CONSENT TO PERSONAL DATA PROCESSING “SkinDealer”

I (hereinafter the “Personal Data Subject” or the “User”) hereby give my consent to Mavlikhanov Andrei Minkharizovich (natural person), administrator of the SkinDealer mobile application (hereinafter “We”, hereinafter also Mavlikhanov A. M.), to process my personal data on the following terms:

List of personal data

We may process the following personal data of the User:

• SteamID64;
• Public Steam profile name (nickname);
• Avatar and Steam profile link;
• CS2 inventory data (obtained from Steam services and stored on our servers to display inventory, listings, and trade features);
• IP address;
• Technical device information (model, operating system, Application version);
• Application usage data (page views, actions in the Application, cookies and similar technologies);
• Content of messages sent by the User through the Application’s built-in chat and comments section.

Steam-related data is obtained directly from Steam services with the User’s consent upon authorization.

Purposes of personal data processing

Personal data is processed solely for the following purposes:

• Providing access to Application features (finding partners for P2P trades of CS2 skins, displaying profile, inventory, and listings);
• Ensuring correct operation of the Application, usage analytics, and improving service quality;
• Managing access to extended features (technical support, status checks);
• Ensuring security, preventing fraud, and complying with legal requirements, including through review (moderation) of chat and comment messages in the Application by authorized staff (moderators) or automatically — to detect and prevent deception of Users, fraudulent acts, and other violations of the User Agreement.

Methods of personal data processing

Processing includes collection, recording, systematization, accumulation, storage, clarification (updating, alteration), retrieval, use, transfer (provision, access), blocking, deletion, and destruction of personal data, with and without automation.

Moderation of correspondence and retention of deleted materials

For the purposes stated in the section “Purposes of personal data processing”, We may review the content of the User’s messages in the Application chat and comments. Such review is not aimed at collecting data beyond what is necessary to ensure Users’ security and resolve disputes between them.

When a User deletes a message, comment, or other material in the Application chat, such material immediately ceases to be displayed in the interface for all Users. Actual (final) deletion of this material from our servers occurs upon expiry of 90 (ninety) calendar days from the moment the User initiated deletion. If a User deleted a message, comment, or chat, actual deletion of that material after 90 days also applies to copies of it in complaints and correspondence snapshots. Neighbouring messages in a snapshot that the User did not delete are not erased by this period. During the stated period the material is stored with restricted access and used solely for moderation, investigation of fraud complaints, resolution of disputes between Users, and compliance with legal requirements. After this period the material is deleted with no possibility of recovery, except where longer retention is expressly required by applicable law.

Term of the consent

This consent is valid from the moment it is given (by checking the corresponding box during registration or use of the Application) until it is withdrawn, or for the period necessary to achieve the processing purposes or comply with legal requirements (but not more than 3 years after the User stops using the Application). Deleted chat and comment materials are retained in accordance with the period stated in the section “Moderation of correspondence and retention of deleted materials” above.

Right to withdraw consent

The User may withdraw this consent at any time by sending a written request to: skindealer.trade@gmail.com. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. After withdrawal, personal data processing stops, except where processing is necessary to perform a contract or comply with legal requirements.

Transfer of personal data to third parties

Transfer of personal data to third parties is possible only in the following cases:

• To analytics providers — solely in anonymized (de-identified) form;
• To public authorities — upon a lawful request in accordance with applicable law.

We do not collect, store, or process the User’s payment details. CS2 inventory data is obtained directly from Steam services and is not transferred to third parties.

Personal data protection measures

We undertake to take the necessary organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination, or other unlawful acts. Access to the content of Users’ correspondence is limited to a defined circle of authorized staff (moderators) acting solely for the purposes stated in this Consent.

Rights of the personal data subject

The User has the right to:

• obtain information about their personal data;
• access, rectify, block, or delete data;
• restriction of processing;
• data portability;
• withdraw consent;
• lodge a complaint with the relevant supervisory authority (in the EU — the data protection authority of their Member State; in other jurisdictions — the relevant authority).

To exercise these rights, send a request to: skindealer.trade@gmail.com. A response will be provided within 30 days (or 1 month in accordance with the GDPR). Please note that a request to delete chat and comment messages is fulfilled in the manner described in the section “Moderation of correspondence and retention of deleted materials” of this Consent.

Additional provisions for users in the European Union (GDPR)

If the User is in the European Union, personal data is processed on the basis of their consent and/or for the performance of a contract, and as regards moderation of correspondence — also on the basis of legitimate interest in ensuring Users’ security and preventing fraud (Art. 6(1)(f) GDPR). For personal data protection questions the User may contact: skindealer.trade@gmail.com.

Digital Services Act (DSA) — trader status for users in the European Union

We are not a trader within the meaning of Articles 30 and 31 of the Digital Services Act (DSA). This Application is provided as a non-commercial hobby tool with no monetization, in-app purchases, advertising, or revenue. Accordingly, consumer rights arising from applicable EU consumer protection law do not apply to the relationship between you and us.

In accordance with DSA requirements, Apple displays “non-trader” status on the App Store product page when the Application is distributed in the European Union. For any questions related to this status or the Application, contact: skindealer.trade@gmail.com.

This consent is given by checking the corresponding box during registration or use of the Application and has the same legal force as a handwritten signature.

Contact information

Email: skindealer.trade@gmail.com