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

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

By doing so, our aim is to help you make informed choices about the use and processing of Personal Data. To support this, we employ a range of methods and procedures on our website to provide clear, relevant information about how Personal Data is used. If you require specific details about your data, we will make every effort to provide them promptly and at the appropriate time. If you have any questions, we are happy to explain any applicable legal constraints. To contact us, please email us at info@barclay-valnor.app

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

We process Personal Data for a range of purposes, including providing you with the website, connecting you to third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining and delivering the Services, complying fully with legal and regulatory obligations, and undertaking administrative and business activities to enable the delivery and use of the Services. We also process your Personal Data to better understand your preferences and needs.

Gaining access to essential resources to better safeguard your rights in relation to your personal data

Our goal is to help you make well‑informed choices about how we handle your Personal Data. That commitment to transparency is why we created this website. To support it, we use a range of methods and procedures—and regularly review them—to ensure you continue to receive the most relevant information about our use of your Personal Data. We also provide notices, policies, and consent tools designed to put you in control. Where specific details are needed, we will provide them clearly and at the appropriate time, including at points where data is collected. If you have any questions about how this process works, we are more than happy to respond, explain, and provide clarifications, always within the bounds of the law and applicable requirements. If you would like to learn more, please get in touch with us via email at: info@barclay-valnor.app

Keep Your Personal Information Safe and Secure

While we cannot guarantee the absolute security of Personal Data—no one can—we remain fully committed to using a range of measures to protect your Personal Data. Our Privacy and Security Policy covers all key areas to support your long-term safety.

Scope?

This Policy outlines the types of Personal Data our Company collects from customers and explains how we process it, share it with third parties, and keep it secure. Our Policy covers information about an identified or identifiable individual, where a person can be recognised directly or through a combination of other information we hold or can access. Under our Policy, we define 'processing' as any operation involving the use or handling of Personal Data, including the management, organisation, and storage of such data. Our services are intended for a general audience but are not available to anyone under the age of 18, and we do not authorise anyone under this age to use them. Accordingly, we do not knowingly collect information from anyone under 18, as they are not permitted to use our services. If we become aware that we have collected data relating to a person under 18, we will delete it promptly.

2. What Personal Information Do We Collect from You?

By using our services or channels, or by browsing our website, you agree that we may collect personal data about you. In some cases, we may ask you for this information directly. Alternatively, we may analyse your interactions with our services or channels to gather this information, or obtain it from our third-party partners

3. You are not required to provide your personal information to our company or deal with any consequences arising from it

You are not obliged to share any personal data with us. However, if you choose not to provide certain personal data, this may affect how we deliver our services to you and could result in limited access to our website or limited use of certain features.

4. What Types of Personal Data Do We Collect? When you visit our website, we may gather the following personal information:

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

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

Our Company processes your personal data for the purposes set out in this section and does so in accordance with the applicable legal framework.
We require a lawful basis, as without one Our Company cannot process your personal data. The lawful bases on which Our Company relies to process your personal data include:

• We have obtained your consent to process your Personal Data for one or more of the following purposes, including when you submit personal information via the Website for us to share with a third-party trading platform
• The Company or a third party may need to process the information in order to pursue their legitimate interests. For example, this could involve improving our Services or defending ourselves against litigation that may arise.
• All processing carried out on our website must comply with applicable legal requirements, and we confirm that it does comply with those requirements.

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 outlined a list of the reasons and legal bases under which you may find us using the Personal Data you have provided to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Where appropriate, the Company may disclose Personal Data to third parties providing services such as data storage, hosting of IP address data, or user experience analytics.
We also accept requests from individuals who ask us to share certain Personal Data with third-party trading platforms. In such cases, we will transfer the Personal Data you provide to the platforms you specify. If you choose this option, the platforms’ privacy policies will govern how your data is used. In these circumstances, your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with its business partners or affiliated entities. This enables us to access the resources needed to enhance and improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or public authorities to protect the rights or property of others.
We may also share your Personal Data with prospective investors or purchasers, or with lenders to the Company or its affiliates. This typically occurs in connection with transactions such as asset sales, restructurings, mergers, consolidations, or insolvency proceedings involving the Company or related parties.

Online Tracking Notice

You may encounter third-party services on our website, such as advertising partners and analytics providers. These organisations may also use cookies and similar technologies to collect data.
Cookies are small text files stored on your device whenever you visit or access our website. We use them to gather information about your preferences and browsing patterns to improve the user experience, understand what our users value, and design products and services aligned with customer interests. In addition, cookies help us compile statistics and carry out analytics.
Some of the cookies we use are session cookies. These are temporarily placed on your device and expire once you close your browser. Other cookies are persistent, meaning they 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 May Use Cookies and Third-Party Services

Each cookie and its use can vary, depending on its intended purpose.

Cookies have been blocked or removed
You can manage your cookie preferences in your browser settings. You may use the links below for guidance with this process.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please be aware that certain website functions and features may not work as intended if this occurs.

Online Tracking Notice Please note that, at present, our service does not recognise Do Not Track requests.
8. Learn more about storing 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, or for a longer period where permitted by applicable law and for orders where this is required. In some 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 needed.
From time to time, we will review and assess the Personal Data we hold to ensure we no longer retain information we do not require.

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

Under certain circumstances, we may transfer your Personal Data to other countries, which may involve your permission for us to send this data to a country other than your own, or to international organisations. We take all necessary measures to protect and defend your Personal Data and ensure you can exercise your rights and effectively access legal remedies if needed.
All residents of the EEA (European Economic Area) can benefit from these protections and safeguards.

• In certain circumstances, we may transfer your Personal Data to a third country or international organisation that the European Commission has recognised as providing an adequate level of protection for Personal Data, 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')
• When a transfer occurs, we carry it out under a legally binding and enforceable instrument between public authorities or bodies, 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. For more information, you can view 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 to learn more about these details and how they relate to the security measures we apply to protect your Personal Data when 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, including protections against accidental or unlawful destruction, loss, or alteration.
While we take every reasonable precaution, we cannot guarantee that your Personal Data will be maintained without error, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, but is not limited to, disclosures resulting from transmission errors, unauthorised access by third parties, or other causes beyond our control.
Where we are legally required, or due to other circumstances beyond our control, we may need to share your Personal Data with third parties, such as public authorities. In such cases, we cannot manage or guarantee the security measures those third parties provide.
Please note that transmitting Personal Data over the internet is not entirely secure and carries inherent risks. Because of these risks, we cannot guarantee the security of your Personal Data that you transmit to us online.

11. Links to Third-Party Websites

Our website includes links to external sites and applications that are outside our Company's control. Accordingly, we are not responsible for how these third-party websites collect or process your Personal Data. While our Policy covers activity on our website, it does not extend to third-party websites.
Before visiting any third-party website or app, please review its privacy policy before using its services. You should also carefully consider whether you wish to provide them with your Personal Data.

12. Understanding the Amendments to Our Policy

We reserve the right to update this Policy at any time. If we make changes, we will promptly notify you via a notice on our website and display the updated Policy. For significant updates to this Policy, we will use the methods we consider most appropriate and will issue a notification by way of an announcement on our website. Unless stated 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 a review of the personal data we hold about you, to have it rectified, and to ask us to delete any Personal Data you do not wish us to retain. You also have the right to restrict the types of data we collect. For those residing in the EEA, please see this page:
Anyone wishing to exercise their data rights may contact us using the email address below. Access rights
We will assess the accuracy of the Personal Data we process. Where appropriate, we will grant you access to your Personal Data and provide an electronic copy of the data processed. We reserve the right to charge a reasonable fee for additional copies of your data. When requested, we will provide this data electronically.
Your right of access must not infringe the rights of others. If a request would adversely affect others’ rights, we may refuse to comply or limit our response. Your rights related to rectification
If you wish to correct inaccurate Personal Data, you may ask us to rectify any incomplete or incorrect information. Your Right to Erasure
Legitimate grounds may include: (a) we no longer need the Personal Data for the original purpose; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing for specific reasons; (e) the Personal Data has been processed unlawfully; or (f) 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.
Processing restrictions
You may ask us to restrict processing if you believe the data is inaccurate. While restricted, the data may only be retained with your consent, for the protection of others’ rights, for the establishment, exercise or defence of legal claims, or for important public interests of a Member State or the EU.
Right to data portability
For automated processing based on consent or a contract, you have the right to obtain all Personal Data the Company holds about you.
You also have the right to request that this data is transferred to another controller where technically feasible. Exercising your data portability rights does not affect your right to erasure.
Right to object
You may object at any time to our use of your Personal Data based on legitimate interests pursued by the Company or third parties, including related profiling. We will cease 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 before withdrawal.
You also have the right to lodge a complaint with the supervisory authority responsible for Personal Data.
You may further ask the supervisory authority in your Member State to protect your individual rights regarding Personal Data processing within the EU.
As outlined in this section 13, your rights in relation to Personal Data may be limited by EU and Member State laws. In line with your rights, we will provide the information requested under section 13 within one month of receiving your request, but we may extend this by a further two months depending on the complexity and number of requests. You will be notified within one month of any extension and the reasons for it.
We will provide the information requested under section 13 free of charge unless a request is unfounded or excessive, particularly if repeated, in which case we may charge a reasonable fee to cover administrative costs, or we may refuse to act on the request.
If we have reasonable doubts about your identity in connection with a request, the Company may ask for additional information.