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PRIVACY POLICY

Privacy Policy
Last updated: Mar 31, 2022


INTRODUCTION

This Privacy Policy sets out how, we, SkinsMonkey being the Data Controller, are
committed to safeguard your privacy and how we collect, retain, process, share
and transfer your personal data when you visit the Website and/or the
Application and use our Service.

This Privacy Policy does not apply to websites, applications, or services that
we do not own or control.

By Personal Data or Data, we mean any information that can either identify you
as an individual or that can be connected to you indirectly, that we may
collect, retain, process, share, and transfer when you visit our Website and/or
Application and use SkinsMonkey Service.

Other capitalized terms in this Privacy Policy shall have the meanings defined
in the SkinsMonkey Terms of Use.


DATA CONTROLLER DETAILS

The following companies of SkinsMonkey are joint controllers of Personal Data
processed under this Privacy Policy. In this respect, the below companies
jointly undertake the processing of the Personal Data.

Virtual Asset Empire Ltd,
13 Kypranoros Str.,
Evi Building, 1st Floor, Office 102,
1061 Nicosia, Cyprus

Under the arrangement between the companies of SkinsMonkey, VIRTUAL ASSET EMPIRE
LTD is responsible for exercising of the rights of the data subjects and for
provision of the information to the data subjects who can use VIRTUAL ASSET
EMPIRE LTD as a contact point.


DATA PROTECTION OFFICER

You may contact the Data Protection Officer of SkinsMonkey with regard to all
issues related to the processing of your Personal Data and to the exercise of
your rights under GDPR using the following contact details:

VIRTUAL ASSET EMPIRE LTD

Email: gdpr@skinsmonkey.com

Virtual Asset Empire Ltd, 13 Kypranoros Str., Evi Building, 1st Floor, Office
102, 1061 Nicosia, Cyprus


PERSONAL DATA WE COLLECT FROM YOU

 1. Basic Account Data

This is the Personal Data that is provided by you or collected by us to enable
you to sign up for and use the Service.

 2. Personal Data collected from third parties

When you sign in SkinsMonkey through your Steam account we receive User data
from a third party, namely, Valve Corporation. The Personal Data we receive is
Steam ID, avatar, username. We will be able to identify your Steam community
profile and access public information related to your Steam account, including
the list of your virtual items.

 3. Personal Data collected directly from you

Additionally, we will ask you to provide your email in order to create your
account and communicate with you the latest news about our Service.

Once you sign in, your SkinsMonkey Account will be automatically created and
assigned with an Account ID (the "SkinsMonkey ID") that is later used to
reference your SkinsMonkey Account without directly exposing your personal
information. You also have the option to provide us with additional Personal
Data in order to make your account more personalized.

 4. Usage Data

The Personal Data collected directly and/or indirectly when you are accessing
and/or using the Service via Application and/or Website are the following:

 * IP address and location info (country, city, etc);

 * Device information (screen size, OS, browser information);

 * OS information (name, version, language);

 * Information sent by you in the form of messages in the online chat with
   technical support. Information transmitted in support chat is confidential
   and protected;

 * Information you may provide when you pay for a virtual item purchase a
   product or service from us, including information necessary to process your
   orders with the relevant payment merchant, which may include the amount of
   any transaction, but will not include your financial information, which will
   only be submitted directly to the payment merchant under secure protocols;

 * Cookies. We use "Cookies", which are text files placed on your computer, and
   similar technologies (e.g. web beacons, pixels, ad tags and device
   identifiers) to help us personalize the Service for you, analyze how you use
   our Service, as well as improve the Service we are offering, improve
   marketing, analytics and/or enhance the Website and Application functionality
   and performance. For further information in relation to the use of cookies
   please visit our Cookies Policy.

 * Log data related to your activity on SkinsMonkey Website.

 * Anonymous data. SkinsMonkey also processes anonymous data, aggregated or not,
   to analyze and produce statistics related to the habits, usage patterns, and
   demographics of customers as a group and/or as individuals. Such anonymous
   data does not allow the identification of the Users to which it relates.
   SkinsMonkey may share anonymous data, aggregated or not, with third parties.

 5. Payment and Purchase Data

Purchase Data is the Personal Data that you provide for the purposes of signing
up for our paid plans to access additional features/functionality, or to make
any purchases through SkinsMonkey.

The Personal Data such as your name, financial information, or cardholder data,
and any other billing information, will be submitted directly to, processed, and
stored by the respective Payment Service provider upon your consent to their
privacy policies.

We may receive Personal Data from our payment partners such as the sum of
payment to enable us to send you invoices, process your payment, and provide you
with what you've purchased.

 6. KYC Data

In the event you want to perform certain transactions on the Website or
Application, you might be required to go through the KYC (Know-Your-Client)
procedure, which is carried by third-party identification service provider
during which it will collect from you the following information and documents:

 * First and last name;
 * Date of birth;
 * Gender
 * ID document (i.e. passport) number
 * Copy of your ID document
 * Picture of you holding ID document
 * Address
 * Utility bill
 * Citizenship
 * Residence
 * Mobile phone number


SHARING YOUR PERSONAL DATA

SkinsMonkey does not sell Personal Data. SkinsMonkey may disclose Personal Data
to the following parties:

 * Payment processors retained by SkinsMonkey to process payments of the users
   of the Services (these companies may be located anywhere in the world but
   mainly they are located in the European Union);
 * Providers of hosting, maintenance, and security services retained by
   SkinsMonkey to run the Website (these companies may be located anywhere in
   the world but mainly they are located in the European Union);
 * Advertising and marketing companies that aggregate Personal Data from
   different sources to evaluate certain personal aspects relating to the data
   subject, to perform marketing research and to provide advertising and
   marketing services to third parties (these companies may be located anywhere
   in the world but mainly they are located in the European Union);
 * Government authorities including tax authorities and police (it may be
   government authorities of any country but mainly it is government authorities
   of the European Union);
 * Companies providing analytic services such as Google Analytics.
 * Valve Corporation in order to perform your exchanges, sales and purchases;
 * The companies of SkinsMonkey when it is necessary to perform the contract to
   which the data subject is a party.


DATA RETENTION

SkinsMonkey stores and processes your Personal Data as long as your account
exists or as necessary for the operation of our Service, the compliance of our
legal and contractual obligations and the protection of its legitimate
interests, or during the validity of your consent as stated in this Privacy
Policy. After you close your account and/or upon your request we will delete
and/or anonymize your Personal Data without undue delay, but not later than 30
day, so that it no longer identifies you, unless we are legally allowed or
required to maintain certain Personal Data, including the following:

 * If there is an unresolved issue relating to your account, such as an
   outstanding credit on your account and/or an unresolved claim and/or dispute
   we will retain the necessary Personal Data until the said issue is resolved;
 * Where we need to retain the Personal Data for our legal, tax, audit, and
   accounting obligations and/or any other legal obligation, we will retain the
   necessary Personal Data for the period required by the applicable law;
 * Where necessary for the purpose of our legitimate business interests such as
   fraud prevention and/or to maintain the security of our Users.


YOUR RIGHTS

 1. Right to access your Personal Data

You have the right to enquire to be provided with a copy of your Personal Data
and/or the way that we store your Personal Data and/or erase your Personal Data
by sending us a written request in any way possible.

 2. Right to rectification

You have the right to ask us to change some of your Personal Data or contact us
with a request to change and/or correct your Personal Data if this is
inaccurate.

 3. Request to erasure of Personal Data

You have the right to request us to delete all or some of your Personal Data,
for example, if:

 * They are no longer needed for any processing purposes;
 * Consent has been used as a legal basis for their processing;
 * There is no legitimate interest for the further processing of Personal Data;
 * They were used for marketing purposes.

 4. Right to object

The right, at any time, to object to us processing your personal data on grounds
relating to your particular situation;

The right to object to your personal data being processed for direct marketing
purposes.

 5. Right to object to automated processing

You have the right to object to a decision based on automated processing. Using
this right, you may request us to review your Personal Data manually, because
you believe that automated processing of your Personal Data may not consider the
unique situation.

 6. Right for data portability

You have the right to request us to provide you with a copy of your Personal
Data in a structured, commonly used and machine-readable format (e.g. xml, csv).
Furthermore, you have the right to request us to transmit the said Personal Data
directly to another controller.

 7. Right to lodge a complaint

You have the right to lodge a complaint with a supervisory authority, in
particular to the member state of the European Union of your habitual residence,
place of work or place of the alleged infringement.

To exercise any of the rights please contact us via email: gdpr@skinsmonkey.com.


PERSONAL DATA BREACH

A personal data breach may, if not addressed in an appropriate and timely
manner, result in physical, material or non-material risk to your rights and
freedoms. Therefore, as soon as we become aware that a personal data breach has
occurred, we will notify the personal data breach to the Commissioner for
Personal Data Protection without undue delay and, where feasible, not later than
72 hours after having become aware of it, unless we are able to demonstrate, in
accordance with the accountability principle, that the personal data breach is
unlikely to result in a risk to your rights and freedoms. Where such
notification cannot be achieved within 72 hours, the reasons for the delay
should accompany the notification without undue further delay.


CHILDREN'S PRIVACY

Our Service is strictly restricted to Users who are 16 years of age or older. We
do not knowingly collect or solicit Personal Data from any User under the age of
16 or knowingly allow such persons to use our Service. If we find out that we
have collected the Personal Data of a User under the age of 16, we will delete
the account and respective Personal Data as quickly as possible in accordance
with the applicable legislation. If you are a parent or legal guardian and
believe that we might have collected and/or processed any Personal Data from or
about a child under the age of 16, please contact us. A child for the purposes
of this Privacy Policy, means any person who is under the age of 16.


CROSS-BORDER DATA TRANSFER

SkinsMonkey may transfer Personal Data to data controllers and processors
established outside the European Union (the "EU") or European Economic Area
("the EEA") for the purposes stipulated in this Privacy Policy.

We have included in our agreements with data controllers and processors located
outside the EU or EEA issued by the European Commission regulating the transfer
and processing of Personal Data in order to ensure that the Personal Data is
safeguarded, stored and processed in a secured way.

In this respect, we use Standard contractual clauses (SCC) adopted by the
European Commission as a mechanism to transfer data from the EU countries.
Organizations engaged in the processing of personal data on behalf of
SkinsMonkey have adopted SCC, as appropriate, in order to ensure
confidentiality, security, and legality of the processing of your personal data.


CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. We will post any changes in
relation to the Privacy Policy and, if the changes are significant, we will
notify you accordingly by email. We encourage you to review our Privacy Policy
before using the Service and/or access the Website and/or the Application.

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