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).

1. 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).
2. 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 Al For image import/OCR, image and recognised text data may be processed; depending on the function also by external service providers. External Al service providers may act as processors or independent controllers depending on the specific service used.

Automated content moderation: images you upload (in particular profile and banner pictures, posts and comments) are automatically scanned by an external content-moderation service provider (located in the EU) to detect and prevent unlawful or prohibited content, in particular sexual or pornographic imagery.

For this purpose the image is transmitted to and analysed by the moderation service provider, which acts as a processor on our behalf. The legal basis is our legitimate interest in a safe service and the protection of our users (Art. 6(1) (f) GDPR).

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, authentication and identity service providers, Al and OCR service providers, image hosting services, content moderation service providers, push notification providers, platform and payment providers, advertising service providers, analytics, error-monitoring 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. Uploaded images are subject to automated content moderation to detect prohibited content (see Section 8); an image classified as prohibited may be automatically rejected.

This does not produce legal effects concerning you or similarly significantly affect you within the meaning of Art. 22 GDPR - you can upload different content or contact us. Other 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 Stuttgart

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

- Emre Kandemir

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