Privacy Policy

1. Who We Are

Roaring Burst Play ("we," "us," "our," or "the Platform") is a Canadian free social arcade entertainment service operating at roaringburstplay.com. We provide interactive digital entertainment experiences, including our flagship title Legion Gold — Empire's Fortune, exclusively to adults aged 19 and older residing in Canada. We do not conduct financial transactions, process payments, or offer any form of monetary reward or exchange through our platform.

As a Canadian-based operator, we are subject to the Personal Information Protection and Electronic Documents Act (PIPEDA, S.C. 2000, c. 5), along with substantially similar provincial legislation including British Columbia's Personal Information Protection Act (PIPA), Alberta's Personal Information Protection Act (PIPA), and Québec's Act respecting the protection of personal information in the private sector (Law 25). We are committed to meeting the highest standards of privacy protection across all Canadian jurisdictions.

2. Scope of This Policy

This Privacy Policy applies to all personal information collected through:

• The roaringburstplay.com website and all subdomains
• Our interactive arcade experiences, including Legion Gold — Empire's Fortune
• Electronic communications you initiate with us (email, contact forms)
• Any other service or feature we offer that links to this Privacy Policy

This Policy does not apply to third-party websites, services, or platforms that may be linked to from our website. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices of those external parties.

This Policy is incorporated by reference into our Terms of Service and Cookie Policy. Together, these three documents form the complete framework governing your use of Roaring Burst Play and our handling of your information.

3. Information We Collect

We collect only the information necessary to provide, maintain, and improve our services. The following table describes the categories of information we may collect and the circumstances in which each arises:

We do not collect sensitive personal information such as financial data, government identification numbers, health information, or biometric data. We have no mechanism for collecting such data and no purpose for which we would require it. We do not process credit card numbers, bank account details, or any form of payment information.

4. How We Use Your Information

We use the personal information we collect for the following specific purposes, each of which is tied to a legitimate operational need:

• Age verification and access control: To confirm that users meet the minimum age requirement of 19 years for access to our platform, in compliance with our responsible play commitments and applicable law.
• Platform delivery and performance: To serve our website content, load arcade experiences, maintain session continuity, and ensure technical functionality across all supported devices and browsers.
• Analytics and improvement: To understand how users navigate and engage with our platform, identify areas for improvement, test new features, and optimize overall user experience.
• Communications and support: To respond to inquiries submitted through our contact form, address technical issues, and follow up on feedback you have provided to us.
• Security and fraud prevention: To detect, investigate, and prevent activities that may threaten the security, integrity, or availability of our platform or that may harm our users.
• Legal compliance: To comply with applicable Canadian laws and regulations, respond to lawful requests from government authorities, and enforce our Terms of Service.
• Cookie preference management: To remember your cookie consent decisions and display preferences so that we do not repeatedly prompt you for information you have already provided.

We will not use your information for any purpose other than those listed above without first obtaining your explicit consent. We do not sell, rent, or trade personal information to any third party for commercial purposes of any kind.

5. Legal Bases for Processing

Under PIPEDA, our collection, use, and disclosure of personal information is governed by the principle of meaningful consent. Depending on the nature of the information and the purpose of processing, we rely on the following bases:

• Express consent: Where we ask you to actively agree (e.g., cookie consent, contact form submission), we rely on your express, informed consent.
• Implied consent: When you voluntarily provide information in contexts where the purpose is obvious (e.g., submitting a contact form to receive a response), consent is implied by your action.
• Legitimate business purposes: For technical data collected automatically (e.g., server logs, performance monitoring), we rely on the legitimate interest of operating a functional, secure digital platform, provided that such interests do not override your privacy rights.
• Legal obligation: Where we are required by law to collect, retain, or disclose information, compliance with that legal obligation is our basis for processing.

You may withdraw consent at any time, subject to legal and contractual restrictions. Withdrawal of consent may affect your ability to use certain features of our platform. To withdraw consent, please contact our Privacy Officer using the details in Section 11.

6. Disclosure of Your Information

Roaring Burst Play does not sell, rent, or trade your personal information. We may share information only in the limited circumstances described below:

• Service providers: We engage trusted third-party service providers to assist with hosting, analytics, email delivery, and security monitoring. These providers act as data processors on our behalf and are contractually prohibited from using your information for any purpose beyond the services they provide to us. All service providers are selected with privacy compliance as a key criterion.
• Analytics platforms: We use aggregated and anonymized data to analyze platform performance. Where identifiable data is shared with analytics platforms, it is subject to data processing agreements that limit use and require appropriate security measures.
• Legal requirements: We may disclose information when required to do so by law, court order, or lawful request from a regulatory authority, government body, or law enforcement agency. We will, where legally permitted, notify you of such a disclosure.
• Protection of rights: We may disclose information where we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of Roaring Burst Play, our users, or the public.
• Business transitions: In the event of a merger, acquisition, or sale of all or a portion of our assets, personal information held by us may be transferred to the acquiring entity, subject to the same privacy obligations as those described in this Policy.

We do not transfer personal information outside Canada without ensuring an equivalent level of privacy protection is in place. Where cross-border transfers are necessary for service delivery, we rely on contractual safeguards consistent with PIPEDA requirements.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to operate and improve our platform. Cookies are small data files stored on your device that help us recognize returning visitors, remember preferences, and analyze usage patterns. For a full explanation of the specific cookies we use, their purposes, and how to manage your preferences, please review our Cookie Policy.

In summary, we use the following categories of cookies:

• Strictly necessary cookies: Required for basic platform functionality. These cannot be disabled without preventing you from using the platform.
• Performance cookies: Collect anonymized data about how visitors use our platform to help us improve it.
• Functional cookies: Remember your preferences and settings to improve your experience on return visits.
• Analytics cookies: Help us understand traffic patterns and measure the effectiveness of our content.

You have the right to refuse non-essential cookies. Our cookie banner allows you to exercise this right at any time. Please note that disabling certain cookies may affect the functionality of some features.

8. Data Retention

We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Our general retention principles are as follows:

• Contact and communication data: Retained for up to 24 months from the date of last communication, after which it is securely deleted unless a legal obligation requires longer retention.
• Technical and usage data: Retained in anonymized or aggregated form for analytical purposes. Identifiable technical data (such as IP logs) is retained for up to 12 months and then purged or anonymized.
• Age verification records: Retained for the duration of the user's engagement with the platform and for up to 12 months thereafter, to support compliance obligations.
• Cookie and consent records: Retained for up to 36 months to document consent decisions in accordance with regulatory guidance.

When information is no longer required, we destroy, erase, or anonymize it in a secure manner. We do not retain personal information indefinitely or without purpose.

9. Security Safeguards

We take the security of your personal information seriously. Roaring Burst Play implements a range of technical, organizational, and physical safeguards appropriate to the sensitivity of the information we hold and the risks associated with its processing.

Our security measures include, but are not limited to:

• Encryption of data in transit using TLS (Transport Layer Security) protocols
• Access controls ensuring that personal information is accessible only to authorized personnel who require it for legitimate business purposes
• Regular security assessments and vulnerability reviews of our platform infrastructure
• Secure deletion procedures for information that is no longer required
• Employee training on privacy and data security obligations
• Contractual requirements for third-party service providers to maintain equivalent security standards

While we strive to use commercially reasonable means to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. In the event of a data breach that poses a real risk of significant harm to individuals, we will notify the Office of the Privacy Commissioner of Canada and affected individuals in accordance with PIPEDA's mandatory breach reporting requirements.

10. Your Privacy Rights

As a Canadian resident, you have the following rights with respect to your personal information under PIPEDA and applicable provincial privacy legislation:

• Right of access: You have the right to request access to the personal information we hold about you, including information about how it has been used and disclosed.
• Right to correction: If the personal information we hold about you is inaccurate, incomplete, or outdated, you have the right to request that we correct it.
• Right to withdraw consent: You may withdraw your consent to our collection, use, or disclosure of your personal information at any time, subject to legal and contractual restrictions.
• Right to complain: If you believe we have not handled your personal information in compliance with applicable privacy law, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca, or with the applicable provincial privacy commissioner in your province.
• Right to information about third-party disclosures: You may request information about third parties to whom we have disclosed your personal information.

To exercise any of these rights, please submit a written request to our Privacy Officer using the contact information provided in Section 11. We will respond to all access requests within 30 days of receipt. In complex cases, we may extend this timeline by up to an additional 30 days, in which case we will notify you of the extension and the reason for the delay.

We may require you to verify your identity before processing your request, to protect your personal information from unauthorized access.

11. Contact Our Privacy Officer

Roaring Burst Play has designated a Privacy Officer who is responsible for overseeing compliance with this Privacy Policy and with applicable Canadian privacy legislation. If you have any questions, concerns, or complaints regarding the handling of your personal information, or if you wish to exercise any of your privacy rights, please contact our Privacy Officer:

We take all privacy inquiries seriously and are committed to resolving concerns in a timely, transparent, and fair manner. If you are not satisfied with our response, you have the right to escalate your complaint to the Office of the Privacy Commissioner of Canada at 30 Victoria Street, Gatineau, Quebec K1A 1H3 or online at www.priv.gc.ca.

This Privacy Policy may be updated from time to time to reflect changes in our practices or legal requirements. We will post the updated Policy on this page with a revised effective date. Material changes will be communicated via a notice on our homepage. Your continued use of the platform following such notice constitutes acceptance of the updated Policy.