Privacy Policy

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

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

We want you to be able to make informed decisions about the use and processing of Personal Data. That’s why we created this website. To achieve this, we use various methods and procedures to provide you with relevant information about how Personal Data is used. If we believe you need specific details, we will share them at the appropriate time. We are happy to answer any questions and provide any clarifications permitted by law. You can reach us by email at the following address: info@blue-orion.com

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

Personal Data may be processed by Us for various 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 delivering the Services, complying with regulatory and legal obligations, and conducting administrative and business activities to support the provision and use of the Services. We also process Personal Data to better understand your preferences and needs.

To make use of essential tools designed to protect your rights concerning Personal Data:

We want you to be able to make informed decisions about how your Personal Data is used and processed. That is why we created this website. To that end, we use various methods and procedures to give you clear, relevant, and timely information about the use of Personal Data, including notices, policies, and contextual explanations. If we determine that you need more specific details, we will provide them, whether through this site or directly, at the appropriate time. We are happy to answer any questions and to offer any clarifications permitted by law. You can reach us by email at: info@blue-orion.com

Protect Your Personal Data:

While we cannot guarantee the absolute security of your Personal Data, we will continue to employ a range of methods and techniques to safeguard it. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy describes the types of Personal Data the Company collects about natural persons and how it is processed, shared with third parties, secured, and otherwise handled. It concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including through a combination of other information we hold or can access. The Policy defines 'processing' as any operation involving the use or collection of Personal Data, including the management, structuring, and storage of such data. Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from individuals under 18, nor do we knowingly allow such persons to use our services. If we become aware of information about a child, we will delete it as quickly as we can.

2. What Personal Data Do We Hold About You?

If you use our Services and channels, or visit our website, we collect Personal Data. In some cases, we may request your Personal Data. In other cases, we collect it by analysing how you use our Services and channels, or by receiving information about you from our third-party partners.

3. No obligation to disclose personal information to the company and potential consequences.

However, you are not required to provide us with Personal Data. In some situations, though, choosing not to share Personal Data may have consequences. It may prevent us from delivering the Services or limit users’ ability to access the website.

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

This includes details of your online activity log and traffic data (such as IP address and the date and time of access), the language you use, software crash logs, the browser type, and information about the device you use. The information we collect is not personal and cannot be used to identify you. Personal data we receive from you means any information you voluntarily provide to us when you connect to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading may include your full name, address, phone number, and email address.

5. Legal Basis and Grounds for Processing Personal Data

Your personal data is processed by the Company for the purposes outlined in this section and in accordance with the applicable legal basis.
Without a valid legal basis, the Company cannot use personal data relating to you. 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 through 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 pursue their legitimate interests. For example, this may be necessary to improve Our Services or to establish or defend legal claims.
  • Processing must comply with a legal obligation.

Contact us by email for more details on processing activities required to protect legitimate interests.
Below is a list of purposes and legal bases for which we may use the information you provide. Personal Data.

Scope Legal Basis

1. To share your Personal Data with third parties at your request to enable access to digital trading.
If you request it, we may ask for Personal Data from you to forward it to third-party companies

You have consented to the processing of your Personal Data for one or more purposes.

2. To respond to your requests, questions, or concerns
Personal Data is required to help us address any questions you may have regarding the Services.

Processing is necessary for the legitimate interests of the Company or a third party.

3. To comply with any legal, administrative, or judicial obligations, Personal Data is processed to meet applicable legal requirements.

Processing is necessary to comply with legal obligations.

4. Enhancing Our Services
We may use Personal Data to enhance Our Services. This includes, among other things, crash and malfunction reports we collect in connection with the Services.

Processing is necessary for the Company’s legitimate interests or those of a third party.

5. To prevent fraud and misuse of Our Services

Processing is required to pursue the legitimate interests of the Company or those of a third party.

6. To execute and manage actions aligned with the requirements of Our Services
These activities include back-office operations, business development activities, strategic decision-making, and oversight mechanisms, etc.

Processing is necessary for the legitimate interests of the Company or a third party.

7. To perform analyses, including statistical analysis
We employ a range of analytical techniques (including statistical methods) to make decisions on various issues.

Processing is necessary for the legitimate interests of the Company or a third party.

8. To protect our assets, rights, and interests—as well as those of third parties—we have developed HTML0 to establish and defend legal claims
We may process Personal Data to safeguard our rights, interests, and assets, or those of third parties, in compliance with applicable laws, regulations, agreements, and any relevant terms, conditions, or policies.

Processing is necessary for the legitimate interests of the Company or a third party.

6. Transfer of Personal Data to Third Parties

The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, for purposes including processing IP address information and analyzing user experiences.
You may 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 submit to Us to those third-party platforms. The use of your Personal Data is subject to their privacy policies, and your information may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners to access resources that help enhance and improve the products and services we provide to customers.
Where necessary to protect the rights or property of third parties, or as required by law, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may additionally share your Personal Data with prospective investors, buyers, or lenders of the Company or any other company within the group in connection with 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 business within the group.

ONLINE TRACKING NOTICE

We may engage third-party providers, such as advertising networks that serve advertisements on our Website or analytics companies. These providers may also use cookies or similar technologies.
Cookies are small text files placed on your device when you visit or access the Website. They collect information about your preferences and browsing behavior to enhance your experience, remember your settings, and tailor products and services you may find relevant. Cookies are also used for statistical and analytics purposes.
Some of the cookies we use are session cookies, which are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device for a period after you close your browser. These help the Website recognize you as a returning user and make it easier to return to the Website.

7. Cookies and Third-Party Services

We may use them according to their intended purpose:

Type of cookie Scope Legal Basis
Type of cookie

Cookies are strictly necessary

Cookies are strictly necessary

These cookies are essential for accessing the features you’ve requested and for navigating our website as intended. They enable us to deliver the information, products, and services you have requested from us.
They are necessary for your device to download and stream data, allowing you to move around the site, use its features, and easily return to pages you’ve visited previously.

Cookies collect personal data—such as your username and last login date—to confirm that you are logged in to the site. These session cookies are deleted when you close your web browser.

Type of cookie

Functionality Cookies

Scope

Cookies enable us to recognize you each time you visit our site and to save your settings and preferences.

Additional information

They persist until their expiration date and remain stored even after the browser is closed.

Type of cookie

Cookies for performance

Scope

We use cookies to collect statistical data on the site's performance and to improve it. They also enable us to conduct analysis on our website.

Additional information

Cookies store anonymous data that is not linked to any identifiable or identified natural person. They can be deleted when you close your browser. Some cookies remain valid indefinitely

Cookies are blocked or have been removed
To block or remove cookies, change your browser settings. Below are links to help with the process for several popular browsers.

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari
However, please note that some or all of the Website's functions and features may not operate as expected if this occurs.


ONLINE TRACKING NOTICE This service does not currently respond to Do Not Track signals.
8. Retention of Your Personal Data

The Company will retain Personal Data about you for as long as is necessary to fulfill the purposes of processing Personal Data, as described in this Policy, or for longer periods as allowed by applicable laws, regulations, internal policies, and applicable orders. We will share your information with third-party trading platforms for a period of 12 months. If you provide consent to this, we will continue to share your data for an additional 12 months.
We routinely review the Personal Data we hold to ensure it remains necessary and is not kept longer than required.

9. Transfers of personal data to a third country or an international organisation

Your personal information may be transferred to other countries, meaning your personal data may be sent to a third country (a country other than the one in which you reside) or to international organizations or jurisdictions. The Company takes all necessary measures to protect 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 all residents of the EEA (European Economic Area).

  • Transfer to a third country or 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 carried out under a legally binding, enforceable instrument between public entities or authorities pursuant to Article 46(2)(a).
  • The transfer was carried out in accordance with the standard contractual clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. You can review these Commission-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.
The Company can provide details about the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. To request this information, please email info@wealthwaydigital.uk


10. Personal Data Security

We have implemented appropriate organizational and technical measures to safeguard Personal Data. These measures include preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data, including but not limited to disclosures caused by transmission errors, unauthorized access by a third party, or other causes beyond our control.
In the event of legal obligations or other requirements beyond our control, we may be required to provide your Personal Data to third parties, such as public authorities. In such cases, we cannot control the security measures those third parties apply to your Personal Data.
Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to third-party websites maintained by others

Our website may include links to third-party websites and applications. These sites and apps are not under the Company’s control. We are not responsible for any collection or processing of Personal Data by those sites or apps. This Policy does not apply to activities carried out through them.
When you visit any third-party site or app, we recommend that you read its privacy policy before deciding to access or use it. We also suggest exercising caution when providing any Personal Data to them.

12. Updates to this Policy

This Policy may change at any time. If we update it, we will notify you by posting the revised Policy on our website. Additionally, when we make material changes to this Policy, we will attempt to notify you using methods we deem appropriate and will publish an announcement on our website. Unless expressly stated otherwise, any changes will take effect upon publication of the updated Policy.

13. Your rights regarding your personal information

You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete any Personal Data that we do not require. You may also limit certain types of processing of your personal information. If you are an EEA resident, please refer to this page:
These rights apply to the information you provide in connection with your Personal Data. You can exercise your rights by emailing the address below. Right of access
The Company can verify whether Personal Data about you is being processed. If so, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed 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 conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply or limit its response. Right to rectification
The Company will rectify inaccurate Personal Data. You have the right to request that incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to erasure
You may request erasure if: (a) the Personal Data is no longer needed 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, for reasons related to your particular situation, to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data must be deleted to comply with the Company’s legal obligations. This right does not apply where processing is necessary (a) to comply with a legal obligation under European Union or Member State law; or (b) for the establishment, exercise, or defense of legal claims.
Restriction of processing
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. If processing is restricted, Personal Data may be stored only with your consent, for the establishment, exercise, or defense of legal claims, to protect the rights of another natural person, or for reasons of important public interest of the European Union 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 provided to the Company in a structured, commonly used, and machine-readable format.
You also have the right, where technically feasible, to have your Personal Data transmitted directly from the Company to another controller. Exercising your right to data portability does not affect your right to erasure. Data portability must not adversely affect the rights and freedoms of others.
Right to object
You may object at any time to processing of Personal Data concerning you that is based on the Company’s or a third party’s legitimate interests, including profiling based on those interests. We will stop processing unless we demonstrate compelling legitimate grounds that override your rights, freedoms, and interests, or the processing is for the establishment, exercise, or defense of legal claims.
Direct marketing: you have the right to object at any time to the processing of Personal Data concerning you for direct marketing.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. This does not affect the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with your supervisory authority.
You may also lodge a complaint with a supervisory authority established by a Member State to protect individuals’ fundamental rights regarding the processing of Personal Data within the European Union.
European Union and Member State laws may restrict your rights regarding your Personal Data as described in this section 13. We will provide the information requested under section 13 within one month of receiving your request. This period may be extended by up to two additional months if necessary, considering the complexity and number of requests. We will inform you of any extension and the reasons within one month of receiving your request.
Unless otherwise provided in section 13, the information provided in response to your request under section 13 will be supplied free of charge. If a request is manifestly unfounded or excessive, particularly if repetitive, we may charge a reasonable fee to cover administrative costs or refuse to act on the request.
If we have doubts about the identity of the person making the request, the Company may request additional information.