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 designed to explain how we collect and store the information you provide via 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 choices about the use and processing of Personal Data. That’s why we created this website. To support 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’ll share them with you at the appropriate time. We are happy to answer any questions and will provide any clarifications you need, subject to any limits imposed by law. You can reach us by email at: info@blue-orion.com

Personal data will only be used for the purposes outlined in this Policy.

Personal Data may be processed by us for various purposes, including providing our website to you and connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, meeting regulatory or legal obligations, and carrying out administrative and business activities to support the provision and use of the Services. Personal Data is also processed by us to better understand your preferences and needs.

Use essential tools to safeguard your rights regarding 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, tools, and procedures to deliver clear, relevant information about the use of Personal Data. If we believe you need more specific details, we’ll provide them to you at the appropriate time and through the most suitable channel. We’re happy to answer any questions and will offer any clarifications you need, subject to any limits imposed by law. You can contact us via email at the address below: info@blue-orion.com

Protect your personal data:

While we cannot guarantee the absolute security of your Personal Data, we remain committed to continually implementing a range of measures and techniques to safeguard your Personal Data. Our Privacy and Security Policy is comprehensive.

1. The Scope?

This Policy outlines the types of Personal Data Company collects about natural persons and how we process it, share it with third parties, and keep it secure. 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 by reference to additional information we hold or can access. The Policy defines 'processing' as any activity that involves the use or collection of Personal Data, including its management, structuring, and storage. Our services are intended for a general audience and are not designed for anyone under 18 years of age. We do not knowingly seek or collect information from persons under 18, nor do we knowingly permit them to use our services. If we become aware that we have collected information about a child, we will delete it as quickly as we can.

2. What Personal Data Do We Hold About You?

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

3. There is no obligation to disclose personal information to the company and the consequences of declining.

You are not required to provide Us with Personal Data. However, in certain circumstances, choosing not to do so may prevent Us from providing the Services or limit users' access to the website.

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

This includes your online activity logs, traffic data (such as your IP address and the date and time of access), the language you use, software crash logs, your browser type, and details about the device you use. The information we collect is not personal 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 to a third-party online trading platform through us. Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.

5. The 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 your Personal Data. The legal grounds on which the Company may process your Personal Data are:

  • You have provided your 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 information to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to defend legal claims.
  • Processing must meet a legal obligation.

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

Scope Legal Basis

1. To provide your personal information to third parties at your request to access digital trading.
If you ask us to, we may collect personal information from you to pass on 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
We require Personal Data to 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, regulatory, administrative, or judicial obligations, Personal Data is processed to meet legal requirements.

Processing is required to comply with legal obligations.

4. To enhance 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 legitimate interests pursued by the Company or a third party.

5. To prevent fraud and misuse of Our Services

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

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

Processing is necessary to pursue the Company's legitimate interests or those of a third party.

7. To conduct analysis, including statistical analysis
To make decisions on various issues, we use a range of analytical techniques (including statistical methods).

Processing is necessary to pursue the Company's legitimate interests or those of a third party.

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

Processing is necessary to pursue the Company's legitimate interests or those of a third party.

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 providers) for purposes including processing IP address information and analysing user experience.
You may also ask us to provide certain Personal Data about you to third-party trading platforms. In these cases, we will share the Personal Data you supply with those third-party platforms. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with related entities or business partners. This enables the Company to access the resources needed to enhance and improve the products and services it provides to customers.
Where necessary to protect the rights or property 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 our corporate group in connection with a transaction (including the transfer or sale of assets of the Company or any other group company) or as part of any merger, restructuring, consolidation or insolvency of the Company or any other group business.

ONLINE TRACKING NOTICE

We may engage third-party services, such as providers of advertising on our website and analytics companies. These providers may also utilise cookies or other technologies.
Cookies are small text files placed on your device whenever you visit or access the website. They collect information about your preferences and browsing habits to enhance your user experience, remember your settings, and customise the products and services you may enjoy. Cookies are also used for statistical and analytics purposes.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only for a short time, expiring when you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They are used to help the website recognise you as a returning user and make it easier for you to return to the website.

7. Cookies and Third-Party Services

We 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. 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 visited earlier.

Cookies collect personal information, such as your username and last login date, to confirm you are logged 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 to store your settings and preferences.

Additional information

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

Type of cookie

Cookies for performance

Scope

Cookies are used to collect statistical information about site performance and to help improve it. They also enable us to analyse website usage.

Additional information

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

Cookies are blocked or have been removed
To block or remove cookies, update your browser settings. Use the links below for guidance on several of the most 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 support Do Not Track signals.
8. Retention of your personal data

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 where permitted by law, regulations, policies, and applicable orders. We will share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue to share your data for a further 12 months.
We regularly review the Personal Data we hold and delete information that is no longer required.

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

Your personal information may be transferred to other countries (i.e., your personal data may be sent to a third country—one other than where you reside) or to international organisations or jurisdictions. The Company takes all necessary steps to safeguard 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 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 carried out under a legally binding and enforceable agreement between public entities or authorities in accordance with Article 46(2)(a).
  • The transfer was carried out in accordance with the standard data protection clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. The European Commission’s clauses 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 provide details of the security measures it uses to protect your Personal Data when transferred to third-party countries or international organisations. Please email your request to info@wealthwaydigital.uk


10. Security of Personal Information

We have implemented appropriate organisational and technical measures to safeguard Personal Data, including preventing accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee that the security of your Personal Data will be maintained without error. We are not responsible for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data, including, but not limited to, disclosure caused by transmission errors, unauthorised third-party access, or other events beyond our control.
In certain circumstances, such as when required by law or due to other obligations beyond our control, we may be required to provide your Personal Data to third parties, including public authorities. We cannot control the safeguards those third parties apply to your Personal Data in such situations.
Personal Data cannot be transmitted over the internet with complete security. The Company cannot ensure the security of Personal Data you transmit to us over the internet.

11. Hyperlinks to websites operated by third parties

Links to third-party websites and applications are provided on the website. These sites and apps are not under the Company’s control. We are not responsible for the collection or processing of Personal Data by these third parties. This Policy does not apply to activities carried out on such sites or apps.
When you visit any third-party site or app, we recommend reading its privacy policy before deciding to access or use it. We also suggest doing so before sharing any Personal Data with them.

12. Updates to this Policy

This Policy may be updated at any time. If we make changes to this Policy, we will notify you by posting the updated version on our website. In addition, for significant modifications, we will attempt to contact you using appropriate methods 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 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 we do not require. You may also restrict certain types of processing of your personal information. If you are a resident of the EEA, please refer to this page:
These rights are available to you with respect to the Personal Data you provide. You may exercise your rights by emailing the address below. Access rights
The Company can confirm whether your Personal Data are being processed. If they are, 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 provided electronically if you request it.
The right of access must not conflict with the rights and freedoms of others. If your request would adversely affect another person’s rights and freedoms, the Company may refuse to comply or limit its ability to do so. Right to rectification
The Company may rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of processing. Right to Erasure
The following grounds may apply: (a) Personal Data are no longer needed for the purpose for which they were collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object at any time, on grounds relating to your particular situation, to processing of your Personal Data based on legitimate interests pursued by us or a third party; (e) Personal Data have been processed unlawfully; or (f) Personal Data must be deleted to meet the Company’s legal obligation. 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. If processing is restricted, Personal Data may be kept only with your consent, for the establishment, exercise or defence of legal claims, to protect the rights of another natural person, or for reasons of important public interest in the European Union or a Member State.
Right to data portability
If 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 have provided to the Company in a structured, commonly used and machine‑readable format.
You may 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 object
You may object at any time to the processing of your Personal Data based on the Company’s or a third party’s legitimate interests, including profiling based on those legitimate interests. Unless we demonstrate compelling legitimate grounds for the processing that override your rights, freedoms or interests, or the processing is for the establishment, exercise or defence of legal claims, we will cease processing.
Regarding direct marketing, you have the right to object at any time to the processing of your Personal Data.
Right to withdraw 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 its withdrawal.
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 the fundamental rights of individuals in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights regarding your Personal Data, as described in section 13. We will provide the information requested under your rights in section 13 of this agreement within one month of receiving your request. The timeframe may be extended by up to two months, if necessary, depending on the complexity and number of requests. Within one month of receiving your request, we will notify you of any extension and the reasons for it.
Unless otherwise provided in section 13, the information you request under section 13 will be provided free of charge. If a request is 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 doubts about the identity of the person making the request, the Company may ask for additional information.