Privacy Policy

1. GENERAL PROVISIONS

This Privacy Policy explains how the Company collects, uses, stores, discloses, and protects personal data in connection with the operation of the Platform and the provision of the Services.

The Platform is operated by LUMERYN LIMITED, a company incorporated in England and Wales under company number 17151133, with its registered office at Dept 6713, 126 East Ferry Road, Canary Wharf, London, United Kingdom, E14 9FP (the “Company”, “we”, “us”, or “our”). For the purposes of applicable data protection legislation, the Company acts as the controller of personal data processed through the Platform.

This Privacy Policy applies to all users of the Platform and describes the categories of information collected, the purposes for which such information is processed, the circumstances in which information may be shared, and the rights available to individuals in relation to their personal data.

By accessing or using the Platform, you acknowledge that your personal data may be processed in accordance with this Privacy Policy. Such processing may include information provided directly by you, information generated through your use of the Services, and information received from third-party providers involved in the operation of the Platform.

This Privacy Policy should be read together with the Terms and Conditions and any other legal documentation published on the Platform. In the event of any inconsistency, the relevant provisions of applicable data protection laws shall prevail.

The Company may amend this Privacy Policy from time to time to reflect changes in legal requirements, regulatory guidance, business operations, technical developments, or the Services offered through the Platform. Any updated version will be published on the Platform and will become effective upon publication unless otherwise stated. Continued use of the Platform following the publication of an updated version constitutes acknowledgement of the revised Privacy Policy.

2. INFORMATION WE COLLECT

The Company may collect, receive, generate, and otherwise process personal data in connection with a User’s access to and use of the Platform. The categories of information collected may vary depending on the nature of the Services used, the Transactions performed, and the manner in which the User interacts with the Platform.

Information provided directly by Users may include contact details, account information, email addresses, payment and payout information, and any other information submitted when creating an Account, completing a Transaction, contacting support, or otherwise using the Services.

Where the Platform integrates with Steam or other third-party services, the Company may collect information associated with such accounts, including account identifiers, profile information, trade-related information, Steam Trade URLs, and other data necessary to facilitate authentication, delivery of Digital Items, and the completion of Transactions.

The Company may collect information relating to Transactions conducted through the Platform. This may include records of purchases, sales, payments, payouts, transaction history, Digital Items involved in a Transaction, delivery status, and other information necessary to operate the Services and maintain appropriate business records.

Certain technical and usage information may be collected automatically when Users access or interact with the Platform. Such information may include IP addresses, browser type, device information, operating system details, session information, access times, referral sources, pages visited, actions performed, and other analytical or diagnostic data relating to the use of the Services.

The Company may also receive information from third-party providers involved in the operation of the Platform, including authentication providers, payment processors, fraud prevention services, analytics providers, infrastructure providers, and other service partners. Such information may be used to verify Transactions, maintain platform security, facilitate payments, and improve the Services.

In certain circumstances, the Company may request or collect additional information where reasonably necessary for identity verification, fraud prevention, dispute resolution, compliance purposes, security investigations, or to comply with applicable legal and regulatory obligations.

The Company collects and processes only such information as is reasonably necessary for the operation of the Platform, the provision of the Services, the protection of Users and the Company, and compliance with applicable legal requirements.

3. HOW WE USE YOUR INFORMATION

The Company processes personal data for the purpose of operating the Platform and providing the Services to Users. This includes creating and managing Accounts, facilitating Transactions, delivering Digital Items, processing payments and payouts, and maintaining the overall functionality of the Platform.

Personal data may be used to verify User identity, authenticate access to the Platform, process Orders and Transactions, communicate with Users regarding their Accounts or activities, and provide customer support where required.

The Company may process personal data to monitor, maintain, and improve the performance, security, reliability, and usability of the Platform. This includes analyzing how the Services are used, identifying technical issues, troubleshooting operational problems, and developing new features or improvements.

Personal data may also be used for fraud prevention, risk management, security monitoring, and the detection of suspicious, unauthorized, or unlawful activity. The Company may review account activity, transaction patterns, and other relevant information in order to protect the Platform, its Users, and its business operations.

The Company may process personal data where necessary to comply with legal, regulatory, accounting, tax, compliance, and reporting obligations. This may include maintaining records, responding to lawful requests from competent authorities, enforcing legal rights, and handling disputes, investigations, or claims.

Processing of personal data may be based on one or more lawful grounds, including where such processing is necessary for the performance of a contract with the User, compliance with legal obligations, the pursuit of the Company's legitimate interests, or the User's consent where consent is required by applicable law.

The Company will not process personal data for purposes that are incompatible with those described in this Privacy Policy unless otherwise permitted or required by applicable law.

4. THIRD-PARTY SERVICES

The Platform relies on a number of independent third-party service providers to support the operation of the Services. Such providers may include Steam, payment processors, hosting providers, infrastructure providers, analytics providers, fraud prevention services, communication providers, and other technology partners.

In order to use certain features of the Platform, Users may be required to interact with third-party services or maintain accounts with such providers. The availability and functionality of certain Services may therefore depend on the operation of external systems that are not owned, managed, or controlled by the Company.

The Company may share limited personal data with third-party providers where such sharing is reasonably necessary to facilitate Transactions, provide the Services, verify account activity, process payments, prevent fraud, maintain platform security, or comply with legal and regulatory obligations.

Third-party service providers process personal data in accordance with their own privacy policies, terms, and procedures. The Company does not control and is not responsible for the independent processing activities of third parties once information has been transmitted to them in accordance with the Services requested by the User.

The Company makes reasonable efforts to engage reputable service providers that maintain appropriate operational and security standards. However, the Company does not guarantee the availability, performance, reliability, or security of any third-party service and shall not be responsible for interruptions, delays, restrictions, failures, or other issues arising from the operation of such services.

Where a third-party service becomes unavailable or affects the ability to provide the Services, the Company may suspend, delay, modify, or cancel certain activities or Transactions as reasonably necessary. The Company will take reasonable steps to minimize disruption but does not guarantee that affected Services can be restored or completed.

By using the Platform, the User acknowledges that certain personal data may need to be shared with third-party providers for the proper operation of the Services and that the Company's obligations are limited to its own processing activities and systems.

5. DATA RETENTION

The Company retains personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected and processed, including the provision of the Services, operation of the Platform, completion of Transactions, maintenance of Accounts, and protection of the Company's legitimate business interests.

Personal data may be retained for longer periods where required to comply with applicable legal, regulatory, tax, accounting, compliance, audit, fraud prevention, or record-keeping obligations. The Company may also retain information where necessary to establish, exercise, or defend legal claims, resolve disputes, investigate security incidents, or enforce its contractual rights.

Where a User ceases using the Platform, closes an Account, or otherwise terminates their relationship with the Company, certain information may continue to be retained for a reasonable period in accordance with the purposes described in this Privacy Policy and applicable legal requirements.

The Company periodically reviews the personal data it holds and takes reasonable steps to delete, anonymise, or otherwise securely dispose of information that is no longer required for the purposes for which it was collected, unless continued retention is required or permitted by law.

Retention periods may vary depending on the nature of the personal data, the purpose of processing, applicable legal obligations, operational requirements, and the potential need to preserve information in connection with disputes, investigations, regulatory matters, or legal proceedings.

Once personal data is no longer required and there is no lawful basis for its continued retention, the Company will take appropriate measures to ensure that such information is securely deleted, anonymised, or otherwise rendered inaccessible.

6. DATA SECURITY

The Company implements reasonable technical, organizational, and administrative measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, misuse, destruction, or other forms of unlawful processing.

Security measures may include access controls, authentication mechanisms, encryption technologies where appropriate, monitoring systems, internal policies, staff training, and other safeguards intended to maintain the confidentiality, integrity, and availability of personal data processed through the Platform.

Access to personal data is limited to authorized personnel, contractors, and service providers who require such access for legitimate business purposes and who are subject to appropriate confidentiality and security obligations.

The Company may engage third-party service providers to support the operation of the Platform, including hosting providers, infrastructure providers, payment processors, and technical service providers. While the Company takes reasonable steps to select providers that maintain appropriate security standards, it cannot guarantee the security practices, systems, or operations of independent third parties.

The transmission of information over the internet and through electronic systems involves inherent security risks. Although the Company takes reasonable measures to protect personal data, no method of transmission, storage, or processing can be guaranteed to be completely secure, and the Company cannot guarantee absolute protection against all security threats.

Users are responsible for maintaining the confidentiality and security of their Account credentials, devices, email accounts, Steam accounts, and other access mechanisms associated with the Services. Any unauthorized use resulting from a User’s failure to protect such information remains the User’s responsibility.

The Company regularly reviews and updates its security practices and may implement additional safeguards where reasonably necessary to address evolving security risks, technological developments, operational requirements, or legal obligations.

In the event of a security incident affecting personal data, the Company will take appropriate steps to investigate, mitigate, and address the issue. Where required by applicable law, the Company may notify affected individuals, regulators, or other relevant authorities in accordance with its legal obligations.

7. YOUR RIGHTS

Subject to applicable data protection laws, you may have certain rights in relation to the personal data processed by the Company.

You may have the right to request access to the personal data held about you and to obtain information regarding how such data is collected, used, shared, and retained. You may also have the right to request correction of inaccurate, incomplete, or outdated personal data.

In certain circumstances, you may request the deletion of your personal data where there is no longer a lawful basis for its continued processing. The Company may, however, retain certain information where required to comply with legal obligations, resolve disputes, prevent fraud, enforce agreements, or protect its legitimate interests.

You may have the right to request the restriction of processing of your personal data in specific situations, including where the accuracy of the information is contested or where the processing is alleged to be unlawful.

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before such withdrawal and may affect the availability of certain Services or Platform functionality.

Where permitted by applicable law, you may have the right to object to the processing of your personal data where such processing is based on the Company's legitimate interests. The Company may continue processing where compelling legitimate grounds exist or where required by law.

You may also have the right to receive certain personal data in a structured, commonly used, and machine-readable format and, where technically feasible, to request that such information be transferred to another service provider.

To exercise any of your rights, you may contact the Company using the contact details provided in this Privacy Policy. The Company may request reasonable information to verify your identity before processing a request and may refuse requests where permitted by applicable law.

If you believe that the processing of your personal data does not comply with applicable data protection laws, you may have the right to submit a complaint to the relevant supervisory authority or regulatory body in your jurisdiction.

8. COOKIES

The Platform uses cookies and similar technologies to ensure the proper operation of the Services, maintain security, improve functionality, and enhance the overall user experience.

Cookies are small text files that are stored on a User’s device when visiting the Platform. These files enable the Platform to recognize a User’s browser or device and to remember certain information between visits.

Some cookies are strictly necessary for the operation of the Platform. These cookies support essential functionality such as account authentication, session management, security controls, fraud prevention measures, and the proper delivery of Services. Without such cookies, certain parts of the Platform may not function correctly.

The Company may also use cookies and similar technologies to collect information regarding how Users interact with the Platform. This may include information relating to page visits, navigation patterns, device information, session activity, and other usage statistics. Such information helps the Company monitor performance, improve functionality, identify technical issues, and enhance the user experience.

Certain cookies may be used to remember User preferences and settings, allowing the Platform to provide a more efficient and personalized experience during future visits.

The Platform may also rely on third-party service providers that use cookies or similar technologies in connection with analytics, security, infrastructure, authentication, payment processing, or other operational services. The use of such technologies by third parties is governed by their respective policies and practices.

Users may control, manage, restrict, or disable cookies through their browser settings or other available device controls. However, restricting or disabling certain cookies may affect the functionality, availability, or performance of some features of the Platform.

The Company may update its use of cookies and similar technologies from time to time to reflect changes in the Services, operational requirements, legal obligations, or technological developments. Any material changes will be reflected in this Privacy Policy.

9. CHANGES TO THIS POLICY

The Company may revise, amend, or update this Privacy Policy from time to time to reflect changes in the Platform, the Services, applicable laws, regulatory requirements, business operations, or data processing practices.

Any updated version of this Privacy Policy will be made available on the Platform and will take effect from the date of publication unless otherwise specified. Users are encouraged to review this Privacy Policy periodically to remain informed about how their personal data is processed.

Where required by applicable law, or where the Company considers a change to be significant, reasonable steps may be taken to notify Users of the updated Privacy Policy through the Platform or other appropriate communication channels.

Continued use of the Platform following the publication of an updated Privacy Policy constitutes acknowledgement of the revised Policy and the continued processing of personal data in accordance with its terms.

Nothing in this Section shall affect any rights granted to Users under applicable data protection laws.

10. CONTACT

If you have an account on the Platform, you may delete it at any time from your profile settings. If you have any questions regarding this Privacy Policy, the processing of your personal data, or your rights under applicable data protection laws, you may contact the Company using the contact details provided below, or use the Contact Us form on the Platform and select Privacy & personal data as the topic.

Requests relating to personal data, including requests for access, correction, deletion, restriction of processing, or the exercise of any other applicable rights, should contain sufficient information to enable the Company to identify the relevant User and process the request efficiently.

The Company may request additional information to verify the identity of the individual submitting a request where reasonably necessary to protect personal data and prevent unauthorized disclosure.

The Company will review and respond to requests within the timeframes required by applicable law. In certain circumstances, additional time may be required where a request is particularly complex or where multiple requests have been submitted.

If you are not satisfied with the Company's response regarding the processing of your personal data, you may have the right to contact the relevant supervisory authority in your jurisdiction.

Company: LUMERYN LIMITED

Company Number: 17151133

Registered Office: Dept 6713, 126 East Ferry Road, Canary Wharf, London, United Kingdom, E14 9FP

Email: [email protected]