Privacy Policy
Rookie Gaming Inc. ("Rookie," "we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you access or use the Rookie platform (the "Platform").
This Privacy Policy applies to all users worldwide, including users in the United States, Canada, Mexico, Brazil, Colombia, Peru, India, and all other jurisdictions where we operate. By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is incorporated into our Terms of Service.
Table of Contents
- Data Controller
- Information We Collect
- How We Collect Your Information
- Legal Bases for Processing
- How We Use Your Information
- Information Sharing and Disclosure
- International Data Transfers
- Data Retention
- Data Security
- Your Rights
- Cookies and Tracking Technologies
- Children's Privacy
- Jurisdiction-Specific Provisions
- Changes to This Privacy Policy
- Contact Us
1. Data Controller
The data controller responsible for your personal data is:
Rookie Gaming Inc.
[Registered Address — To Be Updated]
Email: privacy@rookie.gg
2. Information We Collect
2.1 Information You Provide Directly
(a) Account Registration Information
Full legal name, date of birth, email address, phone number, residential address, username and password, country of residence.
(b) Identity Verification (KYC) Information
Government-issued photo identification; national identification numbers (SSN for US, CPF for Brazil, cédula for Colombia, DNI for Peru, Aadhaar/PAN for India, CURP/INE for Mexico, SIN for Canada); selfie photographs; proof of address documents; source of funds documentation.
(c) Financial and Payment Information
Credit/debit card details (tokenized by our payment processor — we do not store full card numbers), bank account details, cryptocurrency wallet addresses, transaction history, e-wallet account information.
(d) Communications
Customer support correspondence, survey responses, feedback, user-generated content.
2.2 Information We Collect Automatically
(a) Device and Technical Information
IP address, device type and operating system, browser type and version, screen resolution, device identifiers, language and timezone.
(b) Usage and Activity Information
Pages visited, games played, bet amounts, outcomes, session durations, click patterns, login/logout timestamps, referral source.
(c) Location Information
Approximate geographic location from IP address; precise location only with explicit consent for territorial eligibility verification.
(d) Cookies and Tracking Data
Cookie identifiers, session tokens, web beacons, local storage data. See our Cookie Policy for details.
2.3 Information from Third Parties
Identity verification results, payment confirmations and fraud assessments, social media profile information (when using social login), analytics data, fraud prevention risk scores, public databases and sanctions lists.
3. How We Collect Your Information
We collect information through direct interaction (account creation, purchases, support), automated technologies (cookies, server logs), third-party sources (verification services, payment processors, social platforms), and public sources (government databases, sanctions lists).
4. Legal Bases for Processing
| Legal Basis | Examples |
|---|---|
| Contract Performance | Account registration, managing your Account, processing purchases and Prize redemptions, providing Games |
| Legal Obligation | AML/KYC verification, tax reporting, responding to lawful requests, sanctions screening |
| Legitimate Interests | Fraud prevention, Platform security, analytics, personalization, direct marketing (where permitted) |
| Consent | Marketing communications, non-essential cookies, precise location tracking |
Where we rely on consent, you may withdraw it at any time, though withdrawal does not affect the lawfulness of prior processing.
5. How We Use Your Information
5.1 Platform Operation
Create and manage your Account, process purchases and Prize redemptions, operate Games, provide customer support, manage responsible play settings.
5.2 Safety, Security, and Compliance
Verify identity and age, detect and prevent fraud, enforce territorial restrictions, monitor for prohibited conduct, comply with applicable laws.
5.3 Communication
Send transactional notifications, marketing communications (with consent where required), respond to support requests.
5.4 Improvement and Analytics
Analyze usage patterns, conduct A/B testing, develop new features, generate aggregated statistical data.
5.5 Responsible Play
Monitor gameplay patterns, deliver responsible play interventions, enforce self-exclusion and cool-off periods.
6. Information Sharing and Disclosure
6.1 Categories of Recipients
- Service Providers: Payment processors, identity verification providers, cloud hosting, customer support tools, email services, analytics, fraud detection — all contractually bound to process data only as instructed.
- Regulatory and Law Enforcement: Where required by law — financial regulators, tax authorities, law enforcement, courts.
- Professional Advisors: Legal, accounting, and insurance advisors under confidentiality obligations.
- Corporate Transactions: In connection with mergers, acquisitions, or sales of assets.
- Other Players: Limited info (username) in leaderboards, tournaments, or chat. Never your real name, financial info, or documents.
6.2 We Do NOT Sell Your Personal Data
We do not sell your personal data to third parties for their own marketing or commercial purposes.
7. International Data Transfers
Your data may be stored and processed in any country where we or our service providers operate. We implement Standard Contractual Clauses (SCCs), Data Processing Agreements (DPAs), and adequacy determinations to ensure adequate protection. For Brazil, we comply with LGPD international transfer provisions.
8. Data Retention
| Data Category | Retention Period |
|---|---|
| Account registration data | Duration of Account + 5 years |
| KYC/identity verification documents | Duration of Account + 7 years |
| Transaction and purchase records | 7 years from transaction date |
| Game round history | Duration of Account + 5 years |
| Customer support communications | 3 years from resolution |
| Marketing consent records | Duration of consent + 3 years |
| Server logs and IP addresses | 12 months |
| Cookie data | As specified in Cookie Policy |
When no longer required, data is securely deleted or anonymized. Anonymized data may be retained indefinitely for analytics.
9. Data Security
We implement comprehensive security measures including:
- Encryption: TLS 1.2+ for data in transit, AES-256 for data at rest
- Access Controls: Role-based access on a need-to-know basis
- Authentication: Multi-factor authentication for administrative access
- Monitoring: Continuous monitoring with automated alerts for suspicious activity
- Payment Security: PCI DSS-compliant payment processors
- Penetration Testing: Regular security assessments
- Employee Training: Regular data protection awareness training
- Incident Response: Documented breach response procedures
In the event of a data breach posing risk to your rights, we will notify you and applicable authorities as required by law.
10. Your Rights
Regardless of your jurisdiction, you have the right to:
- Access: Request a copy of your personal data
- Correction: Request correction of inaccurate data
- Deletion: Request deletion, subject to legal retention requirements
- Withdraw Consent: Withdraw consent at any time
- Marketing Opt-Out: Opt out of marketing communications
- Complaint: Lodge a complaint with your data protection authority
To exercise these rights, contact us at privacy@rookie.gg or through your Account settings. We will respond within 30 days.
11. Cookies and Tracking Technologies
We use cookies and similar technologies as described in our Cookie Policy. You can manage preferences through the cookie consent banner, your Account settings, or your browser settings.
12. Children's Privacy
The Platform is not intended for individuals under the minimum age for their jurisdiction. If we discover we have collected data from a minor, we will promptly delete it and close the associated Account. If you believe a minor has provided data to us, contact privacy@rookie.gg.
13. Jurisdiction-Specific Provisions
13.1 United States — CCPA/CPRA (California)
California residents have the right to: know what personal information is collected; request deletion; request correction; non-discrimination for exercising rights. We do not "sell" or "share" personal information as defined by the CCPA/CPRA.
| CCPA Category | Examples | Collected? |
|---|---|---|
| Identifiers | Name, email, IP address, Account ID | Yes |
| Personal information | Name, address, phone, financial info | Yes |
| Protected characteristics | Age, date of birth | Yes |
| Commercial information | Purchase history, transactions | Yes |
| Internet/electronic activity | Browsing history, game activity | Yes |
| Geolocation data | Approximate location via IP | Yes |
| Sensory data | Selfie photos for verification | Yes |
| Sensitive personal information | Government ID numbers, financial accounts | Yes |
We also comply with Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other applicable state privacy laws.
13.2 Canada — PIPEDA
We obtain meaningful consent for collection, use, and disclosure. You have the right to access and correct your information and to challenge our compliance via the Office of the Privacy Commissioner of Canada. Quebec residents have additional rights under Law 25, including data portability and information about automated decision-making.
13.3 Brazil — LGPD
Under the Lei Geral de Proteção de Dados (Law No. 13,709/2018), you have the right to: confirmation of processing; access; correction; anonymization, blocking, or deletion of unnecessary data; data portability; deletion of data processed with consent; information on sharing; consent withdrawal; filing complaints with the ANPD; and review of automated decisions.
Data Protection Officer (Encarregado):
Email: dpo@rookie.gg
13.4 Mexico — LFPDPPP
You have ARCO rights (Access, Rectify, Cancel, Oppose). You may revoke consent and limit use and disclosure at any time. You may file complaints with INAI. This Privacy Policy serves as your Aviso de Privacidad. Contact privacy@rookie.gg with ARCO requests including your name, Account ID, and description of the right you wish to exercise.
13.5 Colombia — Law 1581 of 2012
You have the right to know, update, rectify, and delete your personal data, and to revoke consent. You may file complaints with the Superintendencia de Industria y Comercio (SIC).
13.6 Peru — Law 29733
You have ARCO-POL rights (Access, Rectify, Cancel, Oppose, Portability, Opposition to automated decisions, Limitation). You may file complaints with the Autoridad Nacional de Protección de Datos Personales.
13.7 India — DPDP Act 2023
Under the Digital Personal Data Protection Act, 2023, you have the right to: consent and withdrawal; access; correction and erasure; grievance redressal; and nomination. You may file complaints with the Data Protection Board of India.
Grievance Officer:
Email: grievance@rookie.gg
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will post the updated policy on the Platform, send an email notification, and display a prominent notice upon your next login. Your continued use constitutes acknowledgment of the updates.
15. Contact Us
Privacy Team / Data Protection Officer:
Email: privacy@rookie.gg
General Customer Support:
Email: support@rookie.gg
Live Chat: Available on the Platform
Mailing Address:
Rookie Gaming Inc.
[Registered Address — To Be Updated]
Brazil (Encarregado): dpo@rookie.gg
India (Grievance Officer): grievance@rookie.gg
Mexico (ARCO Requests): privacy@rookie.gg