We (referred to as 'We', 'Us', or 'Our') are committed to protecting your Personal Data and privacy.
This Privacy Policy explains how we collect and retain the information you submit via the Gaingate website (the 'Website').
We uphold the following principles:

To provide transparency regarding our collection and processing of your personal information:

We want you to make informed decisions regarding the use and processing of Personal Data. That’s why we developed this website. Through various methods and procedures, we provide clear, relevant information on how Personal Data is used. If you require specific details, we will supply them promptly and at the appropriate time. We’re happy to answer any questions and clarify any legal constraints. You can reach us via email at the address below: info@blue-orion.com

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

Personal Data may be processed by us for various purposes, including providing the website and connecting you with third-party trading platforms ("the Services"); enhancing the site; protecting our rights and interests; facilitating the maintenance and delivery of the Services; fulfilling regulatory or legal obligations; and conducting administrative and business activities to support the delivery and use of the Services. Personal Data are also processed to help us better understand your preferences and needs.

To utilize essential tools that safeguard your rights regarding Personal Data:

We want you to make informed choices about the use and processing of Personal Data. Our website was created to help you do just that. We use various methods to provide clear, relevant information on Personal Data usage. If you need more specific details, we will supply them promptly. We are happy to answer any questions and clarify any legal limitations. You can reach us at info@blue-orion.com

Protect your Personal Data:

While we cannot guarantee absolute security of your Personal Data, we will continue to employ a variety of methods and techniques to ensure it remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy explains the types of personal data the Company collects from individuals and how we process, share, and secure it. It covers information related to identified or identifiable natural persons—those who can be recognized directly or through additional data we hold or access. The Policy defines “processing” as any operation involving the collection or use of personal data, including its management, organization, and storage. Our services are intended for general audiences and are not designed for use by anyone under 18. We do not knowingly collect information from minors under 18 or allow them to use our services. If we learn we have inadvertently collected data on children, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our Services, channels, or website, we collect Personal Data. In some cases, we may request your Personal Data directly; in others, we gather it by analysing your use of our Services or channels, or by receiving information from our third-party partners.

3. You are not required to disclose personal information to the company, and no consequences will apply.

You are not obliged to provide Us with any Personal Data. However, in certain circumstances, if you do not supply this information, it may prevent Us from providing the Services or 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), language settings, software crash logs, browser type, and device information. The data collected is not private and cannot identify you. Personal Data We receive from you includes any personal information you voluntarily provide when connecting to a third-party online trading platform through Us. Personal information specifically shared with those platforms to facilitate transactions comprises your full name, address, phone number, and email address.

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

Your Personal Data is processed by the Company for the purposes described in this section and in accordance with the applicable legal basis.
Without a legal basis, the Company cannot use any Personal Data concerning you. The legal grounds under which the Company may process your Personal Data are:

• You have consented 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 process data to meet their legitimate interests. For example, this could involve enhancing our services or defending legal claims.
• Processing must comply with legal obligations.

Contact us by email for more information on the processing necessary to safeguard our legitimate interests.
Below is a list of reasons and legal grounds for which we may use the personal data you provide.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party service providers—such as hosting and storage companies—that process IP address information and analyze user experience.
At your request, we can disclose specific Personal Data about you to third-party trading platforms. Any data you request to be shared will be provided to those platforms, and their use of your Personal Data will be governed by their own privacy policies. Your data may be shared with more than one trading platform.
The Company may share Personal Data with affiliates or business partners. This collaboration helps us enhance and improve the products and services we offer to our customers.
To protect the rights of third parties or our assets, the Company is permitted to disclose Personal Data to regulatory bodies, local authorities, or other official entities.
We may also share your Personal Data with potential investors, buyers, or lenders in the event of a transaction (including the transfer or sale of assets of the Company or any group company) or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other group entity.

ONLINE TRACKING NOTICE

We may engage third-party services, such as advertising partners and analytics providers, that support our website’s operation and improvement. These services may also employ cookies or similar technologies to collect data about your visit.
Cookies are small text files placed on your device whenever you access the website. They record information about your preferences—such as language settings and browsing habits—to enhance your experience, maintain your selected settings, and deliver personalized content or offers. Cookies also support site performance analysis, traffic measurement, and advertising effectiveness.
We use two primary types of cookies: session and persistent. Session cookies are temporary and expire when you close your browser. Persistent cookies remain on your device for a specified period after your session ends, enabling the website to recognize you on return visits, remember your preferences, and streamline your future interactions.

7. Third-Party Cookies and Services

We may use them based on their intended purpose:

Cookies are blocked or removed
To manage or delete cookies, adjust your browser's settings. Below are links to step-by-step guides for the process on some of the most popular browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please note that if this happens, some or all of the Website's functions and features may not work as expected.

ONLINE TRACKING NOTICE This service does not currently support Do Not Track signals.
8. The retention of your personal data

The Company will retain Personal Data about you for as long as necessary to fulfill the processing purposes outlined in this Policy, or for longer periods if permitted by law, regulations, policies, or applicable orders. We will share your information with third-party trading platforms for 12 months, and if you agree, we will continue sharing it for an additional 12 months.
We regularly review Personal Data we have retained to ensure it is no longer needed.

9. Transfers of personal information to a third-party country (country_name) or an international organisation

Your personal information may be transferred to other countries—meaning it could be sent to a third country (other than the one in which you reside) or to international organizations or jurisdictions. We take all necessary steps to safeguard the Personal Data you provide and to ensure that you can exercise your 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 organisation that the European Commission has identified as providing adequate protection for Personal Data under 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 a legally binding, enforceable agreement between public entities or authorities under Article 46(2)(a).
• The data transfer was conducted in accordance with the EU Commission’s Standard Contractual Clauses under Article 46(2)(c) of the GDPR. You can view these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

We can provide details of the security measures we employ to safeguard your Personal Data when it is transferred to third-party countries or international organisations. To request more information, please email info@wealthwaydigital.uk

10. Personal Data Security

We have implemented robust organizational and technical measures to protect Personal Data, preventing accidental or unlawful destruction, loss or alteration.
We cannot guarantee or warrant that the security of your Personal Data will be free of errors. We are not liable for any indirect, incidental or consequential damages resulting from the use or disclosure of Personal Data. This includes, but is not limited to, disclosure caused by transmission errors, unauthorized third-party access, or any other circumstances beyond our control.
If required by law or other obligations beyond our control, we may need to disclose your Personal Data to third parties, such as public authorities. We have no influence over the security measures those third parties apply.
Transmitting Personal Data over the internet is not completely secure. The Company cannot ensure the protection of any Personal Data you transmit to us online.

11. Hyperlinks to third-party websites

The website includes links to third-party sites and applications, which are not subject to the Company’s supervision. We are not responsible for how these sites or apps collect or process Personal Data. This Policy does not apply to activities carried out on those platforms.
Before accessing or using any third-party site or app, we recommend reading its privacy policy and carefully considering any Personal Data you choose to provide.

12. Updates to this Policy

This Policy is subject to change at any time without prior notice. Whenever we update it, we will post the revised Policy on our website to keep you informed. In cases of significant modifications, we will also make reasonable efforts to notify you through any methods we deem appropriate and publish a clear announcement on our site. Unless otherwise noted, all amendments will take effect immediately upon publication of the updated Policy.

Your Rights Regarding Your Personal Information

You have the right to ask us to verify the accuracy of any Personal Data we hold about you, correct any errors, and delete any Personal Data that we no longer need. You may also limit the types of processing we carry out on your information. If you are an EEA resident, please refer to this page:
These rights apply to the Personal Data you provide. To exercise your rights, please send an email to the address below.
Access rights
You may request confirmation of whether we are processing your Personal Data and obtain access to that data. We will provide you with an electronic copy of the Personal Data we hold, and may charge a reasonable fee for additional copies. If you request it, the data will be provided electronically.
Your right of access must not infringe on the rights and freedoms of others. If fulfilling your request would harm another person’s rights, we may refuse or limit our response.
Right to rectification
We will correct any inaccurate Personal Data we hold about you. You may also request that we complete any incomplete Personal Data, considering the purpose of processing.
Right to erasure
You may request deletion of your Personal Data if: (a) it 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 at any time, for reasons specific to your situation, to processing based on legitimate interests pursued by us or a third party; (d) the data has been unlawfully processed; or (e) it must be erased to comply with a legal obligation our company is subject to. This right does not apply if processing is necessary: (a) to comply with a legal obligation under EU or Member State law; or (b) to establish, exercise or defend legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict its processing. During this restriction period, we will only retain and process the data with your consent, to establish, exercise or defend legal claims, to protect another natural person’s rights, or for reasons of substantial public interest under EU or Member State law.
Right to data portability
Where processing is carried out by automated means and based on your consent or a contract to which you are party, you have the right to receive the Personal Data you have provided to us in a structured, commonly used and machine-readable format. You may also request that we transmit this data directly to another controller where technically feasible. Exercising this right does not affect your right to erasure and must not infringe on the rights or freedoms of others.
Right to object
You have the right to object at any time to processing of your Personal Data based on our legitimate interests or those of a third party, including profiling. If you object, we will stop processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
Right to direct marketing
You may object at any time to the processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent for processing your Personal Data at any time. This will not affect the lawfulness of any processing carried out before your withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may also contact the supervisory authority established by your EU Member State to protect individuals’ fundamental rights in relation to Personal Data processing.
EU and Member State laws may limit these rights as set out in Section 13 of this agreement.
We will respond to your requests under Section 13 of this agreement within one month of receipt. Where necessary—taking into account the complexity and number of requests—we may extend this period by up to two further months. We will inform you of any extension and the reasons for it within one month of receiving your request.
Subject to Section 13 of the law, the information you request under these rights will be provided free of charge. However, where requests are manifestly unfounded or excessive—especially if they are repetitive—we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have reasonable doubts about the identity of the individual making a request, we may ask for additional information to confirm their identity.