Privacy Policy

1. Introduction

Welcome to RFL PRO. This Privacy Policy explains how PLAYCRAFT TECH LLC ("Company," "we," "us," or "our") collects, uses, shares, and protects your personal information when you use our platform, including our Telegram application, website, and all related services (collectively, the "Service").

By using our Service, you consent to the collection and use of your information as described in this Privacy Policy. If you do not agree with our practices, please do not use the Service.

2. Operator of Personal Data

The operator of personal data (data controller) responsible for your personal information is:

PLAYCRAFT TECH LLC
26 Pakhlavon Makhmud street, 2nd passage, Chulpon MFY, Yashnabad district, Tashkent, Republic of Uzbekistan
Tax ID (STIR): 312898506
Email: legal@rflpro-uz.com

We process personal data in accordance with the Law of the Republic of Uzbekistan "On Personal Data" and other applicable legislation of the Republic of Uzbekistan. For EU/EEA users, we also act as the data controller as defined under the General Data Protection Regulation (GDPR).

We do not collect or process biometric data, genetic data or other special categories of personal data (such as data on health, racial or ethnic origin, political or religious beliefs).

3. Information We Collect

3.1 Information You Provide

We collect information that you voluntarily provide when using our Service:

• Account Information: Telegram user ID, username, display name, and profile photo (as provided by Telegram)
• Steam Information: Steam ID and trade URL when you link your Steam account for withdrawals
• Communication Data: Messages and content you submit in community features, support requests, and feedback

3.2 Information Collected Automatically

When you use our Service, we automatically collect:

• Usage Data: Actions taken within the app (items obtained, tournaments joined, tasks completed), timestamps, and interaction patterns
• Device Information: Device type, operating system, browser type, and language settings
• Log Data: IP address, access times, pages viewed, and referring URLs

3.3 Payment Information

When you make purchases, payment processing is handled by licensed third-party payment service providers, including payment systems of the Republic of Uzbekistan. Your payment card details are entered on the pages of the payment service provider and are not stored by us. We may receive:

• Transaction IDs and amounts
• Partial payment method information (e.g., last 4 digits of card)
• Billing country
• Transaction status and history

4. How We Use Your Information

We use your information for the following purposes:

4.1 Service Provision

• Create and manage your account
• Process transactions and manage your Crystal balance
• Enable unique item rewards and withdrawals
• Facilitate tournament participation
• Provide customer support

4.2 Service Improvement

• Analyze usage patterns to improve features
• Develop new features and services
• Troubleshoot technical issues
• Monitor and ensure Service security

4.3 Communication

• Send service-related notifications (e.g., tournament announcements, system updates)
• Respond to your inquiries and support requests
• Send promotional communications (with your consent, where required)

4.4 Legal and Safety

• Comply with legal obligations
• Detect and prevent fraud, abuse, and security incidents
• Enforce our Terms of Service
• Protect the rights and safety of users and third parties

4A. Legal Basis and Consent

We process your personal data on the following grounds:

• Your consent. By creating an account, linking your Steam account or making a purchase, you give your consent to the processing of the personal data listed in Section 3 for the purposes listed in Section 4. Consent is given for each purpose separately and covers only the data needed for that purpose.
• Performance of the agreement with you (the Terms of Service): providing the Service, delivering purchased content, handling refunds and support.
• Compliance with legal obligations of the Company, including accounting, tax and consumer protection legislation of the Republic of Uzbekistan.
• Protection of the rights and safety of the Company, users and third parties, including prevention of fraud.

You may withdraw your consent at any time by contacting us at legal@rflpro-uz.com. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. After withdrawal we will stop processing your data and delete it, unless we are required by law to keep certain records (see Section 6).

5. Information Sharing

We may share your information with the following categories of recipients:

5.1 Service Providers

• Payment service providers: Payment processing, including payment systems of the Republic of Uzbekistan (subject to the privacy policy of the provider you choose at checkout)
• Cloud Infrastructure Providers: Data storage and hosting
• Analytics Providers: Service usage analysis

5.2 Platform Partners

• Steam: For item withdrawals (Steam ID and trade URL)
• FACEIT/FASTCUP: For tournament participation and anti-cheat verification

5.3 Legal Requirements

We may disclose your information if required by law, court order, or governmental authority, or when we believe disclosure is necessary to:

• Comply with legal process
• Protect our rights, property, or safety
• Investigate potential violations of our Terms
• Prevent fraud or security threats

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity, which will be bound by this Privacy Policy.

We do not sell personal data.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide the Service and maintain your account
• Comply with legal obligations (e.g., tax and accounting requirements)
• Resolve disputes and enforce our agreements

Specific retention periods:

• Account Data: Retained while your account is active and for 3 years after deletion request
• Transaction Records: Retained for 7 years for tax and legal compliance
• Usage Logs: Retained for 12 months
• Support Communications: Retained for 2 years after resolution

7. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

7.1 Rights Under the Law of the Republic of Uzbekistan "On Personal Data"

• Right to Information: Know whether we process your personal data, which data, for what purposes and to whom it is transferred
• Right of Access: Receive a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Blocking and Deletion: Request that processing be suspended or your data deleted where processing is unlawful or no longer necessary
• Right to Withdraw Consent: Withdraw consent to processing at any time (see Section 4A)
• Right to Object to Cross-Border Transfer: Refuse consent to the transfer of your data outside the Republic of Uzbekistan (see Section 10)
• Right to Appeal: Lodge a complaint with the authorised state body for the protection of personal data of the Republic of Uzbekistan or with a court

7.2 Rights Under GDPR (EU/EEA Users)

• Right of Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right to Restriction: Request limitation of processing
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw previously given consent at any time

You also have the right to lodge a complaint with your local data protection authority.

7.3 Rights Under CCPA (California Users)

California residents have additional rights under the California Consumer Privacy Act:

• Right to Know: Request disclosure of personal information collected, used, and shared
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt-out of the sale of personal information (we do not sell personal information)
• Right to Non-Discrimination: Not be discriminated against for exercising your rights

7.4 Exercising Your Rights

To exercise any of these rights, please contact us at legal@rflpro-uz.com. We will respond without undue delay and within the period established by applicable law, and in any case within 30 days.

We may need to verify your identity before processing your request.

8. Children's Privacy

Our Service is intended for users who are at least 16 years of age.

We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16, we will take steps to delete that information promptly.

If you believe we have inadvertently collected information from a child under 16, please contact us immediately at legal@rflpro-uz.com.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit (TLS/SSL)
• Encryption of sensitive data at rest
• Access controls and authentication requirements
• Regular security assessments and monitoring
• Employee training on data protection

However, no method of transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

10. Storage and Cross-Border Transfers

Your personal data is stored on servers of our hosting providers. Because RFL PRO is an international community, your data may be transferred to and processed in countries other than your country of residence, including the Republic of Uzbekistan and the countries where our hosting and service providers are located.

For users in the Republic of Uzbekistan: by accepting this Privacy Policy you give your consent to the cross-border transfer of your personal data to the countries where our service providers are located. We transfer data only to providers that ensure a level of protection of personal data adequate to the requirements of the legislation of the Republic of Uzbekistan, and we bind such providers by contractual obligations of confidentiality and security. We do not process biometric or genetic data, and we do not transfer abroad any category of data that the legislation of the Republic of Uzbekistan requires to be stored only within its territory.

For users in the EU/EEA, we ensure that any international transfers of personal data are protected by:

• Standard Contractual Clauses approved by the European Commission
• Other legally approved transfer mechanisms

11. Cookies and Tracking

Our website may use cookies and similar tracking technologies to:

• Remember your preferences and settings
• Analyze website traffic and usage patterns
• Improve our Service

Types of cookies we use:

• Essential Cookies: Required for basic website functionality
• Analytics Cookies: Help us understand how visitors use our website
• Preference Cookies: Remember your settings and choices

You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make changes:

• We will update the "Last Updated" date at the top of this page
• For material changes, we will notify you through the Service or via email
• We encourage you to review this Policy periodically

Your continued use of the Service after changes take effect constitutes acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

PLAYCRAFT TECH LLC
26 Pakhlavon Makhmud street, 2nd passage, Chulpon MFY, Yashnabad district, Tashkent, Republic of Uzbekistan
Email: legal@rflpro-uz.com

You may also lodge a complaint with the authorised state body for the protection of personal data of the Republic of Uzbekistan. EU/EEA users may additionally contact their local data protection authority.

We aim to respond to all privacy-related inquiries within 30 days.