We (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, as a consumer, how we collect and store the 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 data in your best interests:

Through these efforts, our goal is to help you make informed decisions about the collection, use, and processing of Personal Data. To support this, our website employs several methods and procedures to provide clear, relevant information on Personal Data practices across our site. If you need specific details about your data, we will work to ensure you receive them promptly and at the appropriate time. Should you have any questions, we are happy to clarify any matters related to legal constraints. To get in touch, please email us at info@zenith-finrevo.com

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

You will find that we process Personal Data for a range of purposes, including providing the website to you, connecting you with third-party trading platforms (the 'Services'), improving the site, protecting our rights and interests, maintaining, provisioning, and operating the Services, ensuring full compliance with legal and regulatory requirements, and conducting administrative and business activities necessary to support the effective delivery and use of the Services. We also process your Personal Data to help us better understand your preferences and needs.

Ensuring you have access to vital resources to safeguard your rights concerning Personal Data

We are committed to helping you make well‑informed decisions about how we handle your Personal Data. This commitment explains why we developed this website. To support this, we use a range of methods and procedures to ensure you continue receiving the most relevant information about our use of your Personal Data. When specific details are needed, we will provide them at the appropriate time. If you have any questions about how this process works, we are happy to respond and offer clarifications, all within applicable legal requirements. To learn more, please email us at: info@zenith-finrevo.com

Keep Your Personal Data Safe and Secure

While we cannot guarantee the absolute security of your Personal Data, as no organisation can, we remain fully committed to deploying multiple measures to protect it. Our Privacy and Security Policy sets out the essential safeguards designed to support your long-term safety.

Scope?

When you review this Policy, you will find an overview of the types of Personal Data our Company collects from customers, as well as the ways we process it, share it with third parties, and safeguard it. This Policy applies to information about an identified or identifiable individual, where a person can be recognised directly, or indirectly through a combination of other information in our possession or that we can access. For the purposes of this Policy, ‘processing’ refers to any operation performed on Personal Data, including its collection, management, organisation, use, disclosure, and storage. Our services are intended for a general audience but are not available to anyone under the age of 18. We do not authorise individuals under this age to use our services and do not knowingly collect their information. If we become aware, or are notified, that we have collected data relating to anyone under 18, we will promptly delete it.

2. What Personal Data Do We Collect from You?

By using our services or channels, or by browsing our website, you acknowledge that we may collect your personal data. In some cases, we may request your personal data directly. Alternatively, we may gather it by analysing your interactions with our services or channels, or through our third-party partners

3. There is no obligation to provide your personal data to our company or to accept any implications arising from doing so

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

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

The Personal Data we collect includes information such as entries from your activity log, traffic data (including IP address and the date and time of access), the language you use on our site, software crash reports, browser type, and device specifications. These categories of data are non-personal, and we do not use them to identify you. We also obtain Personal Data 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, which can include your full name, email address, phone number, and address.

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

Our Company processes your personal data for the purposes explained in this section and in accordance with applicable law.
We require a lawful basis; without it, our Company cannot use your personal data. The legal bases 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 purposes below, including when you submit Personal Data via the Website for us to share with a third-party trading platform
• The Company or third parties may need to process information where this is necessary to pursue their legitimate interests. Examples include improving our Services or defending against legal claims that may arise.
• All processing activities on our website are required to comply with applicable legal requirements, and we confirm that they do comply.

For more information about how we process Personal Data to protect our legitimate interests, please email us.
Below, we outline the reasons and legal bases for how we may use the personal information you provide to us. Personal Data

6. How We Disclose Your Personal Data to Third Parties

Where appropriate, the Company may disclose Personal Data to third-party service providers that offer storage, hosting, IP address data processing, or user experience analytics.
We also accommodate requests to share specific Personal Data 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 also share Personal Data with its business partners or affiliated entities. This allows us to access the resources needed to enhance and continually improve our customer offerings.
Where required, the Company may disclose Personal Data to regulatory, local, or official authorities to protect the rights or property of others.
We may also share your Personal Data with interested investors or buyers, or with lenders to the Company or its affiliates. This typically occurs in the context of transactions such as asset transfers or sales, restructurings, mergers, consolidations, or bankruptcy involving the Company or related parties.

Online Tracking Notice

On our website, we may use third-party services such as advertising providers and analytics firms. These partners may also use cookies and similar technologies that collect data.
When we refer to cookies, we mean small text files stored on your device when you visit or access our website. We use cookies to learn about your preferences and browsing patterns, with the aim of improving the user experience, understanding our users' preferences, and designing products and services based on customer interests. Cookies also help us compile statistics and perform analytics.
Some of the cookies we use are session cookies. These are temporarily stored on your device and expire when you close your browser. Other cookies are persistent cookies, which remain on your device even after you close your browser. These cookies allow the website to recognise you as a returning visitor and keep the preferences you previously set.

7. How We May Use Cookies and Third-Party Services

Each cookie and how it is used may vary, depending on its intended purpose.

Cookies have been blocked or removed
You can manage your cookie preferences via your browser settings. For additional guidance, click one of the links below.

• Firefox
• Microsoft Edge
• Google Chrome
• Safari

Please note that some website functions and features may not work as intended if this occurs.

Online Tracking Notice Please note that our service currently 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 as permitted by applicable laws and for order-related requirements where relevant. 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 another 12 months if needed.
From time to time, we review and assess the Personal Data we hold to ensure it is not kept longer than necessary.

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

Under certain circumstances, we may transfer your Personal Data to other countries or international organizations; where required, this includes obtaining your permission to send your data outside your home country. We take all necessary measures to protect your Personal Data and ensure you can exercise your rights and access effective legal remedies when needed.
All residents of the EEA (European Economic Area) can benefit from 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 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 the transfer occurs, we carry it out under a legally binding, enforceable agreement between public entities or authorities in accordance with Article 46(2)(a)
• We conduct data transfers 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, you can review 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

To learn more about these details and how they relate to the security measures we implement 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. These measures help 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 without errors, and we are not liable for any intangible, incidental, or consequential damages arising from its use or disclosure. This includes, without limitation, disclosures caused by transmission errors, unauthorised access by third parties, or other events beyond our control.
Where we are legally required, 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 level of security those third parties provide.
Please note that transmitting Personal Data over the internet cannot be made completely secure and carries inherent risks. Due to these risks, we cannot guarantee the security of your Personal Data transmitted to us online.

11. Regarding Links to Third-Party Websites

Our website may include links to external sites and applications that are not under our Company's control. Accordingly, we accept no responsibility for how these third-party websites collect or process your Personal Data. Our Policy applies only to activities on our website and does not extend to third-party websites.
Before accessing any third-party website or app, you should 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 changes are made, we will notify you via a notice on our website and display the updated Policy. For material changes, we will communicate through the channels we consider most appropriate and will also issue a notice by posting an announcement on our website. Unless stated otherwise, all amendments to this Policy will take effect immediately upon the publication of the updated 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 inaccuracies rectified, and to ask us to delete any Personal Data you no longer want us to process. You may also restrict the types of data we collect. For individuals residing in the EEA, please refer to this page:
Anyone wishing to exercise their data rights may contact us at the email address below. Access rights
We will assess the accuracy of the Personal Data we process. If it is accurate, we will provide you with access to your Personal Data, including an electronic copy of the data processed. We reserve the right to charge a reasonable fee for any additional copies. When requested, we will provide this data electronically.
Your right of access must not adversely affect the rights and freedoms of others. Where a request would infringe those 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 and complete any incomplete information. Your Right to Erasure
Legitimate grounds may include: (a) we no longer need the Personal Data for its 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) erasure is required to comply with a legal obligation. This right does not apply where processing is necessary (a) to comply with Member State or EU law, or (b) for the establishment, exercise, or defence of legal claims.
Processing restrictions
You may request that we restrict processing if you believe the data is inaccurate. Where processing is restricted, we may store the data but will process it only with your consent, for the defence of legal claims, to protect the rights of another person, or for important public interests of 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 your Personal Data held by the Company in a structured, commonly used, and machine-readable format.
You also have the right to request that we transmit this data 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 processing of your Personal Data based on the Company’s or a third party’s legitimate interests, including profiling related to those interests. We may continue processing if we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.
You may 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 supervisory authority responsible for data protection.
You may further request that a supervisory authority in a Member State protect your individual rights regarding the processing of Personal Data within the EU.
As outlined in this section 13, your Personal Data rights may be limited by EU and Member State laws. We will provide the information referred to in section 13 within one month of receiving your request; we may extend this by up to two months where necessary due to the complexity or number of requests. If extended, we will notify you within one month and explain the reasons.
We will provide information requested under section 13 free of charge unless a request is unfounded or excessive—particularly if repetitive—in which case we may charge a reasonable administrative fee or refuse to act on the request.
If we have doubts about your identity in connection with a request, the Company may ask for additional information to verify it.