Privacy Policy

We (also referred to as 'We', 'Us' or 'Our') are committed to safeguarding your privacy and Personal Data.
This Privacy Policy is designed to inform you about 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 a range of methods and procedures to provide you with relevant information about the use of Personal Data. If we believe you need specific details, we’ll provide them at the appropriate time and place. We’re happy to answer any questions and will offer any clarifications you require, subject to any legal limitations. You can contact us by email at: info@blue-orion.com

Personal Data will be used solely for the purposes set out in this Policy.

Personal Data may be processed by Us for a variety of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), enhancing the site, protecting our rights and interests, supporting the maintenance and delivery of the Services, meeting regulatory or legal obligations, and carrying out administrative and business activities to facilitate the provision and use of the Services. Personal Data are also processed by Us to better understand your preferences and needs.

Access essential tools to exercise and protect your rights in relation to Personal Data:

We want you to be able to make informed choices about how your Personal Data is used and processed. That’s why we created this website. To support this, we use a range of methods and procedures designed to provide clear, relevant information about our use of Personal Data. If we consider that you need more specific details, we’ll provide them at the appropriate time and in the appropriate context. We are happy to answer any questions you may have and to offer any clarifications you require, subject to any limitations imposed by law. You can contact us by email at: info@blue-orion.com

Protect your personal information:

While we cannot guarantee the absolute security of your Personal Data, we can assure you that we will continue to use a range of methods and techniques to ensure your Personal Data remains protected. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy explains the types of Personal Data Company collects about individuals and how we process it, share it with third parties, and keep it secure. This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or indirectly, including by reference to other information we hold or can access. The Policy defines 'processing' as any operation involving the use or collection of Personal Data, including the organisation, structuring, and storage of Personal Data. Our services are intended for general audiences and are not designed for anyone under 18 years of age. We do not knowingly solicit or collect information from anyone under 18, nor do we knowingly permit such individuals to use our services. If we become aware of any information about children, we will delete it as quickly as possible.

2. What Personal Data Do We Hold About You?

When you access our Services and service channels or visit our website, we collect Personal Data. We may request your Personal Data in certain instances. In other cases, we collect it by analysing how you use our Services and service channels, or by receiving information about you from our third-party partners.

3. There is no obligation to disclose personal information to the company and the consequences of not doing so.

You are not required to provide Us with any Personal Data. In some cases, however, you may choose not to supply Us with Personal Data. This may hinder Us from providing the Services or prevent users from accessing the website.

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

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

5. Legal basis and reasons for processing 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 a valid legal basis, the Company cannot use Personal Data about you. The legal grounds on which the Company may process your Personal Data:

  • You have provided 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 pursue their legitimate interests. For example, this can be necessary to enhance Our Services or to establish, exercise, or defend legal claims.
  • Processing must satisfy a legal obligation.

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

Scope Legal Basis

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

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

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

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

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

To meet our legal obligations, processing is necessary.

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

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

5. To prevent fraud and misuse of Our Services

We process data where necessary to pursue the legitimate interests of the Company or a third party.

6. To undertake and manage activities that align with the requirements of Our Services
These activities include back-office functions, business development, strategic decision-making, oversight mechanisms, etc.

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

7. To conduct analyses, including statistical analyses
To inform decisions on various matters, we apply a range of analytical techniques (including statistical methods).

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

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

Processing is necessary for the legitimate interests of the Company or those of 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, processing of IP address information, and user experience analytics.
You may also ask us to provide specific Personal Data about you to third-party trading platforms. In these cases, we will pass on the Personal Data you have provided to Us to those third-party trading platforms. Their use of your Personal Data is governed by their privacy policies, and your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners to access resources that help us enhance and improve the products and services we provide to customers.
Where necessary to safeguard the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company in the group of companies in connection with a transaction (including the transfer or sale of assets of the Company or any other company within the group) 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 services, such as advertising providers on our website or analytics companies. These providers may also use cookies or other technologies.
Cookies are small text files placed on your device when you visit or access our website. They collect information about your preferences and browsing habits to improve your experience, remember your settings, and customise the products and services you may enjoy. Cookies are also used for statistics and analytics.
Some of the cookies we use are session cookies. They are temporarily downloaded to your device and last only until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and make it easier to navigate back to the site.

7. Cookies and Third-Party Services

We may use them based on 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. We use them to deliver the information, products and services you’ve asked for.
They enable your device to download and stream data, allowing you to move around the website, utilise its features, and return to pages you’ve previously visited.

Cookies collect personal data, such as your username and last login date, to verify you are signed in to the site. They are deleted when you close your web browser (session cookies).

Type of cookie

Functionality Cookies

Scope

Cookies help us recognise you each time you visit our site and save your preferences and settings.

Additional information

They remain active until their expiry date and are retained even after the browser is closed.

Type of cookie

Cookies for performance

Scope

Cookies are used to collect statistical information about the website's performance and to help improve it. They also allow us to conduct analysis on our website.

Additional information

Cookies store anonymous data that isn’t linked to any identified or identifiable natural person. You can delete some cookies when you close your browser; others remain valid indefinitely.

Cookies are blocked or have been removed
To block or remove cookies, adjust your browser settings. Below are links to guide you through the process for several popular browsers.

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari
However, please note 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 honour Do Not Track signals.
8. Retention of your personal information

The Company will retain your Personal Data for as long as necessary to fulfil the purposes of processing described in this Policy, or for longer periods as permitted by laws, regulations, policies, or applicable orders. We will share your information with third-party trading platforms for 12 months. If you consent, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold to ensure it is no longer needed.

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

Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country—any country other than the one in which you reside—or to international organisations or jurisdictions). The Company takes all necessary measures to protect the Personal Data you provide and to ensure users 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 an international organisation that the European Commission has determined provides adequate protection for Personal Data transferred to it in accordance with Article 45(3) of Regulation 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, in accordance with Article 46(2)(a).
  • The transfer was conducted in accordance with the Standard Contractual Clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the European Commission can be viewed 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 share details of the security measures it uses to protect your Personal Data when it is transferred to third-party countries or international organisations. To request this information, email info@wealthwaydigital.uk


10. Security of Personal Information

We have implemented appropriate organisational and technical measures to protect Personal Data, including preventing accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be error-free, nor can we be liable for any indirect, incidental, or consequential loss arising from the use or disclosure of Personal Data. This includes, but is not limited to, disclosure due to transmission errors, unauthorised third-party access, or other causes beyond our control.
Where required by law or by other obligations beyond our control, we may be compelled to disclose your Personal Data to third parties, such as public authorities. We cannot control the security measures those third parties apply to your Personal Data in such circumstances.
Personal Data cannot be transmitted over the internet with complete security. The Company cannot ensure the security of Personal Data you transmit to us online.

11. Hyperlinks to websites owned by third parties

Links to third-party sites and applications are provided on this website. These sites and applications are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by those sites or apps. This Policy does not apply to activities carried out through such sites or apps.
When you visit any third-party website or app, we recommend that you read its privacy policy before choosing to access or use it. We also suggest exercising caution when providing any Personal Data to them.

12. Changes to this Policy

This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy on our website. For significant updates, we will also endeavour to inform you through appropriate channels and will publish a notice on our website. Unless otherwise specified, amendments take effect upon publication of the updated Policy.

Your rights in relation to your personal information

You are entitled to ask us to verify the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data that is not required by Us. You may also limit the scope or types of processing applied to your personal information. If you are a resident of the EEA, please refer to this page:
These rights apply to the information you provide in relation to your Personal Data. You may exercise your rights by emailing the address below. Access rights
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 any additional copies. The data will be supplied electronically if you request it.
The right of access must not conflict with the rights and freedoms of others. If a request would adversely affect another person’s rights or freedoms, the Company may refuse to comply or limit how it fulfils the request. Right to rectification
The Company may rectify inaccurate Personal Data. You are entitled to require that incomplete Personal Data concerning you be corrected, taking into account the purposes of processing. Right to Erasure
You may request erasure where: (a) the Personal Data are no longer needed 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, on grounds relating to your particular situation, to processing based on legitimate interests pursued by Us or a third party; (e) the Personal Data have been processed unlawfully; or (f) the Personal Data must be erased 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 defence of legal claims.
Processing restrictions
If you are concerned about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where restriction is applied, Personal Data may only be stored with your consent, or for the establishment, exercise or defence of legal claims, to protect the rights of another natural person, or for important public interest reasons in the European Union or a Member State.
Right to data portability
Where processing is automated and based on consent or on 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 may also request that your Personal Data be transmitted directly by the Company to another controller, where technically feasible. Exercising your right to data portability does not affect your right to erasure. The right to data portability must not adversely affect the rights or freedoms of others.
Right to challenge
You may object at any time to processing of Personal Data about you that is based on legitimate interests pursued by the Company or a third party, including profiling based on those legitimate interests. Unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims, we will cease such processing.
Concerning direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.
Right to refuse consent
You may withdraw your consent for Us to process your Personal Data at any time. This does not affect the lawfulness of processing based on consent before it was withdrawn.
You are entitled to lodge a complaint with your supervisory authority.
You may submit a complaint to a supervisory authority established by a Member State to protect fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights concerning Personal Data as set out in this section 13. We will provide information in response to your requests under section 13 within one month of receipt. This period may be extended by up to two months where necessary, depending on the complexity and number of requests. We will inform you within one month of receiving your request of any extension and the reasons for it.
Subject to section 13, information provided in response to your rights 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 the administrative costs of providing the information or taking the requested action, or we may refuse to act.
If we have reasonable doubts about the identity of the person making the request, the Company may ask for additional information.