Privacy Policy

Welcome to Circle of Life. We are committed to protecting your privacy and handling your personal data with transparency and integrity. This Privacy Policy outlines how Circle of Life collects, uses, processes, and stores your personal information when you use our online casino services, including our website, mobile applications, and any related services. By accessing or using Circle of Life, you agree to the terms of this Privacy Policy. We encourage you to read this policy carefully to understand our practices regarding your data.

This policy is designed to comply with applicable data protection laws, including the General Data Protection Regulation (GDPR), where relevant to our operations and the jurisdictions we serve. Our goal is to provide a secure and enjoyable gaming environment while safeguarding your personal details.

At Circle of Life, we collect various types of information to provide and improve our services, fulfill our legal obligations, and enhance your gaming experience. This information can be broadly categorized as follows:

• Personal Identifiable Information (PII): This includes data that can directly identify you, such as your full name, date of birth, gender, email address, postal address, phone number, and national identification numbers (where required for verification purposes). We collect this during registration and account verification processes.
• Financial Information: To facilitate deposits and withdrawals, we collect payment method details, such as credit/debit card numbers, bank account information, and e-wallet details. Please note that sensitive payment data is often processed by third-party payment providers, and we only store limited information necessary for transaction tracking and regulatory compliance.
• Transactional Data: Details of your betting activity, deposits, withdrawals, and other financial transactions within Circle of Life. This includes game play history, winnings, and losses.
• Technical Data: Information about your device and how you access our services, including IP address, browser type and version, operating system, device identifiers, time zone setting, and location data.
• Usage Data: Information about how you use our website and services, including pages visited, features used, and the duration of your sessions.
• Communication Data: Records of your interactions with our customer support, including emails, live chat transcripts, and phone call recordings.
• Publicly Available Information: In some cases, and where legally permissible, we may collect information about you from public sources to verify your identity or for fraud prevention purposes.

Circle of Life uses your personal information for several purposes, all aimed at providing a secure, compliant, and enjoyable gaming experience:

• Account Management: To set up and manage your Circle of Life account, verify your identity, and confirm you meet eligibility requirements (e.g., age verification).
• Service Provision: To operate our online casino, process your bets, deposits, and withdrawals, and allow you to participate in games.
• Security and Fraud Prevention: To detect and prevent fraudulent activities, money laundering, and other illegal actions, thereby protecting both you and Circle of Life.
• Customer Support: To provide assistance, respond to your inquiries, resolve issues, and improve our customer service.
• Compliance with Legal and Regulatory Obligations: To adhere to licensing requirements, anti-money laundering (AML) laws, responsible gambling regulations, and other legal mandates.
• Personalization and Improvement: To tailor your gaming experience, offer relevant promotions, and analyze usage patterns to improve our services, features, and overall user interface.
• Marketing and Promotions: With your consent, to send you marketing communications about new games, bonuses, and special offers from Circle of Life. You can opt out of these communications at any time.
• Internal Operations: For internal auditing, data analysis, and research to enhance our business processes and security measures.

Under GDPR and similar data protection laws, we must have a lawful basis to process your personal data. Circle of Life relies on the following legal bases:

• Performance of a Contract: Processing is necessary for the performance of the contract to which you are a party (i.e., the Terms and Conditions of Circle of Life) or to take steps at your request before entering into such a contract. This includes managing your account, processing transactions, and providing gaming services.
• Legal Obligation: Processing is necessary for compliance with a legal obligation to which Circle of Life is subject. This covers identity verification, anti-money laundering checks, responsible gambling measures, and reporting to regulatory authorities.
• 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. Our legitimate interests include fraud prevention, network and information security, improving our services, and marketing activities (where consent is not required).
• Consent: In specific situations, we may rely on your explicit consent to process certain types of personal data, particularly for direct marketing communications. Where we rely on consent, you have the right to withdraw it at any time.

Circle of Life may share your personal information with third parties under specific circumstances, always with appropriate safeguards in place:

• Service Providers: We engage trusted third-party service providers to perform functions on our behalf, such as payment processors, IT support, hosting services, customer support platforms, and marketing agencies. These providers are contractually bound to protect your data and only use it for the purposes specified by Circle of Life.
• Regulatory and Licensing Authorities: We will disclose your information to gambling regulators, licensing bodies, and other governmental authorities when required by law or to comply with our licensing obligations.
• Law Enforcement and Fraud Prevention Agencies: To prevent fraud, money laundering, and other illegal activities, we may share information with law enforcement agencies, financial institutions, and specialized fraud prevention organizations.
• Affiliates and Group Companies: Your data may be shared with other entities within our corporate group for operational, analytical, and compliance purposes.
• Auditors and Professional Advisors: To external auditors, legal advisors, and other professional consultants for compliance, financial, or legal advice.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will notify you of any such change in ownership or control of your personal data.

We do not sell your personal data to third parties.

The security of your personal data is a top priority for Circle of Life. We implement robust technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption: We use industry-standard encryption technologies, such as Secure Socket Layer (SSL) encryption, to protect data transmitted between your device and our servers.
• Access Controls: Access to your personal data is restricted to authorized personnel who require it for their job functions, and they are subject to strict confidentiality obligations.
• Firewalls and Intrusion Detection Systems: Our systems are protected by firewalls and continuously monitored for suspicious activity.
• Regular Security Audits: We conduct regular security assessments and penetration tests to identify and address potential vulnerabilities.
• Data Minimization: We only collect and retain personal data that is necessary for the purposes for which it is processed.
• Employee Training: Our staff receive regular training on data protection best practices and security protocols.

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

Depending on your jurisdiction and applicable data protection laws, you may have certain rights regarding your personal data held by Circle of Life. These rights typically include:

• 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 may request the deletion of your personal data under certain circumstances (e.g., if the data is no longer necessary for the purposes for which it was collected).
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in certain situations (e.g., if 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 based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on your consent for processing, you have the right to withdraw that consent at any time.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in the "Contact Us" section. We may require you to verify your identity before fulfilling your request.

Circle of Life uses cookies and similar tracking technologies to enhance your experience, analyze 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 security, network management, and accessibility.
• Analytical/Performance Cookies: These cookies help us understand how visitors interact with our website by collecting information about the number of visitors, which pages are most popular, and how users move through the site. This helps us improve the user experience of Circle of Life.
• Functionality Cookies: These allow our website to remember choices you make (such as your username, language, or region) and provide enhanced, more personalized features.
• Marketing/Targeting Cookies: These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns.

You have the option to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, disabling cookies may prevent you from taking full advantage of the Circle of Life website and services.

Circle of Life retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our retention periods are determined by:

• Contractual Obligations: As long as you have an active account with Circle of Life.
• Legal and Regulatory Requirements: We are legally obliged to retain certain types of data (e.g., transaction records, identity verification documents) for specific periods as mandated by our licensing authority and anti-money laundering regulations. This can typically range from five to ten years after your account closure.
• Dispute Resolution: For the duration necessary to resolve any potential disputes or to establish, exercise, or defend legal claims.
• Legitimate Business Interests: For internal analytical purposes, fraud prevention, and to improve our services, provided your rights are not overridden.

Once the retention period expires, your personal data will be securely deleted or anonymized.

Circle of Life operates globally, and as such, 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) that may not have equivalent data protection laws. When we transfer your data internationally, we take appropriate measures to confirm that your personal data receives an adequate level of protection. These measures may include:

• Transferring data to countries deemed to provide an adequate level of protection for personal data by the European Commission.
• Using standard contractual clauses approved by the European Commission, which provide specific safeguards for personal data.
• Implementing binding corporate rules, where applicable.
• Obtaining your explicit consent for the transfer, where no other legal basis applies.

By using Circle of Life services, you acknowledge and agree to such transfers.

Circle of Life services are strictly intended for individuals who are at least 18 years of age, or the legal age for gambling in their jurisdiction, whichever is higher. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal information from a child, we will take immediate steps to delete that information from our records.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately using the details in the "Contact Us" section.

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

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer:

Email: [email protected]

Postal Address: [Our Registered Office Address, for example: Data Protection Officer, Circle of Life, [Street Address], [City], [Postal Code], [Country]]

We are committed to addressing your inquiries promptly and transparently.