Privacy Policy for BetCircle

Version: 1.0

As of: 2026-03-14

Language: English

1. Data Controller

The data controller within the meaning of the GDPR is:

-BetCircle

-GbR

-Gundelsheimerstrasse 51, 70437 Stuttgart

-info@bet-circle.com

-BetCircle (Data Protection)

2. Scope of this Privacy Policy

2.1 This privacy policy explains the type, scope and purposes of processing of personal

data when using the app "BetCircle", related backend services and associated

marketing, website and communication activities.

2.2 Personal data means any information relating to an identified or identifiable natural

person. The Service is directed at users who are of age (at least 18 years).

2.3 We do not process personal data of persons under 18 years of age; use is permitted

only to persons of full age. Accounts of minors may be deleted as soon as we become

aware of their minority.

3. Categories of Data

Depending on use, we process in particular:

-Account and master data

-Profile data

-Content data

-Bet-tracking and performance data

-Communication and support data (e.g. email correspondence, newsletter, system

emails, service communication)

-Usage and technical data (e.g. device information, logs, timestamps, IP address, login

times/logs, security monitoring)

-Transaction and subscription data

-Consent and preference data

4. Legal Bases

Processing is in particular on the basis of Art. 6(1)(a), (b), (c) and (f) GDPR (for (f) e.g. IT

security, abuse prevention, fraud and spam prevention, product improvement).5.Registration, Login and Account Management

We process the necessary account data for authentication, account security and

provision of the user account (Art. 6(1)(b) GDPR).

6. Profile Functions and Social Interactions

When using social functions (posts, comments, reactions, follows) we process the

necessary content and interaction data (Art. 6(1)(b) GDPR; moderation additionally (f)).

The following may in particular be publicly visible: profile information (e.g. username,

display name, bio, profile/banner image, where applicable website), published posts,

comments and reactions, and statistics or performance metrics (where released by the

user or shown in the app).

7. Bet Tracking and Performance

We process bet data entered or imported by the user to provide tracking and analysis

functions (Art. 6(1)(b) GDPR).

8. Image Processing, OCR and AI

For image import/OCR, image and recognised text data may be processed; depending

on the function also by external service providers. External AI service providers may act

as processors or independent controllers depending on the specific service used.

9. Notifications

We process notification data for in-app and where applicable push functions.

10. Subscriptions and Payments

For paid services we process subscription- and transaction-related data (e.g. contract

performance, invoicing, contract communication); payment processing may be via

external platforms.

11. Marketing, Advertising, Affiliate, Cookies and Tracking

We may use advertising and affiliate links. Where we use tracking or analytics (e.g.

usage statistics, error/performance analysis, where applicable personalised

advertising), these serve to improve the Service and user experience. Collection only

with consent (Art. 6(1)(a) GDPR) where not necessary for operation. Users may withdraw

consent at any time with effect for the future (see Data Subject Rights and contact).

Further information on cookies and tracking technologies may be provided in a separate

cookie policy.

12. Recipients and Processors

Data may be transferred to the following categories: cloud hosting and databases, AI

and OCR service providers, image hosting services, push notification providers,

platform and payment providers, analytics and evaluation tools (where used), sports

data providers, IT security/logging/monitoring service providers. We conclude required

data processing agreements.13. Transfers to Third Countries

Transfers of data to third countries (e.g. USA) may take place where technical service

providers are located there. This is only in accordance with the requirements of GDPR

Arts. 44 ff; we use appropriate safeguards such as EU standard contractual clauses

(and where applicable supplementary measures) where no adequacy decision exists.

14. Storage Period and Deletion

We store data only for as long as necessary or as required by law and delete or

anonymise thereafter. Users may request deletion of their account at any time via the

in-app function.

15. Data Security

We take appropriate technical and organisational measures to protect personal data.

For system security and abuse detection we process inter alia IP addresses and

access/login logs (Art. 6(1)(f) GDPR).

16. Data Subject Rights

Rights of access, rectification, erasure, restriction, data portability, objection and

withdrawal exist under the GDPR.

17. Right to Complain

Users may lodge a complaint with a data protection supervisory authority (Art. 77

GDPR).

18. Provision of Data / Automated Decisions

Certain data is required for core functions. Solely automated decision-making within

the meaning of Art. 22 GDPR does not take place unless otherwise indicated.

19. Changes to this Privacy Policy

We may update this privacy policy when legal, technical or organisational

circumstances change.

20. Contact for Data Protection

Contact for data protection enquiries:

-BetCircle

-info@bet-circle.com

-Gundelsheimerstrasse 51, 70437 StuttgartTerms and Conditions

Terms and Conditions (T&C) for BetCircle

Version: 1.0

As of: 2026-03-14

Language: English

1. Provider and Scope

1.1 These Terms and Conditions ("T&C") govern the use of the mobile application

"BetCircle" and related services ("Service").

1.2 The provider of the Service is:

-BetCircle

-GbR

-Gundelsheimerstrasse 51, 70437 Stuttgart

-info@bet-circle.com

-VAT ID: DE461677496

1.3 These T&C apply to all users of the Service in their respective current version.

1.4 Users' deviating terms do not apply unless the provider expressly agrees to them in

writing.

2. Definitions

2.1 "User" means any natural or legal person using the Service.

2.2 "Account" means the personalised access to the Service.

2.3 "User content" means all content that users upload, create or publish, in particular

profile information, posts, comments and images.

2.4 "Subscription" means a paid, recurring service model (e.g. monthly or yearly) that

may unlock additional features.

3. Subject Matter and Scope of Service

3.1 The Service provides in particular functions for bet tracking, performance analysis,

social interactions (e.g. following, posts, comments), notifications and optional

technical support (e.g. OCR/AI-assisted import).

3.2 The concrete scope of functions may vary depending on platform, region, device,

technical availability and subscription tier.

3.3 The provider does not guarantee any particular economic success from using the

Service. 3.4 The provider may develop, restrict or discontinue functions insofar as this is

reasonable for users.

3.5 The provider is not a bookmaker. The platform does not arrange bets and does not

accept bets itself.

3.6 Gambling involves risks and can lead to financial losses. There is a risk of addiction;

if signs of problematic gambling appear, users should limit use and seek support where

appropriate. The provider recommends responsible gambling (e.g. only with funds

whose loss is affordable; no further payments to "win back" losses).

3.7 No Betting AdviceThe Service does not provide gambling recommendations, betting advice, financial

advice or investment advice. All content available on the platform, including posts,

statistics, rankings and popular picks, represents personal opinions or aggregated user

activity and does not constitute a recommendation to place bets.

3.8 Informational Purpose Only

The Service is intended for informational, analytical and social purposes only. It does

not encourage participation in gambling activities.

4. Registration, Account and Security

4.1 Use of certain functions requires registration and a user account. Use of the

platform is permitted only to persons who have reached the age of 18.

4.2 Users must provide true and current information when registering.

4.3 Access credentials must be kept confidential and must not be disclosed to third

parties without authorisation.

4.4 Users must inform the provider without delay if there is misuse or suspected misuse

of the account.

4.5 The provider may temporarily suspend or permanently disable accounts in the event

of breaches of these T&C.

4.6 Age Verification

The provider may implement reasonable measures to verify that users meet the

minimum age requirement. Accounts found to belong to underage users may be

suspended or deleted.

5. Permitted Use and Prohibited Conduct

5.1 Users may use the Service only in compliance with applicable law and these T&C.

5.2 The following are in particular not permitted:

- Distribution of unlawful, offensive, discriminatory or misleading content

- Infringement of third-party rights (e.g. copyright, trademark, personality rights)

- Technical attacks, circumvention of security measures, automated misuse

(scraping/botting)

- Manipulation of metrics, rankings or interactions

- Use of the Service for unauthorised advertising or spam

- Sale of betting tips or predictions for consideration via the platform without the

provider's express written consent

- Advertising for illegal bookmakers or other unauthorised gambling offers

- Faking bets, statistics or proof (e.g. fake bet slips)

- Insults, targeted harassment, fraud or other abusive community behaviour

- Reverse engineering, decompilation or systematic circumvention of technical

restrictions of the platform or APIs (unless permitted by law)

- Unauthorised use of APIs (e.g. bulk requests, use outside the terms of use,

circumvention of access or rate limits)

- Automated use (bots, scripts, scraping) except in cases expressly permitted by the

provider

5.3 In the event of breaches, the provider may remove content, restrict functions or

suspend accounts.5.4 The provider does not verify or guarantee the quality, legality or profitability of

betting-related content offered by users (free or paid). Users act independently and at

their own risk when offering or purchasing such content.

6. User Content and Rights

6.1 Users remain the owners of their user content.

6.2 Users grant the provider a simple, worldwide, non-exclusive, sublicensable right

limited to the duration of use to host, store, reproduce, process technically and display

user content within the Service insofar as this is necessary to provide the Service.

6.3 Users warrant that they have all necessary rights in uploaded content.

6.4 The provider is entitled to remove unlawful or T&C-violating content.

6.5 Users and third parties may report unlawful or T&C-violating content to the provider

(contact: info@bet-circle.com or via in-app functions where available). The provider will

review valid reports within a reasonable time and act in accordance with legal

requirements (in line with the Digital Services Act (DSA) where applicable). Unlawful or

T&C-violating content may be removed without prior hearing of the author; there is no

obligation to remove content in the case of manifestly unfounded reports.

6.6 No General Monitoring Obligation

The provider is not obliged to actively monitor user content. However, upon becoming

aware of illegal content, the provider will act promptly to remove or disable access in

accordance with applicable laws.

7. Bet Tracking, Data and Recommendations

7.1 The Service serves to document, analyse and present betting-related information in

a social context.

7.2 The Service does not provide legal, tax, financial or investment advice.

7.3 The Service does not warrant the accuracy, completeness or timeliness of user-

generated information or external data sources. The Service may use external data

sources (e.g. sports data APIs, odds or third-party statistics); the provider gives no

guarantee and accepts no liability for the accuracy, completeness, timeliness or

availability of these sources. The provider is not the provider of this external data; use is

subject to the licences or terms of use of third parties. 7.4 Users are solely responsible

for decisions on bets or financial stakes.

7.5 Where the Service offers rankings, leaderboards or similar ordering (e.g. top bettors,

performance overviews), the underlying criteria (e.g. metrics, time periods, weighting)

are made transparent in the app or product description or explained on request. No

guarantee is given for completeness or real-time accuracy of rankings.

7.6 No Recommendation through Rankings

Rankings, leaderboards, statistics and popular picks are based on aggregated user data

and activity. They are provided for transparency and informational purposes only and do

not constitute recommendations or endorsements of any betting decisions.

7.7 User-Generated Data

The provider does not guarantee the accuracy, completeness or authenticity of user-

submitted betting data. Users are solely responsible for the content and correctness of

the information they provide.8. Paid Services, Subscriptions and Withdrawal

8.1 The provider may offer paid features or subscription models. Prices, terms and

scope are shown transparently before conclusion.

8.2 Subscriptions renew automatically for the chosen term unless cancelled in due

time.

8.3 Users can manage and cancel in-app subscriptions within the app or via the

respective app store account (e.g. Apple App Store, Google Play Store).

8.4 Fees already paid are non-refundable subject to mandatory legal provisions.

8.5 Where consumers have a statutory right of withdrawal, the statutory rules apply.

8.6 If the consumer expressly requests immediate performance of digital services, the

right of withdrawal may lapse early under the statutory conditions.

9. Payment Processing

9.1 Payments may be processed via external payment or platform providers.

9.2 The terms of the respective payment service providers or app stores may also apply

to payment processing.

9.3 The provider is not responsible for uninterrupted availability of external payment

services.

10. Advertising and Affiliate Links

10.1 The provider may display advertising, sponsorship notices or affiliate links within

the Service.

10.2 The provider may receive commission for qualified actions via affiliate links.

10.3 Statutory labelling requirements for advertising remain unaffected.

10.4 Third-Party Services

Affiliate links may redirect users to external gambling providers or third-party services.

The provider has no influence over these services and assumes no responsibility for

their legality, content, availability or operations. Users access such services at their own

risk.

11. Availability, Maintenance and Changes

11.1 The provider endeavours to ensure high availability of the Service but does not

guarantee uninterrupted access.

11.2 Maintenance, security updates, developments and technical faults may lead to

temporary restrictions.

11.3 The provider may adapt the Service or individual functions for objective reasons,

provided users' legitimate interests are duly taken into account.

12. Liability

12.1 The provider is liable without limitation for intent and gross negligence.

12.2 For simple negligence the provider is liable only for breach of essential contractual

obligations and only up to typically foreseeable damage.

12.3 Liability limits do not apply to injury to life, body or health or to mandatory statutory

liability (e.g. product liability).12.4 The provider is liable for content of users or external third parties only as provided

by law.

12.5 Use of the platform is at the user's own risk. This applies in particular to betting

decisions and resulting losses.

12.6 No Responsibility for Gambling Outcomes

The provider is not responsible for any financial losses resulting from betting activities.

All betting decisions are made solely at the user's own risk.

13. Data Protection

13.1 Information on the processing of personal data is set out in the Privacy Policy.

13.2 Where consent is required, it is obtained separately.

13.3 Rights of access and data portability (GDPR Arts. 15, 20) and the practical

modalities of data export or portability are set out in the Privacy Policy; they may be

exercised via the contact stated there.

14. Term, Suspension and Termination

14.1 The contract runs for an indefinite period and may be terminated by users at any

time, unless different rules apply to paid subscriptions.

14.2 Users may delete their account at any time via the in-app function.

14.3 The right to terminate for good cause remains unaffected.

14.4 After the end of the contract, access to account- and function-related data may be

restricted or ended as permitted by law.

15. Changes to these T&C

15.1 The provider may amend these T&C with effect for the future where there is an

objective reason (e.g. legal changes, security requirements, function changes).

15.2 Users will be informed of material changes in an appropriate manner.

15.3 Where required by law, express consent will be obtained.

16. Applicable Law and Dispute Resolution

16.1 The law of the provider's country applies, excluding the UN Convention on

Contracts for the International Sale of Goods, unless mandatory consumer protection

rules of the user's country of residence provide otherwise.

16.2 For consumers, the statutory place of jurisdiction applies.

16.3 For businesses and legal entities, the provider's seat may be agreed as place of

jurisdiction where permitted by law.

16.4 Consumers may use the European Commission's online dispute resolution

platform (EU Regulation 524/2013). Further information:

https://ec.europa.eu/consumers/odr

17. Final Provisions

17.1 If individual provisions of these T&C are or become invalid in whole or in part, the

validity of the remaining provisions is unaffected.

17.2 The invalid provision is replaced by the statutory rule.Legal Notice

Legal Notice / Imprint BetCircle

This page contains the information required by law about the service provider (imprint

under TMG § 5 / DDG).

Provider

-BetCircle GbR

Address

-Gundelsheimerstrasse 51

-70437 Stuttgart

-Germany

Contact

-Email: info@bet-circle.com

VAT ID 

-VAT ID No.: DE461677496

Responsible for Content

Responsible for journalistic-editorial content pursuant to § 18(2) MStV (German

Interstate Media Treaty):

- Engin Diyar Aydin, Markomannenstr. 35, 70435 Stuttgart and

- Emre Kandemir, Gundelsheimerstr. 51, 70437 Stuttgart

Online Dispute Resolution

Consumers may use the European Commission's online dispute

resolution platform (EU Regulation 524/2013). Further information:

https://ec.europa.eu/consumers/odr