We (also referred to as 'we', 'us', or 'our') are fully committed to protecting your Personal Data and safeguarding your privacy.
This Privacy Policy is intended to inform you about how we collect and store the information you provide on the Gaingate website (the 'Website').
We uphold and adhere to the following principles:

We aim to remain transparent about how we collect and use your personal information, in your best interests:

Our aim is to help you make informed decisions about the use and processing of Personal Data. To support this, our website uses several tools and processes to provide clear information about how Personal Data is used. If you need specific details about your data, we will make every effort to provide them promptly and at the appropriate time. If you have any questions, we are happy to explain any legal constraints. To contact us, please email info@blue-orion.com

We will use Personal Data only for the purposes set out in this Policy

You will find that we process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and provisioning the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities to enable the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Gaining access to vital resources to support the protection of your rights in relation to Personal Data

Our goal is to help you make well-informed decisions about how we handle your data. This is why we have invested the time in developing this website. To support this, we routinely use a range of methods, processes and safeguards to ensure you continue to receive clear, accurate and relevant information about the use of your Personal Data. We aim to keep this information up to date and easy to understand. Where specific details are required, we will provide them at the appropriate time. If you have any questions about how this process works, we are more than happy to respond and offer clarifications, all within the bounds of applicable legal requirements. If you would like to learn more, please get in touch with us by email at info@blue-orion.com

Keep Your Personal Information Safe and Secure

Unfortunately, we cannot guarantee the absolute security of Personal Data—no one can—but we remain fully committed to using multiple safeguards to protect your Personal Data. Our Privacy and Security Policy addresses all key areas to help ensure your long-term safety.

Scope?

By reviewing this Policy, you will find an overview of the types of Personal Data our Company collects from customers, along with how we process it, share it with third parties, and keep it secure. Our Policy relates to information about an identified or identifiable individual, whom we can recognise directly or by combining it with other information we hold or can access. For the purposes of this Policy, ‘processing’ means any operation involving the use or handling of Personal Data, including its management, organisation, and storage. Our services are intended for a general audience but are prohibited to anyone under 18, and we do not permit use by individuals below this age. Accordingly, we do not knowingly collect information from anyone under 18. If we become aware of any data collection relating to a person under 18, we will delete it promptly.

2. What Personal Information Do We Collect from You?

If you use our services or our channels, or browse our website, you agree that we may collect personal data about you. In some instances, we may ask you to provide personal data directly. Alternatively, we may analyse how you interact with our services or channels, or collect this information through our third-party partners

3. You are not required to provide your personal information to our company or to deal with any implications of doing so

You are not required to share personal data with us. However, in some cases, if you choose not to provide certain personal data, it may affect how we deliver our services to you, which could result in limited access to our website or limited use of certain features.

4. What types of personal data do we collect? When you visit our website, we may collect the following personal information:

The information we collect includes details from your activity log, traffic data (including IP address and date and time of access), your language settings on our site, software crash reports, browser type, and device specifications. This data is non-personal and is not used to identify you. Some of the Personal Data we obtain comes from information you voluntarily provide when you connect to a third-party online trading platform through us. We also receive the personal details you submit directly to those platforms, including your full name, email address, phone number, and address.

5. What Are Our Legal Bases and Justifications for Processing Personal Data

Our Company processes your personal data for the purposes outlined in this section, in accordance with applicable law.
We require a lawful basis because, without one, our Company cannot use your personal data. The lawful bases on which our Company may process your personal data include:

• We have obtained your consent to process your Personal Data for one or more of the following purposes, including when you provide personal information via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process this information where it is necessary for their legitimate interests. Examples include improving our Services or defending ourselves against litigation that may arise.
• All processing carried out on our website must comply with applicable legal requirements, and we can confirm that it does.

To learn more about how we process Personal Data in pursuit of our legitimate interests, please contact us by email at any time.
Below, we set out the reasons and legal bases on which you may find us using the personal information you have provided to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Depending on the circumstances, the Company may disclose Personal Data to third parties that provide services such as data storage, IP address hosting, or user experience analytics.
We also accept requests from individuals who ask us to share specific Personal Data with third-party trading platforms. In such cases, we will transfer the Personal Data you provide to the platforms you specify. If you proceed, their privacy policies will govern its use. In these situations, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners or affiliated entities to access the resources required to enhance and continually improve our customer offerings.
Where necessary, the Company may disclose Personal Data to regulatory, local, or other competent authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or buyers, or with lenders to the Company or its affiliated companies. This typically occurs in connection with transactions such as asset transfers or sales, restructurings, mergers, consolidations, or insolvency proceedings involving the Company or other parties associated with the Company.

Online Tracking Notice

On our website, we may use third-party services, such as advertising providers and analytics firms. These companies may also use cookies and similar technologies to collect data.
By “cookies”, we mean small text files stored on your device whenever you visit or access our website. We use cookies to collect information about your preferences and browsing patterns, with the aim of improving the user experience, understanding your interests, and shaping products and services around customer needs. Cookies also help us compile statistics, measure performance, and carry out analytics.
Some of the cookies we use are session cookies. Session cookies are temporarily placed on your device and expire when you close your browser. Other cookies are persistent, meaning they remain on your device after you close your browser. These help the website recognise you as a returning visitor and retain the preferences you previously set.

7. How We May Use Cookies and Third-Party Services

Each cookie and its use may vary, depending on its particular purpose and function.

Cookies have been blocked or deleted
You can manage your cookie preferences using your browser settings. You can use the links below to help with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that some website functions and features may not operate as expected if this occurs.

Online Tracking Notice Please note that at present our service does not respond to Do Not Track requests.
8. Learn More About How We Store Your Personal Information

Please note that Our Company will retain your Personal Data for as long as necessary to fulfil the purposes outlined in this Policy, and may retain it for longer where permitted by law and for legitimate business purposes, including in relation to specific orders and regulatory requirements. In certain cases, your information may be shared with third-party trading platforms for up to 12 months. With your consent, we may extend this sharing for a further 12 months, if needed.
We periodically review and assess the Personal Data we hold to confirm it remains necessary and is not retained longer than required.

9. Transfers of Personal Data to Third Countries or International Organisations

In certain circumstances, we may transfer your Personal Data to other countries, which means that with your consent we may send this data outside your home country or to international organisations. We take all necessary measures to safeguard your Personal Data and ensure you can exercise your rights and access effective legal remedies if needed.
These protections and safeguards apply to all residents of the EEA (European Economic Area).

• In certain cases, we may transfer your Personal Data to a third country or international organisation that the European Commission recognises as providing an adequate level of 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')
• When the transfer occurs, we do so under a legally binding, enforceable agreement between public bodies or authorities in accordance with Article 46(2)(a)
• We carry out transfers in accordance with the European Commission’s Standard Contractual Clauses for data protection, adopted under Article 46(2)(c) of the GDPR. To learn more, you can view the adopted clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

If you'd like to learn more about our safeguards and how they protect your Personal Data when transferred to third countries or international organisations, please email us at info@wealthwaydigital.uk

10. Protection of Personal Data

In order to safeguard your Personal Data, we have implemented appropriate technical and organisational security measures. These measures are designed to prevent accidental or unlawful destruction, loss or alteration.
While we take all reasonable precautions, we cannot guarantee that your Personal Data will be maintained securely and without error, nor can we be held liable for any intangible, incidental or consequential losses or damages arising from its use or disclosure. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised access by third parties, or other causes beyond our control.
Where we are legally obliged, or due to other constraints beyond our control, we may need to share your Personal Data with third parties, such as public authorities. In such circumstances, we cannot control the level of security these third parties provide.
Please note that transmitting Personal Data over the internet cannot be made entirely secure and carries risks. Because of these risks, we cannot guarantee the security of the Personal Data you transmit to us online.

11. Information on Links to Third-Party Websites

Our website includes links to external sites and applications that fall outside our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. While our Policy covers what happens on our website, it does not apply to third-party websites.
Before visiting any third-party website or app, you should review their privacy policies before using their services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will notify you on our website and display the updated Policy. For significant changes, we will use the methods we consider most appropriate to inform you, including announcements on our website. Unless stated otherwise, all amendments to this Policy take effect immediately upon publication of the updated Policy.

Your Rights in Relation to Your Personal Data

You have the right to request a review of the personal data we hold about you, to have it rectified, and to ask us to delete any Personal Data you do not wish us to retain. You may also restrict the types of data we collect. For residents of the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us using the email address below. Access rights
We will verify the accuracy of the Personal Data we process. Where accurate, we will provide you with access to your Personal Data, including an electronic copy of the processed data. We reserve the right to charge a reasonable fee for additional copies. On request, we will provide this data electronically.
Your right of access must not infringe the rights of others. Where a request would impact others’ rights, we may refuse to comply or limit our response. Your rights to rectification
If you wish to correct inaccurate Personal Data, you may ask us to rectify incomplete or incorrect information. Your right to erasure
Legitimate grounds may include: (a) we no longer need the personal data for its original purpose; (b) you withdraw your consent and there is no legal basis for processing; (c) you object to processing for specific reasons; (e) the Personal Data has been processed unlawfully; or (f) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with EU or Member State law, or (b) to establish, exercise, or defend legal claims.
Restriction of processing
You may ask us to limit processing if you believe the data is inaccurate. Where processing is restricted, we may continue to store the data only with your consent, for the establishment, exercise or defence of legal claims, to protect another person’s rights, or for important public interest of an EU or Member State.
Right to data portability
For automated processing based on consent or a contract, you have the right to receive your Personal Data held by the Company.
You also have the right to request that the data be transferred to another controller where technically feasible. Exercising your right to data portability will not affect your right to erasure.
Right to object
You may object at any time to our processing of your Personal Data based on the legitimate interests of the Company or third parties, including related profiling. We will proceed only where we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is necessary for legal claims.
You have the right to object at any time to the processing of Personal Data for direct marketing.
Right to withdraw consent
You may withdraw your consent to processing at any time, without affecting the lawfulness of processing before withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for your Personal Data rights.
You may also request that a supervisory authority in a Member State protect your individual rights regarding Personal Data processing within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request, but we may extend this by up to two months depending on the complexity and number of requests. You will be notified within one month of any extension and the reasons for it.
We will provide the information you request under section 13 free of charge unless the request is unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act on the request.
If we have doubts about your identity in connection with a request, the Company may request additional information.