Privacy Policy

Version: 1.0  |  Last Updated: June 4, 2025  |  Applies to: neuraldynamicsubc.ca

Roobet ("we," "us," "our") is committed to protecting the privacy and personal information of all individuals who interact with our Platform at neuraldynamicsubc.ca. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in connection with your use of our services.

Please read this Privacy Policy carefully. By using the Platform, you acknowledge that you have read and understood this Policy. This Privacy Policy forms part of our Terms & Conditions. For questions about responsible gaming, please see our Responsible Gaming Policy.

1. Introduction

1.1. Scope

This Privacy Policy applies to all personal information collected, processed, or stored by Roobet in connection with the operation of the Platform and the provision of our services to players located in Canada and other eligible jurisdictions. It covers data collected through the website, mobile applications, customer support communications, and any other touchpoints between you and Roobet.

1.2. Data Controller

Roobet, as the operator of neuraldynamicsubc.ca, acts as the data controller with respect to the personal information described in this Privacy Policy. If you have questions about how your data is handled, please contact our Privacy Officer at [email protected].

2. Data We Collect

2.1. Information You Provide Directly

When you register an account, use our services, or communicate with us, we may collect the following categories of personal data:

• Identity Data: Full legal name, date of birth, government-issued identification number (e.g., passport or driver's licence number), and copies of identity documents submitted for KYC verification;
• Contact Data: Email address, residential address, telephone number;
• Account Data: Username, account password (stored in encrypted form), account preferences, and communication settings;
• Financial Data: Payment method details (e.g., card type and last four digits, e-wallet account identifiers), transaction history, deposit and withdrawal records, and source of funds information where required;
• Communications Data: Records of your correspondence with us, including support tickets, chat logs, and email exchanges;
• Verification Data: Documents and information submitted to satisfy KYC and anti-money laundering requirements.

2.2. Information Collected Automatically

When you access and use the Platform, we automatically collect certain technical and usage data, including:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers;
• Usage Data: Pages visited, games played, session duration, betting history, click-stream data, and feature interactions;
• Geolocation Data: Approximate geographic location derived from your IP address, used to assess eligibility and enforce geographic restrictions;
• Cookie & Tracking Data: Data collected via cookies, web beacons, and similar tracking technologies as described in Section 6.

2.3. Information from Third Parties

We may receive personal data about you from the following third-party sources:

• Identity verification service providers used for KYC and age verification;
• Payment processors and financial institutions in connection with deposit and withdrawal transactions;
• Fraud detection and anti-money laundering service providers;
• Affiliate and marketing partners, where you have arrived at the Platform via a referral link;
• Self-exclusion scheme registries, where applicable.

3. How We Use Your Data

3.1. Primary Purposes

We use your personal data for the following primary purposes:

• To create and manage your Account and provide access to our gaming services;
• To verify your identity, age, and eligibility to use the Platform (KYC);
• To process deposits, withdrawals, and other financial transactions;
• To provide customer support and respond to your enquiries;
• To detect and prevent fraud, money laundering, cheating, and other prohibited conduct;
• To enforce our Terms & Conditions and other policies;
• To comply with applicable legal and regulatory obligations;
• To deliver account-related notifications (e.g., deposit confirmations, withdrawal approvals, security alerts).

3.2. Marketing and Promotional Communications

Where you have provided your consent, we may use your contact data to send you promotional emails, newsletters, and personalised offers. You may withdraw your consent to receive marketing communications at any time by clicking the "unsubscribe" link in any marketing email, or by contacting us at [email protected]. Withdrawal of marketing consent will not affect the lawfulness of processing carried out prior to withdrawal.

3.3. Platform Improvement and Analytics

We use aggregated and anonymised data to analyse usage trends, improve the Platform's functionality, enhance user experience, and develop new products and services. Where possible, this analysis is conducted using data that does not identify individual users.

3.4. Responsible Gaming

We use your gaming data — including session duration, wagering patterns, deposit frequency, and account activity — to identify players who may be exhibiting signs of problem gambling, and to proactively offer responsible gaming tools, resources, or intervention where appropriate. This use of data is carried out in accordance with our legal obligations and legitimate interest in promoting player welfare.

4. Legal Bases for Processing

We process your personal data on the following legal bases, as applicable:

• Performance of a Contract: Processing necessary to create and manage your Account, provide gaming services, and execute financial transactions;
• Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, KYC obligations, and data retention requirements;
• Legitimate Interests: Processing carried out in our legitimate interests or those of third parties, including fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided such interests are not overridden by your fundamental rights and freedoms;
• Consent: Processing based on your explicit consent, including the sending of direct marketing communications. Consent may be withdrawn at any time without prejudice to prior processing.

5. Data Sharing & Third Parties

5.1. Service Providers

We share your personal data with trusted third-party service providers who assist us in operating the Platform and delivering our services. These providers act as data processors and are contractually bound to handle your data only on our instructions and in compliance with applicable privacy laws. Categories of service providers include:

• Identity verification and KYC platform providers;
• Payment processing and banking partners;
• Anti-fraud and anti-money laundering solution providers;
• Cloud hosting and infrastructure providers;
• Customer support software and live chat providers;
• Email delivery and marketing platform providers;
• Analytics and performance monitoring providers;
• Responsible gaming and self-exclusion scheme operators.

5.2. Legal and Regulatory Authorities

We may disclose your personal data to regulatory bodies, law enforcement agencies, courts, or other governmental authorities where we are required or permitted to do so by applicable law, court order, or regulatory direction.

5.3. Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or similar business transaction, your personal data may be transferred to the acquiring or successor entity as part of that transaction, subject to equivalent data protection obligations.

5.4. No Sale of Personal Data

We do not sell, rent, or trade your personal information to third parties for their own independent marketing or commercial purposes.

6. Cookies & Tracking Technologies

6.1. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They enable the website to recognise your device, remember your preferences, and collect information about how you use the site. We use cookies and similar technologies (including web beacons, pixel tags, and local storage) on the Platform.

6.2. Types of Cookies We Use

6.3. Cookie Management

Upon your first visit to the Platform, you will be presented with a Cookie Consent Manager that allows you to accept or decline non-essential cookies. You may update your cookie preferences at any time through the cookie settings available in the footer of the Platform. You may also manage cookies through your browser settings; however, disabling certain cookies may impact the functionality of the Platform.

7. Data Security

7.1. Technical and Organisational Measures

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption of personal data in transit using Transport Layer Security (TLS) technology;
• Encryption of sensitive data at rest;
• Multi-factor authentication for Account access;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Incident response procedures for data breaches.

7.2. Data Breach Notification

In the event of a data breach that poses a real risk of significant harm to affected individuals, we will notify the relevant privacy supervisory authority and affected individuals within the timeframes required by applicable law.

8. Data Retention

8.1. Retention Periods

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, and to comply with our legal, regulatory, and contractual obligations. Typical retention periods are as follows:

• Account and identity data: Retained for the duration of your Account and for a minimum of 5 years following closure, in accordance with AML and financial record-keeping requirements;
• Transaction records: Minimum of 7 years following the date of the transaction;
• Customer communications: Up to 3 years following the conclusion of the relevant interaction;
• Marketing data: Until consent is withdrawn or as required by applicable law;
• Technical and usage data: Up to 24 months in identified form; longer in aggregated, anonymised form.

8.2. Secure Deletion

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with our data destruction protocols.

9. Your Rights

Subject to applicable Canadian privacy laws, you have the following rights with respect to your personal data:

• Right of Access: You may request a copy of the personal data we hold about you;
• Right to Rectification: You may request the correction of inaccurate or incomplete personal data;
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Restrict Processing: You may request that we limit the processing of your data in certain circumstances;
• Right to Data Portability: Where technically feasible, you may request a copy of your data in a structured, machine-readable format;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time;
• Right to Object: You may object to certain types of processing, including direct marketing.

To exercise any of these rights, please submit a written request to [email protected]. We will respond to verified requests within 30 days. We may require proof of identity before processing your request.

10. International Data Transfers

10.1. Cross-Border Transfers

As a result of engaging international service providers — including cloud hosting, payment processing, and analytics partners — your personal data may be transferred to and processed in countries outside of Canada. Such countries may not provide the same level of data protection as Canadian law.

10.2. Safeguards

Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including standard contractual clauses, data transfer agreements, or other approved transfer mechanisms under applicable privacy legislation. By using the Platform, you acknowledge and consent to such international transfers where necessary for the provision of our services.

11. Minors

The Platform is not intended for use by individuals under the applicable minimum gambling age in their jurisdiction. We do not knowingly collect personal data from minors. If we become aware that personal data has been collected from an individual who does not meet the minimum age requirement, we will promptly delete such data and close the associated Account. If you believe a minor has provided us with personal data, please contact us immediately at [email protected].

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or operational requirements. Material changes will be communicated to you via email or a prominent notice on the Platform. The "Last Updated" date at the top of this Policy indicates when the most recent changes were made. Your continued use of the Platform following notification of changes constitutes your acceptance of the revised Privacy Policy.

13. Contact Information

If you have any questions, concerns, or complaints regarding this Privacy Policy or the handling of your personal data, please contact our Privacy Officer:

• Email (Privacy / DPO): [email protected]
• General Support: [email protected]

We are committed to resolving privacy concerns promptly and transparently. If you remain dissatisfied with our response, you may have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) at www.priv.gc.ca.