Privacy Policy

1. What personal data we collect

Account data: email address, username, date of birth (18+ verification), password (hashed — we never store plain-text passwords on a production deployment).

Gameplay data: game results, Crown balances, Club Honour level, session history — anonymised after 90 days in the full product specification.

Technical data: IP address, browser type, device type, session timestamps — processed under legitimate interest (UK GDPR Art. 6(1)(f)).

Honorary Member payments: processed via a payment provider; card numbers are not stored by the Club in the intended architecture.

Communications: support emails and contact form submissions.

2. Lawful basis for processing

Consent (marketing, optional analytics cookies); contract performance (accounts, games, subscription); legal obligation (VAT records); legitimate interests (security, fraud prevention, logging).

3. Your rights (UK GDPR Arts. 15–22)

Access, rectification, erasure, portability, objection, restriction, and the right to complain to the ICO (ico.org.uk/make-a-complaint · 0303 123 1113). Contact: [email protected]. We respond within one calendar month.

4. Data retention

Account data while active; deleted within one calendar month of a deletion request. Payment records: 6 years where HMRC requires. Technical logs: 90 days in specification.

5. ICO registration

M3 Marketing Lim must register with the ICO as a data controller. ICO Registration Number: to be confirmed upon registration — see ico.org.uk/registration.

6. International transfers

Where personal data is transferred outside the UK, we ensure appropriate safeguards, including UK International Data Transfer Agreements (UK IDTAs) or equivalent mechanisms.

7. Contact

[email protected] · M3 Marketing Lim, 2-7 Clerkenwell Green, London, EC1R 0DE