Privacy Policy

We (also referred to as 'We', 'Us', or 'Our') are committed to safeguarding your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the Gaingate website (the 'Website').
We uphold the following principles:

To ensure transparency regarding the collection and processing of 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 support this, we use a range of methods and processes to give you clear, relevant information about how Personal Data is used. If we believe you need more specific details, we’ll provide them at the appropriate time. We’re happy to answer any questions and to offer any clarifications you may need, subject to any limits set by law. You can contact us by email at the address below: info@blue-orion.com

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

We may process Personal Data for a range 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, facilitating the maintenance and provision of the Services, meeting regulatory or legal obligations, and conducting administrative and business activities to support the delivery and use of the Services. We also process Personal Data to better understand your preferences and needs.

Use essential tools to protect your rights regarding Personal Data:

We want you to be able to make informed choices about the use and processing of Personal Data. That is why we created this website. To support this, we use a range of methods and processes to provide clear, relevant information about how Personal Data is used, including through notices and other communications. If we believe you need specific details, we will provide them at the appropriate time. We are happy to answer any questions and will offer any clarifications you require, subject to any limits imposed by law. You can reach us by 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 are committed to continually employing a range of measures and techniques to ensure your Personal Data is protected. 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 we process it, share it with third parties, and keep it secure. It covers information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly, or indirectly in combination with other information we hold or can access. The Policy defines ‘processing’ as any operation that involves the use or collection of Personal Data, including the management, structuring, and storage of Personal Data. Our services are intended for a general audience and are not designed for anyone under 18. We do not knowingly solicit or collect information from anyone under 18, nor do we knowingly permit such persons to use our services. If we become aware that we hold information about a child, we will delete it as soon as reasonably practicable.

2. What personal data do we hold about you?

When you use our services and channels, or visit our website, we collect Personal Data. We may request your Personal Data in certain situations. In other cases, we collect your Personal Data by analysing the use of our Services and service channels, or we may receive it from our third-party partners.

3. You are not required to provide personal information to the company and the consequences of not doing so.

You are not required to provide Us with any Personal Data. However, in some circumstances, you may choose not to supply Us with Personal Data. This may prevent Us from providing the Services or restrict users from accessing the Website.

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

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 used, software crash logs, the type of browser, and information about the device you utilised. 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 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. The Legal Basis and Purposes for the Processing of Personal Data

Your Personal Data is processed by the Company for the purposes set out in this section, and in accordance with the applicable legal basis.
Without a legal basis, the Company cannot process your Personal Data. The legal grounds on which the Company may process your Personal Data are:

  • You have consented 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 require processing to pursue their legitimate interests. For example, this may be necessary to improve Our Services or to establish or defend legal claims.
  • Processing must fulfil a legal obligation.

Contact us by email for more information about the processing required to protect our legitimate interests.
Below is a list of reasons and legal bases under 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 ask us, we may request Personal Data from you to pass it on to third-party companies

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

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

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

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

To comply with legal obligations, processing is necessary.

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

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

5. To prevent fraud and the misuse of Our Services

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

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

Processing is necessary for the Company’s legitimate interests or for 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 ones).

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

8. To safeguard 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 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 for the Company’s legitimate interests or for 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 and analytics services. This may include IP address information and analysis of user experiences.
You may also request that we provide specific Personal Data about you to third-party trading platforms. In these cases, we will share the Personal Data you give us with such third-party trading platforms. Their use of your Personal Data is governed by their 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 helps provide the resources the Company needs to enhance and improve the products and services it offers 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 group, if a relevant transaction occurs (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 business in the group.

ONLINE TRACKING NOTICE

Third-party services, such as advertising providers on our website and analytics companies, may be utilised. These companies may also utilise cookies or similar technologies.
Cookies are small text files placed on your device whenever you visit or access the Website. They are used to collect information about your preferences and browsing habits to enhance your user experience, remember your settings, and customise products and services you may enjoy. Cookies are also utilised for statistics and analytics.
Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last for a short time 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 enable you to return to the Website.

7. Cookies and Third-Party Services

We may use them according to their 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 site, utilise its features, and return to pages you've previously visited.

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

Type of cookie

Functionality Cookies

Scope

Cookies help us recognise you each time you visit our site and also to remember 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

We use cookies to collect statistical information about the site's performance and to help improve it. They also allow us to analyse activity on our website.

Additional information

Cookies store anonymised data that is not linked to any identifiable natural person. They can be removed when you close your browser. Other cookies have no set expiry date.

Cookies are blocked or have been removed
To block or remove cookies, change your browser settings. The links below provide guidance 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 support Do Not Track (DNT) 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 periods as permitted by law, regulations, policies, and 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 not retained longer than necessary.

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

Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country, an additional country other than the one in which you reside, or to international organisations or jurisdictions). Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that individuals can assert their rights and access effective legal remedies.
These protections and safeguards are available to all those who reside in 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 made pursuant to a legally binding, enforceable agreement between public entities or authorities, in accordance with applicable law under Article 46(2)(a).
  • The transfer was conducted in accordance with the European Commission’s Standard Contractual Clauses adopted under Article 46(2)(c) of the GDPR. The 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 about the security measures it uses to protect your Personal Data when transferred to third countries or international organisations. To request this information, please email info@wealthwaydigital.uk


10. Personal Information Security

We have implemented appropriate organisational and technical measures to protect Personal Data, including preventing accidental or unlawful destruction, loss, or alteration of Personal Data.
While we strive to keep your Personal Data secure, we cannot guarantee error-free security. We are not responsible for any indirect, incidental, or consequential losses 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 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. We cannot control the level of protection those third parties apply to your Personal Data in such circumstances.
No method of transmitting Personal Data over the internet is completely secure. The Company cannot ensure the security of Personal Data you transmit to Us through the internet.

11. Hyperlinks to third-party websites

Links to third-party sites and applications may be available on this website. These sites and apps are not operated or supervised by the Company. We are not responsible for the collection or processing of Personal Data by these third parties. This Policy does not apply to activities conducted through such sites or apps.
When you visit any third-party site or app, we recommend reviewing its privacy policy before choosing to access or use it. We also advise exercising caution when providing any Personal Data to them.

12. Changes to this Policy

This Policy may be updated at any time. If we change this Policy, we will notify you by posting the updated Policy on our website. Additionally, when we make significant changes to this Policy, we will attempt to inform you using methods we consider appropriate and will publish a notice on our website. Unless expressly stated otherwise, any amendments will take effect after the revised Policy is published.

13. Your rights regarding your personal information

You are entitled 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 is not required by Us. You may also restrict the scope and 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 in relation to the information you provide concerning your Personal Data. You can request to exercise your rights by emailing the address below. Access rights
The Company can verify whether Personal Data about you is being processed. If it is, 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 the rights or freedoms of another person, the Company may refuse the request or limit how it is fulfilled. Right to rectification
The Company is required to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data concerning you be completed, taking into account the purposes of processing. Right to erasure
The following grounds apply: (a) Personal Data is no longer necessary 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 at any time, on grounds relating to your particular situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data has been processed unlawfully; or (f) Personal Data must be erased to meet 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) to establish, exercise, or defend 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 you request restriction, Personal Data may be retained 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 of the European Union or a Member State.
Right to data portability
Where processing is carried out by automated means and is based on consent or on 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 also request that your Personal Data be transmitted directly by the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising data portability. Data portability must not infringe the rights or freedoms of others.
Right to object
You may object at any time to the processing of Personal Data concerning you that is based on the 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 rights, freedoms, and interests, or the establishment, exercise, or defence of legal claims, we will cease such processing.
For direct marketing, you have the right to object at any time to the processing of Personal Data relating to you.
Right to withdraw consent
You may withdraw your consent to Us processing 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 lodge a complaint with a supervisory authority established by a Member State to protect individuals’ fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State laws may limit your rights in relation to your Personal Data as described in this section 13. We will provide information in response to your requests under section 13 of this agreement within one month of receiving your request. This period may be extended by up to two months if necessary, taking into account the complexity and number of requests. Within one month of receiving your request, we will inform you of any extension and the reasons for it.
Unless otherwise provided in 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 it is 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 request additional information.