The purpose of the present document is to define how CircleChess collects, shares and uses your (i.e. User’s) personal information via https://circlechess.com (the “Website”).

For the purposes of the data protection legislation, CircleChess By CircleChess India Private Limited, a company organized and existing under the laws of Karnataka with its principal place of business located at E-1103,SY NO 92 94/2, PURVA SKYWOOD, Sobha cinnamon apartment, KUDLU VILLAGE, Haralure main road, Bommanahalli, haralur, Bengaluru, Bengaluru Urban, Karnataka, 560068 (“CircleChess”, “we” or “us”) is the “data controller” (the company who is responsible for, and controls the processing of, your personal data).

If you are aged 16 or under, you must ensure that we have your parent/guardian's permission before you provide any personal information to us (including creating an account).

We consider the privacy and security of personal information of our customers and affiliates the issue of utmost importance and value, and therefore, will do everything in our capacity to safeguard it. The present policy shall be applicable to all customers applying for our products and services, as well as all mentors and other members accessing our website or using our mobile application.

We will obtain personal data about you such as your name, address, phone number, and email address when you create an account on CircleChess for purchasing digital chess content and subscriptions, as well as technical data, such as, your device type, IP address (including approximate geographic location based on IP address), operating system information, device identifiers, browser, domain and other necessary system data.

Additionally, we will obtain your personal data when you send us feedback, or contact us for any reason.

We may monitor your use of CircleChess through the use of cookies and similar tracking devices. For example, we may monitor how many times you visit, which pages you go to, traffic data and location data. This information helps us to build a profile of our users, which we use to help improve the way we deliver services to you. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. For further information on our use of cookies, please see our Use of Cookies section below.

• facilitating subscriptions, and digital chess content purchases;
• billing you;
• to help us identify you and any accounts you hold with us;
• administration;
• fraud prevention and detection;
• customising CircleChess and its content to your particular preferences;
• to notify you of any changes to CircleChess or to our services that may affect you;
• statistical analysis; and
• improving our services.

• research, and behavioural analysis;
• customer profiling and analysing your purchasing preferences;
• marketing—see Marketing and opting out, below;
• customising CircleChess and its content to your particular preferences

• access to your account is controlled by a password and username that are unique to you; and
• we store your personal data on secure servers.

• Ensure nobody else will use CircleChess while you are logged into your account (we advise our users to take extra care when using public computers/devices and to NOT leave themselves logged in; it is your responsibility to ensure this does not happen);
• Logout and exit your account on CircleChess when you are not using it, on any private and/or public computer or device; and
• Keep your password and any account details or access details secret and to yourself.

• recognise you whenever you visit CircleChess (this speeds up your access to the website as you do not have to login each time);
• obtain information about your preferences;
• carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitor requirements and interests;
• make your online experience more efficient and enjoyable.

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of CircleChess. For further information about cookies and how to disable them please go to: https://www.aboutcookies.org/ or https://www.allaboutcookies.org/

To opt out of Google Analytics, visit this webpage - https://tools.google.com/dlpage/gaoptout

The third-party vendors, including Google, whose services we use – will place cookies on web browsers in order to serve ads based on past visits to our website. – Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to your website. This allows us to make special offers and continue to market our services to those who have shown interest in our service.

If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

• give consent on his/her behalf to the processing of his/her personal data; and
• receive on his/her behalf any data protection notices.

CircleChess is a tool to help you improve your chess learning. We do not wish for CircleChess to be used for the processing of any sensitive data. Do not use CircleChess (including its messaging function) to share with any user any personal contact information like your phone number or street address. Do not use CircleChess to send or store any item revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

CircleChess does and may contain links to other websites. This Policy applies only to our website, https://circlechess.com, so when you visit other websites please read their privacy policies, as we cannot accept any responsibility for breaches or issues you may have in relation to privacy once you leave our website.

In some cases, the legal basis for the processing of your personal data is your consent. This is the case, for example, if you agree to us emailing you with marketing information.

In other cases, the processing will be necessary for the purposes of our providing you with the Services as referred to in our Terms of Use.

Also, we may process personal data in accordance with our legitimate interest in engaging in providing and developing our services to you and other users – provided that those interests are not outweighed by your rights and interests. If you think that your rights and interests do outweigh our legitimate interests in providing our services, please let us know by emailing us at support@circlechess.com

We may also process your data where:

This is necessary to allow us to comply with our legal obligations; or

If you have previously given consent to our processing your data (for example, in relation to our sending you marketing information by email) you can freely withdraw such consent at any time. You can do this by emailing us at support@circlechess.com If you do withdraw your consent, and if we do not have another legal basis for processing your information, then we will stop processing your personal data. If we do have another legal basis for processing your information, then we may continue to do so subject to your legal rights. More details about your data protection rights are set out in the Your Rights section below.

You may choose not to provide us with personal data and you may turn off cookies in your browser by changing its settings. If you make these decisions, you may continue to browse the pages of https://circlechess.com. However, we will not be able to provide you with the CircleChess service.

You have the right to ask us not to process your personal data for marketing purposes.

You have the right to access information we hold about you, together with an explanation of the categories of data being processed, the purposes of such processing, and the categories of third parties to whom the data may be disclosed.

You can also require us to provide you details of the period for which the data will be stored (or the criteria used to determine that period) and information about your other rights regarding our use of your data. We will provide you with the information within one month of your request, unless doing so would adversely affect the rights and freedoms of others. That would include, for example, another person’s confidentiality or intellectual property rights. We’ll tell you if we can’t meet your request for that reason.

If you wish to exercise this right, please send a request to support@circlechess.com.

You also have the following rights:

• The right to require us to rectify any inaccurate personal data concerning you.
• The right to be ‘forgotten’ by us and have us erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of the Service.
• The right to object to us using your data for the purposes of profiling you or making automated decisions about you. We may use your data to determine whether we should let you know information about the Service which might be relevant to you. Otherwise, the only circumstances in which we will do this is to provide you with the CircleChess service.
• The right to ask us to port your data to another service (if technically feasible) or to provide you with a copy of data we hold about you in a structured, commonly used machine-readable format so that you can provide it to them. We will do so to the extent that we are required to under applicable laws, but not to the extent that this involves disclosing data about any other individual.
• You can also exercise these rights at any time by contacting us at support@circlechess.com. To the extent that it does not involve disproportionate effort on our part, if you exercise any of the above rights we will tell any third parties to whom we have passed your data.
• You can delete your own account via the settings page

Additionally, you have the right to lodge a complaint regarding our use of your data to the supervising authorities.

We will retain personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

If we change our Privacy Policy, we will post any changes on this page. You should check this page occasionally to ensure you are happy with any changes to this policy. We will notify you of any material changes to this policy, by email and by a notification in your CircleChess account seen immediately upon login at the top right of your page.

We welcome your feedback and questions. If you wish to contact us, please send an email to support@circlechess.com.

Last update of this Privacy Policy: 01 July, 2023.