Privacy Policy
Our commitment
Circling TCG has a strong commitment to privacy and to the rights of personal data subjects, acting in strict compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council, of 27 April 2016 (GDPR) and other applicable legislation.
Privacy Policy
We want you to understand how Circling TCG processes personal data, as well as the rights you have as a data subject.
1. What is personal data and what categories of data do we process at Circling TCG?
The GDPR establishes a cross-cutting data protection framework and sets a broader definition of the concept of personal data. Personal data is any information, regardless of the format in which it was collected and the medium in which it is stored, relating to an identified or identifiable natural person.
A natural person is considered identifiable, regardless of nationality or place of residence, who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, electronic identifiers or to one or more specific elements of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Information about legal persons is only subject to the GDPR when it relates, directly or indirectly, to natural persons (for example, where the name of a partner or partners appears in the legal person’s name).
Examples of categories of personal data processed by Circling TCG include:
| Data category | Type / specific examples | Data source | Purpose of processing |
|---|---|---|---|
| Identification and Contact Data | Email; username (nickname); name (if provided); app-generated avatar; user-selected image; defined country/location; IP address; push notification identifiers | Provided by the user during registration or account settings; automatically collected (IP, notifications) | Account creation and management; authentication; communications; security; experience personalization |
| Authentication and Account Data | Password (stored in encrypted form); record of acceptance of the Terms & Conditions and guidelines (with date/time); language preferences; reference price market (TCGPlayer/Cardmarket); PRO subscription status | Provided by the user and generated by the system at the time of joining | Contract performance; proof of consent; subscription management; technical operation of the platform |
| Platform Usage Data | Card inventory; wishlist; trade history; sent/received proposals; ratings (1 to 5 stars); performance metrics; history of added cards | Generated by the user’s activity in the app | Enable core features (trades, collection management); user reputation; experience improvement |
| Communication Data | Chat messages; shared images; content posted in communities; reports with free text; block/follower history | Entered directly by the user | Enable user interaction; moderation; fraud prevention; compliance with legal obligations |
| Technical and Navigation Data | Device type; operating system; logs; errors; performance data; access records | Automatically collected by the system | Platform security; abuse prevention; technical improvement; failure monitoring |
| Location Data (non‑public) | Country/location configured to filter nearby users | Voluntarily provided by the user | Enable geographically relevant trades; result filtering |
| Subscription and Payment Data (PRO) | Subscription status; information related to automatic renewal (processed by App Store / Google Play platforms) | External payment platforms | Premium feature management; contractual compliance |
| Support Data | Communications sent to support; rights requests; complaints | Provided by the user | Respond to requests; legal compliance; complaint management |
| Moderation and Security Data | Report history; alerts for poor ratings; blocks; suspensions | Generated by the system or by other users | Ensure compliance with the Terms; community safety |
2. Who is responsible for processing your personal data?
The entity responsible for processing your personal data is PERFECTROTATION LDA, NIPC 519 451 309, with registered address at Praceta Laura Alves, n.º 2, 3.º esquerdo, 2725-206 Algueirão-Mem Martins, holder of the Circling TCG brand.
3. In what situations do we process your personal data?
At Circling TCG, we process your personal data in the following situations:
- When you create an account and register in the app or on the website;
- When you accept the Terms & Conditions and the Privacy Policy;
- When you use the platform’s features, including inventory management, wishlist creation, sending or receiving trade proposals, participating in communities, and using chat;
- When you subscribe to the PRO plan or use premium features;
- When you contact us for support, questions, or to exercise your rights as a data subject;
- When you enable certain optional settings, such as location filters or notifications;
- When you interact with the platform, allowing the collection of technical data necessary for its operation, security, and continuous improvement.
Data processing is carried out based on the user’s consent, the performance of the contract related to the use of the platform, compliance with applicable legal obligations, and Circling TCG’s legitimate interest in ensuring the security, functionality, and improvement of the service.
Processing is limited to the relationship established between Circling TCG and the platform user.
Content shared by users is their sole responsibility and may be retained for security, fraud prevention, and compliance with legal obligations.
Whenever data is transferred outside the European Economic Area, Circling TCG ensures that appropriate safeguards are adopted in accordance with the GDPR.
4. Minimum age to use the platform
The Circling TCG platform is intended for users aged 13 years or older.
If the user is under 13 years of age, the processing of their personal data may only occur with the consent of those holding parental responsibility, in accordance with applicable legislation.
Circling TCG does not systematically verify users’ age; however, it reserves the right to suspend or delete accounts where there are indications that the platform is being used in violation of this rule.
5. For what purposes do we process your personal data?
Circling TCG ensures that your personal data is processed exclusively for the purposes previously communicated and strictly necessary for the operation of the platform, namely:
| Purpose | Examples of processing |
|---|---|
| Account Creation and Management | User registration; authentication (email and encrypted password); profile management (nickname, avatar, preferences); record of acceptance of the Terms & Conditions and Privacy Policy. |
| Execution of Platform Features | Inventory and wishlist management; sending and receiving trade proposals; trade history; rating and feedback system; participation in communities; use of chat between users. |
| PRO Subscription Management | Activation of premium features; subscription status management; access control to exclusive features; integration with payment platforms (App Store / Google Play). |
| Communication with the User | Sending relevant notifications; technical communications; responses to support requests; clarification of questions; sending important information about the account or policy changes. |
| Platform Security and Moderation | Activity monitoring; fraud or abusive behavior prevention; handling reports; application of blocks or suspensions; logging of access and activity. |
| Platform Improvement and Technical Performance | Usage analysis; collection of technical data (device, operating system, error logs); optimization of user experience. |
| Compliance with Legal Obligations | Data retention for legally required periods; responses to competent authorities; compliance with applicable legal or regulatory duties. |
| Legitimate Interest of the Platform | Defense in legal proceedings; protection of Circling TCG rights; prevention of misuse of the application. |
6. Legal basis for processing your personal data?
Circling TCG may process personal data for the purposes described above, on the following legal bases:
- Consent of the data subject, where applicable, namely for sending non-essential communications, optional notifications or other features that depend on voluntary activation by the user;
- Performance of a contract, in the context of creating and using an account on the platform, including inventory management, wishlist, user-to-user trades, participation in communities, use of chat and, where applicable, subscription to the PRO plan;
- Compliance with legal obligations, namely regarding data retention, cooperation with competent authorities, or compliance with applicable legal and regulatory duties;
- Legitimate interest of Circling TCG, namely for platform security, fraud prevention, content moderation, continuous service improvement, technical performance monitoring and defense of its rights in potential legal proceedings.
Circling TCG adopts appropriate technical and organizational measures to ensure the protection of personal data against destruction, loss, alteration, unauthorized disclosure or access, as well as against any other form of unlawful or abusive processing, ensuring a level of security appropriate to the risk, under the applicable legislation.
7. How long do we keep your personal data?
Circling TCG will only keep your data for the period necessary to fulfill the purposes set out in this Policy or for the period required by applicable legal or regulatory rules, or, as the case may be, until you exercise your right to object or right to erasure. After that retention period, Circling TCG deletes your personal data.
8. To whom does Circling TCG transmit personal data?
Circling TCG does not transmit your personal data to third parties, except where this is necessary for the performance of the contract you have entered into or for compliance with legal obligations to which Circling TCG is subject.
The transmission of data to third parties is carried out in accordance with applicable data protection legislation and within the limits of the purposes and legal bases defined in this Policy.
Circling TCG may use subprocessors that process data on its behalf, namely hosting providers, analytics and security services, ensuring they act under a written contract and only according to Circling TCG instructions.
By way of example, Circling TCG may transmit personal data to payment platforms such as the App Store or Google Play, exclusively for PRO subscription management purposes.
9. What rights do you have as a data subject?
For the purposes of applying the GDPR and other applicable legislation, a data subject is any person, regardless of nationality or residence, whose data is processed within the scope of activities carried out by Circling TCG and whose data is processed under the terms and conditions of this Policy.
The main rights of the data subject are the following:
- (i) Right of access:
You may obtain, at any time, from Circling TCG confirmation as to whether personal data concerning you are being processed or not. And where that is the case, you may access the personal data and information about the processing thereof.
- (ii) Right to rectification
If your personal data is incorrect or incomplete, you may request that it be rectified or completed, including by means of an additional statement.
- (iii) Right to erasure
Provided that one or more of the legal requirements are met, you may request the erasure of your personal data, for example when the data is no longer necessary for the purpose that motivated the processing. This right may be limited in certain situations, such as when the processing is necessary to comply with legal obligations to which Circling TCG is subject.
- (iv) Right to restriction of processing
In certain cases, you may request that Circling TCG restrict the processing of your data. This may occur, for example, if you contest the accuracy of your personal data during the period in which Circling TCG verifies it, or if you have objected to the processing of your data.
- (v) Right to data portability
This right allows you to receive the personal data you provided to us in a structured, commonly used and machine-readable format. You may also request that Circling TCG, where technically feasible, transmit those data to other controllers.
- (vi) Right to object
Where processing is based on Circling TCG’s legitimate interest, or where it is carried out for purposes other than those for which the data were collected but are compatible with them, you have the right to object to the processing of your personal data on grounds relating to your particular situation.
Where processing is carried out on the basis of your consent, you may withdraw it at any time. If you withdraw your consent, your personal data will no longer be processed, unless there is another legal basis that allows such processing.
- (vii) Right not to be subject to automated individual decisions
You may request not to be subject to any decision based solely on automated processing. These decisions are related to the definition of consumption profiles by Circling TCG, based on your preferences and search history, namely to provide a quality service and tailor marketing communications.
- (viii) Right to lodge complaints with the supervisory authority
You have the right to lodge complaints with the competent supervisory authority regarding matters related to the processing of your personal data. In Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados (CNPD). For more information, visit www.cnpd.pt.
How can you exercise your rights?
You may exercise your rights through any of the following channels:
- Email: to the email address support@circlingtcg.com; or
- Letter: addressed to PERFECTROTATION LDA, Praceta Laura Alves, n.º 2, 3.º esquerdo, 2725-206 Algueirão-Mem Martins
How can you contact us?
If you have any questions or need further information regarding the processing of personal data or the rights you have as a data subject, contact us through the following channels:
- Email: to the email address support@circlingtcg.com; or
- Letter: addressed to PERFECTROTATION LDA, Praceta Laura Alves, n.º 2, 3.º esquerdo, 2725-206 Algueirão-Mem Martins
How can you stay updated regarding the processing of personal data?
The "Privacy Policy" may be updated, so Circling TCG advises you to consult this Policy regularly.
Obtain more information about the processing of personal data by consulting the "Cookie Policy", included in the Terms and Conditions of our website.
Last updated: 23 February 2026