Privacy Policy

PRIVACY POLICY

1. INTRODUCTION
At Robro Professional & Management Development Training L.L.C. (“Robro,” “we,” “our,” or “us”) is deeply committed to protecting the privacy and personal data of our users. This Privacy Policy outlines the types of personal data we collect, how we process it, and the measures we take to safeguard your information in compliance with the General Data Protection Regulation (GDPR) and other relevant international and UAE laws.
Robro is an education platform focused on creating the new era of gaming experts.
This Privacy Policy is effective as of January 20, 2025 and remains in force until further updates. All terms used in this Privacy Policy shall have the same meanings as defined in the General Terms and Conditions of Using Robro’s Platform, unless otherwise specified.

1.1. SCOPE OF THE PRIVACY POLICY
This Privacy Policy applies to all personal data collected through our platform, services, and any related digital tools or communications. It governs how Robro collects, uses, and shares personal information provided by our users, ensuring transparency and accountability in all our data processing activities.
1.2. PURPOSE OF DATA PROCESSING
We collect and process personal data to enhance user experience, provide professional training and development services, facilitate platform functionality, and comply with applicable laws and regulations. This includes processing data to:
• Register and identify users on the platform.
• Enable transactions and track user participation in challenges.
• Analyze user activity to improve our services and platform functionalities.

BY ACCESSING OR USING OUR PLATFORM AND SERVICES, YOU ACKNOWLEDGE AND AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO ANY PART OF THIS POLICY, PLEASE DISCONTINUE THE USE OF OUR SERVICES. WE ENCOURAGE USERS TO PERIODICALLY REVIEW THIS DOCUMENT FOR UPDATES OR CHANGES.

2. HOW WE COLLECT PERSONAL DATA
At Robro we collect personal data to deliver and improve our services. This section explains how we collect information from users of our platform.
2.1. DATA PROVIDED BY USERS
We collect personal data directly from users when they:
• Register on the platform and create an account.
• Fill out forms, participate in challenges, or complete surveys.
• Contact our support team or engage with our communication channels.
• Provide information for transactions, such as payment details.
2.2. DATA COLLECTED AUTOMATICALLY
Our platform automatically collects certain data to enhance the user experience, including:
• Technical Data: Such as IP address, browser type, operating system, and device information.
• Cookies: Small text files stored on users’ devices to track preferences and enhance functionality.
• Usage Data: Information about how users interact with our platform, such as navigation patterns and feature usage.
2.3. DATA FROM THIRD PARTIES
We may receive data about users from trusted third parties, such as:
• Payment processors, to confirm transaction details.
• Analytics providers, to analyze and improve our platform’s performance.
• Public databases or other lawful sources, to verify user identity and comply with regulations.

3. WHAT TYPES OF PERSONAL DATA WE PROCESS
To provide our services and enhance the user experience on our platform, Robro collects and processes the following types of personal data:
3.1. PERSONAL INFORMATION PROVIDED BY USERS
• Full name.
• Email address.
• Phone number.
• Date of birth.
• Payment details (such as billing address, card information, or transaction identifiers).
3.2. TECHNICAL INFORMATION COLLECTED AUTOMATICALLY
• Internet Protocol (IP) address.
• Device type and operating system.
• Browser type and version.
• Log data, including access times and visited pages.
• Cookies and similar technologies used to track user preferences and enhance functionality.
3.3. ACTIVITY AND TRANSACTION DATA
• Participation in challenges and related actions on the platform.
• Transaction history, including payments made or received through the platform.
• Data regarding user engagement with platform features, including navigation behavior and interaction analytics.
3.4. DATA FROM THIRD PARTIES
• Information from payment processors to confirm and reconcile transactions.
• Data from analytics providers to improve user experience and platform performance.
• Verification data obtained from public records or other lawful sources to ensure compliance with legal and regulatory requirements.
3.5. SPECIAL NOTE ON SENSITIVE DATA:
We do not intentionally collect sensitive personal data (such as health information, religious beliefs, or political affiliations). However, if such data is inadvertently provided, it will be handled strictly in accordance with this Privacy Policy and applicable laws.
By using our platform, users consent to the processing of their personal data as outlined above. For further details on how data is processed, stored, or shared, please refer to subsequent sections of this Privacy Policy.

4. FOR WHICH PURPOSES WE USE PERSONAL DATA
At Robro we process personal data strictly to provide high-quality services while complying with legal and regulatory requirements. The personal data we collect is used for the following purposes:
• USER REGISTRATION AND IDENTIFICATION. To create and manage user accounts, verify user identity, and ensure compliance with our Terms and Conditions, including eligibility requirements for platform participation.
• PROVIDING PLATFORM SERVICES AND FUNCTIONALITY. To facilitate the operation of our platform, including enabling participation in challenges, managing user progress, and delivering tailored training and educational resources.
• PERFORMANCE OF FINANCIAL TRANSACTION. To process payments, fees, and refunds related to challenges and managed accounts, ensuring secure and efficient transactions through trusted payment providers.
• ANALYSIS AND IMPROVEMENT OF SERVICES. To analyze user behavior, preferences, and platform usage trends to improve our services, develop new features, and enhance the user experience.
• LEGAL AND REGULATORY COMPLIANCE. To comply with applicable laws and regulations, including those of the United Arab Emirates and international standards, such as anti-money laundering (AML) and data protection requirements.
• MARKETING AND COMMUNICATIONS. To provide users with updates, promotional content, and notifications about services or challenges, subject to user preferences and consent.
• FRAUD PREVENTION AND SECURITY. To monitor, investigate, and prevent unauthorized access, fraudulent activities, and other security threats to protect the integrity of our platform and user data.
• CUSTOMER SUPPORT. To assist users with inquiries, address complaints, and resolve issues related to the platform and its services.

BY AGREEING TO THIS PRIVACY POLICY, YOU ACKNOWLEDGE THAT YOUR PERSONAL DATA MAY BE PROCESSED FOR THESE PURPOSES. WE ENSURE THAT ALL PROCESSING ACTIVITIES ARE CONDUCTED TRANSPARENTLY AND IN ACCORDANCE WITH APPLICABLE LAWS, INCLUDING THE GDPR AND UAE DATA PROTECTION REGULATIONS.

5. WHERE DO WE PROCESS YOUR INFORMATION?
Robro is located and the Platform is run from UAE. 
We follow the standard set by European Union (“EU”) data protection rules and, therefore, when we share personal information of EU and UK users with service providers located outside the EU and UK, we put in place appropriate contractual guarantees to ensure the use of your personal information takes place under a similar standard only.

6. HOW WE SHARE PERSONAL DATA
At Robro we are committed to maintaining the privacy of your personal data. We share personal data only when necessary and in accordance with this Privacy Policy. Below is an outline of how and why personal data may be shared:
6.1. SHARING WITH SERVICE PROVIDERS
We may share your personal data with trusted third-party service providers to facilitate the operation of our platform and ensure the delivery of services. This includes:
• Payment Processors: For processing payments and refunds related to challenges and managed accounts.
• Analytics Providers: To monitor and enhance platform performance and user experience.
• Hosting Providers: To securely store and maintain platform data.
6.2. LEGAL AND REGULATORY REQUIREMENTS
We may disclose personal data if required to do so by law or in response to valid legal requests, such as subpoenas or court orders. This includes compliance with:
• Applicable UAE laws and international regulations.
• Anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
• Tax reporting and other regulatory requirements.
6.3. BUSINESS TRANSFERS
In the event of a merger, acquisition, or sale of Robro’s assets, your personal data may be transferred to the acquiring entity as part of the business transaction. We will ensure that the new owner upholds the commitments outlined in this Privacy Policy.
6.4. SAFEGUARDING USERS’ RIGHTS AND PLATFORM INTEGRITY
We may share personal data to:
• Investigate and prevent fraudulent activities, unauthorized access, or other breaches of our Terms and Conditions.
• Protect the safety and rights of our users, employees, or the public.
6.5. AGGREGATED AND ANONYMIZED DATA
We may share aggregated or anonymized data that cannot be used to identify individual users with third parties for research, analysis, or marketing purposes. This data does not include personally identifiable information.
6.6. USER CONSENT
Where required by law, we will obtain your explicit consent before sharing your personal data with third parties for purposes not covered in this Privacy Policy.
Robro ensures that any data shared is protected with appropriate contractual agreements, confidentiality measures, and adherence to applicable laws, including GDPR and UAE data protection regulations.

7. YOUR DATA PROTECTION RIGHTS & CHOICES
At Robro we ensure that users retain control over their personal data, in compliance with GDPR and UAE data protection regulations.
You have the right to access your personal data and request a copy of the information we hold about you. Additionally, you can request the correction of any inaccurate or incomplete data to ensure it is up to date.
In certain circumstances, you may ask us to delete your data, such as when it is no longer necessary for the purposes outlined in this Privacy Policy or if you withdraw your consent. You may also request restrictions on data processing or object to its use for specific purposes, such as direct marketing.
If you wish to transfer your data to another service provider, we can provide it in a commonly used, machine-readable format where technically feasible. Furthermore, you can withdraw consent for processing at any time, without affecting the lawfulness of processing prior to the withdrawal.
To exercise these rights, contact us at admin@hash-hedge.com . We aim to respond to all requests within 30 days, except where extensions are permitted by law. If you believe your rights have been violated, you may lodge a complaint with your local data protection authority or the UAE regulator.

8. FOR HOW LONG WE RETAIN PERSONAL DATA
At Robro we retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with legal, regulatory, or contractual obligations.
8.1. RETENTION PERIODS
• User Account Information: Retained for the duration of the user’s active account and up to five (5) years after account closure, as required by UAE law or for legitimate business purposes.
• Transaction and Financial Records: Retained for a minimum of five (5) years to comply with anti-money laundering (AML) regulations, tax obligations, and audit requirements.
• Technical Data (e.g., IP addresses, cookies): Retained for up to one (1) year or as specified by local regulations for analytics, security, or service improvement.
• Marketing Data: Retained until the user withdraws consent or requests deletion, whichever comes first.
8.2. DELETION AND ANONYMIZATION
When personal data is no longer necessary for the specified purposes or retention periods, we will securely delete or anonymize it. Anonymized data may be used for research, analysis, or business development purposes, without identifying individual users.
8.3. USER REQUESTS FOR DATA DELETION
Users have the right to request the deletion of their personal data in accordance with applicable laws. We will process such requests unless the data is required to:
• Fulfill ongoing legal or regulatory obligations.
• Resolve disputes or enforce our agreements.
• Maintain security and fraud prevention records.
By adhering to these retention policies, Robro ensures the secure handling of user data and compliance with GDPR, UAE regulations, and international standards.

9. INTERNATIONAL DATA TRANSFERS
At Robro personal data collected through our platform may be transferred to and processed in countries outside the United Arab Emirates, including the European Union (EU), the United States, and other jurisdictions where our service providers or business partners operate. These transfers are necessary to ensure platform functionality, process transactions, analyze user activity, and maintain high-quality service delivery.
To safeguard personal data during international transfers, we comply with UAE regulations, the GDPR, and other international data protection laws. We ensure that recipients of personal data provide an adequate level of protection recognized by UAE or EU regulatory authorities. In cases where such protection is not guaranteed, we implement additional measures, including Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), or obtaining explicit user consent when legally required.
We may engage third-party service providers located outside the UAE to process personal data. These providers are contractually obligated to uphold data protection standards in line with this Privacy Policy and applicable laws.
Users may request details about the safeguards applied to their personal data during international transfers or exercise their rights regarding these transfers by contacting us at admin@hash-hedge.com . By using our platform and services, you acknowledge and consent to the international transfer of your personal data as described in this Privacy Policy.

10. CHILDREN’S INFORMATION
Robro recognizes the importance of protecting the privacy and safety of children. Our platform, services, and offerings are not intended for individuals under the age of 18, and we do not knowingly collect or process personal data from children.
10.1. RESTRICTIONS ON ACCESS BY MINORS
Individuals under the age of 18 are prohibited from creating accounts, using our services, or providing any personal data on the platform. By accessing or using our platform, you confirm that you are at least 18 years old.
10.2. INCIDENTAL COLLECTION OF CHILDREN’S DATA
If we become aware that personal data of a child has been collected inadvertently, we will take immediate steps to delete such data from our records. In cases where parental or guardian consent is legally required, we will ensure compliance with applicable regulations, such as the UAE data protection laws and GDPR.
10.3. PARENTAL OR GUARDIAN INVOLVEMENT
Parents or legal guardians who suspect that their child has provided personal data to Robro are encouraged to contact us immediately at admin@hash-hedge.com . We will cooperate fully to address any concerns and ensure the data is promptly removed.

11. AUTOMATED DECISION MAKING
At Robro, we are committed to transparency regarding the use of automated decision-making technologies in processing personal data. This section outlines how such technologies may be applied, their implications for users, and the measures we take to ensure compliance with applicable laws and safeguard user rights.
11.1. DEFINITION AND SCOPE
Automated decision-making refers to decisions made by systems or algorithms without human intervention. On our platform, these processes may include actions such as verifying user eligibility for services, analyzing user activity to detect fraud, or tailoring platform functionality to enhance user experience.
11.2. APPLICATIONS OF AUTOMATED DECISION-MAKING
We may use automated systems to:
• Assess eligibility for certain platform features, such as participation in challenges or access to advanced services.
• Monitor user activity to identify potential security risks, fraudulent behavior, or violations of our General Terms and Conditions.
• Personalize the user experience, such as recommending relevant challenges, training materials, or features based on usage patterns.
11.3. USER RIGHTS AND SAFEGUARDS
In compliance with GDPR and UAE data protection regulations, we ensure the following safeguards for users affected by automated decision-making:
• Users have the right to obtain information about the logic behind automated decisions that significantly affect them.
• Users may request human intervention to review decisions made by automated systems and provide feedback or appeal outcomes.
• Automated decision-making processes are regularly tested, reviewed, and refined to ensure fairness, accuracy, and compliance with applicable laws.
11.4. LIMITATIONS AND COMPLIANCE
We do not engage in automated decision-making processes that produce legal or similarly significant effects without implementing appropriate safeguards or obtaining user consent where required. For example:
• Automated decisions involving sensitive personal data are subject to stricter scrutiny and require explicit user consent or compliance with legal obligations.
• All automated processes are designed to align with GDPR, UAE data protection laws, and other international standards.

12. SECURITY
At Robro, the security of personal data is a top priority. We implement industry-standard technical, administrative, and physical safeguards to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction.
12.1. MEASURES TO SAFEGUARD PERSONAL DATA
We employ a combination of security measures, including but not limited to:
• Data encryption in transit and at rest to prevent unauthorized access.
• Regular system monitoring and vulnerability assessments to identify and mitigate potential security risks.
• Secure storage facilities with restricted access to authorized personnel only.
• Implementation of secure authentication mechanisms for accessing personal data.
• Employee training programs on data protection and information security best practices.
12.2. LIMITATIONS OF SECURITY MEASURES
While we strive to protect personal data using commercially reasonable efforts, no method of electronic transmission or storage is completely secure. As such, we cannot guarantee the absolute security of personal data. Users are advised to take precautions, such as using strong passwords and safeguarding account credentials, to further protect their data.
12.3. SECURITY BREACH NOTIFICATION
In the unlikely event of a data breach that affects personal data, we will notify affected users and relevant regulatory authorities as required by applicable laws. The notification will outline the nature of the breach, the data involved, and any actions users should take to minimize potential risks.
12.4. USER RESPONSIBILITIES
Users are responsible for maintaining the confidentiality of their account credentials and for ensuring that they use secure devices and networks when accessing our platform. If you suspect unauthorized access to your account, please contact us immediately at admin@hash-hedge.com.

13. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA (BRAZIL, EEA, UK VISITORS/CUSTOMERS ONLY)
At Robro, we ensure that the collection and processing of personal data comply with applicable legal frameworks, including the General Data Protection Regulation (GDPR), the United Kingdom General Data Protection Regulation (UK GDPR), and the Brazilian General Data Protection Law (LGPD).
13.1. PERFORMANCE OF A CONTRACT
We process personal data when it is necessary to perform our contractual obligations with you. This includes:
• Registering and managing user accounts.
• Facilitating financial transactions and processing payments.
• Providing services and maintaining the functionality of our platform.
13.2. COMPLIANCE WITH LEGAL OBLIGATIONS
In certain cases, we process personal data to comply with our legal obligations, such as:
• Tax and accounting requirements.
• Anti-money laundering (AML) regulations.
• Responding to lawful requests from public authorities.
13.3. CONSENT
Where required, we process personal data based on your explicit consent. This applies to:
• Sending marketing communications or newsletters.
• Using cookies or similar tracking technologies (as outlined in our Cookie Policy).
• Collecting and processing sensitive data (only where explicitly permitted).
13.4. LEGITIMATE INTERESTS
We process personal data based on our legitimate interests, provided such processing does not override your fundamental rights and freedoms. Examples include:
• Enhancing and improving our platform’s functionality.
• Protecting against fraud and unauthorized access.
• Conducting analytics to better understand user behavior and preferences.
13.5. USER RIGHTS AND OBJECTIONS
If you are located in Brazil, the EEA, or the UK, you have the right to object to the processing of your personal data based on our legitimate interests. To exercise this right or to inquire about the legal basis for any specific data processing activity, contact us at admin@hash-hedge.com.

14. USE OF COOKIES
At Robro we use cookies and similar technologies to enhance your experience on our platform, provide essential functionality, and analyze user behavior. This section explains how we use cookies and your choices in managing them.
14.1. WHAT ARE COOKIES?
Cookies are small text files that are placed on your device (computer, smartphone, or other devices) when you access our platform. They store information about your interaction with our platform, which helps us improve your user experience.
14.2. TYPES OF COOKIES WE USE
We use the following categories of cookies on our platform:
• Essential Cookies: These cookies are necessary for the operation of our platform. They enable basic functions like page navigation and access to secure areas. Without these cookies, the platform cannot function properly.
• Performance and Analytics Cookies: These cookies help us understand how users interact with our platform by collecting and reporting information anonymously. This allows us to improve platform performance and user experience.
• Functional Cookies: These cookies allow us to remember your preferences and provide enhanced functionality, such as language settings or saved login details.
• Marketing and Advertising Cookies: These cookies track your browsing activity to deliver personalized advertisements and promotions that are relevant to your interests.
14.3. PURPOSES OF USING COOKIES
We use cookies to:
• Enhance platform functionality and improve user experience.
• Analyze traffic and user interactions to identify areas for improvement.
• Provide tailored content and advertisements based on user preferences.
• Remember user preferences and login details for convenience.
14.4. THIRD-PARTY COOKIES
Our platform may include cookies set by third parties, such as analytics providers (e.g., Google Analytics) or advertising partners. These third parties may collect data about your online activities across other websites and applications.
14.5. MANAGING COOKIES
You can manage or disable cookies through your browser settings at any time. However, please note that disabling certain cookies may impact your ability to use some features of our platform.
• Browser Settings: Most browsers allow you to block or delete cookies. Refer to your browser’s help section for instructions.
• Cookie Preferences: You can adjust your cookie preferences directly on our platform by accessing the cookie settings.
14.6. CONSENT TO COOKIES
By using our platform, you consent to the use of cookies in accordance with this Privacy Policy. You can withdraw or modify your consent at any time through the cookie settings on our platform or your browser preferences.

15. CHANGES TO OUR PRIVACY POLICY
At Robro, we periodically update this Privacy Policy to reflect changes in laws, regulations, business practices, or our services. These updates ensure continued compliance and transparency in how we process personal data.
Users will be notified of significant changes through announcements on our platform or, where required by law, via email. The updated Privacy Policy will take effect on the “Effective Date” indicated at the top of this document.
By continuing to use our platform and services after the updates become effective, you confirm your acceptance of the revised terms. For material changes requiring explicit consent, such as those mandated by applicable laws, we will request your agreement before applying the updates.

16. HOW TO CONTACT US
If you require any more information or have any questions about our privacy policy, please feel free to contact us by email at admin@hash-hedge.com .