Privacy Policy

Introduction

Circl Gaming Limited whose registered office is at Murrays Mills, Bengal Street, Manchester, United Kingdom, M4 6LS will always be committed to protecting and respecting your privacy.

When you access our website or app or participate in a Game, we will collect certain personal information. Please read our privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or the appropriate supervisory authorities in the event you have a complaint.

Circl Gaming Limited is the data controller for the purposes of the GDPR in instances where you make an enquiry with us, registered with the Information Commissioner's Office, registration number ZA873904.

We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the products and services we offer. When changes are made, we will update the date at the top of this document and notify users via in-app notification or service email.

The type of personal information we collect

Personal information is any data relating to an identified or identifiable person. We process the information you give us, whether through interactions with our website, our app or by any other form of correspondence.

Information you provide to us

The categories of personal information we process include:

• Contact details (title/name/address/email address/phone number)
• Date of Birth

Information we collect from you

When you use our website/app, we may collect:

• Device details
• App login information
• App usage data
• Location data
• Information required for legal and regulatory compliance

We may use tools to personalise the user experience of our website/app, which may be monitored at any time using the player account menu in the website/app or via device settings on your device.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• Information that you provide in the course of communications with us. The includes information you provide when requesting further details of our app through the website.
• Information that you provide by filling in forms on the website/app. This includes information provided when you register as a user of the website/app. The provision of your name, date of birth and contact details for age and identity verification are required to enable you to use the app.
• Any information provided by you when using our website/app and/or making complaints
• If you contact us, we may keep a record of that correspondence
• We may also ask you to complete feedback forms or answer surveys that we use for research purposes, although these will not be mandatory, and you do not have to respond to them.

We also receive personal information indirectly, from the following sources in the following scenarios:

• Details of your visits to the website and/or app including, but limited to, traffic data, location data, web logs and other communication data, and the other resources that you access.
• If you provide us with any personal data relating to other people (friends, colleagues etc), you confirm that they consent to the processing of their personal data and that you have informed them of our identity and the purposes (as set out above or elsewhere) for which their personal information will be processed.

We use the information that you have given us in order to:

Purpose	Lawful Bases for Processing
Delivery and performance of our App services in accordance with our Terms and Conditions	It is necessary to process your personal data to facilitate performance of the service contract
Providing information on your account, such as transaction history, bonus rewards and P&L	It is necessary to process your personal data to facilitate performance of the service contract
Prevention and detection of crime including money laundering, fraud or other crimes	We have a legal obligation to report any such activity to the relevant authorities and regulators
Compliance with Gambling Commission codes of conduct, regulations, and guidelines	We have a legal obligation to provide our services within the law and regulations set down by, the Gambling Commission
Providing you with updates about our App, additional features, and providing you with exclusive bonuses and offers	You will consent
Improving our App and website and the overall App user and website visitor experience	It is our legitimate interest to allow analytics and search engine providers to help improve and optimise our website and App
Ensure maintenance of a secure connection between the App and your device	It is our legitimate interest to ensure the integrity and security of personal data flowing through our systems
Initiate action against any user who acts outside any relevant codes of conduct, laws, regulations or our Terms and Conditions.	It is our legitimate interest to ensure protection of our company products, services, and reputation
Analyse and track use of the App for reporting and analytical purposes	It is our legitimate interest to monitor App usage in order to continually improve the user experience

Where personal information is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information and your consent.

You are able to remove your consent at any time to the services which will require the closure of your account. You can do this by contacting our Data Protection Officer on privacy@playcircl.com. This email inbox is proactively monitored, so you can confidently expect your query to be addressed. We aim to respond to enquiries within 30 working days but will usually be in touch much sooner.

We may share this information with third party service providers to carry out age and identity verification processes. We also use the services of a third-party payment agent to process financial transactions, but we do not store or process any financial data such as credit card numbers ourselves.

Circl Marketing Policy and Procedures

We provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

(i) Marketing directly from us

You will receive marketing communications from us by push notification, email or text if you have requested information from us and you have not opted out of receiving that marketing.

(ii) Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

(iii) Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the "unsubscribe" links on any marketing message sent to you or by contacting us at any time.

Where you opt-out of receiving marketing messages, we will still process your personal information in order to fulfil any contract with you and in accordance with our legal and regulatory obligations.

(iv) Cookies

Cookies provide information about the device used by a User to access the website/app. We may use cookies where appropriate to provide the services or to gather information about your device in order to assist us in running and improving our services. This information will not identify you personally as it is purely statistical data. As a result, cookies are not considered to be part of your personal data.

Where used, these cookies are downloaded to your device and stored on the device's memory/hard drive. You can adjust the settings on your device to decline any cookies if you prefer. However, this may result in you not being able to access the services.

Disclosing your personal data

We will never disclose your personal data to any other party other than in accordance with our Terms & Conditions and this Privacy Policy or in the circumstances detailed below:

• in the event that we sell any or all of our business, we may disclose data to a buyer under the terms of an appropriate Confidentiality Agreement.
• where we are legally required by law to disclose your personal information to a regulatory body or legal authority.
• in the course of an Investigation made according to our Terms & Conditions.

Transferring Data Outside the UK/EEA

In operating our website and app it may become necessary to transfer data that we collect from you to locations outside of the UK or the EEA for processing. By providing your personal data to us, you implicitly agree to this transfer and/or processing all of which will continue to be done in accordance with our Privacy Policy.

We will only transfer your personal data outside of the UK/EEA where:

• you have given your explicit consent, or
• it is necessary for us to set up or fulfil a contract you have entered into with us; or
• to comply with a legal duty or obligation.

If we do transfer your personal data outside of the UK/EEA, we will take measures to ensure it is protected to the same standards as it would be within the UK/EEA by relying on one of the following:

• We will use contracts that require the recipient to protect your personal data to the same standards as it would be within the UK/EEA.
• We will use contracts that require the recipient to protect your personal data to the same standards as it would be within the UK/EEA.

In some instances we may be compelled by law to disclose your personal data to a third party and may have limited control over how it is protected by that party.

How we store your personal information

We store all personal data in secure databases in encrypted form and we do our utmost to ensure that all reasonable steps are taken to make sure that your data is treated stored securely. Unfortunately, the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the absolute security of data that you send us electronically, so sending such information is done so entirely at your own risk.

We will retain your personal data for as long as is necessary to provide you with our products and ongoing services and for a reasonable period thereafter, to enable us to meet our contractual and legal obligations and to deal with complaints and claims.

In some circumstances we are legally obligated to retain information to comply with legal obligations relating to crime prevention or gambling specific regulations.

At the end of the retention period, your personal data will be securely deleted in accordance our personal data retention and destruction policy and schedule.

Third Party Links

On occasion we include links to third parties' websites on the website/app. Where we provide external links, it does not mean that we endorse or approve that site's policy towards visitor privacy and security. You should review their privacy policy before sending them any personal data.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - known as a "data subject access request". This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing it.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Some of these rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. if you would like to exercise any of your rights as set out above, you can contact us at privacy@playcircl.com. If you make a request, we have one month to respond to you.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge £10 if your request for access is clearly unfounded or excessive.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at Circl Gaming Ltd, Murrays Mills, Bengal Street, Manchester, United Kingdom, M4 6LS

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO's address:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

You can contact Circl Gaming Limited in relation to data protection and any of the contents of this privacy policy by emailing privacy@playcircl.com