PRIVACY POLICY
Introduction and Overview
Thank you for visiting our website. This Privacy Policy explains how we collect,
use, and protect your personal information when you use our platform to purchase CS
skins. It applies to users who interact with our website and services, including
customer support channels.
This Privacy Policy is effective as of 23 September 2024 and supersedes all previous
versions. It applies to all users, including residents of the European Union (EU).
We may periodically update this policy to reflect changes in our practices,
applicable laws, or regulatory requirements. Whenever updates are made, the "Last
Updated" date will be revised.
GDPR Compliance
We are fully committed to complying with the General Data Protection Regulation
(GDPR) and other applicable privacy laws. We ensure that personal data is collected
and processed in accordance with the key principles of GDPR, including:
• Lawful Basis: We process your personal data based on lawful bases,
such as your consent, the performance of a contract, compliance with legal
obligations, protection of vital interests, or our legitimate interests.
• Consent: We will always seek your informed and explicit consent
before collecting or processing your personal data for purposes requiring consent.
You may withdraw consent at any time without affecting the legality of processing
based on prior consent.
• Data Subject Rights: You have rights regarding your personal data,
including the right to access, rectify, erase, restrict processing, data
portability, and object to processing. We provide mechanisms to exercise these
rights and respond promptly to requests.
• Accountability and Documentation: We maintain detailed records of
our data processing activities, implement technical and organisational safeguards,
and conduct regular assessments to mitigate risks to personal data.
• International Data Transfers: If personal data is transferred
outside the European Economic Area (EEA), we ensure that appropriate safeguards
(e.g., Standard Contractual Clauses or Binding Corporate Rules) are in place to
protect your data.
Data Controller
[please provide], registered under the number + 2347035446499, with its office at 270 Murtala Muhammed Way Yaba, Lagos State Nigeria , is the data controller responsible for collecting, using, and protecting your personal data in compliance with applicable laws, including GDPR.
Information Collection
We collect personal data from you when you interact with our website or services,
including:
• Contact Information: for example, email address, phone number, and
address.
• User Account Information: for example, username, login information,
account
preferences, profile picture, steam ID, session data, activity logs, clickstream
data, and usage-related data.
• Identity Information: for example, name, surname, government-issued
or national ID
number, date of birth and details of identification documents.
• Authentication and Identification Information (including
biometrics): for example,
data associated with multi-factor authentication, facial recognition, and
fingerprints.
• Payment Information: for example, bank account details, payment card
particulars,
billing address, and information related to payment method.
• Financial InformationFinancial Information: for example, bank
account details, transaction history, and
current balance, among other relevant details.
• Transactions Information: for example, the history of orders and
transactions with
us, alongside the current balance.
•Legal Compliance Information: for example, all data necessary for
legal and
regulatory compliance, including Anti-Money-Laundering (“AML”) and
Know-Your-Customer (“KYC”) related requirements (including proof of address,
photographic evidence, occupation details, data from sanctions and watchlist
screening, risk assessment information, etc.).
• On-Premises Video Surveillance Information: for example, data
obtained from video
surveillance conducted at our office premises.
• Claims and Disputes Information: for example, information linked to
claims and
disputes that may arise.
• Technical and Device Information: for example, information about
your device,
browser type, operating system, IP address, and other technical specifics.
• User Support and Communication Information: for example, all data
related to
communication with you (e.g., email exchanges, records of incoming and outgoing
calls, chat history, user support events, surveys, etc.).
• Marketing Information: for example, data associated with your
marketing choices
and preferences.
We collect this data through forms, cookies, and direct interactions when you use
our website or engage with customer support.
Use of Personal Information
Your personal data may be used for the following purposes:
• To process and fulfil your orders.
• To provide customer support and resolve inquiries.
• To communicate with you about your orders, updates, and promotional offers
(subject to your preferences).
• To personalise your experience on our website.
• To improve our website, services, and products.
• To comply with legal obligations, such as tax and accounting requirements.
We process your personal data based on legal grounds such as the fulfilment of a
contract, legal obligations, legitimate interests, and your consent when necessary
(e.g., for marketing).
Sharing of Personal Information
Your personal data may be shared with third parties in the following instances:
• Service Providers: We share your data with trusted third-party
providers who assist with website operations, payment processing, and order
fulfilment. These providers are subject to strict data protection agreements.
• Legal Compliance: We may share your data with regulatory authorities
or law enforcement when legally required or to protect our rights.
• With Your Consent: In situations where we need to share data for
purposes beyond this policy, we will seek your explicit consent.
We do not sell or rent your personal data to third parties.
Retention of Data
We retain your personal data for the duration necessary to fulfil the purposes
outlined in this Privacy Policy unless extended retention is mandated by applicable
laws. For example, legal requirements, such as those related to Anti-Money
Laundering (“AML”), accounting, taxation, and similar regulations, may prescribe
specific retention periods. In cases where applicable laws do not specify a
particular retention period, we establish it ourselves in accordance with the
principles outlined by the GDPR. Once your personal data is no longer needed for the
purposes defined in this document, we employ secure deletion or anonymization
procedures to ensure the irreversible removal or anonymization of your information.
For instance:
• Order Information: Retained for the duration required for tax and
financial record-keeping (typically 7 years).
• Account Data: Retained while your account is active or as long as
needed for service delivery.
• Marketing Data: Retained until you opt out or withdraw consent.
When no longer needed, we will securely delete or anonymise your personal data.
Data Security
We implement strict security measures to protect your personal data from
unauthorised access, alteration, or disclosure. These measures include encryption,
secure storage systems, and restricted access to sensitive information. However, no
method of data transmission or storage is entirely secure, and we cannot guarantee
absolute security.
In the event of a security breach involving your personal data, we will notify you
and relevant authorities in compliance with applicable law.
Cookies and Tracking Technologies
We use cookies and other tracking technologies to collect information about your
browsing activities, preferences, and device details. Cookies allow us to enhance
your experience by remembering your preferences and improving our website
functionality.
For more detailed information on the types of cookies we use and how you can manage
your preferences, please refer to our [Cookies Policy]
.
Third-Party Links and Services
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these external sites. We recommend reviewing the privacy policies of any third-party sites you visit before sharing your personal information.
Your Rights and Choices
Under GDPR, you have specific rights regarding your personal data, including:
• Right to Access: You can request a copy of the personal data we hold
about you and information on how it is processed.
• Right to Rectification: If any personal data is inaccurate or
incomplete, you have the right to request corrections.
• Right to Erasure: Under certain circumstances, you can request the
deletion of your personal data.
• Right to Restriction of Processing: You can ask us to limit the
processing of your personal data in specific situations.
• Right to Data PortabilityRight to Data Portability: You have the
right to receive your personal data in a commonly used, machine-readable format or
request that it be transferred to another organisation.
• Right to Object: You may object to the processing of your data for
certain reasons, including direct marketing.
• Rights Related to Automated Decision-Making and Profiling: If
applicable, you have the right not to be subject to automated decisions that have a
significant legal or personal impact.
You can exercise these rights by contacting us using the details provided in the
"Contact Us" section.
International Data Transfers
As a company based in Cyprus and offering services to EU residents, your personal data may be transferred to countries outside the EEA for processing purposes. When such transfers occur, we ensure that appropriate safeguards are in place to comply with GDPR, including the use of Standard Contractual Clauses or other approved mechanisms.
Marketing Communications and Opt-Out
If you have provided consent to receive marketing communications, you may opt out at any time by clicking the "unsubscribe" link in any promotional email or contacting us directly. You may also manage your marketing preferences in your account settings.
Children’s Data
Our website and services are not intended for children under 16 years of age. We do not knowingly collect or process personal data from children. If we learn that we have inadvertently collected personal data from a child, we will take immediate steps to delete the information.
Breach Notification
In the unlikely event of a data breach that affects your personal data, we will notify you and the relevant authorities without undue delay, in accordance with GDPR requirements.
Complaints
If you have any concerns about how we process your personal data, we encourage you to contact us first. However, you also have the right to lodge a complaint with the relevant supervisory authority in your country if you believe that we have violated your data protection rights.
Updates to the Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The most recent version will always be available on our website. We encourage you to review this Privacy Policy periodically.
Contact Us
If you have any questions, concerns, or would like to exercise your GDPR rights,
please contact us:
270 Murtala Muhammed Way
Yaba, Lagos State
Nigeria
+ 2347035446499
finance@skinsng.com
Please provide relevant details to help us process your request effectively. We may
need to verify your identity before proceeding with certain actions to protect your
personal data.