This Privacy Policy, as amended or otherwise changed from time to time (this “Privacy Policy”), explains the manner in which COG Holdings Global Limited (COG), its subsidiaries, affiliates, and other corporate entities under common ownership including, but not limited to, all websites that link this Privacy Policy (“COG”, “we“, “us“, or “our“) collects, uses, maintains and discloses user information obtained through its mobile app/platform, websites: https://circleofgames.com/ (Website), applications, brands, services and products (collectively, “Services”). Whenever you access or use the Services, you accept the terms and conditions of this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of the Services.

On occasion, COG may update and change this Privacy Policy to reflect changes in law, our personal data collection and use practices, the features available through the Services, or advances in technology. If material changes are made to this Privacy Policy, the changes will be prominently posted on websites and applications. Capitalized terms not defined herein shall have the meanings ascribed to them in COG’s Use Terms and Conditions.

“Personal Data” means data you may give COG to identify or contact you, including, for example, your name, address, User ID, telephone number, e-mail address, any blockchain addresses, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.

We only collect and process Personal Data about you where we have lawful bases to do so.  Lawful bases include consent where you have given consent, contract, and legitimate interests.

We may collect Personal Data from you, such as your first and last name, mobile number, e-mail and mailing addresses, User ID, date of birth, government issued identification, and password when you register for an account on the Services (“Account”) or otherwise use the Services.

We may also collect other Personal Data provided by third party identity verification services or via social networking websites.

If you tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.

We may collect your Personal Data, such as your User ID and it may be used to track you across devices and connect you to alternative datasets that we have, including but not limited to, discord data, your wallet, and game related data.

Certain services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.

If you provide us feedback or contact us via e-mail, message chat or similar functionality, we will collect your name and e-mail address, as well as any other content included in the communication, in order to send you a reply.

Transactional information when you request information or purchase a product or service from us.

We also collect other types of Personal Data that you provide to us voluntarily when seeking support services, such as email, information submitted via online form, video conferencing service information, other contact information, or other information provided to support services staff.

We may collect other data, including but not limited to, referral URLs, your location, blockchain analytics information related to blockchain addresses you provide.

Our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data.

Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website.

We retain information on your behalf, such as transactional data and other session data linked to your Account.

We will only use your Personal Data when the law allows.

Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law.

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

- facilitate the creation of and secure your Account on the network;
- identify you and perform identity verification through a service provider;
- provide improved administration of our websites and Services;
- improve the quality of experience when you interact with our websites and Services;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account is created;
- send you administrative e-mail notifications, such as Account activity, transaction processing, security or support and maintenance advisories;
- identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;
- notify you about important changes to our Terms and Conditions or Privacy Policy; and respond to your inquiries or other requests.

COG uses IP addresses to make our website and Services more useful to you, and to perform identity verification.All data collected automatically will be used to administer or improve our Services.

COG uses IP addresses to make our Website and Services more useful to you, and to perform identity verification.COG uses information from log files to analyze trends, administer the Services, track users’ movements around the Services, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.

COG may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience with our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.

COG may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content and navigation of our Services.

COG reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.

COG may collect data that is necessary to identify, examine, and prevent fraud, cheating and other violations of our Terms and Conditions and applicable laws ("Violations"). This data is used only to identify, examine, and prevent violations. Such data will be retained for the minimum amount of time required to fulfill this purpose. If the data shows that violations have occurred, we will retain the data further to establish, exercise, or defend any legal claims during the applicable statute of limitations or until the legal case or a related legal case has been resolved. This data may not be disclosed to you if such disclosure will adversely affect our efforts to identify, examine, and prevent violations.

Unless the law specifies a different retention period, we will only keep your Personal Data for the time strictly necessary to carry out the operations for which said Data has been collected by us.

In principle, we destroy the Personal Data without delay after the purpose of collection and use of Personal Data is achieved. However, this is not the case when preservation is required according to laws and regulations.

The destruction procedure and method are as follows:
- Personal Data printed on paper: shredded with a shredder or incinerate
- Personal Data stored in electronic file format: Deleted using a technical method that cannot reproduce the record.

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:We may use your Personal Data to form a view on what Services we think may be of interest to you. You will receive marketing communications from us if (i) you have requested information from us; or (ii) use our Services, in each case, you have chosen to opt-in and not opted out of receiving marketing communications.

We may transfer or otherwise make available your Personal Data to authorized third parties, including affiliates, and associate partners/business partners. We will get your express opt-in consent before we share your Personal Data with any company outside of COG for marketing purposes.

You acknowledge by providing your personal information in connection with receiving services from COG, that you have an established business relationship with COG. As such, you provide COG with express consent to contact you using your personal information for all matters relative to your services with COG. This may include the use of auto-dialled or pre-recorded telephonic communications for operational communication, which may include the verification of your personal information, the collection of a debt, or any other necessary communication or confirmation in connection with any element of your ongoing service with COG. You further acknowledge that this established business relationship may extend beyond the standard eighteen months from the last transaction standard. You understand that services with COG may not have such a transaction within eighteen months, but that the relationship will still be considered as ongoing due to the specific nature of COG services. The established business relationship which is created upon the initiation of services, and the providing of personal information to COG shall continue for five years following the providing or updating of any personal information in connection with your services with COG. With respect to sales and marketing from COG specifically, you understand that the same existing business relationship standard applies.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us. However, where you opt out of receiving marketing messages, this will not apply to Personal Data provided to us as a result of your use of our Service, a product/service experience or other transactions. Further, COG Games is not responsible for the collection and use of your Personal Data by any Company outside of COG Games. COG Games assumes no liability whatsoever for any disclosure of Personal Data due to unauthorized third-party access or other acts of third parties, or any other acts or omissions beyond the reasonable control of COG Games.

How we Share your Information – Personal Data shared with third parties.

‍We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

It may be necessary to disclose your Personal Data to comply with any legal obligation, to defend or investigate any illegal or suspected violations of COG’s Terms and Conditions, to enforce our Terms and Conditions and this Privacy Policy, or to protect the rights, safety, and security of COG, our users, or the public.

We may share your Personal Data with third party service providers to provide you with the Services; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and to verify your identity. These third party service providers are required not to use your Personal Data other than to provide the services requested by you.We may share some or all of your Personal Data with third parties (e.g. the purchaser or new owner) in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires COG assets, that company will possess the Personal Data collected by COG and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

Our Services may contain links to other third party or external affiliates’ websites, extensions, and resources which are regulated by their own privacy policies. COG is not responsible for the privacy policies of these third party websites even if they were accessed using the links from our Services.

We do not have any control or authority over the contents of those sites, extensions or resources provided by third parties or external affiliates, and accept no liability for any losses caused by them, if you access or use any of the third-party links, extensions or resources. It is solely at your own risk and you will be subject to third parties’ separate terms and conditions of use.Other than as stated in this Privacy Policy, COG does not disclose any of your Personal Data to third parties unless required to do so by law enforcement, court order, or in compliance with legal reporting obligations.

Transfers outside of the EEA 

‍We may share your Personal Data within COG and other companies that assist in providing COG Services which are based in various locations globally. If you are based in Europe, this will involve transferring your data outside the European Economic Area (EEA). In addition, many of our external third parties are also based outside of the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA. We may transfer personal data from EEA to third countries outside of EEA, under the following conditions:

‍Contractual Obligation: Where transfers are necessary to satisfy our obligation to you under our EULA, including to provide you with our services and customer support services, and to optimize COG Games; and

‍Consent: where you have consented to the transfer of your Personal Data to a third country.

Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

- In respect of transfers to entities in the US, we may transfer Personal Data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Data Transfers
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- Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA. If you wish to be informed about what Personal Data we hold and want it removed from our systems, please contact us at support@circleofgames.com

‍Updating Information

‍You can update your personal or account information by contacting our support team at support@circleofgames.comWe will retain your information for as long as your Account is not closed or as needed to provide you access to your Account.

If you wish to close your Account, open a ticket in our support center. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our Terms and Conditions.

Cookies

‍We collect web browser information in order to enhance your experience on our Services and track how the Services are being used. Cookies are small data files that are stored on your computer’s hard drive, and in addition to using cookies to provide you with a better user experience, we use cookies to identify and prevent fraudulent activity. The information collected can include, but is not limited to, your IP address, referral URLs, the type of device you use, your operating system, the type of browser you use, geographic location, and other session data. Cookies are not permanent and will expire after a short time period of inactivity. You may opt to deactivate your cookies, but it is important to note that you may not be able to access or use some features of our Services. Please note that COG is not responsible and cannot be held liable for any loss resulting from your decision or inability to use such features.

Security of Information

‍We take the protection of your Personal Data seriously. We use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your Personal Data. However, please note that no transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. Additionally, we aim to enforce internal regulations and rectify issues as soon as they are discovered.

‍Legal Rights Concerning Your Information

‍Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which are set out in more detail below:

Request Access:  This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request Correction: If you need to add or change any information, you can log into your Account and make the change in your settings. If it doesn’t look like you can make the change on your own, please reach out to us at support@circleofgames.com and we make work to correct any errors.

Request Deletion: This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with applicable law.

‍Please note: your right of deletion would not apply for various reasons including if we need to retain your Personal Data in order to comply with a legal obligation or to establish or defend a legal claim. Where we are unable to comply with your request of deletion, we will notify you at the time of your request.

Object to processing: You have the right to object to the processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of Processing: This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
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(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to delete it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request to Transfer: If you ask us, we will provide you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdrawal of Consent: This applies where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.If you withdraw your consent, we may not be able to provide certain products or Services to you. We will advise you if this is the case at the time you withdraw your consent.If you wish to exercise any of the rights set out above, please contact us at support@circleofgames.com 

Accessing your Information

‍You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your rights to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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Children’s Privacy

‍Unfortunately, if you’re under 18, you cannot use our Services without parental consent. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with Personal Data without verification and parental consent, we will work to delete it immediately.

Limitation of Liabilities

‍COG makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents available through our Services and expressly disclaims liability for errors and omissions in the contents available through our Services. No warranty of any kind, implied, expressed or statutory, including but not limited to the warranties of non-infringement of third-party rights, title, merchantability, fitness for a particular purpose and freedom from computer virus, is given with respect to the contents available through the site/platform or its links to other internet resources as may be available to you through the site/platform or our Services.

Contact Us

‍If you have any queries or complaints about our collection, use or storage of your Personal Data, or if you wish to exercise any of your rights in relation to your personal information, please contact us at : support@circleofgames.com We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your Personal Data.Based on the applicable laws of your country, you may have a right to request access to the Personal Data we collect from you, change, or delete the Personal Data. To request the review, update or removal of your Personal Data, please contact us at; support@circleofgames.com 

Last Updated: November 29, 2023

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