We (also referred to as “We,” “Us,” or “Our”) are committed to protecting your Personal Data and 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 ensure full transparency in how we collect and process your personal information:

At Blue Orion, our goal is to empower you to make informed decisions about the collection, use and processing of your Personal Data. To achieve this, we have developed our website, where we employ industry best practices, along with various methods and procedures, to deliver clear, relevant information on Personal Data practices. If we believe you require more specific details, we will share them promptly at the appropriate time. We welcome any questions and are committed to clarifying any legal limitations that may apply. Please contact our team by email at the address below: info@blue-orion.com

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

We may process Personal Data for various purposes: to provide the website to you and connect you with third-party trading platforms (the 'Services'), to improve and protect the site and our interests, to support the maintenance and delivery of the Services, to fulfil legal and regulatory requirements, and to carry out administrative and business activities that facilitate the delivery and use of the Services. We also process Personal Data to gain a better understanding of your preferences and needs.

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

We want you to make informed choices about how your Personal Data is used and processed. To support this, we’ve developed our website to provide clear, relevant information on our data practices. If you require specific details, we’ll supply them promptly and 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

Protect Your Personal Data:

While we cannot guarantee absolute security for your Personal Data, we remain committed to employing a variety of methods and techniques to protect it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This policy outlines the types of Personal Data the Company collects about natural persons, how it processes that data, shares it with third parties, and safeguards it. It applies to information related to an identified or identifiable individual. An identifiable individual is someone who can be identified directly or through a combination of personal data we hold or can access. The Policy defines "processing" as any operation involving the collection or use of Personal Data, including its management, structuring, and storage. Our services are intended for the general public and not designed for use by anyone under 18. We do not knowingly seek or collect information from individuals under 18, nor do we permit them to use our services. If we become aware that we have collected data from a child, we will delete it as quickly as possible.

2. What personal data do we hold about you?

When you access our services and channels or visit our website, we collect Personal Data. In some cases, we may ask you to provide Personal Data directly; in others, we collect it by analysing your use of our services and channels or by receiving information from our third-party partners.

3. You are not required to provide personal information to the company, and there are no consequences for withholding it.

You are not required to provide us with any personal data. However, in certain cases, choosing not to supply personal data may prevent us from offering the Services or restrict users from accessing the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal information:

This includes information about your online activity log, traffic data (including IP address, access date and time), the language used, software crash logs, browser type, and device details. This information is not private and cannot be used to identify you. Personal Data we receive from you: any personal data you choose to provide when you connect with a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading: your full name, address, telephone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

Your Personal Data is processed by the Company for the purposes outlined in this section, in accordance with the applicable legal basis.
Without such a legal basis, the Company cannot use your Personal Data. The legal grounds on which the Company relies to process your Personal Data:

• 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 need to process data in order to pursue their legitimate interests. For instance, this may be required to improve Our Services or to defend legal claims.
• Processing must comply with legal obligations.

Contact us via email for more information on the processing required to safeguard your 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 your Personal Data, including IP address information and user experience analytics, with third-party service providers such as hosting and storage companies.
You can also request that we transmit specific Personal Data to third-party trading platforms. In these cases, we will share only the data you have provided, and its use will be governed by the platforms’ privacy policies. Your Personal Data may be distributed across multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners to access the resources needed to enhance and improve the products and services offered to customers.
If required to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
Additionally, in the event of a transaction—such as a sale or transfer of assets, merger, restructuring, consolidation, or bankruptcy of the Company or any affiliated business—we may share your Personal Data with potential investors, buyers, or lenders.

ONLINE TRACKING NOTICE

Third-party services, such as advertising providers or analytics firms, may be used. These partners may also employ cookies or other technologies.
Cookies are small text files placed on your device each time you visit or access the website. We use cookies to collect information about your preferences and browsing habits to enhance the user experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistical analysis and analytics.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and expire when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a set period after you close your browser. They help the website recognize you as a returning user and enable you to revisit the site.

7. Third-Party Cookies and Services

We may use them according to their purpose:

Cookies are blocked or removed
To block or remove cookies, you need to change your browser's settings. Below are links to instructions for some of the most widely used browsers.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

However, please be aware that some or all of the Website's features and functions may not work as expected 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 Personal Data about you for as long as necessary to fulfill the purposes described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders. We will share your information with third-party trading platforms for 12 months. If you agree to this, we will continue sharing your data for a further 12 months.
We regularly review the Personal Data we retain to ensure it is no longer needed.

9. Transfers of personal information to a third party in country_name or to an international organisation

Your personal information may be transferred to other countries (for example, to a third country different from your country of residence) or to international organizations or jurisdictions. Company takes all necessary measures to protect the Personal Data you provide and to ensure that data subjects can exercise their rights and pursue 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 European Commission has determined provides adequate 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')
• The transfer is made pursuant to an enforceable and legally binding agreement between public entities or authorities under Article 46(2)(a).
• The data transfer was executed in accordance with the standard contractual clauses for data protection adopted by the European Commission under Article 46(2)(c) of the GDPR. These clauses 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 of the security measures we employ to protect your Personal Data when it is transferred to third-party countries or international organisations. 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.
However, we cannot guarantee error-free security of your Personal Data or accept liability for any indirect, incidental or consequential damages arising from its use or disclosure. This includes, without limitation, unauthorized access, transmission errors or any other cause beyond our control.
When legal or regulatory requirements obligate us, we may need to disclose your Personal Data to third parties, such as public authorities. We cannot control how these third parties secure your data.
Data transmitted over the internet cannot be completely secure, and The Company cannot ensure the protection of Personal Data you transmit to us online.

11. Hyperlinks Leading to Third-Party Websites

Links to third-party websites and applications are provided on our website. These external services are not supervised by the Company, and we are not responsible for their collection or processing of Personal Data. This Policy does not apply to activities carried out on those sites or apps.
Before accessing or using any third-party website or application, we recommend that you review their privacy policy and provide any Personal Data directly to them.

12. Changes to this Policy

This Policy may be updated at any time. Whenever we make changes, we will notify you by posting the revised Policy on our website. For significant revisions, we will attempt to inform you through the methods we deem appropriate and will publish an announcement on our website. Unless explicitly stated otherwise, any amendments will take effect upon publication of the revised Policy.

Your Rights Regarding Your Personal Information

You have the right to ask us to confirm whether we are processing your Personal Data, to correct any inaccuracies, to erase any Personal Data we no longer require, and to restrict certain processing activities. You may also request notification of any recipients of your Personal Data. If you reside in the EEA, please refer to this page:
These rights apply to any Personal Data you provide to us. To exercise your rights, please send an email to the address below. Access rights
The Company can confirm whether we process your Personal Data and provide you with access to it. Upon request, we will supply: (a) a copy of the Personal Data undergoing processing; (b) the purposes of processing; (c) categories of data; (d) recipients or categories of recipients; (e) retention periods; (f) sources of the data; and (g) any safeguards for international data transfers. We will provide this information electronically, unless you request otherwise, and we may charge a reasonable fee for additional copies.
Your right of access is subject to the rights and freedoms of others. If providing the information would infringe another person’s privacy or rights, we may refuse or limit our response by redacting third-party information. Right to rectification
You have the right to obtain the correction of any inaccurate or incomplete Personal Data concerning you. Upon your request, we will update, amend or complete the data and, where appropriate, inform recipients of those changes, unless doing so proves impossible or involves disproportionate effort. Right to erasure
You may request erasure of your Personal Data under the following circumstances: (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 to processing based on legitimate interests and there are no overriding grounds for processing; (d) the data have been unlawfully processed; (e) erasure is necessary to comply with a legal obligation under Union or Member State law; or (f) the data were collected in relation to the offer of information society services to a child. This right does not apply if processing is necessary: (i) to comply with a legal obligation; (ii) for public interest in the area of public health; (iii) for archiving purposes in the public interest, scientific or historical research, or statistical purposes; or (iv) to establish, exercise or defend legal claims.
Processing restrictions
If you contest the accuracy of your Personal Data, you may request that we restrict further processing. While processing is restricted, we may only store the data and use it with your consent, to establish, exercise or defend legal claims, to protect another individual’s rights, or for reasons of significant public interest within the Union or a Member State. We will inform you before lifting any restriction.
Right to data portability
When we process your Personal Data by automated means based on your consent or a contract, you have the right to receive the data in a structured, commonly used, machine-readable format. You may also request that we transmit those data directly to another controller, provided this is technically feasible. Exercising this right shall not adversely affect the rights and freedoms of others.
Right to object
You have the right to object at any time, on grounds relating to your particular situation, to processing of your Personal Data based on our legitimate interests, including profiling. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, or for the establishment, exercise or defence of legal claims.
Concerning direct marketing You have the right to object at any time to processing of your Personal Data for direct marketing purposes, including profiling related to such marketing activities. If you object, we will immediately cease processing for those purposes.
Right to withdraw consent
You may withdraw your consent for any processing that relies on consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.
Complaints and appeals You have the right to lodge a complaint with your local data protection authority, such as the Data Protection Commission in Ireland. You may also appeal to the supervisory authority in any Member State where you work, reside or believe an infringement has occurred.
Further limitations and procedures EU and Member State laws may impose additional restrictions on your rights under Section 13. We will respond to your request under Section 13 within one month of receipt. We may extend this period by up to two months for complex or numerous requests and will inform you of any extension and its reasons within the initial one-month period.
Unless Section 13 provides otherwise, we will supply the requested information free of charge. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have reasonable doubts regarding the identity of the requester, the Company may request additional information to confirm identity.