PRIVACY

We process data about your use of our website and services (“

”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. We obtain such data through the use of cookies and similar technologies.

We process usage data to have a better understanding of how you use our website and services. The legal basis for this processing is our legitimate interest, namely monitoring and improving our website and services and accommodating the services for individual interests of every User.

We process your account data (“

”). The account data may include your name and adress, email address, phone number, country, STEAM ID, and other data that you provide while registering as well as your purchase history. We obtain such data directly from you.

We process account data for the purposes of operating our website, providing our services, ensuring the security of our website and services and communicating with you as our User. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract as well as our legitimate interest, namely monitoring and improving our website and services.

We process information relating to provision of services by us to you in our website (“

”). The transaction data may include your contact details, bank account details and the transaction details. The transaction data is processed to supply purchases goods and provide services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you, other Users and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

We process information related to anti-money laundering prevention measures (“

”). AML data may additionally include address or residence, ID documentation, including your photo, documents regarding your source of wealth, utility bill and others. We are required by the law to request such information to carry out “know your client” obligations.

We may process information that you provide to us for the purpose of subscribing to our email messages and newsletters (“

”). The messaging data is processed to send you the relevant messages and newsletters. The legal basis for this processing is your consent. Also, if you are a User and you do not object, we may also process messaging data on the basis of our legitimate interest, namely seeking maintain and improve customer relations.

We may process information relating to any communication that you send to us (“

”). The correspondence data may include the communication content and metadata associated with the communication. In case of communication through our website, the website will generate the metadata associated with communications made using the website contact forms. The correspondence data is processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business, ensuring uniform and high quality consultation practice and for investigating disputes between you and our employees.

We may process any of your personal data identified in this notice where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

We may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Your personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case it shall be kept for no longer than:

will be retained for as much as will be necessary for the relevant processing purposes;

will be retained for no longer than

following your last update on the account;

will be retained for no longer than

following the end of provision of services;

will be retained as long as it is necessary to comply with the related legal requirements;

 will be retained for as long as your account is active, unless you withdraw your consent earlier;

 will be retained for no longer than

following the end of such communication.

Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

We may disclose your personal data to other Users you purchased Products from or our Platform, only to the extent necessary for the purposes of providing invoices on your request.

We may disclose your personal data to any member of

, including our subsidiaries, our ultimate holding company and all its subsidiaries, insofar as reasonably necessary for the purposes set out in this notice. Such may include internal administration purposes as well as provision/sharing of IT services or data centers in our group.

We may disclose your personal data to our

and/or

 insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We may disclose your personal data to our

,

 insofar as reasonably necessary for the purposes of protecting your personal data and fulfilling our legal obligations.

We may disclose your personal data to our payment service providers. We will share transaction data with our

only to the extent necessary for the purposes of processing your payments, transferring funds and dealing with complaints and queries relating to such payments and transfers.

We may disclose your personal data to

 insofar as it is reasonably necessary to provide specific services (including, providers of servers and maintenance thereof, email service providers). We take all the necessary measures to ensure that such subcontractors would implement proper measures to ensure security and privacy of your personal data.

In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is

to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Persons, indicated in this Section may be established

,

and

. In case we will transfer your personal data to such persons, we will take all the necessary and in the legal acts indicated measures to ensure that your privacy will remain properly secured, including where appropriate, signing standard contractual clauses for transfer of data.

In case your consent, we will be allowed to send you marketing messages via email and/or leave a notification in an Account to inform you on what we are up to.

Also, if we already have provided services to you and you do not object we will inform you about our other products that might interest you including other information related to such.

You may opt-out of receiving marketing messages at any time, by:

choosing the relevant link in any of our marketing messages;

contacting us via email.

Please be informed that as our business activities consist of a network of closely related services, it may take a few days until all the systems are updated, thus you may continue to receive marketing messages while we are still processing your request.

The opt-out of the marketing messages will not stop you from receiving messages directly related to the provision of services set in the Terms & Conditions.

Your principal rights under data protection law are as follows in the Sections ahead.

- you have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information.

- you have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. Please notice that you may exercise most of this right by logging into your account and changing the data.

– this applies in some circumstances only. Those circumstances include when: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) you withdraw consent to consent-based processing and there are no other legal basis to process data; (iii) you object to the processing under certain rules of applicable data protection laws; (iv) the processing is for direct marketing purposes; or (v) the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. Such exclusions include when processing is necessary: (i) for exercising the right of freedom of expression and information; (ii) for compliance with our legal obligation; or (iii) for the establishment, exercise or defense of legal claims.

In some circumstances you have the

of your personal data. Those circumstances are when: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, however we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defense of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.

You have the

of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the purposes of the legitimate interests pursued by us or by a third party.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes).

You have the

of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

. To the extent that the legal basis for our processing of your personal data is:

consent; or

performance of a contract or steps to be taken at your request prior to entering into a contract, necessary to enter into such, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Cookies are small textual files containing identifier that is sent by a web server to your web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies are small textual files containing identifier that is sent by a web server to your web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

In the website we use cookies of three main types, for the following purposes:

required cookies – used to ensure proper performance of the website, security of customers and their data, provision of high-quality services and effortless set-up of an account;

functional cookies – used to enhance the website user experience, analyze the use of the system and in accordance to such improve the provision of services;

advertising cookies – used to observe user online behavior and optimize marketing campaigns according to such information.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.