1. INTRODUCTION AND DATA CONTROLLER
This Privacy Policy explains how personal data is collected, used, stored, and protected when you access or use games available on https://growbit.net/ as the primary domain, together with its official mirror domains, and any related software, games, wallets, features, or services operated in connection with the platform (collectively, the "Website" or the "Service").
The Website is operated by 0-000-000000 Sociedad de Responsabilidad Limitada, a company duly incorporated under the laws of the Republic of Costa Rica, CIN 0-000-000000, with its registered office at Calle 4, Paso de la Vaca, San José, Costa Rica (hereinafter referred to as the "Company", "GrowBit", "we", "us", or "our").
For the purposes of Costa Rican data protection law, the Company acts as the data controller in respect of personal data processed through the Website.
This Privacy Policy is adopted in accordance with Law No. 8968 – Ley de Protección de la Persona frente al Tratamiento de sus Datos Personales, its implementing regulations, and other applicable Costa Rican legal requirements.
By accessing or using the Website, the Service, or any official mirror domains operated by the Company, you acknowledge that you have read and understood this Privacy Policy.
GrowBit is an independent platform and is not affiliated with, endorsed by, or sponsored by Ubisoft or Growtopia, or by any of their respective owners, publishers, developers, affiliates, officers, employees, licensors, or representatives. References to Growtopia, World Locks, Diamond Locks, Blue Gem Locks, or DLS are used solely to identify supported virtual items, virtual currencies, or user-facing gameplay integrations.
2. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy applies to personal data processed in connection with:
- Registration and use of an account on the Website;
- Participation in online gambling, gaming, wagering, and related activities;
- Deposits, gameplay, tips, transfers, and withdrawals using Growtopia-related virtual items and currency, including World Locks, Diamond Locks, and Blue Gem Locks, counted on the Website as Diamond Locks (DLS);
- Cryptocurrency deposits and withdrawals, where such functionality is enabled;
- Fiat deposits and withdrawals, once such functionality is enabled;
- Access via the Website and any official mirror domains operated for redundancy, accessibility, continuity of service, or regional availability;
- Communications with customer support, compliance, legal, or technical teams; and
- Monitoring, security, AML/KYC, and fraud-prevention measures implemented to protect the integrity of the Website.
This Privacy Policy must be read together with the Terms and Conditions, AML and KYC Statement, Responsible Gaming Policy, System Fairness Policy, Risk Disclosure Statement, and any other notices or policies published on the Website.
3. CATEGORIES OF PERSONAL DATA PROCESSED
Depending on how you interact with the Website, the Company may collect and process the following categories of personal data:
3.1. Identification and Contact Data
Information provided during account registration or verification, such as your full name, date of birth, nationality, country of residence, email address, username, and other contact details.
3.2. Account and Game-Account Data
Information relating to your GrowBit account and supported third-party game accounts, including your account ID, account status, login history, linked or verified Growtopia account information (including the GrowID you provide for deposits and withdrawals), and proof of ownership or control of game accounts used for in-game trades, deposits, and withdrawals.
3.3. Verification and Compliance Data
Where required for legal, security, AML/CFT, fraud-prevention, responsible-gaming, or risk-management purposes, copies of identification documents, age-verification information, proof of address, proof of ownership or control of game accounts or cryptocurrency wallets, source-of-funds information, source-of-wealth information, and other data necessary to confirm your identity, eligibility, or lawful use of the Website.
3.4. Transaction and Gameplay Data
Records of deposits, wagers, wins, losses, bets, game rounds, withdrawals, transfers, tips, bonuses, promotions, balances of DLS, cryptocurrency balances, fiat balances where enabled, wallet addresses, transaction hashes, transaction timestamps, game IDs, round IDs, and related activity on the Website.
3.5. Technical and Usage Data
Automatically collected data such as IP addresses, device identifiers, browser type, operating system, session logs, login history, authentication events, security events, activity patterns, pages viewed, clicks, technical logs, and other data used for security, fraud prevention, troubleshooting, analytics, and system integrity.
3.6. Communications Data
Records of communications with customer support, compliance, legal, or technical teams, including emails, chat messages, support tickets, verification correspondence, complaints, disputes, and related communications.
3.7. Cookies and Similar Technologies
Information collected through cookies, local storage, analytics tools, pixels, and similar technologies, as described in the Cookies and Similar Technologies section of this Privacy Policy.
3.8. Sensitive Personal Data
The Company does not intentionally collect sensitive personal data, such as health data or biometric data, except where strictly required to comply with legal obligations, verify identity, prevent unlawful access to the Platform, protect users, or prevent fraud, abuse, or other unlawful activity.
4. PURPOSES AND LEGAL BASES FOR PROCESSING
Personal data is processed only where there is a lawful basis under Costa Rican law. The Company processes personal data for the following purposes:
- Performance of a contract, including account creation, account management, gameplay, deposits, withdrawals, redemptions, balance management, and customer support;
- Compliance with legal obligations, including AML/CFT requirements under Law No. 7786, Costa Rican data protection requirements, and other applicable legal obligations;
- Security and fraud prevention, including enforcement of the one-account-per-user rule, detection of multi-accounting, collusion, botting, exploit abuse, tip laundering, trade laundering, sanctions exposure, and other prohibited conduct;
- Website operation, maintenance, and improvement, including system monitoring, troubleshooting, analytics, performance monitoring, infrastructure reliability, and product development;
- Marketing communications, where you have provided consent or where otherwise permitted by law;
- Responsible-gaming controls, including cooling-off periods, self-exclusion, account restrictions, and harm-prevention measures;
- Protection of legitimate interests, such as preventing abuse of services, protecting account ledgers, defending legal claims, enforcing contractual rights, and maintaining platform integrity;
- Creation of aggregated and anonymized statistical data for analytical, operational, security, reporting, or business purposes.
If you do not provide the personal data requested, the Company may be unable to register your account, provide services, process withdrawals or redemptions, complete verification, or respond to inquiries or complaints.
Where processing is based on consent, you may withdraw such consent at any time, subject to legal, contractual, security, AML/CFT, fraud-prevention, or record-retention limitations.
5. MARKETING COMMUNICATIONS
The Company may send marketing or promotional communications relating to Website features, bonuses, tournaments, races, promotions, rewards, or updates only where you have provided consent or where such communications are otherwise permitted by law.
You may opt out of marketing communications at any time by contacting customer support or using available opt-out mechanisms. Opting out does not affect your ability to use the Website, although you may no longer receive promotional notices.
Where you voluntarily participate in promotions, competitions, leaderboards, races, or similar activities and accept prizes or rewards, the Company may, where lawful, reference your username, nickname, avatar, ranking, reward amount, or similar non-real-name information for promotional, leaderboard, or transparency purposes.
Real names or directly identifying details are not published for promotional purposes without explicit consent, unless required by law.
6. COLLECTION OF PERSONAL DATA
Personal data is collected directly from you when you:
- Register an account;
- Participate in gameplay;
- Make deposits;
- Request withdrawals or redemptions;
- Use tips, transfers, bonuses, races, rewards, or promotions;
- Complete verification;
- Communicate with customer support, legal, compliance, or technical teams;
- Submit complaints, disputes, or appeals; or
- Interact with the Website through its technical features.
Certain technical data is collected automatically when you access or use the Website.
The Company may also receive limited personal data from trusted third-party service providers acting on its behalf, such as identity verification providers, fraud-prevention providers, blockchain analytics providers, infrastructure providers, hosting providers, analytics providers, customer-support tools, email delivery providers, security providers, game providers, payment providers, or transaction security providers.
Such data is processed strictly in accordance with this Privacy Policy and applicable contractual, technical, and organizational safeguards.
7. DATA RECIPIENTS AND ACCESS
Access to personal data is strictly limited to authorized personnel and service providers who require such access to perform their duties, including compliance, payments, security, fraud review, customer support, legal, and technical functions.
The Company does not sell or rent personal data.
Personal data may be disclosed to third parties only where necessary to:
- Provide, operate, secure, or improve the Website;
- Facilitate payment, deposit, withdrawal, redemption, or transaction processing;
- Verify identity, age, account ownership, wallet ownership, or source of funds;
- Comply with legal, regulatory, AML/CFT, sanctions, tax, accounting, or reporting obligations;
- Prevent fraud, abuse, collusion, botting, exploit abuse, money laundering, terrorist financing, sanctions violations, or unlawful activity;
- Investigate disputes, suspicious activity, complaints, technical issues, or security incidents;
- Respond to lawful requests from competent authorities;
- Enforce the Terms and Conditions or other policies; or
- Protect the rights, safety, property, users, providers, or integrity of GrowBit.
Where third-party service providers process personal data on behalf of the Company, contractual safeguards are in place to ensure confidentiality and security in accordance with Costa Rican law.
8. INTERNATIONAL DATA TRANSFERS
Due to the technical nature of online services, certain service providers supporting the Website may be located outside Costa Rica.
Where personal data is transferred internationally, the Company ensures that appropriate legal, contractual, technical, and organizational safeguards are implemented to protect personal data in accordance with Law No. 8968 and other applicable Costa Rican legal requirements.
These safeguards may include data-processing agreements, confidentiality obligations, access controls, encryption, security monitoring, and other protective measures.
9. DATA RETENTION
Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, including providing the Website, complying with legal obligations, resolving disputes, preventing fraud, enforcing agreements, maintaining accurate account ledgers, and protecting the integrity of the Website.
Data relating to identity verification, transactions, AML/CFT monitoring, fraud-prevention, account ledgers, and security-related records is retained for at least five (5) years following account closure, the last transaction, or the end of the relevant business relationship, in accordance with Costa Rican law, unless a longer retention period is required or permitted by applicable law.
Technical logs and analytics data may be retained for shorter periods unless needed for security, fraud prevention, dispute resolution, compliance, or legal claims.
After expiry of applicable retention periods, personal data is securely deleted, archived, or irreversibly anonymized unless a legal hold, investigation, dispute, enforcement need, or other lawful basis applies.
10. SECURITY OF PERSONAL DATA
The Company implements appropriate technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, disclosure, or destruction.
These measures may include access controls, authentication controls, encryption or hashing where appropriate, network and infrastructure security, system monitoring, security logging, internal security policies, role-based access, incident detection and response, backup and recovery procedures, and vendor security controls.
No online service can guarantee absolute security. Users are responsible for safeguarding their login credentials, using strong passwords, enabling two-factor authentication where available, protecting their email account, and promptly notifying the Company of any suspected unauthorized access to their account.
11. DATA SUBJECT RIGHTS
Under Law No. 8968, you may have the right to:
- Access your personal data;
- Request correction of inaccurate or incomplete data;
- Request deletion or restriction of data, subject to legal, AML/CFT, fraud-prevention, accounting, security, dispute-resolution, and record-retention obligations;
- Object to certain processing activities;
- Withdraw consent where processing is based on consent;
- Opt out of marketing communications; and
- Lodge a complaint with the Costa Rican data protection authority, where applicable.
Requests may be submitted to:
The Company may require identity verification before processing a request. The Company may refuse or limit requests where permitted by applicable law, including where fulfilling the request would conflict with legal obligations, AML/KYC requirements, fraud-prevention needs, security obligations, dispute handling, or the rights and freedoms of others.
13. CHILDREN AND AGE RESTRICTIONS
The Website and Service are intended only for individuals who are at least eighteen (18) years old and who have reached the minimum legal age required to access online gambling, gaming, wagering, cryptocurrency gambling, or similar services in their jurisdiction, whichever is higher.
The Company does not knowingly allow individuals under the applicable minimum age to register, access, or use the Website.
If the Company becomes aware that an underage individual has provided personal data or used the Website, the Company may restrict, suspend, or close the account and take steps to delete or limit the relevant personal data, subject to legal, AML/CFT, fraud-prevention, security, and record-retention obligations.
14. THIRD-PARTY LINKS AND SERVICES
The Website may contain links, integrations, games, tools, wallets, software, or services provided by third parties.
Third-party providers may process personal data under their own privacy policies and terms. The Company is not responsible for the privacy practices, content, security, or actions of third-party websites, services, games, wallets, platforms, or communication channels that are not controlled by the Company.
You should review the privacy policies and terms of any third-party services you access.
15. MIRROR DOMAINS
growbit.net is the primary domain of the Website.
Any other domains designated by the Company may operate as official mirror domains for redundancy, accessibility, continuity of service, or regional availability.
The same Privacy Policy, Terms and Conditions, account rules, AML/KYC controls, data-processing practices, security measures, restrictions, and enforcement rights apply regardless of which official domain is used.
Users should ensure that they access only official GrowBit domains. The Company is not responsible for phishing websites, impersonation domains, fake support accounts, malicious links, wallet-draining websites, or third-party websites falsely claiming to be associated with GrowBit.
16. CONTACT DETAILS
For privacy-related questions, legal inquiries, data subject requests, or compliance matters, contact:
For general account or support inquiries, contact:
For marketing-related inquiries, contact:
You should contact the Company from the email address associated with your GrowBit account whenever possible.
17. UPDATES TO THIS PRIVACY POLICY
This Privacy Policy may be updated periodically to reflect changes in legal requirements, business practices, security practices, Website features, supported currencies, mirror domains, provider integrations, or operational needs.
Updated versions will be published on the Website with the revised effective date.
Continued use of the Website after updates constitutes acceptance of the revised Privacy Policy, unless mandatory law requires otherwise.
18. GOVERNING LAW
This Privacy Policy is governed by the laws of the Republic of Costa Rica, unless mandatory data protection, consumer-protection, or other applicable law in your jurisdiction requires otherwise.
GrowBit is an independent platform and is not affiliated with, endorsed by, or sponsored by Ubisoft or Growtopia, or by any of their respective owners, publishers, developers, affiliates, officers, employees, licensors, or representatives. References to Growtopia, World Locks, Diamond Locks, Blue Gem Locks, DLS, or related names are used solely to identify supported virtual items, virtual currencies, or user-facing gameplay integrations.
Questions? Email legal@growbit.net