Responsible Gambling Policy

This Policy forms part of Circl's Terms & Conditions and all definitions used are the same as set out in these documents.

Playing Circl is supposed to be fun and harmless but for some people gaming and gambling may go beyond enjoyment and become a habit that can cause problems for the individual and those around them.

At Circl we take very seriously our responsibility to ensure that we adopt and maintain a responsible attitude towards gaming and gambling and we have a number of systems and processes in place to try and avoid problems developing. We are particularly focused on three areas:

Under Age Gambling

Gambling under the age of 18 is an offence in the UK. To play in our games, you must be 18 years of age or over.

By registering your Circl Account with us, you represent to us that you are at least 18 years old and acknowledge that we will use your personal data to verify that this is the case. This may include supplying the details that you have provided to authorised data verification agencies. We use a variety of tools to verify the age of new players. If we are unable to verify a player's age to our satisfaction, we will suspend that player's Circl Account immediately until such verification has been provided.

If we become aware that a minor has submitted or has attempted to register a Circl Account, we will immediately suspend this Circl Account and will take steps to remove that player's personal data from our records.

Any player who provides dishonest information regarding their age automatically forfeits their right to any Prizes won. All monies staked will be returned and we may also provide any such personal data or information to the Gambling Commission and other relevant authorities.

Filtering Systems

We recommend that parents and guardians who use a family shared computer install filtering software in order to restrict internet access to children and minors.

There are a number of other third party applications that parents or guardians can use to monitor or restrict their computer's access to the Internet, for example:

· Net Nanny filtering software protects children from inappropriate web content: https://www.netnanny.com/

· CYBERsitter filtering software allows parents to add their own sites to block: https://cybersitter.27labs.com/

· Bet Blocker Parental Control allows parents to enter specific URLs that they do not want their children to access: https://betblocker.org/

Please Note: Circl provides these links for information only and does not control, endorse, or guarantee content or products found on these sites.

Problem Gambling

Whilst the majority of people do gamble responsibly, for some, gambling can become a problem. It may help you to keep control by remembering the following:

· establish limits for depositing, wagering and losses before you commence gambling. Set a Deposit Limit via the online tool on the app.

· gambling is not advised if it interferes with your daily responsibilities.

· gambling is not advised if you are in recovery for any dependency or are under the influence of alcohol or any other substance.

· gambling is not advised if your primary aim is to recoup losses.

Our Customer Service team have received awareness training on problem gambling issues. Please ask them for help if you have any issues.

Self-Exclusion

Any User that feels that they are developing a problem with gambling on our app can ask us to suspend or close their Circl Account for a minimum period of six months (or any period requested by the User up to a maximum of five years). To apply a self-exclusion, please contact the Customer Service team.

Deposit Limits

We offer the ability for our customers to limit the amount of money that they are able to deposit online into their account on either a daily, weekly or monthly basis. These limits may be revised downwards at any time but any increase will only be implemented after 24 hours following the request. This facility is available in the Account Management section of the app.

If any player is concerned that their gambling may be becoming a problem but you do not wish to contact us about it, please contact GAMCARE (www.gamcare.org.uk), a professional support agency established to help problem gamblers recognize and cope with their gambling.

Fairness and Transparency

At Circl we strive to present our games with the utmost fairness and transparency at all times. If you believe that we are not doing so then please contact the Customer Service team.

In particular we draw players' attentions to:

· Betting Rules

· Help pages

· Account Management: Users can easily access a full history of their transactions, withdrawals and deposits

Complaints & Disputes procedures

We will try our best to deal with all players fairly at all times but if you have a complaint then please contact the Customer Service team, and we will try to address your issue(s) as quickly and fairly as we can.

In any email to us please include your username and full name, and ensure that the email address you use is the same one that you have registered on your Circl Account. Please also include a clear explanation of your complaint. The Customer Service team will investigate your complaint and respond to you with the shortest possible delay.

If you are not satisfied with our response, please contact us and we will refer you to either:

· If it is in relation to a betting transaction, the Independent Betting Adjudication Service (IBAS: https://www.ibas-uk.com/); a third party organisation offering independent adjudication in relation to betting and gaming disputes.

· If it is in relation to another matter, the Gambling Commission (https://www.gamblingcommission.gov.uk/).