Last Updated: 14 October 2026
1. Introduction and Who We Are
This Privacy Policy explains how LEARNHARBOR UK LTD ("we", "us", "our") collects, uses, and protects your personal data when you visit or use our website and social casino-style games (the "Service"). We are the data controller for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
Our Details:
Company Name: LEARNHARBOR UK LTD
Company Number: 16834957
Registered Office: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF
Contact for Data Protection Matters: support@goldenfoxstudio.com
For data protection enquiries, email support@goldenfoxstudio.com.
Important Notice Regarding the Nature of Our Service:
Our Service provides social casino-style games for entertainment purposes only. Game Coins may be purchased with real money, but games do not offer cash prizes or cash-out. Virtual coins, chips, and other in-game items cannot be exchanged for real money or anything of monetary value. You must be at least 18 years of age to access or use the Service. We do not knowingly collect personal data from anyone under the age of 18.
2. The Personal Data We Collect
We may collect and process the following categories of personal data about you:
A. Information You Provide Directly:
Account Registration Data: Name, username, email address, password, and date of birth (for age verification purposes).
Profile Information: Display name, avatar, and any other information you choose to add to your profile.
Community play: Your display name, weekly Circuit score and poker table presence are visible to other players. Your poker hole cards remain private during a hand and may be shown to the other players at your table after showdown.
Payment Information: When you buy Game Coins, we collect the billing name, phone number and address you enter at checkout, together with the purchase amount and payment status. Card details are entered on the payment provider's secure page; we do not receive or store full card numbers on our servers.
Communications: Information you provide when you contact us, submit a support request, or participate in surveys, promotions, or community features (such as chat or forums).
B. Information Collected Automatically:
Technical Data: IP address, browser type and version, device type and model, operating system, and unique device identifiers.
Usage Data: Information about how you interact with the Service, including game activity, session duration, pages viewed, features used, and in-game purchase history.
Location Data: General geographic location derived from your IP address (at a country or city level).
C. Information from Third Parties:
Social Media Login: If you choose to register or log in via a third-party social media platform, we may receive certain information from that platform in accordance with your privacy settings on that platform (e.g., your name, email address, and profile picture).
3. How We Use Your Personal Data and Our Lawful Bases
We process your personal data for the purposes set out below. For each purpose, we have identified the lawful basis under Article 6 of the UK GDPR upon which we rely.
To provide the Service: We process Account Data, Profile Information, Payment Information, Technical Data, and Usage Data for creating and managing your account, enabling gameplay, processing purchases of virtual currency, and providing customer support. Lawful basis: Performance of a Contract (Art. 6(1)(b)).
To ensure age compliance: We process Account Data (date of birth) for verifying that users are 18 or over, as required by our Terms of Service and applicable standards for social casino products. Lawful basis: Compliance with a Legal Obligation (Art. 6(1)(c)) and Legitimate Interests (Art. 6(1)(f)) — ensuring our Service is not accessed by minors.
To improve and personalise the Service: We process Technical Data and Usage Data for analysing usage patterns, troubleshooting technical issues, and developing new features. Lawful basis: Legitimate Interests (Art. 6(1)(f)) — improving our Service and user experience.
To send you marketing communications: We process Account Data (email address) and Usage Data for informing you about new games, features, promotions, or offers that may be of interest (only where you have opted in). Lawful basis: Consent (Art. 6(1)(a)) — you may withdraw consent at any time.
To ensure the security and integrity of the Service: We process Technical Data, Usage Data, and Account Data for detecting and preventing fraud, cheating, abuse, or other illegal activity. Lawful basis: Legitimate Interests (Art. 6(1)(f)) — protecting our Service and users from harm.
To comply with legal and regulatory obligations: We process any data as required for responding to lawful requests from authorities and maintaining records as required by law. Lawful basis: Compliance with a Legal Obligation (Art. 6(1)(c)).
Legitimate Interests:
Where we rely on legitimate interests, we have conducted a balancing test to ensure that our interests do not override your rights and freedoms. You have the right to object to processing based on legitimate interests (see Section 8).
4. Cookies and Similar Technologies
We use cookies and similar tracking technologies to operate and improve the Service, analyse usage, and (where you consent) personalise content and marketing. For detailed information about the cookies we use and how you can manage your preferences, please see our Cookie Policy.
Consent for Non-Essential Cookies:
We will obtain your consent before placing any non-essential cookies (such as analytics or advertising cookies) on your device. You can withdraw your consent at any time through our cookie preference centre or your browser settings. Withdrawing consent will not affect the lawfulness of processing carried out before withdrawal.
5. Who We Share Your Personal Data With
We may share your personal data with the following categories of recipients:
Service Providers and Processors: Third-party companies that provide services on our behalf, including cloud hosting and infrastructure providers; payment processors (for in-app purchases); analytics providers; customer support platforms; email and marketing service providers (where you have consented to marketing); and fraud prevention and security services. All processors are bound by written contracts that require them to protect your data and process it only in accordance with our instructions.
Professional Advisers: Legal, accounting, and insurance advisers where necessary for the operation of our business.
Law Enforcement and Regulatory Authorities: Where we are required by law to disclose information, or where disclosure is necessary to protect our rights, property, or the safety of our users or others.
Business Transfers: In the event of a merger, acquisition, or sale of all or part of our assets, your personal data may be transferred to the acquiring entity, subject to standard confidentiality protections.
We do not sell your personal data to third parties.
6. International Transfers
Some of our service providers may be located outside the United Kingdom. Where we transfer your personal data to a country that has not been deemed to provide an adequate level of data protection by the UK Secretary of State, we will ensure that appropriate safeguards are in place, such as:
The UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses; or
Reliance on an exemption permitted under UK data protection law.
You may request a copy of the relevant safeguards by contacting us using the details in Section 1.
7. How Long We Keep Your Personal Data
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.
Account registration and profile data: Active account data is retained while your account is open. Inactive accounts are deleted after 24 months of inactivity.
Transaction and purchase records: Retained for 6 years after the transaction, as required for tax and accounting purposes.
Customer support communications: Retained for 3 years after the enquiry is resolved.
Technical and usage logs: Retained for 12 months.
Marketing consent records: Retained until you withdraw consent, plus 12 months for audit purposes.
When retention periods expire, we will securely delete or anonymise your personal data.
8. Your Rights Under the UK GDPR
You have the following rights in relation to your personal data:
Right of Access: You can request a copy of the personal data we hold about you.
Right to Rectification: You can ask us to correct any inaccurate or incomplete personal data.
Right to Erasure ("Right to be Forgotten"): You can ask us to delete your personal data in certain circumstances (e.g., where it is no longer necessary for the purpose it was collected).
Right to Restrict Processing: You can ask us to limit how we use your data in certain circumstances.
Right to Data Portability: You can request that we provide your data in a structured, commonly used, machine-readable format, or transmit it to another controller, where technically feasible.
Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we have compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defence of legal claims.
Right to Withdraw Consent: Where we rely on consent, you can withdraw it at any time. Withdrawal will not affect the lawfulness of prior processing.
How to Exercise Your Rights:
To exercise any of these rights, please contact us using the details in Section 1. We will respond to your request within one month, although this period may be extended by a further two months for complex or numerous requests. We may ask you to verify your identity before processing your request.
Right to Complain:
You have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you are unhappy with how we have handled your personal data. You can contact the ICO at:
Website: https://ico.org.uk
Helpline: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We would appreciate the opportunity to address your concerns directly before you approach the ICO.
9. Security of Your Personal Data
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
Encryption of data in transit (TLS/SSL) and at rest where appropriate;
Access controls and authentication mechanisms;
Regular security assessments and monitoring;
Staff training on data protection and information security;
Written contracts with processors requiring equivalent security standards.
While we take security seriously, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.
10. Children's Privacy
Our Service is strictly for users aged 18 and over. We do not knowingly collect or solicit personal data from anyone under 18. If we become aware that we have inadvertently collected personal data from a person under 18, we will take steps to delete that data as soon as possible. If you believe we might have any information from or about a person under 18, please contact us using the details in Section 1.
11. Automated Decision-Making and Profiling
We do not use your personal data for automated decision-making that produces legal or similarly significant effects. We may use profiling for analytics and personalisation purposes (e.g., to recommend games), but this does not have a legal or similarly significant impact on you. Where we rely on consent for any profiling, you have the right to withdraw that consent at any time.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by email or through a prominent notice on the Service. The "Last Updated" date at the top of this policy indicates when it was most recently revised.
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
13. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact us:
LEARNHARBOR UK LTD
167-169 Great Portland Street, 5th Floor
London, England, W1W 5PF
Company Number: 16834957
Email: support@goldenfoxstudio.com