Roostoo Privacy Policy

Version 1.4

Effective Date: May 2, 2020

Roostoo (“we” or “us” or “our”) respects the privacy of its users (“user” or “you”) that use our mobile “Roostoo” application (“App”), (“Website”) and other digital services (including “App”, “Website” collectively, the “Services”) offered by “Roostoo”.

This Privacy Policy explains when and why we collect personal information about people who use our App or visit our Website or use our Services and how we use the personal information, the conditions under which we may disclose your personal information to others, and how we keep personal information secure. This Privacy Policy also explains how we use cookies and similar technology on our Website and in connection with our Services.

Please note that your access to and use of our App, or Website, or Services, is subject to our Terms of Service which is located at Accordingly, by accessing our App, or Website, or using any of our Services, or otherwise howsoever providing us with your Personal Data, you are agreeing to be bound by this Privacy Policy. Should you disagree with any clause in the Privacy Policy and Terms of Service, please immediately cease your use of our Website, our App, our Content and our Services.

Information You Provide to Us

The types of personal information we collect depend on the product or service you (“You”) receive from us. This information may include, but not limited to:

(a) the e-mail addresses of those who communicate with us via e-mail; (b) information related to your use of the App and Website. Usage Data includes your personalized virtual portfolio, virtual trade activities, 1IP address, Cookies, geographic location, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and date and time of your request; (c) aggregate information concerning app usage patterns and what app pages you access or visit; (d) information volunteered by the user (such as survey information and/or site registrations); (e) information regarding the type of mobile device or tablet (device ID, model and manufacturer, operating system, version) you are utilizing to access our App, Website, and Services; (f) information such as your name, profile picture, favorite crypto, nationality, university or school, email address and password creation, when you participate in any interactive features of the Services (such as API keys, user accounts, configuration settings, and user referrals); and (g) any other information that you share with Roostoo.

Roostoo uses collected information for the following purposes:

  • To take steps such as processing your registration on our App and Website or sending you information about changes to our terms or policies;
  • Where necessary for purposes which are in Roostoo’s or third parties’ legitimate interests such as (a) to provide the information or content you have requested; (b) to contact you about our programs, products, features or services; (c) for internal business purposes such as identification and authentication or customer service and user preference syncing between devices; (d) to ensure the security of our App and Website, by trying to prevent unauthorized or malicious activities; (e) to enforce compliance with our Terms of Use and other policies; (f) to help other organizations (such as copyright owners) to enforce their rights; and (g) to tailor content, advertisements, and offers for you or for other purposes disclosed at the time of collection.
  • Where you give us consent, such as (a) where you request us to send marketing information to you via a medium where your consent is needed, including alerts via mobile push notifications; (b) where you give us consent to place cookies and to use similar technologies; and (c) on other occasions where we ask you for consent, for a purpose we explained at that time.
  • When legally required to do so, we may also provide access to your personally identifiable information to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of our Services, to limit our legal liability and protect our rights, or to protect the rights, property or safety of users of the App, Website or the public.

Sharing of Information

When we have your permission, or under the following circumstances:

  • We may share your information with the third party partners that host mock trading competitions on the Roostoo App, if you are a direct participant of the partner’s mock trading competitions.
  • We may share your information when in connection with, or during negotiations of, any merger, sale of Roostoo assets, financing or acquisition of all or a portion of our business by another company. Between and among Roostoo and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership.
  • We may allow third parties (vendors, consultants and other service providers who need access to such information to carry out work on our behalf) to provide analytics services and serve advertisements on our behalf across the internet and in applications. This information may be used by Roostoo and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit
  • We may aggregate, anonymize, and publish data for statistical and research purposes only. For example, we may compile and share information related to the popularity of certain products tracked by users. In any such instance, the information will not be able to be traced back to any individual.
  • If you wish to opt out possible usage of your personal data, or not receive marketing information about our programs, products, features or services, you may send an email to us at


Roostoo will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

Roostoo will store some the personal information you provide on its secure servers. Information that Roostoo collects may be stored and processed in and transferred between any of the countries in which Roostoo operates to enable the use of the information in accordance with this privacy policy.

We take precautions to ensure the security of your personal information. However, we cannot guarantee that hackers or unauthorized personnel may gain access to your personal information despite our efforts. You should note that in using the Roostoo Services, your information will travel over the Internet and through third-party infrastructures and mobile networks, which are not under our control.

Roostoo is not responsible for the privacy policies or practices of any third party.We cannot protect, nor does this Privacy Policy apply to, any information that you transmit to other users. You should never transmit personal or identifying information to other users.

Data Storage

Roostoo uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Roostoo and the related App, Website, and Services. Roostoo owns the code, databases, and all rights to the related App, Website, and Services.


We do not intentionally gather Personal Data from visitors who are under the age of 18. If a child under 18 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 18, we will attempt to delete the information as soon as possible.

Transfer and Processing of Personal Information

Roostoo is located in Hong Kong and the terms of this Privacy Policy and the related Terms of Use shall be governed by and construed in accordance with the laws of the Hong Kong SAR, without regard to any principles of conflicts of law. If you are not located in Hong Kong, by accessing the App, Website and Services and providing personal information through it, you agree and acknowledge and consent to the collection, maintenance, processing, and transfer of such information in and to Hong Kong and other countries and territories. These other jurisdictions may have different privacy laws from your home jurisdiction and provide different levels of protection of personal information. Roostoo does have processes and procedures in place to provide adequate levels of protection to protect the transfer of data from the European Union. You agree that the terms of this Privacy Policy and the Terms of Use will apply and you consent to the transmission and processing of your personal information in any jurisdiction.

Information that Roostoo collects may be stored and processed in and transferred between any of the countries in which Roostoo operates to enable the use of the information in accordance with this privacy policy. In addition, personal information that you submit for publication on the website may be published on the internet and may be available around the world. You agree to such cross-border transfers of personal information.

Do Not Track (DNT): Because there is currently no industry or legal standard for recognizing or honoring DNT, we do not currently respond to DNT signals.

EU and EEA Users’ Rights

If you are habitually located in the European Union or European Economic Area, you generally have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We briefly describe these rights below:

You have the right to access your personal data and, if necessary, have it amended, deleted or restricted. In certain instances, you may have the right to the portability of your data. You can also ask us to not send marketing communications and not to use your personal data when we carry out profiling for direct marketing purposes. You can opt out of receiving e-mail newsletters and other marketing communications by following the opt-out instructions provided to you in those e-mails. Transactional account messages will be unaffected even if you opt out from marketing communications.

California Consumer Privacy Act (CCPA)

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Roostoo disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that Roostoo delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.


Any questions about this Privacy Policy should be addressed to this e-mail address: