Privacy Policy

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

We are committed to being transparent about how we collect and use your personal data in your best interests:

By doing so, our goal is to help you make informed decisions about the use and processing of Personal Data. To support this, our website uses several methods and procedures to provide relevant information about Personal Data usage. If you require specific details about your data, we will work hard to ensure you receive them promptly and at the appropriate time. Should you have any questions, we will be happy to clarify anything relating to legal constraints. To contact us, please email info@blue-orion.com

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

We handle Personal Data for a range of purposes, including providing you with access to the website, connecting you with third-party trading platforms (referred to as 'Services'), improving the site, protecting our rights and interests, maintaining and providing the Services, ensuring full compliance with legal and regulatory obligations, and carrying out administrative and business activities necessary for the delivery and use of the Services. We also process your Personal Data to help us better understand your preferences and needs.

Ensuring access to essential resources to protect your Personal Data rights

We are committed to helping you make well-informed choices about how we handle your data. That is why we created this website and invested the time to explain our practices clearly. To support this, we use a range of methods and procedures to ensure you consistently receive the most relevant information about the use of your Personal Data. 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 happy to answer them and provide clarification, all in line with legal requirements. If you would like to know more, please contact 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, as no one can, but we remain fully committed to using a range of measures to protect your Personal Data. Our Privacy and Security Policy covers all essential bases, helping to ensure your long-term security.

Scope?

In this Policy, we outline the types of Personal Data our Company collects from customers, including how we process it, share it with third parties, and keep it secure. Our Policy covers information about an identified or identifiable individual, whom we can recognise directly or indirectly through 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; however, they are prohibited for anyone under the age of 18, and we do not authorise use by individuals below this age. Accordingly, we do not knowingly collect information from anyone under 18. If we become aware that we have collected data relating to a person under 18, we will promptly delete it.

2. What Personal Information Do We Collect from You?

For anyone who uses our services or related channels, or browses our website, you agree that we may collect personal data about you. In some instances, we may ask you to provide this information directly. Alternatively, we may analyse how you interact with our services or channels, or obtain it through our third-party partners

3. There is no requirement to provide your personal information to our company or to address any consequences of doing so

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

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

The Personal Data we collect includes information such as activity log details, traffic data (including IP address and dates and times of access), your chosen site language, software crash reports, browser type, and device specifications. The above information is non-personal and is not used to identify you. We may also obtain Personal Data that you voluntarily provide when you connect to a third-party online trading platform through us. In addition, we receive personal details you submit directly to those platforms, such as your full name, email address, phone number, and address.

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

Our Company processes your personal data for the purposes outlined in this section and complies with the applicable legal framework.
We require a lawful basis; without one, our Company cannot use your personal data. The lawful grounds that permit our Company to process your personal data include:

  • We have obtained your consent to process your Personal Data for one or more of the reasons set out below, including where you submit personal information through the Website for us to share with a third-party trading platform
  • The Company or a third party may need to process this information to pursue legitimate interests, including enhancing our Services, improving the user experience, or defending against potential legal claims and disputes that may arise.
  • All processing carried out on our website complies with the relevant legal requirements, and we can confirm that it does.

If you would like more information about how we process Personal Data to protect our legitimate interests, please contact us by email.
Below, we've set out the reasons and legal bases on which we may use the personal information you provide to us. Personal Data

Scope Legal Basis

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

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

2. To enable us to address your questions, concerns, or requests
We require your Personal Data to assist with enquiries related to our services.

We undertake this processing to pursue the legitimate interests of the Company or a third party.

3. We process your Personal Data to fulfil our legal, administrative, judicial and regulatory obligations, and to ensure we comply with all applicable requirements.

We must process this Personal Data to comply with our legal obligations.

4. For the purpose of improving Our Services
We may use the Personal Data we collect to enhance Our Services, including by reviewing crash reports, malfunction data, and other diagnostics related to Our Services.

We process personal data when required for the Company’s or a third party’s legitimate interests.

5. Steps We Take to Reduce the Risk of Fraudulent Activity and Misuse of Our Services

We must process data where necessary for the Company’s or a third party’s legitimate interests.

6. To Carry Out and Coordinate Our Activities in Line with Our Service Requirements
These activities include support functions, business development initiatives, strategic decision-making, governance and oversight systems, and more

We process this Personal Data when necessary for the legitimate interests of the Company or a third party.

7. Conducting analysis, including statistical evaluations
We use a range of analytical methods (including statistical techniques) to support decision-making across multiple issues.

We process this Personal Data when necessary for the legitimate interests of the Company or a third party.

8. As part of protecting our assets, rights and interests, and those of third parties, we take measures to assert and defend against legal claims
To do so, we may process Personal Data to protect our rights, interests and assets, or those of third parties, in line with applicable laws, regulations, agreements, and any relevant terms, conditions or policies

We process this Personal Data when necessary for the legitimate interests of the Company or a third party.

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 storage, IP address hosting, or user experience analytics.
We also accommodate requests from individuals who want us to share specific Personal Data about themselves with third-party trading platforms. In such cases, we will transfer the Personal Data you provide to the platforms you choose. 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. We do this to access the resources needed to enhance and improve our customer offerings.
Where appropriate, the Company may disclose Personal Data to regulatory, local, or other official 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 affiliates. This typically occurs in connection with transactions such as asset transfers or sales, restructuring, mergers, consolidations, or insolvency proceedings relating to the Company or other parties associated with the Company.

Online Tracking Notice

You may encounter our use of third-party services on our website, such as advertising providers or analytics firms. These companies may also use cookies and similar technologies that collect data.
When we say cookies, we mean small text files stored on your device whenever you visit or access our website. We use cookies to learn about your preferences and browsing behaviour so we can enhance the user experience, understand what our visitors value, and design products and services aligned with customer interests. Cookies also help us compile statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Others are persistent cookies, which remain on your device after you close your browser. These allow the website to recognise you as a returning visitor and retain the preferences you previously set.

7. How We Use Cookies and Third-Party Services

Each cookie may serve a different purpose, and its use can vary accordingly.

Cookie Type Scope Legal Basis
Cookie Type

Cookies Can Be Essential

Cookies Can Be Essential

To access the features you’ve requested and to ensure you can continue navigating our website with ease, these cookies are required. They help deliver the products, information, and services you need.
These cookies enable your device to download and stream the necessary data, allowing you to move around the site easily, make the most of its key features, and revisit pages you’ve viewed with your preferences intact.

We use cookies to collect Personal Data, such as your username and last login date. This helps us confirm that you had an active session on the site. When you close your browser, we delete these session cookies.

Cookie Type

Cookies Optimised for Functionality

Scope

Cookies help us recognise you when you visit our site, and they enable you to retain your chosen settings and preferences. Without cookies, your experience would be reset on each visit, requiring you to configure your preferences every time.

Additional details

Functionality cookies will remain active until they reach their expiry date. They preserve all stored information even after the browser is closed.

Cookie Type

Performance Cookies

Scope

Cookies help us gather statistical information about our website’s performance, while also enabling us to enhance its overall quality and user experience. They also allow us to analyse activity across our website so we can understand how well it is performing

Additional details

Any information that could identify a person will be stored in cookies in an anonymised form. While some cookies will be deleted as soon as you close your browser, others will remain active when you next visit our website.

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

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari
Please note that some features and functions of the website may not operate as intended if this occurs.


Online Tracking Notice Please note that our service does not currently recognise 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 we may keep it for a longer period where permitted by law and in connection with orders, where applicable. 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 required.
We periodically review and assess the Personal Data we hold to confirm whether it is still needed.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which means we have your permission to send this personal data outside your home country, or to international organisations. We take all necessary measures to protect and safeguard your Personal Data and ensure you can exercise your rights and access effective legal remedies if needed.
All residents of the EEA (European Economic Area) can rely on these protections and safeguards.

  • 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 line with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the 'GDPR')
  • When a transfer takes place, we carry it out under a legally binding and enforceable agreement between public bodies or authorities in accordance with Article 46(2)(a)
  • We carry out the transfer 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, see 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 would like more information about these details and how they relate to the security measures we use to protect your Personal Data when it is transferred to third countries or international organisations, please email us at info@wealthwaydigital.uk


10. Protection of Personal Data

To safeguard your Personal Data, we have implemented robust security measures to prevent accidental or unlawful destruction, loss, or alteration.
While we take every reasonable precaution, 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 damages arising from its use or disclosure. This includes, but is not limited to, disclosures caused by transmission errors, unauthorised access by third parties, or other circumstances 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 cases, we cannot control the security measures those third parties apply.
Please note that transmitting Personal Data over the internet cannot be made entirely secure and carries inherent risks. For this reason, we cannot guarantee the security of any Personal Data you send to us online.

11. Regarding Links to Third-Party Websites

Our website includes links to external sites and apps that are outside our Company’s control. As such, we accept no responsibility for how these third-party websites collect or process your Personal Data. Our Policy applies only to our website and does not extend to third-party websites.
Before visiting any third-party website or app, please review their privacy policies before using their services. You should also carefully consider whether you wish to share your Personal Data.

12. Understanding Amendments to Our Policy

We reserve the right to amend this Policy at any time. If we make changes, we will notify you via a notice on our website and make the updated Policy available. For significant changes, we will inform you using the methods we deem most appropriate, including an announcement on our website. Unless we state otherwise, all amendments to this Policy take effect immediately upon publication of the revised Policy.

Your Rights in Relation to Your Personal Data

You have the right to request access to the Personal Data we hold about you, to have it rectified, and to ask us to delete Personal Data in appropriate circumstances. You may also request that we restrict the types of data we process. For residents of the EEA, please refer to this page:
If you wish to exercise any of your data rights, please contact us using the email address below. Access rights
We will assess the accuracy of the Personal Data we process and, where appropriate, provide you with access to it, including an electronic copy of the data. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, we will provide this information electronically.
Your right of access must not infringe the rights of others. Where a request would affect the rights of others, we may refuse to comply or limit our response. Your right to rectification
If your Personal Data is inaccurate or incomplete, you may request that we correct or complete it without undue delay. Your right to erasure
Valid grounds for this may include: (a) we no longer need the Personal Data for its original purpose; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (d) the processing is unlawful; or (e) deletion 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, for example if you believe the data is inaccurate. While processing is restricted, the data will be stored and processed only with your consent, for the establishment, exercise or defence of legal claims, to protect another person’s rights, or for important reasons of public interest in a Member State or the EU.
Right to data portability
Where processing is automated and based on consent or a contract, you have the right to receive the Personal Data you have provided to the Company.
You may also request that we transfer this data to another controller where technically feasible. Exercising your right to portability does 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 Company’s or a third party’s legitimate interests, including related profiling. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing is required for the establishment, exercise or defence of 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 carried out before withdrawal.
You also have the right to lodge a complaint with the authority supervising your Personal Data rights.
You may additionally ask a supervisory authority in a Member State to protect your individual rights in relation to Personal Data processing within the EU.
As set out 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 referred to in section 13 within one month of receiving your request, and we may extend this by up to two months depending on the nature 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 we consider the request unfounded or excessive, particularly if repetitive, in which case we may charge a reasonable fee to cover administrative costs or decline to act.
If we have doubts about your identity in connection with a request, the Company may ask for additional information.