Privacy Policy

Last Updated: November 27, 2025

1. Overview

This Privacy Policy ("Policy") describes the practices of Roma Gaming Club ("the Provider," "we," "our") regarding the collection, utilization, disclosure, and protection of personal data when you use our gaming platforms, websites, applications, and associated offerings (collectively, the "Platform").

Your utilization of our Platform constitutes your consent to the data handling activities outlined herein. Our procedures are designed to comply with relevant data protection legislation, including the GDPR, CCPA, VCDPA, PIPEDA, and other applicable regional privacy statutes.

2. Types of Data Collected

We obtain personal data through several channels, categorized as follows:

2.1 Information You Provide Directly
When registering an account, utilizing specific Platform functionalities, or contacting us, you may supply personal details such as:
• Identity Data: Full name, email, telephone number, and home address.
• Credentials: Username, hashed password, and security prompt responses.
• Profile Data: Birth date, gender, and general location information.
• Marketing Choices: Your preferences concerning promotional communications and subscriptions.

2.2 Information Gathered Automatically
During your interaction with our Platform, certain information is collected automatically, including:
• Technical Specifications: Device type, OS version, browser details, and IP address.
• Interaction Data: Length of visits, access times, and in-Platform activities (e.g., transactions, feature usage).
• Device Signatures: Unique device identifiers, hardware profiles, and network connectivity information.

2.3 Information from External Sources
We may receive personal data from third-party entities, such as:
• Social Media Platforms: Basic profile information when you link your social media account to our Platform.
• Verification Services: Data from specialized providers that assist with fraud prevention and eligibility confirmation.
• Advertising Networks: Information regarding your engagement with advertisements and campaign performance metrics.

3. Purposes of Data Processing

We use your personal data for legitimate business objectives, primarily to provide, enhance, and secure our Platform.

3.1 Platform Delivery and Administration
• Establishing and maintaining user profiles.
• Facilitating financial transactions and payment handling.
• Delivering user assistance and addressing service inquiries.

3.2 Promotional Activities
• Distributing marketing materials, service updates, and event notifications aligned with your interests.
• Presenting customized advertisements or content recommendations.
• Conducting research surveys and evaluating marketing campaign effectiveness.

3.3 Platform Improvement
• Analyzing usage trends to refine user experience and Platform design.
• Creating and piloting new functionalities.
• Monitoring system performance and diagnosing technical problems.

3.4 Legal and Security Obligations
• Adhering to relevant gaming laws, privacy regulations, and consumer safeguards.
• Preventing fraudulent activities, unauthorized access, or Platform misuse.
• Upholding our Terms of Service and other binding agreements.

4. Data Disclosure Practices

We do not sell your personal data. Disclosure occurs only under the following circumstances:

4.1 Trusted Service Partners
We engage reputable third-party vendors to support Platform operations, including:
• Cloud Infrastructure Providers: For secure data hosting and storage solutions.
• Financial Transaction Processors: For handling payment operations.
• User Support Systems: For managing customer service interactions.
• Analytical and Marketing Services: For assessing Platform metrics and optimizing outreach.

4.2 Business Transfers
In scenarios involving mergers, acquisitions, or asset transfers, your personal data may be disclosed to the succeeding entity, in compliance with legal standards and notification requirements.

4.3 Legal Compliance
We may disclose personal data when compelled by legal duty, such as in response to subpoenas, court mandates, or regulatory inquiries.

5. Tracking Technologies

We employ tracking technologies to improve Platform functionality, security, and personalization.

5.1 Cookies and Comparable Tools
Cookies (small text files stored on your device) are used to:
• Preserve user session continuity.
• Remember your preferences (e.g., language, settings).
• Monitor Platform performance and identify technical issues.

5.2 Preference Management
You can manage tracking preferences through:
• Browser Settings: Configure your web browser to refuse or restrict cookies.
• Advertising Opt-Out Portals: Utilize industry self-regulation platforms.
• In-Platform Controls: Adjust permissions within the application's privacy or account settings.

6. Data Protection Protocols

We implement comprehensive technical and organizational measures to safeguard your personal data against unauthorized access, alteration, or destruction, including:
• Encryption: Industry-standard TLS protocols for secure data transmission.
• Access Management: Multi-factor authentication and privilege-based access controls.
• Security Assessments: Regular security evaluations, penetration tests, and vulnerability scans.
• Certified Systems: Utilization of infrastructure adhering to SOC 2 compliance standards.

7. Your Data Subject Rights

Depending on your jurisdiction, you may possess the following rights:

7.1 Access and Portability
Request confirmation and a copy of the personal data we hold about you, including details about its processing.

7.2 Rectification and Processing Limits
Request correction of inaccurate data or limitations on how your data is processed under specific conditions.

7.3 Erasure and Consent Withdrawal
Request account deletion or revoke consent for certain data processing activities, subject to legal retention requirements.

8. Data Retention Timeline

We retain personal data only as long as necessary for defined purposes or to meet legal obligations:
• Account Information: Maintained while your account is active and for a prudent period thereafter.
• Legally Mandated Data: Kept to satisfy regulatory, tax, or legal hold requirements.
• Marketing Data: Retained based on your active consent or until you opt out.

9. Specific Provisions for California Residents (CCPA/CPRA)

California residents have additional rights, including:
• Right to Know: Request disclosure about data collection and usage purposes.
• Right to Deletion: Request erasure of personal information, with certain legal exceptions.
• Right to Opt-Out: The right to opt-out of the "sale" or "sharing" of personal data. We currently do not engage in such practices.
• Non-Discrimination: Assurance that you will not face discrimination for exercising your privacy rights.

We will verify your identity before processing such requests and aim to respond within 45 days, with a permissible 45-day extension if needed.

10. Policy Amendments

We may revise this Policy periodically to reflect operational, legal, or regulatory changes. Notification of material changes will be provided via:
• Conspicuous notices within the Platform;
• Email communications to your registered address; or
• An updated version posted on our official website.

The "Last Updated" date at the top indicates the latest revision.

11. Contact Details

For privacy-related questions, to exercise your rights, or to lodge a complaint, please contact us at: [email protected]

Your continued use of the Platform signifies your acknowledgment of this Policy and any subsequent modifications.