How RROTA handlesaccount, wallet, and product data.

“RROTA,” “we,” “us,” and “our” refer to the operator of the applicable RROTA Service. “Services” include rrota.xyz, Spin-to-Win, the official Telegram Mini App, user accounts, product features, community tools, support channels, campaigns, and future services that reference this Policy.

Where required by applicable law, RROTA acts as the controller or equivalent responsible party for personal information it decides how and why to process. Certain third-party services may act as processors for RROTA or as independent controllers under their own policies.

This Policy does not govern an independent third party’s website, wallet, blockchain application, market tracker, social platform, exchange, authentication system, or other service.

RROTA may receive information:

• Directly from a user during account creation, product use, wallet connection, support, or communication.
• Automatically from a browser, device, application, server, security system, cookie, or local-storage mechanism.
• From authentication, hosting, database, analytics, wallet, blockchain, communication, or infrastructure providers.
• From the public Solana blockchain and public block explorers.
• From campaign, referral, leaderboard, mission, reward, or transaction activity generated through a Service.
• From public communications, social profiles, or community interactions where a user chooses to contact or mention RROTA.

• Create, authenticate, secure, and manage accounts.
• Operate RROTA websites, Spin-to-Win, Telegram Mini App access, profiles, missions, bonuses, referrals, and progression.
• Calculate and display weekly, monthly, yearly, all-time, promotional, and event-based leaderboard activity.
• Review reward eligibility, investigate suspicious activity, and administer approved rewards or withdrawals.
• Connect public wallets and verify relevant public blockchain activity.
• Detect bots, abuse, duplicate accounts, manipulated referrals, exploits, fraud, phishing, and unauthorized access.
• Maintain internal balances, Boost Credits, game records, campaign records, and product integrity.
• Provide support, answer inquiries, investigate security reports, and maintain formal communications.
• Measure performance, diagnose errors, improve user experience, and develop new features.
• Comply with legal obligations, enforce the Terms, resolve disputes, and protect users, RROTA, and third parties.

RROTA may combine information from different Services where reasonably necessary for account security, product operation, campaign administration, fraud prevention, support, or a consistent user experience.

RROTA does not use seed phrases or private keys because those credentials are not collected.

Public blockchain information is different from ordinary private database information. A wallet address, token transfer, transaction signature, amount, time, and related account activity may be visible to anyone through Solana infrastructure and block explorers.

RROTA may associate a public wallet address with an account, deposit, withdrawal, eligibility review, reward, campaign, or support request where necessary to provide a feature.

RROTA generally cannot delete, modify, hide, or reverse information already recorded on a public blockchain. Closing an account or submitting a deletion request does not remove public blockchain records.

Wallet addresses can become linked to a person through other activity. Users should consider the privacy implications before using the same wallet across multiple applications.

RROTA Services may use cookies, browser storage, session tokens, device identifiers, or similar technology for authentication, account security, preferences, language, session continuity, product state, analytics, performance, and fraud prevention.

Some storage may be essential for login, security, or core functionality. Blocking essential storage may prevent an account, game, wallet-linked feature, or preference from working correctly.

Browser and device settings can be used to delete or block many cookies and local-storage items. Where legally required, RROTA may request consent before using non-essential technologies.

RROTA may use technical signals, account patterns, referral data, activity timing, device or session information, wallet information, transaction records, and gameplay data to detect bots, duplicate accounts, farming, manipulation, fraud, abuse, or security threats.

Automated rules or scoring may help flag activity for restriction or review. Where required by law, RROTA will provide applicable rights relating to a decision based solely on automated processing that produces a legal or similarly significant effect.

Suspicious activity may be reviewed manually. RROTA may preserve relevant information for security, investigation, dispute, enforcement, and fraud-prevention purposes even after an account is restricted or closed.

RROTA is not required to publish confidential abuse-detection logic, security thresholds, investigation methods, or signals that could enable circumvention.

Information may be disclosed where reasonably necessary to operate, secure, support, and improve the Services, administer campaigns, process requested actions, comply with law, or protect rights and safety.

Information may also be disclosed in connection with a merger, restructuring, financing, acquisition, transfer of assets, insolvency, or similar transaction, subject to applicable law and appropriate protections.

RROTA may disclose information to authorities or other parties where reasonably believed necessary to comply with law, respond to a valid legal request, investigate fraud or security incidents, enforce agreements, or protect users, RROTA, or third parties.

Aggregated or de-identified information that does not reasonably identify an individual may be used or disclosed for analytics, product development, reporting, security, and communication.

RROTA and its service providers may process information in countries other than the user’s location. Those countries may have different privacy and data-protection rules.

Where required, RROTA may use contractual safeguards, adequacy decisions, consent, necessity for providing a requested Service, or another legally recognized transfer mechanism.

Public blockchain information is distributed across a global network and is not limited to one country.

RROTA retains information for no longer than reasonably necessary for the purposes described in this Policy, subject to applicable legal, security, fraud-prevention, operational, and dispute needs.

Retention periods may depend on:

• The period an account remains active
• The time needed to provide a requested Service
• Leaderboard, campaign, reward, and withdrawal review periods
• Security, abuse-prevention, fraud-detection, and dispute needs
• Backup, logging, and technical recovery cycles
• Legal, tax, accounting, compliance, and recordkeeping obligations
• The need to establish, exercise, or defend legal claims

Information may remain in backups for a limited period after it is removed from active systems. Public blockchain records may remain available permanently and are not controlled by RROTA.

RROTA may retain limited records after an account closes where necessary to prevent repeat abuse, demonstrate compliance, complete a transaction, resolve a dispute, or enforce the Terms.

RROTA uses reasonable technical and organizational measures intended to protect information against unauthorized access, misuse, loss, alteration, and disclosure.

Measures may include access controls, authentication, encrypted transport, infrastructure security, logging, backups, monitoring, fraud detection, least-privilege practices, and incident review. The exact measures may change as Services develop.

No internet service, database, blockchain application, wallet, authentication system, transmission method, or storage system is completely secure. RROTA cannot guarantee absolute security.

Users are responsible for securing devices, email accounts, authentication methods, browser sessions, wallets, recovery information, and transaction approvals.

RROTA may need enough information to verify identity, account ownership, wallet relationship, jurisdiction, and the scope of a request. Additional sensitive credentials such as a seed phrase or private key will never be required.

A request may be denied or limited where permitted by law, including where information must be retained for security, fraud prevention, legal obligations, disputes, transaction records, or the rights of another person.

Public blockchain information generally cannot be deleted or corrected by RROTA.

• Browse many public RROTA pages without creating a game account.
• Choose not to connect a wallet where a wallet is optional.
• Disconnect a wallet through the wallet provider or applicable interface.
• Control cookies or local storage through browser and device settings, subject to essential-function limitations.
• Stop using the Services at any time.
• Request eligible privacy actions through the official contact address.
• Unsubscribe from optional marketing communication where an unsubscribe method is provided.

Some choices can limit functionality. For example, refusing authentication storage may prevent login, and refusing to connect a wallet may prevent wallet-linked features.

RROTA Services are not directed to children who are below the age required to consent to data processing or enter the applicable agreement in their jurisdiction.

Users must satisfy the eligibility requirements in the Terms. RROTA does not knowingly seek to collect personal information from a child in violation of applicable law.

A parent, guardian, or other person who believes a child has provided information unlawfully should contact RROTA so the matter can be reviewed.

RROTA may link to independent services such as wallets, Solana infrastructure, explorers, market trackers, trading interfaces, Telegram, social networks, ChatGPT, authentication providers, audit providers, hosting providers, and other applications.

Those services may collect information directly and process it under their own privacy policies. RROTA does not control their cookies, security, retention, data sharing, account rules, or international transfers.

Users should review the third party’s policy before creating an account, connecting a wallet, approving a transaction, or submitting information.

RROTA may update this Policy to reflect new products, data practices, service providers, security measures, legal requirements, or operational changes.

The updated date will be shown on this page. Material changes may also be announced through the website, product interface, blog, email, Telegram, or another official channel where appropriate.

Continued use after an update may be treated as acknowledgment of the revised Policy where permitted by applicable law. Where consent is required for a new purpose, RROTA will seek it as required.

Privacy questions and eligible requests can be sent to:

To protect accounts and users, RROTA may request reasonable verification before acting on an access, correction, deletion, or similar request. Never send a seed phrase, private key, wallet password, or recovery code.