights in relation to Personal Data processing. Other limitations EU and Member State law may restrict the rights described in this section 13, as stated in that section. We will respond to requests made under section 13 within one month of receipt. Where necessary given the nature or number of requests, this period may be extended by up to two months; we will inform you of any extension and the reasons within one month of receiving your request. Fees and refusals Subject to section 13, the information you request will generally be provided free of charge. If a request is manifestly unfounded or excessive, in particular because it is repetitive, the Company may charge a reasonable fee to cover administrative costs or refuse to act on the request. Identity verification If we have doubts about the identity of the person making a request, the Company may request additional information to verify identity.