We (referred to as 'We', 'Us' or 'Our') are dedicated to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and store the information you provide through Gaingate (the 'Website').
The following principles govern this policy:

To ensure complete transparency in how we collect and process your personal information:

We want to empower you to make informed choices about the use and processing of Personal Data. That’s why we’ve created this website and implemented methods and procedures to deliver clear, relevant information on our data practices. If you need specific details, we’ll provide them at the appropriate time. We’re happy to answer any questions and clarify any legal limitations. You can reach us via email at info@blue-orion.com

Personal Data will be used solely for the purposes specified in the Policy.

Personal Data may be processed by us for multiple purposes, including providing the website to you and connecting you with third-party trading platforms (the 'Services'), enhancing and securing the site, protecting our rights and interests, facilitating the maintenance and provision of the Services, fulfilling any regulatory or legal obligations, and conducting administrative and business activities to support the delivery and use of the Services. We also process Personal Data to gain a better understanding of your preferences and needs.

Leverage robust tools to safeguard your rights concerning Personal Data:

This website serves as your comprehensive guide to our Personal Data practices. Our aim is to place you in a position to make informed choices about how your Personal Data is collected, used, and processed. To achieve this, we implement a variety of robust methods and procedures that deliver clear, relevant information about our data handling practices. Whenever you need more specific details, we will provide them promptly at the appropriate time. We are always happy to answer your questions and clarify any legal limitations that may apply. You can securely reach us at any time via email: info@blue-orion.com

Safeguard Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we assure you that we will continue to employ a variety of measures and techniques to protect it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy describes the types of Personal Data the Company collects from natural persons. It explains how we process, share with third parties, and secure that data. This Policy relates to information concerning identified or identifiable natural persons. An identifiable natural person is someone who can be recognized directly or by combining other information we hold or access. The policy defines “processing” as any operation requiring the use or collection of Personal Data, including its management, organization, and storage. Our services are intended for general audiences and are not designed for individuals under the age of 18. We do not knowingly seek or collect Personal Data from persons under 18, nor do we knowingly allow them to use our services. If we discover that we have collected information about children, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our services, channels, or visit our website, we collect Personal Data. In certain cases, we may ask you to provide it directly. In others, we gather Personal Data by analyzing your use of our services and channels or by obtaining information from our third-party partners.

3. There is no obligation to disclose personal information to the company, and no consequences will apply.

You are not obliged to provide us with any Personal Data. However, under certain circumstances, you may also choose not to supply this information. Doing so could limit our ability to deliver the Services or prevent users from accessing the website.

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

This includes details of your online activity log, traffic data (including IP address, date and time of access), chosen language preferences, software crash reports, browser type and version, as well as information about your device model and operating system. Such data is not considered private and cannot identify you personally. Personal Data We receive from you: any personal details you voluntarily submit when connecting to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate transactions: this includes your full name, residential address, phone number and email address.

5. The Legal Basis and Reasons for the Processing of Personal Data

We process your Personal Data for the purposes outlined in this section and based on the applicable legal grounds.
Without a valid legal basis, the Company cannot use your Personal Data. Below are the legal grounds that allow the Company to 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 so that we can transfer it to a third-party trading platform.
• The Company or a third party may need to process data to meet 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 more information on the processing required to safeguard 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 share your Personal Data—such as IP address information and user experience analyses—with third-party service providers, including hosting and storage providers.
You may request that we transfer specific Personal Data about you to third-party trading platforms. In such cases, we will share the Personal Data you supply with these platforms. Their use of your Personal Data is governed by their privacy policies, and your data may be shared with multiple trading platforms.
The Company may also share Personal Data with our affiliates or business partners to access resources that help us enhance and improve the products and services we offer to customers.
If required to safeguard third-party rights or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors, buyers, or lenders during transactions—such as asset transfers or sales within the Company group—or as part of any merger, restructuring, consolidation, or bankruptcy involving the Company or any group entity.

ONLINE TRACKING NOTICE

Third-party services, such as advertising partners or analytics providers, may be used. These third parties may also leverage 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 user experience, remember your settings, and tailor products and services to your interests. Cookies also support statistical analysis and analytics.
Some cookies, known as session cookies, are temporarily downloaded to your device and expire when you close your browser. Others, called persistent cookies, remain on your device after you close your browser. These help the website recognize you as a returning user and facilitate seamless access on subsequent visits.

7. Third-Party Cookies and Services

We may use them according to their intended purpose:

Cookies are blocked or removed
To block or remove cookies, you need to change your browser settings. Below, you’ll find links providing step-by-step instructions for some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that certain or all of the Website’s functions and features may not work as you expect 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 processing purposes described in this Policy, or for longer periods as permitted by law, regulations, policies, or applicable orders. We'll share your information with third-party trading platforms for 12 months; if you consent, we'll continue sharing it for another 12 months.
We regularly review retained Personal Data to ensure it is no longer needed.

9. Transfers of Personal Information to a Third-Party Country or an International Organisation

Your personal information may be transferred internationally—for example, to a third country outside your country of residence or to international organizations or jurisdictions. We take all necessary measures to safeguard the Personal Data you provide and ensure that you can exercise your rights and access effective legal remedies.
These protections and safeguards apply to all residents of the EEA (European Economic Area).

• Transfer to a third country or international organisation that the EU Commission has determined, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, provides adequate protection for Personal Data transferred to it. (the 'GDPR')
• The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under viro Article 46(2)(a).
• The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. These clauses adopted by the European Commission are available online at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

For information on the security measures we employ to protect your Personal Data when it is transferred to third-party countries or international organisations, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented comprehensive organizational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration.
However, we cannot guarantee that your Personal Data will remain completely secure at all times, nor can we be held liable for intangible, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, any breach resulting from transmission errors, unauthorized third-party access, or other causes beyond our control.
If required by law or other binding obligations, we may be compelled to disclose your Personal Data to third parties, such as public authorities. In such cases, we have no control over how these third parties protect your information.
Because no method of data transmission over the Internet is entirely secure, the Company cannot guarantee absolute protection of Personal Data you send to us online.

11. Hyperlinks to websites owned by third parties

Links to third-party websites and applications are provided on this website for your convenience. These platforms operate independently of the Company; we are not responsible for their collection or processing of Personal Data. Consequently, this Policy does not govern activities on those sites or apps.
Before accessing or using any third-party website or application, we recommend reviewing its privacy policy and deciding whether to disclose any Personal Data.

12. Amendments to This Policy

This Policy may be updated at any time. When we make changes, we will notify you by posting the revised Policy on our website. For significant updates, we will also use additional methods we deem appropriate and publish an announcement on our site. Unless stated otherwise, all amendments will take effect upon publication of the updated Policy.

Your rights in relation to your personal information

You have the right to ask us to verify the accuracy of any Personal Data we hold about you, correct any mistakes, and delete Personal Data that we no longer need. You may also request restrictions on certain types of processing. If you reside in the EEA, please refer to this page:
These rights apply to the Personal Data you provide. To exercise them, email us at the address below.
Access rights
We will confirm whether we are processing your Personal Data and, if so, provide you with an electronic copy. We may charge a reasonable fee for additional copies. We will supply the data electronically upon request.
The right to access Personal Data must not infringe the rights and freedoms of others. If your request conflicts with another individual’s rights, we may refuse or limit our response.
Right to rectification
We will correct any inaccurate Personal Data and complete any incomplete information, taking into account the purpose of processing.
Right to erasure
You may request erasure of your Personal Data where: (a) it is no longer necessary for its original purpose; (b) you withdraw consent and no other legal basis applies; (c) you object to processing based on our or a third party’s legitimate interests; (d) it has been unlawfully processed; or (e) we must erase it to comply with a legal obligation. This right does not apply if processing is necessary to fulfil a legal requirement under EU or Member State law, or to establish, exercise, or defend legal claims.
Processing restrictions
If you question the accuracy of your Personal Data, you may request that we restrict its processing. During the restriction period, we will only retain your data with your consent, to establish, exercise, or defend legal claims, to protect another individual’s rights, or for reasons of significant public interest under EU or Member State law.
Right to data portability
When processing is automated and based on your consent or a contract, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to request direct transfer to another controller, where technically feasible. Exercising this right does not affect your rights under erasure and must not infringe others’ rights or freedoms.
Right to object
You may object at any time to processing based on our or a third party’s legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your rights, or if processing is needed for legal claims. You may also object to direct marketing processing at any time.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal will not affect the lawfulness of processing carried out before you withdrew consent.
Right to lodge a complaint
You have the right to file a complaint with the supervisory authority in your jurisdiction or to appeal to the EU Member State authority responsible for safeguarding individuals’ data protection rights.
EU and Member State laws may limit your rights regarding your Personal Data as described in Section 13. We will respond to your request under Section 13 within one month of receipt. This period may be extended by up to two additional months, depending on the complexity and number of requests. We will notify you of any extension and its reasons within one month of your initial request.
Unless Section 13 provides otherwise, we will provide the requested information free of charge. However, if your request is manifestly unfounded or excessive, especially if repetitive, 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, we may ask for additional information.