Privacy Policy

Last updated: 4 September 2026

1. Definitions and Terminology

For the purposes of this Privacy Policy, the following terms have the meanings set out below.

"Personal Data" means any information relating to an identified or identifiable natural person. This includes data provided during registration, data generated through use of a Website, communication with support, and technical data generated through interaction with the platform, where such data may directly or indirectly identify a User.

"Company", "we", "us" or "our" refers to WESTERN COURT LIMITED, a company incorporated in England and Wales under company number 15467867, with its registered office at International House, 6 South Molton Street, London, England, W1K 5QF, acting as the data controller under the UK General Data Protection Regulation and the Data Protection Act 2018.

"Websites" means the online platforms operated by the Company at caelunix.com and Caelunix.com, through which Users access digital entertainment content, account features, support services and related functionality. Each Website is operated as a separate platform with its own Accounts and its own user records.

"User" means any individual who accesses or uses a Website, whether registered or not, including those who interact with entertainment experiences or to whom JustCoins are allocated.

"Account" means a user account created on a specific Website that provides access to additional functionality, including participation in entertainment experiences, activity history and the record of JustCoins allocated on that Website.

"JustCoins" means internal digital interaction units provided for use within a Website for entertainment purposes only. They are not money or electronic money, do not represent stored value, have no real-world value and cannot be redeemed or transferred.

"Activity Data" means data generated from a User's interaction with entertainment experiences and platform features.

"Technical and Device Data" means data automatically collected when a Website is accessed or used, including IP address, browser type, device details, operating system, access timestamps and basic system logs.

2. Introduction

The Company recognises the importance of protecting the privacy and personal data of individuals using its online entertainment platforms. Personal Data is processed in a lawful, fair and transparent manner, with appropriate technical and organisational measures in place to safeguard its confidentiality, integrity and security.

This Privacy Policy explains how Personal Data is collected, used, disclosed and retained in connection with the Websites caelunix.com and Caelunix.com. The Websites provide digital entertainment platforms offering interactive experiences accessed through internal digital interaction units known as JustCoins. JustCoins operate within a closed system and have no use outside the Website on which they were allocated. The platforms do not provide gambling services, do not involve betting or wagering, do not allow withdrawals and do not offer prizes or any form of monetary value.

For the purposes of the UK General Data Protection Regulation and the Data Protection Act 2018, the Company acts as the data controller for both Websites and determines the purposes and means of processing Personal Data collected through them and through related communications.

This Privacy Policy applies to all Users of both Websites, whether registered or not, and covers the processing of Personal Data in connection with account registration, use of entertainment experiences, the allocation and use of JustCoins, technical interaction with the Websites and communication with support.

3. Separate Platforms and Separate Records

Accounts are created separately on caelunix.com and on Caelunix.com. Registering on one Website does not create, extend or duplicate an Account on the other.

Account records, activity history and JustCoins allocations are maintained separately for each Website. The Company does not merge user profiles across the Websites, does not combine activity histories into a single profile and does not transfer Account data from one Website to the other for the purpose of creating a combined user record.

Where the same individual registers on both Websites, each Account is treated as a separate user record. Requests submitted by a User under section 8 of this Policy are handled in relation to the Website or Websites identified in the request.

Because the Company acts as data controller for both Websites, limited Personal Data may be processed across both platforms where strictly necessary for security, fraud prevention, enforcement of platform rules or compliance with legal obligations, as described in sections 5 and 7.

4. Categories of Personal Data We Collect

The Company processes only the Personal Data required to operate the Websites and provide entertainment experiences. Data collection is limited to functional and technical needs.

Account Data: When creating an Account, Users provide basic details such as first name, last name, email address, phone number and login credentials. This data is used to enable access and maintain core platform functionality.

Age Confirmation: Users confirm that they are at least eighteen (18) years old. This confirmation is based on self-declaration and is used to restrict access to the Service. Documentary verification is not required as a standard part of registration, but may be requested in the circumstances described in section 5.

Activity Data: Data generated through a User's interaction with entertainment experiences, including session activity, saved favourites, JustCoins allocation and usage, and in-platform actions. This information is required to operate and maintain the internal entertainment environment.

Transaction Reference Data: Limited payment-related data such as transaction references, timestamps, amounts and status. This is used to allocate JustCoins, handle refund requests and payment disputes, and maintain internal records. Full payment card details are processed by third-party payment providers and are not stored by the Company.

Support Data: Information provided when Users contact support, including contact details, message content and communication history. This is used to handle requests and improve service quality.

Verification Data: Where reasonably necessary to confirm age, confirm account ownership, protect an Account, prevent fraud, comply with applicable legal requirements or satisfy payment provider procedures, the Company may request additional information from a User. Such data is processed only for the purpose for which it was requested and is retained no longer than necessary for that purpose.

Technical Data: Data collected automatically during use of a Website, including IP address, browser type, device details, operating system, access timestamps and system logs. This is used for security, system performance and issue resolution, and is not used for advertising or profiling.

The Company does not knowingly collect data from individuals under eighteen (18). It does not process special category data, biometric data or precise location data, and does not carry out automated decision-making producing legal or similarly significant effects.

5. Purposes of Processing Personal Data

The Company processes Personal Data only for specific and legitimate purposes directly related to the operation of the Websites and the provision of entertainment experiences. This includes enabling access to the platforms, creation and management of Accounts, participation in experiences and the use of JustCoins within the relevant Website.

Personal Data is also used to support payment processing and the allocation and use of JustCoins as internal digital interaction units limited to in-platform entertainment, and to review refund requests and payment disputes.

In addition, the Company processes data to maintain the security, stability and proper functioning of the Websites, including system monitoring, fraud and misuse prevention, enforcement of the Terms of Service and the Fair Play Policy, and protection of platform integrity. This includes detecting attempts to operate multiple Accounts in breach of platform rules, to trade or transfer Accounts, or to link Accounts across the Websites in order to create or extract real-world value.

Personal Data is further used to enforce age restrictions by limiting access to Users who confirm they are at least eighteen (18) years old, and to handle enquiries, support requests and complaints.

Where necessary, Personal Data may be processed to comply with applicable legal and regulatory obligations, including obligations relating to sanctions, fraud prevention and record-keeping.

The Company does not use Personal Data to provide gambling services, enable betting or wagering, or offer any form of financial return. Personal Data is not used for behavioural advertising or for financial or credit assessment.

6. Data Retention

The Company retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, operate the Websites, provide entertainment experiences and comply with applicable legal and record-keeping requirements. Retention is limited to what is appropriate for a non-financial, entertainment-only service.

Account Data and Activity Data are retained for as long as the Account remains active. Following closure, restriction or termination of an Account, such data is retained only for the period necessary to resolve outstanding matters, prevent misuse and meet applicable legal obligations, after which it is deleted or anonymised.

Transaction Reference Data is retained for the period required by applicable accounting, tax and record-keeping obligations.

Support and communication data is retained for up to six (6) years from the last interaction, unless a longer period is required by law or for the resolution of a dispute.

Once the applicable retention period ends, Personal Data is securely deleted, anonymised or permanently made inaccessible using appropriate technical and organisational measures.

The Company does not retain Personal Data for behavioural profiling or financial assessment purposes.

7. Legal Basis for Processing Personal Data

The Company processes Personal Data only where permitted under the UK General Data Protection Regulation and the Data Protection Act 2018.

Processing is necessary for the performance of a contract with the User where it relates to the operation of the Websites, access to entertainment experiences, management of Accounts, allocation and use of JustCoins, payment processing and handling of refund requests.

The Company also relies on its legitimate interests, including protecting the platforms, preventing fraud and misuse, enforcing platform rules across both Websites and ensuring stable and secure operation of the Service.

Personal Data may additionally be processed where necessary to comply with legal or regulatory obligations to which the Company is subject.

Where processing is based on consent, including in relation to non-essential cookies, that consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

8. Data Subject Rights

Users are entitled to exercise their rights under applicable data protection law. These include the right to access, correct or delete Personal Data, to restrict or object to processing, and to request data portability where relevant. Where processing is based on consent, Users may withdraw that consent at any time.

Requests may be submitted using the contact details set out in this Privacy Policy and will be handled in line with applicable legal requirements. Where a User holds Accounts on both Websites, the request should identify the Website or Websites concerned.

Users may also submit a complaint to the Information Commissioner's Office, the supervisory authority for data protection in the United Kingdom.

9. Disclosure of Personal Data

The Company discloses Personal Data only in limited and defined circumstances:

• To third-party service providers supporting the technical operation, hosting, security and administration of the Websites.
• To payment service providers, limited to the data necessary to process and confirm transactions and to handle refund requests and payment disputes.
• To professional advisers where required for legal, compliance or operational purposes.
• To competent authorities where disclosure is required or permitted by law.

The Company does not sell, rent or otherwise commercially exploit Personal Data. Personal Data is not shared for advertising, behavioural targeting or profiling purposes.

10. Cross-Border Data Transfers

Personal Data may be transferred by the Company to jurisdictions outside the United Kingdom where required for the operation of the Websites. Where such transfers involve countries that are not covered by UK adequacy regulations, the Company applies appropriate safeguards, including the use of the International Data Transfer Agreement or the UK Addendum to the Standard Contractual Clauses recognised under the UK GDPR.

Such transfers are limited to the Personal Data necessary for the specific purpose, in accordance with the principle of data minimisation.

11. Security and Safeguards

The Company implements appropriate technical and organisational measures to protect Personal Data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include secure hosting, encrypted communications, restricted system access and internal procedures ensuring the proper handling and confidentiality of data.

The Company maintains processes to identify, assess and manage Personal Data breaches. Where a breach is likely to result in a risk to the rights and freedoms of individuals, the Company will take appropriate steps, including notifying the Information Commissioner's Office and, where required, affected individuals in accordance with applicable law.

12. Cookies and Tracking Technologies

The Websites use cookies and similar technologies for the secure and proper operation of the platforms. These tools help maintain session continuity, prevent misuse and protect system security. The Company does not use cookies or similar technologies for advertising, behavioural tracking or marketing.

The following categories of cookies may be used:

• Strictly Necessary Cookies: essential for the operation of a Website, enabling core functions such as page navigation, access to secure areas and prevention of fraudulent activity.
• Performance and Analytics Cookies: collect aggregated data about interaction with a Website, such as pages visited and time spent, to help monitor performance and improve the user experience.
• Functionality Cookies: allow a Website to remember preferences and settings, such as language, region or interface options.
• Security and Fraud Prevention Cookies: used to detect suspicious activity, assist with authentication and protect the platform from misuse or unauthorised access.

Cookies are set separately for each Website and are not used to link activity across caelunix.com and Caelunix.com for profiling purposes.

Non-essential cookies are used only where the User has given consent, which may be withdrawn at any time. Users can also manage or disable cookies through their browser settings, although restricting certain cookies may affect the functionality or performance of a Website.

13. Changes to this Privacy Policy

The Company may update this Privacy Policy from time to time to reflect changes in practice, legal requirements or operational needs. Any updated version will be published on the Websites with a revised "last updated" date.

Where required by law, the Company will take reasonable steps to notify Users of material changes. Continued use of a Website after such updates constitutes acceptance of the revised Policy.

Contact Information

If you have any questions, requests or concerns regarding this Privacy Policy, the processing of your Personal Data or your rights under applicable data protection law, you may contact the Company at:

WESTERN COURT LIMITED

Company Number: 15467867

Address: International House, 6 South Molton Street, London, England, W1K 5QF

Email: support@caelunix.com (caelunix.com) / support@Caelunix.com (Caelunix.com)