Privacy Policy

Last Updated: January 1, 2026

1. Introduction & Controller Identity

Welcome to The Apex Circuit, operated by Iconic Turns GmbH. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. The data controller responsible for your personal data is Iconic Turns GmbH, located at Friedrichstraße 123, 10117 Berlin, Germany. You can contact us at support@www.morningsuninn.com for any privacy-related inquiries.

2. Data We Collect Automatically

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. The data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. This data helps us ensure the security of the social casino platform and optimize the user experience during simulated gameplay.

3. Data Provided by You

We may collect, use, store and transfer different kinds of personal data about you which you provide directly to us. This includes Identity Data (first name, last name, username or similar identifier), Contact Data (email address), and Profile Data (your simulated VIP level, feedback, and survey responses). If you choose to upgrade from a guest account to a registered account to preserve your Apex Tokens (APX), we require minimal contact information to secure your profile. We do not collect any Financial Data as all transactions within the VIP Store are entirely simulated.

4. Use of Processing (Simulated Purchases)

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you (providing access to the social casino games). Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. When you interact with our VIP Paddock Store, your Profile Data is processed to update your simulated APX balance. This processing ensures that your virtual progress is accurately tracked and protected against unauthorized access.

5. Legal Basis (GDPR Context)

Our legal basis for processing your personal data under the General Data Protection Regulation (GDPR) includes: Consent (where you have clearly agreed to our processing for a specific purpose, such as marketing emails), Contractual Necessity (where processing is required to provide the free-to-play services you requested), and Legitimate Interests (such as improving our platform, preventing fraud, and ensuring network security). We ensure that any processing under legitimate interests is balanced against your privacy rights.

6. Data Sharing with Third Parties

We do not sell your personal data. We may share your data with trusted third-party service providers acting as processors based in the EU who provide IT and system administration services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International Data Transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

8. Data Retention Periods

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. For guest accounts, data is retained strictly on a session basis unless linked to a registered profile.

9. User Rights (Access, Deletion, Portability)

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: Request access to your personal data, Request correction of your personal data, Request erasure of your personal data (the "right to be forgotten"), Object to processing of your personal data, Request restriction of processing your personal data, Request transfer of your personal data (data portability), and Right to withdraw consent. You can exercise these rights by contacting our support pit crew at support@www.morningsuninn.com.

10. Security Measures & Encryption

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes end-to-end encryption for account credentials and secure socket layer (SSL) technology for all web traffic. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

11. Children's Privacy (18+)

The Apex Circuit is strictly limited to users who are 18 years of age or older. Our website and social casino games are not intended for children, and we do not knowingly collect data relating to children. If we become aware that we have collected personal data from anyone under the age of 18, we will take immediate steps to delete that information from our servers and terminate any associated simulated accounts.

12. Changes & Updates to this Policy

We keep our privacy policy under regular review. This version was last updated on the date stated at the top of this page. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Any substantial changes to this policy will be communicated via an in-platform notification or via email for registered users.