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Circl

Terms & Conditions

02 June 2021

Version: 1.0.0

1. GENERAL INTRODUCTION, DEFINITIONS AND STIPULATIONS

1.1 Circl provides the Services to you through Circl Gaming Limited, a company duly incorporated and registered on 17th March 2020 under the laws of England and Wales, with Company Registration No. 12520259, and having its registered office and business address at 77 Murray's Mills, 50 Bengal Street, Manchester, M4 6LS, United Kingdom.

1.2 The Circl Rules are the rules under which Circl provides its services through the Website and the Mobile App. The Circl Rules include these Terms and Conditions, the Privacy Policy, and the Rules of Play. Any conflict between the terms of the Circl Rules will be resolved in the following order of priority:

1.2.1 these Terms and Conditions,

1.2.2 the Privacy Policy and;

1.2.3 the Rules of Play.

1.3 The Circl Rules constitute the complete, final and exclusive agreement between the Account Holder ("you") and Circl ("us" or "we") in respect of your use of the Services.

1.4 By using the Services in any way (including applying to register as an Account Holder, logging-in, using the Services, participating in the games, or accepting any Prize), you agree:

1.4.1 to become a party to and be bound by the Circl Rules from the time that you commence using the Services;

1.4.2 that you have read, understood and accepted the Circl Rules; and

1.4.3 that you shall abide by all the Circl Rules.

1.5 Circl may update, amend, edit and supplement the Circl Rules at any time. Any substantial amendment to the Circl Rules shall be notified in advance by Circl to the Account Holder, before coming into effect and will require your consent. If you do not agree with the amendment(s) to the Circl rules, you will not be permitted to continue using the Services.

1.6 The Account Holder understands that Circl reserves the right to change or remove any of its Services at any time.

1.7 All references in the Circl Rules to the singular shall include the plural and vice versa. All references to "the" shall include "a/an" and vice versa.

1.8 An "Account Holder" is an individual having a contractual relationship with Circl by creating a Circl Account on the Website and/or Mobile app.

1.9 A "Card" refers to all types of cards with a function of "payment", "charge", "debit", "virtual" and/or similar.

1.10 A "Circl Account" is an account held by an Account Holder, for bona fide transactions, with a strict aim to establish a normal commercial relationship with Circl and with the strict purpose of conducting betting and other gaming and gambling transactions.

1.11 The "Contract" is the contractual relationship between Circl and an Account Holder and shall be constituted under and governed by the Circl Rules, i.e. the "Terms and Conditions", the "Privacy Policy" and the "Rules of Play".

1.12 A "Financial Institution" is a bank and/or other institution regulated by an applicable domestic financial services Act or similar.

1.13 "Force Majeure" refers to any occurrence or condition beyond one's reasonable control which leads to a delay or default in the performance of the affected party's contractual obligation and shall, for the purposes of the Circl Rules, include acts of God, government restrictions (including the denial or cancellation of any necessary licence where such denial or cancellation is made through no fault of the affected party), wars, outbreak of hostilities, riots, civil disturbances, insurrections, acts of terrorism, fire, explosions, floods, theft, malicious damage, strikes, lockouts, legislative or administrative interference, including any such actions related to or arising out of mass illness or pandemic conditions and/or any other cause beyond the reasonable control of the party whose performance is affected.

1.14 The "Governing Authorities" are the relevant authorities of a given jurisdiction.

1.15 The "Governing Law" is the law of a given jurisdiction.

1.16 "Mobile App" refers to downloadable mobile applications through which the Services are provided to the Account Holders.

1.17 An "Inactive Account" is a Circl Account, which has not recorded any log-in and/or log-out for a period exceeding 12 consecutive months.

1.18 A "Payment Solution Provider" is an intermediary acting as a payment agent for various different payment methods.

1.19 The "Place of the Contract" is England and Wales.

1.20 "Pools Betting Duty" refers to the special tax applicable on gaming and betting.

1.21 A "Prize" is an amount, a bonus or a reward that can be won by the Account Holder.

1.22 The "Regulator" is the relevant gaming authority, which is a regulatory authority established by the law of its country to govern all forms of gaming in a given jurisdiction.

1.23 The "Services" are the gaming and betting products provided by Circl to the Account Holder.

1.24 "Software" shall mean all software used by Circl to offer and/or operate the Services and/or run the Website and the Mobile App.

1.25 The "Website" is the internet gateway accessible through the internet address www.playcircl.com where all current and relevant information regarding Circl's operations and Services are published

1.26 All trademarks, service marks and trade names as well as images, graphics, text, concepts or methodologies (collectively the "Intellectual Assets") found on the Website and Mobile App, and the material contained therein are the exclusive property of Circl and/or Circl's suppliers and partners. The Account Holder is not entitled to exploit or otherwise use any Intellectual Asset for whatever purpose, except for what is allowed by law.

2. LICENCES

Circl Games Limited is duly licensed in Great Britain and is regulated by the Gambling Commission of Great Britain to provide facilities for remote pool betting, under the Remote Operating Reference Number: xxxxxx, valid from DD MMM YYYY.

3. ACCOUNT RULES

3.1 Creation of a Circl Betting Account

3.1.1 The Services are intended to be used by players who play or register in the UK only. We will not be responsible for any illegal or unauthorized use of the Software and/or the Services by you.

3.1.2 If we reasonably suspect that you are using the Software or Services from outside the UK, this may result in us terminating your account, freezing the funds in your account and providing your details to our licensors and/or the relevant authorities and you shall be liable for any damage or loss resulting therefrom.

3.1.3 You must not download the Software, use the Services under any circumstances or apply to become an Account Holder if you are under the age of 18 years old. If you are under the age of 18 years old and you download the Software or use the Services you will have materially breached the Terms and Conditions and we will close your account in accordance with section ‎3.3.1 below

3.1.4 PLEASE NOTE : If you are under the age of 18 and gamble you are committing a criminal offence in the UK.

3.2 An individual cannot participate or interact with any of the Services unless that individual is an Account Holder.

3.2.1 To be registered as a player, an individual must register personally and submit an application for registration. The following information must be provided:

a. date of birth;

b. player's first and last name;

c. player's full residential address;

d. player's valid email address and contact number;

e. valid occupation details; and

f. a username and a password

3.2.2 As part of the registration process, the potential customer is asked to confirm that they agree with the Terms and Conditions and affirm that they are of over 18 years of age. Before you are able to deposit any funds into your account, wager any real funds or bonuses, or play any free-to-play version of any gambling game that we offer, we will take steps to verify that you are 18 years of age or older.Before you are able to gamble, we will also take steps to verify your identity by verifying (as a minimum) your name, address and date of birth.

3.2.3 If on completion of these age and/or identity verification processes, you are shown to be under the age of 18 or to have provided false or inaccurate information on registration, you will have materially breached the Terms and Conditions and we will close your account in accordance with applicable regulation and terminate the Contract. You will not be able to gamble until we are able to verify your age and identity as set out above.

3.2.4 In order to undertake the age and identity verifications mentioned above, we typically use third party service providers. If, as a result of such verification, we are not adequately satisfied as to the results, we may request that you provide any one of the following: (a) government issued ID verification document (such as driver's license, passport or birth Certificate); (b) proof of address (utility bill such as electricity or water bill, or a bank statement in your name, showing the address as registered on your account); or (c) proof that the payment method registered is yours (such as front and back copies of your debit card, with the middle digits and security CVV code covered). Such documents can be scanned and uploaded through the Website or sent to us by email, as shall be applicable from time to time. We may request that copies of such documents are notarized at your own expense, meaning that the documents are stamped and attested by a Public Notary, if, for example we reasonably believe that your document is not legitimate or valid. Should the documents fail our internal security checks – for example, if we suspect that they have been tampered with, or are in any way proved to mislead or misrepresent – we shall be under no obligation to accept such documents as valid, and under no obligation to provide feedback on the exact nature of our findings with regards to these documents. Any failure by you to provide the documentation reference above, will result in you failing the age and/or identity verification process.

3.2.5 In addition to the age and identity verification processes set out above, at a later date we may also undertake further verification steps to ensure that all information we hold in respect of you is up-to-date and accurate, and to check your source of funds, financial standing, occupation and other similar details. We may also undertake verification steps to confirm that you are the registered holder of any payment method to which you seek to withdraw funds. As part of this process, you may be required to provide the following documentation: government issued ID verification document (such as driver's license, passport or birth certificate), proof of address (utility bill such as electricity or water bill, or a bank statement in your name, showing the address as registered on your account), proof that the payment method registered is yours (such as front and back copies of your debit card, with the middle digits and security CVV code covered) and/or financial documents to attest your source of wealth or source of funds (such as bank statements, monthly pay-slips, P60). Such documents can be scanned and uploaded through the Website or sent to us by email, as shall be applicable from time to time. We reserve the right to restrict your account including without limitation restricting the amount you may deposit into the account based on the information you provide, or if such information is not provided by you. We shall not be liable to you for any losses which you incur (i) prior to any such restriction being set; or (ii) on any other accounts you may have registered or which you reactivate whether prior or following any such restriction being set.

3.2.6 We may also perform background checks on you, from time to time, for the purposes such as detection and prevention of fraudulent activities, establishing your source of wealth or source of funds and detection and analysis of activity suspected as related to anti-money laundering or terrorism financing. As part of this process, you may be required to provide, government issued ID verification document (such as driver's license, passport or birth certificate), proof of address (utility bill such as electricity or water bill, or a bank statement in your name, showing the address as registered on your account), proof that the payment method registered is yours (such as front and back copies of your debit card, with the middle digits and security CVV code covered) and/or financial documents to attest your source of wealth or source of funds (such as bank statements, monthly pay-slips, P60). Such documents can be scanned and uploaded through the Website or sent to us by email, as shall be applicable from time to time. We are under no obligation to advise you of on each occasion of that due diligence, verification, investigation and/or on-going monitoring takes place. Such activities may include the use of specific third party companies, who perform services as required, and publicly available information. If such due diligence, verification, investigation or on-going monitoring raises issues of concern, we may close your account and terminate the User Agreement in accordance with our Terms laid out herein.

3.2.7 An individual applying to become an Account Holder furthermore warrants and represents:

a. to be a physical person (a legal entity will not be accepted as an Account Holder);

b. not to be a resident of restricted jurisdictions. Circl reserves the right to only allow players to open an account from permitted jurisdictions only.

c. not to be a professional player in any sport, competition or league where Circl offers betting;

d. not to be restricted by limited legal capacity;

e. not to be acting on behalf of another party;

f. not to be classified as a compulsive problem gambler, and/or be included (whether voluntarily or involuntarily) on any register or database of excluded players;

g. not to be depositing funds originating from criminal and/or other illegal activities; h. not to be depositing funds through a Card which the Account Holder is not authorised to use and/or utilizing a Card in a jurisdiction in which betting and gaming are prohibited;

i. not to be depositing funds through a Card which is not in the name of the Account Holder;

j. not to be conducting criminal activities whereby a Circl Account is directly or indirectly involved;

k. not to be holding an active account with another legal entity which is part of the same group as Circl, meaning other entities directly or indirectly controlled by Circl Gaming Limited.

l. not to use the Services if it is illegal in his/her country of residence or otherwise restricted for him/her to open a gaming account, purchase or use services from Circl and/or otherwise participate in the games offered. It is the Account Holder's responsibility to ensure his/her use of Circl's Website/Mobile app and Services is legal;

m. not to find the Website/Mobile App or the Services offensive, objectionable, unfair, nor indecent; and

n. to maintain his/her Circl Account details up-to-date in terms of the following: first and last name, country of residence, valid email address and phone number.

3.2.8 An individual applying for a Circl Account acknowledges and accepts:

a. all definitions and stipulations as stated under the Circl Rules;

b. the Circl Rules as currently published on the Website/Mobile App, as well as any possible future changes to the Circl Rules;

c. that the Place of the Contract in England and Wales; and

d. that the Contract is governed by: (i) the Circl Rules as published in English; (ii) any regulatory provisions or other decisions made from time to time by the Governing Authorities; and (iii) the Governing Law of the Place of the Contract.

3.2.9 An individual applying for registration warrants and represents that any information provided in their application form is true and correct. Failing this, Circl will not register the individual, and where that individual has already been registered, Circl will block the Circl Account when it becomes aware that the individual has provided false information when registering as a player.

3.2.10 Circl reserves the right to refuse the registration of any individual for any reason, at its sole discretion. Any contractual obligations already made will be honoured.

3.2.11 You can only register one (1) Account with us, which can then be used across all of our Services. If we identify that You have acted fraudulently or dishonestly in opening multiple/duplicate accounts, we reserve the right to suspend, close or withhold any winnings/funds and bonus credits that have accumulated on those accounts. We also reserve the right to close any and all accounts.

3.3 Management of a Circl Account

3.3.1 Circl reserves the right at its own discretion and at all times, to:

a. decline to open a Circl Account and/or to close an existing Circl Account without any explanation whatsoever;

b. decline to accept deposits without any explanation whatsoever;

c. deal with bets containing obvious price or terms errors as per section 12 of these General Terms and Conditions.

d. cancel the bets even after the end of the event if these bets are won by the User as a result of a technical failure.

e. request documents to verify: (i) the identity of the Account Holder, (ii) his/her authorization to use a specific Card and/or (iii) other facts and information provided by the Account Holder. Further documentation may be requested to fulfil other regulatory requirements. Such request may be made at any given moment and Circl reserves the right to suspend an account pending investigation;

f. transfer and/or licence, without prior notice, data regarding an Account Holder to any other legal entity, in any country, ultimately managed and controlled by Circl Limited, subject to Circl guaranteeing that the said data at all times is transferred and managed in accordance with applicable laws, data protection acts and/or similar;

g. transfer and/or licence, without prior notice, the rights and liabilities regarding an Account Holder to any other legal entity, in any country, ultimately managed and controlled by Circl Limited, subject to Circl guaranteeing the liabilities being honoured;

h. hold and manage funds belonging to Account Holders in accordance with generally accepted guidelines for cash management regarding such funds; this may include a Financial Institution and/or a Payment Solution Provider being entrusted to hold funds in the name of and/or for the benefit of Account Holders, as approved by the Regulator;

i. forfeit and/or confiscate funds available on a Circl Account and/or refuse to honour a claim, in the event that, directly or indirectly: (i) the Circl Rules have been violated; and/or (ii) other unauthorised activities have occurred in connection with a betting event and/or the operation of a Circl Account (such as, but not limited to, breach of the law or other regulations, breach of a third party's rights, fraud, and cheating);

j. suspend and/or cancel the participation of an Account Holder in the games, promotional activities, competitions or other services, whenever Circl is of the opinion that there are legitimate concerns that a Circl Account is, has been, or may be used for illegal, fraudulent or dishonest practices;

k. suspend and/or cancel the participation of the Account Holder in the Services, and/or forfeit and/or confiscate funds available on their Circl Account if the Account Holder is found cheating, or if it is determined by Circl that the Account Holder has employed or made use of a system (including machines, robots, computers, software or any other automated system) designed to defeat or capable of defeating the Mobile App and/or Software.

Circl is committed to detect and prevent software programs, which are designed to enable artificial intelligence ("AI Software") to play on its Website and/or Mobile App including but not limited to opponent-profiling, player collusion; robots, other 'cheating' software or anything else that in our reasonable opinion distorts normal game play and enables the player to have an unfair advantage over other players. You acknowledge that Circl will take measures to detect and prevent the use of such programs and AI Software using methods (including but not limited to reading the list of currently running programs on a player's computer) and the customer agrees not to use any AI Software and/or any such programs.

l. suspend and/or cancel the participation of Account Holder in the Services, and/or forfeit and/or confiscate funds available on their Circl Account if there is evidence that multiple accounts have the same Card or e-payment account, and/or have registered, or accessed the account, or placed bets using the same mobile phone device/account/number.

3.3.2 Circl warrants and represents at all times to:

a. manage funds belonging to Account Holders in a secure and appropriate manner; and/or

b. absorb the cost of and pay the Pools Betting Duty, as applicable, at the Place of the Contract;

c. manage data regarding an Account Holder in accordance with applicable laws, data protection acts and/or similar;

d. not offer contingencies to customers to proceed to any fund transfer between customers' accounts.

3.3.3 Circl is required by its licence to inform the Account Holder about what happens to funds, which we hold on the account for them, and the extent to which funds are protected in the event of insolvency. Under the current Gambling Commission’s insolvency rating system your funds are not protected. For more information, please follow this link: gamblingcommission.gov.uk

Customer funds are kept in accounts separate from our company accounts, but they would form part of the assets of the business in the event of insolvency. This meets the Gambling Commission's requirements for the segregation of customer funds at the level: not protected.

3.3.4 A Circl Account does not accrue interest. The Account Holder shall not treat Circl as a financial institution.

3.3.5 A Circl Account is non-transferable. It is prohibited for players to sell, transfer or acquire accounts from or to other players. Funds cannot be transferred between Circl accounts.

3.3.6 An Account Holder shall not allow any other individual, including any minor, to use or reuse its Circl Account, access and/or use any material or information from the Website/Mobile App, accept any Prize, or access and/or participate in the Services.

3.4 Responsible gaming – Account settings

3.4.1 An Account Holder may, in the Circl Account settings:

a. set a limit on the amount that they may wager or deposit into their Circl Account within a specified period of time, depending on their country of residence;

b. exclude themselves from playing for a definite period of time.

c. apply a "Time Out" to their account, a temporary block of 24 hours, one week, one month or two months in order for clients to take a temporary break from their gambling.

3.4.2 An Account Holder who has set a deposit limit as above in a) may change or revoke the limit in the Circl account settings. Increasing or revoking a limit takes effect seven days after Circl has registered the change. Decreasing a limit takes effect immediately after Circl has registered the change. Circl shall not accept a wager from an Account Holder contrary to a limit or exclusion set by themselves as above.

3.4.3 If Circl believes that a player's gambling will cause them financial or personal difficulties, Circl reserves the right to close their Circl Account.

3.4.4 For further information on financial protection please refer to Self-exclusion and Financial Protection of Players Section below:

3.5 Self-exclusion and Financial Protection of Players

3.5.1 Self-exclusion is a formal process through which customers, at their discretion, request to be barred for a definite period. Self-exclusion shall become effective immediately. During this time, we cannot accept deposits or bets. We will close the customer's account and return any remaining balance. Any ongoing bets will remain active and any winnings will be paid to the customer on termination of the event. Once the self-exclusion period becomes effective, it cannot be cancelled by the Company for any reason whatsoever and the customer cannot open another account. Once a customer requests self-exclusion this decision is irrevocable until the defined period of self-exclusion has expired, at which time the customer can contact Circl and either request to resume gambling or set another period of self-exclusion. A 24 hour "cooling off" period will apply to those who have been approved to resume gambling.

3.5.2 We are aware that whilst for the majority of customers gaming is simply an entertaining pastime, for a small number of people it can become a problem. For any players wishing to limit their gaming, Circl offers Self-exclusion, which allows an Account Holder to close their account immediately for at least six months. You can send us an email on support@playcircl.com to request a self-exclusion period or threshold (minimum 6 months). Alternatively, the customer can access their personal Circl account and from the "Account" menu the customer will then be able to go to "Self-Exclusion" section, select the period for self-exclusion (six months, one year, two years, five years or indefinite), and confirm the selection by clicking the "Save" button. The request will be accepted immediately and the client will receive confirmation by email.

3.5.3 Alternatively, players are able to self-exclude themselves on the free online self-exclusion scheme, excluding themselves from using gambling websites/mobile apps by companies licenced in Great Britain for a period of your choosing. To register, please visit the GAMSTOP website: https://www.gamstop.co.uk/.

3.5.4 We take all reasonable steps to ensure that the self-exclusion procedure is adhered to and we shall use all reasonable endeavors to ensure that no promotional material is sent to customers who have excluded themselves from playing. However, the customer accepts that we are in no way responsible towards the customer or any third party if they continue to play with any added accounts, in which they have changed any registration details (including cases in which the customer opens an account with the same details but inserted differently in the registration form) or if publicity material is inadvertently forwarded to him. We also strongly recommend that the Account Holder seeks urgent professional assistance if they find a way to continue playing during the self-exclusion period.

3.6 Deposit Limits

3.6.1 When setting up your account you may also choose to impose a ceiling on the maximum deposit you may make within a specified period of time, daily, weekly or monthly.

3.6.2 Upon setting a limit or exclusion in the manner contemplated above, you can only change or revoke the limit or exclusion by written notice or electronic notice sent to support@playcircl.com. To note, this still doesn't guarantee we will accept the change or revoke the deposit limit request, we would look to ensure we have followed all relevant steps provided by the UKGC that mitigates any risk of 'Problem Gambling'.

3.7 Inactive accounts 3.7.1 An "Inactive Account" is a Circl Account which has no record of any log-in and/or log-out for a period exceeding twelve (12) consecutive months.

3.7.2 Circl reserves the right to close the Inactive Account once the account reaches zero balance. All Account Holders whose Circl Accounts remain inactive for 12 months will be notified of any balance remaining their Circl Accounts and will be advised to withdraw any remaining balance. The Account Holders may, therefore, reactivate their Circl Accounts by logging in/logging out or withdrawing their funds within the 30 days' time window without incurring any fees. Should any Account Holder reactivate their Circl Account within three months, they will be refunded any inactivity fees.

3.8 Chargebacks 3.8.1 Subject to the sub-clauses below and without prejudice to Circl's right to seek redress under any applicable legislation, regulation, enactment or policy, or under any other provision of the Circl Rules, Circl shall have the right to block a Circl Account when a chargeback has been requested in relation to that Circl Account.

3.8.2 When a chargeback has been requested, Circl will send a "Chargeback Notice" to the Account Holder at the email address mentioned in the Account Holder's details, in order to seek confirmation of the Account Holder's identity and of the payment method used to credit to the Account Holder's Circl Account any funds entirely unrelated to a chargeback ("Untainted Funds").

In the absence of confirmation by the Account Holder of the Account Holder's identity and of the payment method used to credit Untainted Funds to the Account Holder's Circl Account, following a Chargeback Notice, Circl will send two written reminders to the Account Holder at the email available to it, each of which will be subject to a processing fee of fifty (50) EURO drawn on any Untainted Funds.

3.8.3 Where a Circl Account has been blocked due to a chargeback and the Account Holder has not:

a. logged in to the Circl Account for a period of thirty (30) consecutive months; or

b. confirmed to Circl his/her identity and the details of the payment method used to credit Untainted Funds to the Account Holder's Circl Account and then requested a withdrawal; any Untainted Funds on the Circl Account will be treated as though they were funds on an Inactive Account and Circl will remit the balance on the Circl Account of the Account Holder to the Gambling Commission.

3.9 Closure of a Circl Account

3.9.1 An Account Holder may close their Circl Account at any time by contacting Circl's Customer Support using the contact details provided in the "FAQ" section on the Website/Mobile App, either by email or live chat. Any funds in the Circl Account will be remitted to the Account Holder.

3.9.2 Should an existing Circl Account be closed, any obligations already entered into will be honoured.

3.9.3 Account Holders who wish to recover funds held in a closed, blocked or excluded account are advised to contact Customer Support.

3.9.4 In the case of closure of their Circl Account due to gambling addiction or fraud, an individual must not open a new Circl Account. Circl will not be liable should the individual succeed in opening a new account, nor for any direct or indirect consequential damages. Circl reserves the right to close an account opened in breach of this rule at any point.

4. PAYMENT RULES

4.1 Deposits to and withdrawals from a Circl Account shall at all times be made through a Financial Institution or a Payment Solution Provider. Procedures, terms and conditions, availability, and duration for deposits/withdrawals may vary depending on time as well as the country and Financial Institution in question. Current advice is available when logged in on the Website/Mobile App under the headings "Deposit" or "Withdrawal". We reserve the right to request further information and documentation from you in order to carry out the necessary verifications as required by law.

4.2 Circl does not accept cash funds sent or delivered directly to Circl or a Payment Solution Provider.

4.3 Circl will credit to the Circl Account all funds received by Circl from or on behalf of the Account Holder, or owed by Circl to the Account Holder.

4.4 Method of payment/withdrawal from/to Circl Account

4.4.1 An Account Holder is only allowed to:

a. make deposits to his/her Circl Account with his/her personal Card or via his/her personal account created with one of the Financial Institutions or their licensees;

b. request withdrawals of funds held on his/her Circl Account to his/her personal account created with one of the Financial Institutions or their licensees.

4.4.2 An Account Holder is responsible for providing Circl with the correct details of his/her personal account for the purpose of withdrawals from his/her Circl Account.

4.4.3 An Account Holder must not allow third parties to use his/her Circl Account to make deposits to or withdrawals from his/her Circl Account.

4.4.4 It is the Account Holder's sole responsibility to ensure that he complies with the above provisions.

4.5 Circl shall not accept a wager from an Account Holder unless a Circl Account has been established in the name of the Account Holder and there are adequate funds in the Circl Account to cover the amount of the wager, or funds necessary to cover the amount of the wager are provided in an approved manner.

4.6 Circl shall not deal with the credit balance of a Circl Account except:

a. to debit from the Circl Account a wager made by the Account Holder or an amount the Account Holder indicates they want to wager in the course of a game they are playing or about to play;

b. to remit funds standing to the credit of the Circl Account to the Account Holder, at the Account Holder's request, in terms of regulation 37 of the Remote Gaming Regulations;

c. to pay reasonable bank charges for deposits received and funds withdrawn; or

d. as otherwise authorised by the Remote Gaming Regulations.

4.9 The balance of a Circl Account may turn negative in case of a chargeback.

4.10 Withdrawals from a Circl Account are made through payments addressed to the Account Holder or transferred to a bank account held in the name of the Account Holder, as advised by the Account Holder. Whenever possible, Circl will restrict withdrawals to be made only to the same account utilised by the Account Holder to make deposits.

4.11 When an Account Holder wishes to withdraw funds they have deposited into their Circl Account but have not wagered in any game or sport betting offer, Circl reserves the right to refuse to transfer the funds to another bank account than the one the funds originated if Circl suspects fraud and/or money laundering.

4.12 Depending on the payment method chosen by the Account Holder, minimum and/or maximum deposit limits may apply.

4.12.1 To withdraw an amount from the account, the Account Holder must complete the following steps.

1. Choose Payment in the Account section.

2. Choose payment system.

3. Provide the required personal data and indicate the amount.

4. Press Confirm. A message confirming the payment will then appear.

The withdrawals will be remitted only to the same account from which the funds originated

• There can also be limitations for withdrawals.

• No cash deposits / withdrawals will be affected.

4.13 Circl reserves the right to charge the Account Holder for administrative costs resulting from withdrawals made by the Account Holder, as indicated on the Website/Mobile App.

4.14 Placing a bet through the Internet may be illegal in the jurisdiction in which an Account Holder is resident and/or domiciled; if so, the Account Holder is not authorised to use a Card for the purpose of placing a bet.

4.15 The participation of an Account Holder in the Services in a jurisdiction where such participation is prohibited by law shall not affect any stakes or payment made to and accrued for the benefit of Circl.

4.16 It is the sole responsibility of the Account Holder to pay and proceed with all necessary diligence in relation to taxes on any Prize, if and where applicable.

4.17 It is unlawful to deposit money from ill-gotten means.

4.18 Only one active payment method per account is permitted.

5. SECURITY RULES

5.1 Circl upholds strict confidentiality regarding all relations with the Account Holder. However, if required by the Governing Authority, a judge or, when required to do so by law, another public authority, and/or in the event of an Account Holder violating the Circl Rules, data can be disclosed to a third party for investigation purposes.

5.2 The Account Holder is given a personal account number. The Account Holder chooses a password and a username. It is the Account Holder's own responsibility not to share this information. If the Account Holder has reasons to believe that others have become aware of this information, the Account Holder should immediately contact Circl's Customer Support and a new password will be issued. Circl is not required to maintain usernames or passwords. If the Account Holder misplaces, forgets, loses, or shares with a third party their username and/or password, or is otherwise unable to enter the Website/Mobile App or any Service for any reason other than Circl's error, Circl will not be responsible and will not be held liable for any claim regarding that Circl Account.

5.3 All telephone communications between the Account Holders and Circl are recorded for security and training purposes and/or compliance with accounting and finance regulations.

5.4 All electronic communications between the Account Holder and Circl are kept on record for compliance with accounting and finance regulations.

5.5 Card deposits may, from time to time, be partially and/or fully declined subject to certain security systems managed in collaboration with a Payment Solution Provider and/or a Financial Institution. Such security measures may decline Cards that are legitimate, but which nevertheless it may not be possible to process at a particular time. Circl's personnel do not control the said systems, nor do they have any knowledge of the reasons for any deposits being declined.

5.6 Circl may request documents to verify the identity of the Card user and/or authorisation to use a specific Card and/or other facts and information provided by the Account Holder before expediting deposits and/or withdrawals. This may cause slight delays. From time to time, chargebacks are received and these will be treated in accordance with Circl procedures.

5.7 It is illegal to use and/or abuse an error or an instance of incompleteness on the Website/Mobile App, and/or in any of the Software and/or Services provided on the Website/Mobile App. Should the Account Holder detect or become aware of such an error or incompleteness, they shall:

a. refrain from taking any advantage whatsoever thereof;

b. keep strictly confidential such error or incompleteness;

c. upon detection or becoming aware of such error or incompleteness, notify it to Circl by sending an email to support@playcircl.com.

Without prejudice to other remedies available under law or equity, should the Account Holder not comply with this clause, Circl:

a. shall be entitled to full compensation for all costs that may be associated with the error or incompleteness, and harm resulting from the breach of this clause by the Account Holder;

b. reserves the right to, notably but not limited to, block the Account Holder's Circl Account, and/or freeze or subtract all or part of the Circl Account balance without prior notice, in order to cover part or all of the damages suffered or envisaged to be suffered by Circl.

5.8 An Account Holder's identity will be determined on the basis of all or a combination of information, such as name, mailing address, email address, Card number, and any other type of identification that may possibly be required.

6. DISCLAIMER

6.1 The Circl Rules as published in English and as may be amended from time to time in accordance with these Rules govern the Contract between you and Circl. These Rules may be published in a number of languages for information purposes and for ease of your access. All versions will convey the same principles in different languages. Should there be any discrepancy between the terms in the English language version and the version in any other language, the English version will prevail.

6.2 The Account Holder is advised to comply with applicable legislation in the jurisdiction in which they are domiciled and/or resident. Circl does not provide advice to the Account Holder regarding tax and/or legal matters. Should the Account Holder wish to obtain advice regarding tax and legal matters, they are advised to contact appropriate advisers and/or authorities in the jurisdiction in which they are domiciled and/or resident.

6.3 In the event of Circl being found liable in any way by a court of law and/or a similar authority with legal competence and/or jurisdiction over Circl, then Circl's liability is limited to the amount of the stake, or the Account Holder's net winnings, whichever is the lesser. Alternatively, when relevant and applicable, the amount recorded in the Circl Account or the amount transferred into or out of the Circl Account, whichever is the lesser.

6.4 Circl reserves the right, at all times, to resolve any dispute, at its own discretion, in accordance with principles of equity.

6.5 Circl makes no representation or warranty, explicit or implicit, as to the legal rights of the Account Holder to participate in the Services, nor shall any of Circl's employees, licencees, distributors, wholesalers, affiliates, subsidiaries, advertising, promotion or other agencies, media partners, agents or retailers have the authority to make any such representation or warranty. The Account Holder shall not use the Services, open, use or reuse a Circl Account, enter the Website/Mobile App, nor accept any Prize if the Account Holder does not fully understand, agree to, wish to become a party to, and comply with, without exception, all the Circl Rules contained herein, and as these may be amended from time to time.

a. Circl does not acknowledge or accept any liability for damage and/or losses to an Account Holder and/or a third party caused directly and/or indirectly due to the Account Holder:

b. making deposits to his/her Circl Account via a third party's card or account;

c. requesting withdrawals from his/her Circl Account to a third party's account;

d. providing incorrect details of his/her personal account for the purpose of withdrawals from his/her Circl Account;

e. allowing third parties to use his/her Circl Account to make deposits to or withdrawals from his/her Circl Account.

6.6 The Account Holder should take all appropriate measures to protect the data and/or Software stored on their computer against all damage of any sort or intrusion.

6.7 The connection to the Website/Mobile App and the participation of the Account Holder in any Service is under the Account Holder's responsibility.

6.8 Circl does not acknowledge or accept any liability whatsoever for damage and/or losses to an Account Holder and/or a third party caused directly and/or indirectly due to any:

a. mistake, misprint, misinterpretation, mishearing, misreading, mistranslation, spelling mistake, fault in reading, transaction error, technical failure, technical hazard, registration error, manifest error, cancellation of a game for any reason, Force Majeure and/or any other similar event;

b. violation of the Circl Rules;

c. collusion and/or criminal actions;

d. advice provided by Circl;

e. failure of Circl's central computer system or any part thereof; delays, losses, errors or omissions resulting from the failure of any telecommunications or any other data transmission system; and/or

f. financial risk and loss, including but not limited to variances in exchange rates;

6.9 The Account Holder understands that the Services offered on the Website/Mobile App are for entertainment value only. The Account Holder is not required to use the Services, and such participation, if elected by the Account Holder, is at the Account Holder's sole choice, discretion, and risk. The Account Holder's interest in the Services and the Website/Mobile App is personal, and not professional. The Account Holder enters the Website/Mobile App for their sole personal entertainment. Any other entrance, access, use or reuse of the Services and/or the Website/Mobile App by the Account Holder/Player is prohibited.

6.10 The SMS notification service is purely for the benefit of the Account Holder. Circl does not acknowledge or accept any liability whatsoever should there be a mistake in the content of the SMS notifications or should the Account Holder fail to receive the SMS notification(s).

6.11 All Prizes won through competitions and promotions organised by Circl will be sent within an estimated and not guaranteed delay of six weeks from the end of the competition, promotion or tournament.

6.12 Should the Account Holder's participation in the Services be interrupted by a failure of the telecommunication system, or of the Account Holder's computer system, preventing them from continuing to use the Services after they have placed a wager, Circl shall take all reasonable steps to ensure that its approved computer system enables the Account Holder to resume, upon restoration of the system, the Account Holder's participation in the Services as at the time immediately before the interruption. If Circl's system does not enable the Account Holder to do so, Circl shall:

a. ensure that the game is terminated;

b. refund the amount of the wager to the Account Holder in their Circl Account.

6.13 Should a Service miscarry after starting due to a failure on the part of Circl 's computer operating system, Circl shall:

a. refund the amount wagered in the Service, and if the Account Holder has an accrued credit at the time the Service miscarries, credit the monetary value of the credit to the Account Holder's Circl Account or, if the said account no longer exists, by paying it to the Account Holder in an approved manner;

b. immediately inform the Regulator of the circumstances of the incident;

c. refrain from conducting a further Service if the Service is likely to be affected by the same failure.

6.14 Participation in the Services implies knowledge and acceptance of the limits of the Internet, especially:

a. technical capacity, response time for consultation, interrogation or transfer of information, risk of interruption, and in general risks inherent in any connection and transmission failure;

b. failure in the protection of data;

c. contamination risks by potential viruses circulating on the net.

Hence, without prejudice to other clauses of this Disclaimer section, Circl shall not be responsible for (including but not limited to):

a. transmission and/or reception of any data and/or information on the Internet;

b. any dysfunction of the network preventing the good progress of any game;

c. failure of any reception material or communication circuit;

d. loss of any data;

e. any damage caused by a virus, computing bug or technical failure;

f. any damage caused to the material of the Player, including hardware and software;

g. any failure preventing or limiting participation in a game, or a failure damaging the Account Holder's system, including their hardware and software.

6.15 Gaming material (whether electronically obtained or obtained by other means) is automatically invalid if counterfeited, mutilated, forged, altered or tampered with in any way, or if illegible, mechanically or electronically reproduced, obtained outside authorised legitimate channels, or if it contains printing, production, typographical, mechanical, electronic or any other errors.

6.16 Circl is not responsible for lost, late, illegible, incomplete, damaged, mutilated, misdirected or 'postage due' mail, requests, Prize claims or entries.

6.17 Circl's liability for any error or malfunction included in the games is limited to replacement. Circl shall not be liable for playing device malfunctions nor attempts by the Account Holder to use the Services by methods, means or ways not intended by Circl.

6.18 The Account Holder shall hold Circl, its employees, officers, directors, licencees, distributors, wholesalers, affiliates, subsidiaries, advertising, promotion or other agencies, media partners, agents and retailers harmless and shall fully indemnify the same from any and all costs, expenses, liabilities and damages whatsoever that may arise as a result of Account Holder's:

a. entry, use or reuse of the Website/Mobile App;

b. use of any Website/Mobile App material;

c. entry, use or reuse of the servers used to provide the Services;

d. participation in the games and Services; or

e. the acceptance of any Prize.

6.19 Under no circumstances, including but not limited to negligence, shall Circl, its Software and Mobile App, software suppliers, subsidiary companies, or affiliates be liable for any direct, indirect, incidental, special or consequential damages resulting from the use of or the inability to use Circl's or its suppliers' products, Mobile App and/or materials. The Account Holder specifically acknowledges and agrees that Circl is not liable for any defamatory, offensive or illegal conduct of any Account Holder. If the Account Holder is dissatisfied with any Service, or with any of the present Circl Rules, the Account Holder's sole and exclusive remedy is to discontinue using the Services.

6.20 The Account Holder understands, acknowledges and accepts that any resemblance of names, circumstances or conditions used, depicted, described or suggested in the games operated on the Website/Mobile App with reality is entirely coincidental and unintended.

6.21 The Account Holder understands that Circl reserves the right to change or remove any of its Services at any time.

6.22 The Account Holder shall review the Circl Rules as posted on the Website/Mobile App on a regular basis, and not less than once a month.

7. BONUS RULES

7.1 General

7.1.1 Circl regularly organises bonus campaigns for the different gaming products offered. The terms and conditions of the bonus system shall be defined in the bonus terms and conditions tailored to each bonus campaign. Bonuses can be subject to the obligation of wagering them a certain number of times ("Wagering Requirement") before they can be withdrawn. If a bonus is subject to a Wagering Requirement, winnings generated by the wager of the bonus will be able to be withdrawn only when the Wagering Requirement is fulfilled.

7.1.2 An Account Holder is eligible for one bonus per campaign, with the exception of so-called "Refer a friend" campaigns.

7.1.3 An Account Holder is only eligible for one bonus per Account which shall mean no more than one bonus per user, IP address, computer device, family, residential address, telephone number, credit or debit card and/or e-payment account, e-mail address, and environments where computers or devices are shared (university, fraternity, school, public library, workplace, etc.).

7.1.4 Circl further reserves the right to ask any customer to provide sufficient documentation for Circl to be confident in its absolute discretion as to the customer's identity before Circl credit any bonus, free and risk-free bet or offer to the customer's account.

7.1.5 Circl reserves the right to offer a specific bonus to a specific customer or group of customers.

7.1.6 In the case of discrepancy between the English version of the bonus terms and conditions and any translation of them, the English version shall prevail.

7.1.7 Circl reserves the right to cancel or amend the terms and conditions of any customer offer or promotion at any time.

7.2 Sportsbook

7.2.1 Each qualifying bet is subject to the qualification rules detailed in the individual bonus.

7.3 Bonus Abuse

7.3.1"Bonus Abuse" includes, but is not limited to:

• breach of terms and conditions of a bonus, free bets or any other promotional offer; • the opening of multiple accounts to claim multiple bonuses;

7.3.2 Where there is a reasonable suspicion that the Account Holder has committed or attempted to commit a bonus abuse, either on their own or as part of a group, Circl reserves the right to:

• forfeit the bonus allocated to the Account Holder and any winnings from that bonus, and/or • revoke, deny, or withdraw a bonus offer from the Account Holder, and/or • block an access to particular products, and/or • exclude the Account Holder from any future promotional offers, and/or • terminate the Account Holder's account with immediate effect.

7.3.3 Where there is a reasonable suspicion that a series of bets has been placed by a customer or group of customers which, due to a bonus, free bet or any other promotional offer, result in guaranteed customer profits irrespective of the outcome, Circl reserves the right to reclaim the bonus and in its absolute discretion to settle bets at the correct odds, void the free bets and/or void any bet funded by the bonus or bonus winnings.

7.4 Refer a Friend

7.4.1 For "Refer a friend" campaigns, an Account Holder can benefit from more than one bonus per campaign and/or per month, subject to the limit set up in each specific "Refer a friend" campaign.

7.4.2 Referrers are not permitted to refer a member of their family nor are they permitted to refer friends or colleagues from the same household or with whom they share a credit or debit card or e-payment account, IP address and/or computer device.

7.4.3 Circl reserves the right to withhold the bonus from the Referrer and to discount bets made by one or more Referees where Circl suspects that the Referrer/Referee(s) has abused the spirit of the bonus offer including, but not limited to, instances where Referees make identical or very similar deposit and betting patterns.

8. BETTING

8.1 Any dispute relating in any way to the use of these Services, the Website or the Mobile App should be emailed to support@playcircl.com. Should the reply not be considered satisfactory; clients may refer their case to Independent Betting Adjudication Service (IBAS) for independent arbitration, in line with clause 13 below.

8.2 Circl reserves the right to make changes to the site, betting limits, payout limits, and offerings.

8.3 A bet can be declared void, and will be, in the event of required compliance with applicable law or Force Majeure.

8.4 Circl's Rules of Play constitute the specific rules regarding betting rules and are an integral part of the Contract between Circl and an Account Holder. By accepting the Circl Rules, the Account Holder confirms that they have read and understood the Rules of Play and that the Account Holder will abide by them.

8.5 We reserve the right to limit or refuse any bet, stake or other wager made by you through your account at any time. We are not obliged to give reasons for doing so but will make reasonable efforts to give reasons where possible.

9. ACCOUNT LIMITS, PAYOUT LIMITS AND MAXIMUM BETS

9.1 The following are the limits that can be won by a single client in respect of any one day's business. Our operators are not authorised to accept bets that exceed these limits. In the case of bets taken in error, the limit will stand. All limits are noted in Pounds Sterling.

Sports - £3,600

9.2. It is the responsibility of the customer to ensure details of their bets/wagers are correct. Once bets/wagers have been placed they may not be cancelled by the customer. Circl reserves the right to cancel any bet/wager at any time.

10. BET CONFIRMATION

10.1. Bets will not be valid if there are insufficient funds in your account.

10.2. A bet that you request will only be valid once accepted by Circl servers. Each valid bet will receive a unique transaction code/ID. We shall not be liable for the settlement of any bets, which are not issued with a unique transaction code/ID. If you are unsure about the validity of a bet, please check your account history or contact us.

10.3. Should a dispute arise, you and Circl agree that the Circl transaction log database will be the ultimate authority in such matters.

11. RESULTING AND PAYOUT

11.1 All bets and wagers are subject to the Rules of Play as stated in the Circl Terms and Conditions.

11.2 Circl reserves the right to suspend a market and/or cancel any bet/wager at any time. When a market is suspended any bets entered will be rejected. Circl also reserves the right to cease betting on any markets at any time without notice.

11.3 Winnings from resulted bets are added to the balance of your betting account. Any funds/winnings credited to an account in error are not to be considered available for use, and Circl reserves the right to void any transactions involving such funds and/or withdraw the relevant amount from your account and/or reverse the transaction, either at the time or thereafter when found.

11.4 Circl reserves the right to withhold payment and to declare bets on an event void if we have evidence that the following has occurred: (1) the integrity of the event has been questioned; or (2) match fixing has taken place. Evidence of the above may be based on the size, volume or pattern of bets placed with Circl and other operators across any of our betting channels. A decision given by the relevant governing body of the sport in question (if any) will be conclusive. If any customer owes any money to Circl for any reason, Circl have the right to take that into account before making any payments to that customer.

11.5 In the case of a series of bets being placed by individuals or a syndicate to manipulate the Rules of Play, Circl have the right to withhold/stop payment or winnings until such a time as Circl are satisfied no Rules have been broken.

12. OBVIOUS PRICE OR TERMS ERRORS

12.1 Whilst every effort is made to avoid errors, however, sometimes they can still occur due to human error or system problems. Obvious errors, also referred to as palpable errors, or omissions in respect of the announcing, publishing or marking of events, data, statistics, or results sometimes occur despite our efforts to ensure total accuracy.

12.2 We will make every effort to inform clients before the event starts of an obvious error, but this may not be possible in all cases.

13. CLAIMS AND DISPUTES

13.1 Circl recognises its responsibility and obligation to comply with the Licensing Objectives of the Gambling Act 2005 and the Licence Conditions and Codes of Practice. Monitoring of procedures is ongoing and subject to compliance inspection. The process of resolution of claims and disputes between Circl and the customer are defined by and implemented according to Circl Procedure on Fair and Open Practice: Dispute Resolutions.

13.2 Circl is committed to providing a high quality, accessible and responsive service to customers and the local community. However, if a customer is dissatisfied they should inform us by communicating their complaint to us either verbally or in writing. All complaints are taken seriously, investigatedthoroughly and handled in a confidential manner.

13.3 The customer should provide us with a comprehensive description and nature of the complaint, whether it is an original complaint, or a follow-up to a reply they were not satisfied with, their name and postal address including a contact telephone number.

13.4 A 'complaint' means a complaint about any aspect of the Circl's conduct of the licenced activities, and a 'dispute' is any complaint which:

a) is not resolved at the first stage of the complaints procedure; and

b) relates to the outcome of the complainant's gambling transaction.

13.5 In the first instance, Circl will endeavour to resolve the complaint to the satisfaction of both parties within fifteen working days. Should this not be possible we will explain why and provide a date by which the customer can expect a full response.

13.6 In the event of a complaint relating to the outcome of a customer's gambling that is unable to be satisfactorily resolved between the Circl and the customer within a period of three months from notification, we have an obligation to submit a detailed report for independent arbitration. As an independent third party dispute resolution, Circl applies to the Independent Betting Adjudication Service (IBAS), which acts as an impartial adjudicator on disputes that arise between betting/gambling operators and their customers after they have been through the operator's own internal dispute procedures and if a deadlock exists. Disputes may be filed under www.ibas-uk.com. The arbitrators' decision is final.

13.7 During the dispute resolution process:

a) Customers also have the means and opportunity of submitting their own version of events.

b) The dispute is investigated in full by the independent party.

c) Both parties are notified in writing of the proposed outcome of the investigation.

d) This procedure may, but need not, provide for the independent party's proposed resolution of the dispute to be binding on both parties.

13.8 Circl is obliged to keep a record of all complaints and disputes, other than those considered to be trivial, including all disputes referred for arbitration that are not resolved at the first stage of the complaints procedure. Circl has a requirement to submit reports of the outcome of disputes, referred to the arbitrator, to the Gambling Commission at intervals determined by the Commission either by the arbitrator or by Circl.

13.9 An actual summary of the contractual terms on which gambling is offered, set out in plain and intelligible language, is available to customers on request, with customers being notified of changes to terms before they come into effect.

14. GOVERNING LAW AND JURISDICTION

These Terms of Service are governed by and interpreted in accordance with the laws of England and Wales. Unless otherwise specified, disputes arising in connection with these Terms of Service shall be subject to the exclusive jurisdiction of the courts of England and Wales.