Controller and Contact
Controller: Gardenia Services Co.
Registered Address: Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, MH 96960, Republic of the Marshall Islands
Privacy Contact: support@roundz.gg
Personal Data We Collect
Depending on how you use the Service, we may collect:
- Account and identity data: Account identifiers, nickname, verification status, and, where required for verification, age confirmation, identity documents, and residence information.
- Wallet and transaction data: connected wallet addresses, message signatures, deposit and withdrawal addresses, blockchain transaction details, internal balances, Paid Game entries, Game settlements, deposits, withdrawals, and screening results.
- Gameplay and integrity data: games joined, inputs, match results, disconnections, cheating or collusion indicators, security logs, and authoritative server records.
- Technical and location data: IP address, browser and device characteristics, connection-quality signals, VPN/proxy indicators, and geolocation signals used to determine eligibility.
- Communications: information you provide in support requests, verification correspondence, complaints, or other communications with us.
- Analytics and advertising data: landing page, referral URLs, campaign parameters, page views, and interactions with the Service, where such technologies are enabled and permitted.
We generally do not collect your name, postal address, email address, or phone number unless you provide them voluntarily (for example, when contacting support) or we request them for required verification, legal compliance, or security purposes.
How We Use Personal Data
We use personal data to:
- provide, authenticate, secure, and maintain the Service;
- process Paid Game entries, administer Game Pools, calculate settlements, and process deposits and withdrawals;
- verify age, location, eligibility, identity, and wallet ownership;
- screen for and prevent cheating, fraud, money laundering, sanctions evasion, and other prohibited activity;
- enforce the Roundz Terms and Conditions;
- maintain records, resolve errors, respond to legal requests, and comply with legal obligations;
- improve and test the Service; and
- measure advertising performance and understand usage trends, where permitted.
Legal Bases for Processing
Where the GDPR, UK GDPR, or similar law applies, we process personal data based on:
- Contract: to provide the Service and perform our obligations under the Terms;
- Legitimate interests: to secure and improve the Service, prevent abuse, ensure game integrity, understand usage, and protect our rights, where those interests are not overridden by your rights;
- Consent: where required, including for non-essential cookies or similar technologies; and
- Legal obligation: to comply with applicable laws, regulatory obligations, and recordkeeping duties.
How We Share Personal Data
We may share personal data with:
- Hosting and infrastructure providers that support the delivery of the Service;
- Blockchain and wallet-connection providers that facilitate wallet authentication and transactions;
- Identity-verification, KYC, and screening providers that assist with age, location, sanctions, and anti-fraud checks;
- Professional advisers and support providers assisting with legal, accounting, security, or customer service;
- Authorities or counterparties where required by law, necessary to protect rights or safety, investigate wrongdoing, enforce our Terms, or in connection with a corporate transaction.
Wallet addresses and blockchain transactions are publicly visible on the relevant blockchain network. We do not control third-party processing of public blockchain data.
We do not sell personal data for money.
International Transfers
Roundz is established in the Republic of the Marshall Islands. Your data may be processed in the Marshall Islands, and other countries where our service providers operate. Where required by applicable law, we will use appropriate legal transfer mechanisms, such as standard contractual clauses.
Retention
We retain personal data for as long as reasonably necessary to operate the Service, maintain security, resolve disputes, prevent fraud, comply with legal obligations, and enforce agreements. Identity, transaction, security, and compliance records may be retained for longer periods where required or reasonably necessary for these purposes.
Your Rights
Depending on your location, you may have rights to request access, correction, deletion, restriction, objection, portability, withdrawal of consent, or information about our processing.
To make a request, contact support@roundz.gg. We may need to verify your identity before fulfilling a request. We may retain certain data where permitted or required by law, including for security, fraud prevention, transaction records, or legal obligations.
If the GDPR or UK GDPR applies, you may also have the right to lodge a complaint with a data-protection authority.
Security
We use reasonable technical and organizational measures designed to protect personal data. No internet service, wallet, or network is completely secure. You are responsible for protecting your Account credentials and external wallet credentials.
Children
The Service is not directed to persons under 18. We do not knowingly permit minors to use Paid Games. If you believe that a minor has provided personal data to Roundz, please contact support@roundz.gg.
Changes to This Notice
We may update this Privacy Notice from time to time. We will post the revised version through the Service and update the Effective Date. Where required by law, we will provide additional notice or obtain consent.