PRIVACY POLICY

This Privacy Policy (hereinafter the “Policy”) describes what personal data is collected when using the website skindealer.trade and related services (hereinafter the “Website”), and how it is processed, stored, transferred, and protected.

The Policy is drafted in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, and also takes into account the EU General Data Protection Regulation 2016/679 (GDPR) for users in the European Union and the California Consumer Privacy Act (CCPA) where applicable.

1. Personal data operator

The personal data operator and data controller is:

Individual entrepreneur Mavlikhanov Renat Andreevich (hereinafter the “Operator”, “We”, hereinafter also IE Mavlikhanov R.A.).

OGRNIP: 325930100089708

INN: 614022554644

Address: Gorlovka, Pushkinskaya st. 61, apt. 21

E-mail: skindealer.trade@gmail.com

For any questions related to personal data processing, contact the stated e-mail. Response time is no more than 30 days.

2. What data we collect

2.1. Data when using the Website (collected automatically):

• IP address;
• browser and device data (User-Agent, language, screen resolution, operating system);
• cookies and similar technologies (see section 10);
• Website usage data (page views, clicks, traffic source, time on page).

2.2. Data upon Steam authorization (if you use the corresponding functionality):

• SteamID64;
• public profile name (nickname);
• avatar URL and Steam profile link.

Data is transferred by Steam through the official Steam OpenID mechanism. The Steam account password is not transferred to the Website and is not processed by us.

2.3. Data when taking out a subscription (where a subscription is active under the Public Offer):

• email address provided at checkout;
• transaction identifiers, payment status and amount, transmitted by the payment provider;
• subscription details (plan, term, activation status).

Full bank card details and other payment data are not collected or stored by us. They are processed by the payment provider in accordance with its privacy policy and PCI DSS requirements.

2.4. Data when contacting support:

• email address provided in the request;
• content of the request and correspondence.

2.5. Data when using chat and comments:

• content of messages sent through the Website’s built-in chat and comments section;
• message metadata (time sent, sender, recipient).

Such data may be reviewed by authorized staff (moderators) for the purposes stated in clause 4.4 of this Policy. Retention and deletion of message content are described in section 6.

3. Data we do NOT collect

We do not knowingly collect or process:

• Steam account passwords;
• full bank card and payment wallet details;
• phone numbers;
• passport data;
• biometric data;
• precise geolocation data (GPS);
• advertising device identifiers (IDFA, GAID).

4. Purposes of processing and legal bases

4.1. Providing Website features. We process technical data, Steam authorization data, and subscription data to provide the User with access to the Website, its features, and paid services. Legal basis: performance of a contract (Public Offer).

4.2. Payment and subscription processing. We process e-mail, transaction identifiers, and subscription details to activate, renew, and provide technical support for paid services. Legal basis: performance of a contract, legitimate interests.

4.3. Technical support. We process e-mail and the content of the request to respond to User inquiries. Legal basis: performance of a contract / legitimate interests.

4.4. Security and prevention of abuse. We process IP address, device data, and usage data to protect the Website against unauthorized access, fraud, and abuse (including preventing the creation of multiple accounts). The same purposes include review (moderation) of chat and comment content — both automatically and by authorized staff (moderators) — to detect and prevent deception of Users in P2P trades and other violations of Website rules. Legal basis: legitimate interests.

4.5. Analytics and Website improvement. We process de-identified usage data and technical browser data to analyze stability and improve the interface and user experience. Legal basis: your withdrawable consent (given through the cookie banner or continued use of the Website; may be withdrawn at any time).

4.6. Compliance with law. We may process the listed data to the extent necessary to meet requirements of applicable law (including accounting, tax, and anti-fraud reporting). Legal basis: legal obligation.

5. Age restrictions

The Website and related services are intended solely for persons aged 18 or older. We do not knowingly collect personal data of persons under 18. If we become aware that we have received data of a minor, such data will be deleted without delay. If you are a parent or legal guardian and believe that a child has provided us with data, please contact us at the e-mail in section 1.

6. Retention periods and security

6.1. Retention periods:

• authorization and activity data — for the period of use of the Website plus 1 year after cessation of use;
• subscription and payment data (transaction identifiers, amounts, statuses) — for the period established by the tax legislation of the Russian Federation (but not less than 5 years from the transaction);
• support request data — 1 year after the last response;
• analytics and cookie data — in accordance with the policies of analytics providers (usually up to 26 months) or until withdrawal of your consent;
• content of chat and comment messages — see clause 6.3 below.

6.2. Security measures: we apply technical and organizational measures to protect data against unauthorized access, loss, alteration, or destruction (TLS encryption in transit, access restriction, logging, regular updates). Access to data is granted only to the extent necessary to perform job duties. Access to the content of Users’ correspondence is limited to a defined circle of authorized moderators.

6.3. Retention and deletion of chat and comment messages. When a User deletes a message, comment, or other material in the Website chat, such material immediately ceases to be displayed in the interface for all Users. Actual (final) deletion of the 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 this period the material is stored with restricted access and used solely for the purposes stated in clause 4.4 (moderation, investigation of fraud complaints, resolution of disputes between Users, 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.

7. Cross-border data transfers

Data may be processed on servers located both in the Russian Federation and outside it. When transferring personal data of users from the European Economic Area (EEA) and other jurisdictions with similar requirements, the European Commission’s Standard Contractual Clauses (SCC) or other applicable protection mechanisms are used.

8. Third parties (processors)

We do not sell personal data. Transfer to third parties occurs only in the following cases:

8.1. Payment providers. A payment provider is used to process subscription payments. The User’s full payment details are processed exclusively by the payment provider in accordance with its policy and the PCI DSS standard.

8.2. Infrastructure and analytics providers. Technical data and usage data may be transferred to cloud and analytics providers (for example, for hosting, monitoring, web analytics). Processing is carried out on the basis of data processing agreements. The current list of processors is provided on request.

8.3. Public authorities. Only upon a lawful request of competent authorities in accordance with applicable law.

9. Your rights

Depending on your jurisdiction, you may have the following rights:

• right of access — to learn what data we process;
• right to rectification — to request correction of inaccurate data;
• right to erasure (“right to be forgotten”) — to request deletion of data;
• right to restriction of processing — under certain conditions;
• right to data portability — to receive data in a structured format;
• right to object — to processing based on legitimate interests;
• right to withdraw consent — at any time (for analytics and cookies);
• right to lodge a complaint — with the data protection authority of your country (for users in the Russian Federation — Roskomnadzor; for EU users — the data protection authority of your Member State).

To exercise your rights, send a request to skindealer.trade@gmail.com with the subject “Personal data request”. We will respond within 30 days. In some cases we may request confirmation of your identity to prevent unauthorized access to data. Please note that a request to delete chat and comment messages is fulfilled in the manner and within the time limits stated in clause 6.3 of this Policy.

For California users (CCPA): we do not sell your personal data. You may request disclosure of collected data (right to know), its deletion (right to delete), and to opt out of sharing with third parties (right to opt-out of sharing) — via the same e-mail.

10. Cookies

The Website uses cookies and similar technologies to:

• ensure operation (session persistence, language settings) — strictly necessary cookies, no consent required;
• Website usage analytics — set only with your consent;
• ensure security and protection against fraud.

You may manage cookies through browser settings or the consent banner. Refusing analytics cookies does not affect the core features of the Website.

11. Changes to the Policy

We may update this Policy in connection with changes in law or in the functionality of the Website. The new version takes effect upon publication on the Website. Continued use of the Website after an update means acceptance of the new version. We will notify of material changes via a banner on the Website.

12. Contact information

For all questions related to personal data processing, this Policy, or the exercise of your rights, contact the Operator:

Individual entrepreneur Mavlikhanov Renat Andreevich (IE Mavlikhanov R.A.)

OGRNIP: 325930100089708

INN: 614022554644

Address: Gorlovka, Pushkinskaya st. 61, apt. 21

E-mail: skindealer.trade@gmail.com