Privacy Policy

Welcome to Circle of Life, an online gaming platform. We are committed to protecting your privacy and the security of your personal information. This Privacy Policy outlines how Circle of Life collects, uses, processes, and safeguards your data when you interact with our website, services, and applications. By registering an account and using our services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. We encourage you to review this policy periodically as it may be updated from time to time.

Circle of Life operates in full compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) where relevant. Our commitment is to transparency and responsible data handling, so your gaming experience is enjoyable and secure.

To provide you with our services, Circle of Life collects various types of information. This includes:

• Personal Identifiable Information (PII): This includes your full name, date of birth, gender, email address, postal address, telephone number, and national identification details (where required for verification). We collect this during registration and account verification processes.
• Financial Information: Details related to your payment methods, such as bank account numbers, credit/debit card numbers (though these are typically processed by secure third-party payment providers and not stored directly by us), and transaction history.
• Technical Information: Your IP address, device type, operating system, browser type, unique device identifiers, and network information. This is gathered automatically when you access our platform.
• Usage Data: Information about how you use our services, including your gaming activity, login times, pages viewed, and features used.
• Communication Data: Records of your communications with us, including emails, chat logs, and telephone calls, for customer support and quality assurance.
• KYC (Know Your Customer) and AML (Anti-Money Laundering) Information: Documents and data required to verify your identity and source of funds, such as copies of passports, utility bills, or bank statements.

Circle of Life uses the collected information for several essential purposes:

• To Provide and Manage Our Services: This includes creating and maintaining your account, processing your bets and transactions, and enabling you to access and use our games.
• For Security and Verification: To verify your identity, age, and location, as well as to conduct fraud prevention, anti-money laundering, and responsible gambling checks. This is crucial for maintaining a safe and compliant gaming environment at Circle of Life.
• Customer Support: To respond to your inquiries, resolve issues, and provide assistance via various communication channels.
• Personalisation: To tailor your gaming experience, offer personalised promotions, and recommend games based on your preferences and activity.
• Marketing and Promotions: To send you marketing communications about new games, bonuses, and special offers, where you have consented to receive such communications. You can opt out at any time.
• Improving Our Services: To analyse usage patterns, troubleshoot technical issues, and enhance the functionality and user experience of our platform.
• Legal and Regulatory Compliance: To comply with our legal obligations, including reporting to regulatory authorities and enforcing our terms and conditions.

Circle of Life processes your personal data based on several legal grounds, as permitted by GDPR and other applicable laws:

• Contractual Necessity: Processing is necessary for the performance of a contract with you, specifically to provide our gaming services and fulfil our terms and conditions.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which we are subject, such as anti-money laundering laws, age verification requirements, and responsible gambling regulations.
• Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by Circle of Life or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms. These legitimate interests include improving our services, preventing fraud, protecting network and information security, and direct marketing (where permitted).
• Consent: In certain situations, we may rely on your explicit consent to process your personal data, particularly for sending marketing communications. You have the right to withdraw your consent at any time.

Circle of Life may share your personal information with third parties under specific circumstances:

• Service Providers: We engage trusted third-party service providers to perform functions on our behalf, such as payment processors, IT support, customer service, and marketing agencies. These providers are contractually obligated to protect your data and use it only for the purposes for which it was disclosed.
• Regulatory and Law Enforcement Authorities: We may disclose your information to government bodies, regulatory authorities, or law enforcement agencies if required by law, court order, or to comply with our licensing obligations. This includes reporting suspicious transactions or activities.
• Fraud Prevention and Anti-Money Laundering Agencies: To combat fraud and financial crime, we may share information with specialist agencies.
• Affiliates and Group Companies: Your data may be shared with other entities within our corporate group for operational purposes, provided they adhere to this Privacy Policy.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity. We will notify you of any such change.

We do not sell, rent, or trade your personal information to third parties for their independent marketing purposes.

Circle of Life employs robust technical and organisational measures to protect your personal data from unauthorised access, alteration, disclosure, or destruction. We utilise industry-standard security protocols, including:

• SSL Encryption: All data transmitted between your browser and our servers is encrypted using Secure Socket Layer (SSL) technology.
• Firewalls: We implement advanced firewall systems to prevent unauthorised access to our network.
• Access Controls: Access to personal data is restricted to authorised personnel on a need-to-know basis.
• Regular Audits: Our security systems and practices are regularly audited and updated for ongoing protection.

While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously work to enhance our protective measures.

Under applicable data protection laws, you have several rights regarding your personal data. Circle of Life is committed to upholding these rights:

• Right to Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You can request that we correct any inaccurate or incomplete personal data we hold about you.
• Right to Erasure (Right to Be Forgotten): You can request the deletion of your personal data under certain circumstances, for example, if the data is no longer necessary for the purposes for which it was collected.
• Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain situations, such as when you contest the accuracy of the data.
• Right to Data Portability: You can request to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when processing is based on legitimate interests.
• Right to Withdraw Consent: Where we rely on your consent for processing, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact our customer support team using the details provided in the "Contact Us" section. We will respond to your request in accordance with applicable laws.

Circle of Life uses cookies and similar tracking technologies to enhance your experience, analyse website usage, and for marketing purposes. Cookies are small text files stored on your device when you visit our website.

• Essential Cookies: These are necessary for the website to function correctly, enabling core functionalities like secure login and transaction processing.
• Analytical/Performance Cookies: These cookies help us understand how visitors interact with our website, allowing us to improve its performance and design.
• Functionality Cookies: These remember your preferences, such as language or region, to provide a more personalised experience.
• Targeting/Advertising Cookies: These are used to deliver relevant advertisements to you and measure the effectiveness of our marketing campaigns.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our website and your ability to use some services.

Circle of Life retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Typically, we retain account information for a period of five years after your account becomes inactive or is closed, in accordance with our legal and regulatory obligations, particularly those related to anti-money laundering and responsible gambling. After this period, your data will be securely deleted or anonymised.

In some cases, we may retain data for longer periods if required by law or for legitimate business interests, such as resolving disputes or enforcing our agreements.

As Circle of Life operates globally, your personal data may be transferred to, and stored at, a destination outside of your country of residence, including countries outside the European Economic Area (EEA). When we transfer your data internationally, we put appropriate safeguards in place to protect your privacy rights, as required by GDPR and other relevant data protection laws.

These safeguards may include:

• Transferring data to countries deemed to provide an adequate level of data protection by the European Commission.
• Implementing standard contractual clauses approved by the European Commission.
• Relying on your explicit consent for specific transfers.

Circle of Life services are strictly not intended for individuals under the age of 18 (or the legal age of majority in your jurisdiction, whichever is higher). We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected personal data from a child, we will take immediate steps to delete that information from our records. We urge parents and guardians to monitor their children's online activity so they do not access our services.

Circle of Life reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or technological advancements. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by email. We encourage you to review this policy periodically to stay informed about how we are protecting your information. Your continued use of our services after any changes signifies your acceptance of the updated Privacy Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by Circle of Life, please contact our dedicated customer support team.

You can reach us via:

• Email: [email protected]
• Live Chat: Available 24/7 on our website.
• Postal Address: [Please refer to our website for the official registered office address.]

Our team is committed to addressing your inquiries promptly and transparently.