The Company is primarily responsible for processing your personal data in accordance with this Policy. While we are the primary data controller, some processing activities may involve third parties, as outlined in subsequent sections of this Policy.

As the data controller, we are responsible for ensuring that all personal data processing activities described in this Policy comply with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679). The GDPR provides a comprehensive legal framework for protecting the rights and freedoms of individuals with respect to the processing of their personal data.

We adhere to data minimization principles, collecting only the essential personal data necessary for the operation of our services as outlined in this Policy.

1. Account Information

We obtain essential account data directly from you or authorized third parties to facilitate login access and enable you to make purchases.

Third-Party Integration Data

For Steam users, we receive specific account information from Valve Corporation, including your Steam ID, username, and profile picture. This information allows us to verify your Steam identity and access publicly available account details, such as your virtual item inventory.

Please note: Valve Corporation's use of your personal data is independent of our control. We encourage you to review Valve's Privacy Policy for information on their data handling practices.

2. Personal Data Collection

When you register an Account on the Website, we collect your email address. Upon successful registration, we automatically create your Account and assign a unique Consumer ID for internal reference.

Automatic Data Collection

When you access and use the Website, we automatically collect the following information:

• Network Data: IP address, location information, and details about your mobile operator or internet provider.
• Device Information: Operating system, browser specifications, screen resolution, time zone, language settings, device model, and manufacturer.
• Usage Data: Session information, page visits, interface interactions, and referral sources.
• Cookie Data: We use cookies to collect certain data. Please refer to our Cookie Policy for more information.

Transaction Information

We collect data related to your transactions on the Website, including deposits, product purchases, and withdrawals to your Steam account.

Payment Processing

Although we do not directly process payments, our payment provider shares the following information with us when you make a purchase:

• A unique transaction identifier
• The payment method used
• Your IP address at the time of the transaction

Communication Records

When you contact us through the Website or via email, we collect:

• Your name
• Your email address
• Any additional information you voluntarily provide.

We use cookies for information access and storage. Specific implementation details and your options to manage cookies are outlined in our Cookie Policy.

General Principle: We will store personal data only for the duration necessary to fulfill the purposes outlined in this Policy. In the event of any dispute, we will retain data for the period required to resolve such matters.

Automatically Collected Data: 14 months from your last website visit.

Account and Transaction Data

• Stored while maintaining active account status
• Will be erased if account remains unused for 6 consecutive months

Contact Data

• Retained only for the duration of active communication
• Immediately erased upon completion of communication purpose

Payment Data

• Stored for up to 6 years from product provision date
• Maintained to support consumer dispute resolution and address potential issues

Cookie Data

• Storage period defined in the separate Cookie Policy
• Varies according to specific cookie type

Right to Access (Article 15)

You have the right to request confirmation from us regarding whether we are processing your personal data. If we are processing your data, you have the right to obtain a copy of this personal data.

Right to Erasure (Article 17)

You have the right to request the erasure (removal) of your personal data from our systems. We will comply with your erasure request in the following circumstances:

• Your personal data is no longer necessary for the original purposes of collection
• You withdraw your previously given consent, and no other legal basis exists for continued processing
• We have no legal obligation to retain your personal data under applicable legislation
• Your personal data has been processed unlawfully
• No legal restrictions prevent the exercise of this right
• Any other circumstances where erasure is required or permitted by applicable law

Right to Object to Processing Based on Legitimate Interest (Article 21)

You have the right to object to the processing of your personal data when such processing is based on our legitimate interest. Upon receiving your objection, we will cease processing your data unless we can demonstrate compelling legitimate grounds that override your interests and rights, or if the processing is necessary for the establishment, exercise, or defense of legal claims.

Right to Restriction of Processing (Article 18)

You have the right to request that we restrict the processing of your personal data in the following circumstances:

• When you have objected to processing based on our legitimate interest, we will restrict processing pending verification of whether our legitimate grounds override your rights;
• When you have contested the accuracy of your personal data, we will restrict processing until we have verified the accuracy of the data;
• When the processing is unlawful, and you oppose the erasure of your personal data, requesting the restriction of its use instead;
• When we no longer need the personal data for processing purposes, but you require the data for the establishment, exercise, or defense of legal claims.

Right to Lodge a Complaint (Article 77)

You have the right to file a complaint with the relevant supervisory authority if you believe that the processing of your personal data violates your rights under the General Data Protection Regulation (GDPR).

You can always contact us for any issue concerning the processing of Your personal data, including complaints.

Nevertheless, if you suppose that your rights under applicable data protection legislation have been violated, you can lodge a complaint either:

With the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our incorporation). The Website of the Commissioner http://www.dataprotection.gov.cy/; or

With the data protection authority of the country of Your habitual residence or place of work. You can find the list of all EU Data Protection Authorities on the Website of the European Data Protection Board https://edpb.europa.eu/about-edpb/board/members_en.

How Do We Exercise Your Rights?

We take data protection very seriously and therefore we have dedicated our support personnel to handle Your requests in relation to your rights stated above. You can always reach them at [email protected].

Do We Collect Information from Children?

Our Website is not intended for use by children, and therefore we do not collect or process, at least intentionally, the personal data of individuals under 18 (eighteen) years.

Will Your Personal Data Be Shared with Anyone?

To ensure the proper operation of the Website, we may share Your personal data with third parties, including:

Our contractors, subcontractors, external consultants. We may engage third parties to service the Website and, accordingly, transfer Your personal data to them. We guarantee that these persons have a contractual obligation with us to process Your personal data in accordance with this Policy and the applicable law.

Website Hosting Providers. We use the services of hosting providers and host our Website on their server. In this regard, they may have access to Your personal data, but in encrypted form.

Analytics and IT service providers. We may also use the services of companies that help us to analyze the operation of the Website, Your interaction with it and help us to monitor and prevent any external threats to the Website. We currently use the services of the following providers:

Cloudflare. Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107, USA helps us to optimize the operation of the Website and ensure its protection. Please read more in Cloudflare Privacy Policy. The United States does not provide an adequate level of personal data protection, so standard contractual clauses (SCC) apply to the transfer of Your personal data to Cloudflare.

Google. Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Dublin, 368047, Ireland provides Google Analytics services. Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA provides reCAPTCHA services. Please read more in Google Privacy Policy. The United States does not provide an adequate level of personal data protection, standard contractual clauses (SCC) apply to the transfer of Your personal data to Google LLC.

Openid. We use OpenId services to identify your Steam community profile and access information about your Steam account. For this purpose, we share your Steam with https://openid.net/.

What are Cookies?

Cookies are small data files stored on your computer or mobile device. They contain specific information, such as your preferred language or site settings, which your browser may retransmit to us when you revisit our website, depending on the cookie's lifespan.

Cookie Types and Purpose

The following table provides detailed information about the cookies we use, including their type, purpose, and expiration time.

Essential and Security cookies are strictly necessary for technical reasons (Technically necessary cookies). These cookies do not require your consent.

Analytics cookies are optional. You can manage them through our cookie settings or by configuring your browser to reject cookies. Specific instructions can be found in your browser's manual. You can also delete existing cookies on your device at any time via browser settings. Here are management links for popular browsers:

• Google Chrome
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

Yes, we will update this Policy as necessary to remain compliant with relevant laws. The current version will be posted on the Website, so please monitor all updates.