GDPR COMPLIANCE
General Data Protection Regulation Policy
Last updated: 4 December 2025
1. DATA CONTROLLER
MOXIE SKINS LTD is the controller of your personal data.
Registered office: Academy House, 11 Dunraven Place, Bridgend CF31 1JF, United Kingdom
Data Protection Officer: dpo@skinmeister.pro
2. YOUR RIGHTS UNDER GDPR
As a data subject, you have the following rights:
- Right of Access: Request copies of your personal data
- Right to Rectification: Request correction of inaccurate data
- Right to Erasure: Request deletion of your data ("right to be forgotten")
- Right to Restrict Processing: Request restriction of data processing
- Right to Data Portability: Receive your data in a structured format
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent at any time
- Right to Complain: Lodge a complaint with the data protection authority
3. DATA WE COLLECT
Account Information:
- Steam ID and username
- Email address
- Profile avatar and display name
- Steam inventory data
- Trade URL
Transaction Data:
- Purchase and sale history
- Payment information
- Wallet balance and transaction logs
- Trading history and patterns
Technical Data:
- IP address and location data
- Browser type and version
- Device information
- Cookies and similar technologies
- Usage analytics
Communication Data:
- Support tickets and correspondence
- Chat messages (where applicable)
- Marketing preferences
4. LEGAL BASIS FOR PROCESSING
We process your data on the following legal bases:
Contract Performance:
- Account creation and management
- Transaction processing
- Providing marketplace services
- Customer support
Legitimate Interests:
- Fraud prevention and security
- Service improvements
- Business analytics
- Direct marketing (with opt-out)
Legal Obligations:
- AML/KYC compliance
- Tax reporting obligations
- Cooperation with law enforcement
- Regulatory compliance
Consent:
- Marketing communications
- Non-essential cookies
- Newsletter subscriptions
5. RETENTION PERIODS
We retain data for the following periods:
- Account data: Duration of the account + 6 years
- Transaction records: 7 years (legal requirement)
- AML/KYC documents: 5 years after the end of the business relationship
- Support tickets: 3 years
- Marketing data: Until consent is withdrawn
- Technical logs: 90 days
- Cookies: As per the Cookie Policy
6. DATA SHARING & TRANSFERS
Third-Party Recipients:
- Steam/Valve (authentication and trading)
- BitSkins API (market data)
- Cloudflare (CDN and security)
- AWS (hosting in EU regions)
- Vercel (platform hosting)
- Law enforcement agencies (where required by law)
International Transfers:
- Data is primarily processed within the EU
- Steam services may involve US transfers
- We use Standard Contractual Clauses where required
- Appropriate safeguards for all transfers
7. DATA SECURITY MEASURES
We implement appropriate technical and organisational measures:
- TLS 1.3 encryption for data in transit
- AES-256 encryption for data at rest
- Regular security audits and penetration testing
- Access controls and authentication
- Data protection training for employees
- Incident response procedures
- Regular backups and disaster recovery
- ISO 27001 compliant practices
8. DATA BREACH PROCEDURES
In the event of a personal data breach:
- We assess the risk to data subjects
- Report to the data protection authority within 72 hours where required
- Notify affected users without undue delay
- Internal documentation of all breaches
- Steps to prevent recurrence
- Cooperation with regulatory investigations
9. CHILDREN'S DATA
Our services are not directed at individuals under 18. We do not knowingly collect personal data from children. If we discover that we have collected data from a child without parental consent, we will take steps to delete this information.
10. AUTOMATED DECISION-MAKING
We use automated systems for:
- Fraud detection and prevention
- AML transaction monitoring
- Market price calculations
- AI-powered item analysis
You have the right to request human review of automated decisions that significantly affect you.
11. EXERCISING YOUR RIGHTS
To exercise your GDPR rights:
- Email our DPO at dpo@skinmeister.pro
- Include proof of identity
- Specify which right(s) you wish to exercise
- We respond within 30 days
- No fee for most requests
- Complex requests may take up to 90 days
12. COMPLAINTS
If you're dissatisfied with our data processing:
- Contact our DPO first at dpo@skinmeister.pro
- You may lodge a complaint with the data protection authority
- UK Information Commissioner's Office: ico.org.uk
13. UPDATES TO THIS POLICY
We may update this GDPR Policy periodically. Material changes will be communicated by email or prominent website notice. The "Last updated" date will be adjusted accordingly.
14. CONTACT INFORMATION
Data Protection Officer:
Email: dpo@skinmeister.pro
Address: Academy House, 11 Dunraven Place, Bridgend CF31 1JF, United Kingdom
General Enquiries:
Email: privacy@skinmeister.pro
Support: support@skinmeister.pro