Privacy Policy

 

Clerkwell Partners Incorporated (“we” or “our” or “Clerkwell Partners” or “Clerkwell”) have a responsibility to protect and respect your privacy and look after your personal data and are committed to providing our Users with the utmost in privacy and security as they visit our Website at https://clerkwellpartners.com and access our Services through any mobile application (together, “Website”).  We abide by all industry guidelines and monitor our systems, processes, management, and operating methods to maintain the highest commercial standards.

When you use our Website, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of our service offering.

This Privacy Policy explains what personal data we collect, how we use your personal data, reasons we may need to disclose your personal data to others and how we store your personal data securely.

Updates to this Privacy Policy

We reserve the right to modify this Policy statement at any time, without prior notice, by updating this page on our Website.

Who are we?

Clerkwell Partners is a partner-led consultancy that provides end-to-end strategic support to the iGaming sector—helping operators, investors and platforms unlock value, navigate complex markets and drive outcomes.

We are a company registered under the laws of British Virgin Islands with BVI company number: 2181094, having its registered address situated at Intershore Chambers, Road Town, Tortola, British Virgin Islands.

Personal Data

For the purpose of the UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018 (the Act), personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How the law protects you

Data protection laws state that we are only able to process personal data if we have valid reasons to do so. The basis for processing your personal data includes, but is not limited to, your consent, performance of an agreement, to enable billing and remittance, and to contact you for client service purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

How we may receive information about you

We may collect and process the following data about you:

(a) Information you give us. You may give us information about you by:

(i) filling in forms on our site  https://clerkwellpartners.com (our site);

(ii) subscribing to our newsletter with your email address;

(iii) uploading and posting reviews to our Website;

(iv) registering to upload and post content to our forum;

(v) participating in any other social media functions;

(vi) providing feedback;

(vii) completing a survey for research purposes;

(Viii) notifying us of a problem with our Website; or

(ix) corresponding with us by phone, post, e-mail or otherwise

Usage Information: We collect information about your interactions with our Website such as the pages or content you view, your searches for information, messages between parties, requests created and other actions on the Website.

Log Data and Device Information: We automatically collect log data and device information when you access and use our Website. That information includes, among other things: details about how you’ve used our Website (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using our Website.

Cookies and Similar Technologies: We use cookies and other similar technologies when you use our Website or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers.  In many cases the information we collect using cookies and other tools is only used in a non-identifiable without reference to personal information. For example, we may use the information we collect to better understand website traffic patterns and to optimize our Website experience. In some cases, we associate the information we collect using cookies and other technology with your personal information.

Geo-location Information: When you use certain features of the Website, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. Clerkwell Partners may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

Pixels and Software Development Kits (SDKs): Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. For apps, that third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads.  Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting info@clerkwellpartners.com with a description of your request and validation information.

For more information on our use of these technologies, see our Cookie Policy.

Information that we collect

(a) When you visit our Website, you may be asked to provide information that:

may include your name and title, address, e-mail address and phone number, personal description, preferences, and payment information (such as credit or debit card information) to enable billing and remittance.

(b) When you visit our Website, we may automatically collect the following:

(i) technical information, including the internet protocol (IP) address used to connect your computer to the internet, your browser type and version, time zone setting, browser plug-in types and versions, operating system and Platform;

(ii) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

(iii) information about you from the messages you post on the Website, including but not limited to messages you send, forms you complete, files you upload, and your communications with us via email and SMS.

(c) Information we receive from other sources. We may receive information about you as a result of your use of any other websites we operate or other services we provide. We may also receive information about you from third parties who we work closely with.

(d) If you provide us with personal data about a third party, you warrant that you have obtained the express consent from the third party for the disclosure and use of their personal data.

(e) We may ask for your payment information, such as debit or credit card details. All payment card information is handled by a third party. We do not handle any payment card information ourselves and are not PCI compliant.

How we use Cookies

Please read our separate Cookie Policy.

Use of information and data

For all Users, we use the information held about you:

(a) to enable us to provide you with access to the relevant parts of the Website and to supply the services you have requested;

(b) to improve our Website and to ensure that the content is presented in the most effective manner for you;

(c) to deal with enquiries and carry out our obligations arising from any contracts entered into between you and us;

(d) to administer accounts, process payments and keep track of billing and payments;

(e) to provide you with the information, products and services that you request from us;

(f) to send you our monthly newsletter (only if you have expressly opted-in);

(g) to periodically send promotional emails about new products and services, special offers or other information which we think you may find interesting using the email address which you have provided (only if you have expressly opted-in);

(h) to contact you for market research purposes to review, develop and improve our Website, our products and our services;

(i) if you are an existing user, we will only contact you by electronic means (e-mail) with information about goods and services related to our services. If you are a new user, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

Information and Data Usage:

New Clients

• Your Identity documents will allow us to comply with Know Your Customer (KYC) legislation.
• Your financial payment details will allow us to send invoices, pay refunds and ensure that contracts are carried out.
• We may retain personal data in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, and assist with any investigations and take other actions as permitted by law.

We have set out, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Personal Data Category	Activity/Purpose	Lawful basis for processing
Personal details including name, company and contact information	To enable us to respond to the submission of forms on the Website and manage and process transactions and our relationship with you. We also use contact information to deliver notifications and relevant marketing materials.	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (e.g., to recover debts due to us). (c) Necessary for our legitimate interest (e.g., to develop and grow our business).
Credit card information and payment details	To facilitate transactions and the payment of services.	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (e.g., to be able to take payments for the services we provide and facilitate).
Location details	To enable us to fulfil our contract in delivering services and to allow us to invoice for commencement fees. Anonymised location data is also used to aid us in understanding our user base through analytics.	(a) Performance of a contract with you. (b) Necessary for our legitimate interests (e.g., to be able to provide and take payments for services).
Electronic identification data including IP address and information collected through cookies	To enable us to analyse the use of the Website and help improve the Website’s usability.	(a) Necessary for our legitimate interest (e.g., to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
Contractual details including the goods and services provided	To enable us to facilitate transactions correctly and to fulfil our legal obligations to keep financial records.	(a) Performance of a contract with you. (b) To meet our legal obligations.
Device and browser details	To help us improve the Website’s usability.	(a) Necessary for our legitimate interest (to enable us to keep our Website updated and relevant, and improve its usability).

 

Please Note: We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Sharing your information

We may share your personal information with any other member of our group, which means our subsidiaries, our holding company, and its subsidiaries.

We may also share your information with selected third parties including our business partners and suppliers, advertisers and advertising networks, and analytics and search engine providers. They are not allowed to contact you unless for marketing purposes unless you have given permission for them to do so.

We may disclose your personal information to third parties if we sell or buy any business or assets, or if we are under a duty to do so in order to comply with any legal obligation; or in order to enforce or apply our terms of use; or to protect the rights, property, or safety of Clerkwell Partners, our customers, or others.

We may use the information that you provide to us if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation; or in order to enforce our Website Terms and any other agreement, or to prevent fraud.

In the event that we sell any or all of our business to a buyer, or enter into a joint venture with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

By using our Website, you agree to us using your personal information in this way.

Storage of your data

We will process (collect, store and use) the information you provide in a manner compatible with UK GDPR and the Act. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure. We do not carry out automated decision making or profiling. We follow accepted standards to store and protect the personal data we collect, including the use of encryption if appropriate.

• We will keep your information for 5 years from the last date on which you have been active on our Website.
• We may retain records where necessary to fulfil our regulatory or statutory duties.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.

By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Security

The Act and UK GDPR requires us to implement appropriate technical measures to protect data. We verify the identity of any individual who requests access to data before granting access. We use Transport Layer Security (TLS, also known as SSL) to encrypt any data you supply to us through our Website.  All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Data breaches

In the event of a data breach, we shall ensure that our obligations under applicable data protection laws are complied with where necessary.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will collect express consent from you if legally required prior to using your personal data for marketing purposes. All information that may be used for marketing purposes is collected on a strictly opt-in basis. You can opt-out at any time by contacting us at info@clerkwellpartners.com

If you have submitted your email in order to receive our newsletter, you can use the “Unsubscribe” link at the bottom of that newsletter if you no longer wish to receive it.

 

In addition, UK GDPR and the Act provides you with the following rights. To:

• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party in certain formats, if practicable.
• Make a complaint to a supervisory body which in the United Kingdom is the Information Commissioner’s Office. The ICO can be contacted through this link: https://ico.org.uk/concerns/

Please do inform us if you think we are retaining or using your personal data incorrectly.

Links to other sites

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to Information and updating your data

You must maintain the accuracy of your information and ensure all your details, including but not limited to, name, address, title, phone number, e-mail address and payment details are kept up to date at all times. You may email info@clerkwellpartners.com or write to Clerkwell Partners Incorporated, Intershore Chambers, Road Town, Tortola, British Virgin Islands, with any requests to update your information.

You have the right to access the information we hold about you. Please contact us so that we can obtain this information for you.

Changes to our Privacy Policy

Last update: July 2025

Any changes we make to our privacy notice in the future will be posted on the Website and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.

Contact

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to info@clerkwellpartners.com