Data Controller:
Social First OyContact information for Data Protection Officer: Mikko Kähärä, [email protected]
Social First Oy operates the GamerPay platform ("GamerPay", "we", "us", "our") and is the data controller responsible for the processing of personal data in connection with the GamerPay service.
We ask you to carefully read our Terms & Conditions and Privacy Policy which together form part of our agreement with you.
1.1. When creating a user profile ("Profile"), you enter into a legal agreement with Social First Oy (operating as GamerPay) concerning the use of our services on the GamerPay platform.
1.2. We process personal data only to the extent necessary to provide our services, verify identity, prevent fraud, and comply with applicable law, in accordance with Article 6 of the GDPR.
1.3. This Privacy Policy explains how we collect, use, store and protect your personal data.
Information obtained through GamerPay must only be used for the purpose of concluding or completing trades. You may not share, sell, or otherwise use data about other users for unrelated purposes.
We process only information necessary to operate the service, including:
3.1 Profile data: Username, SteamId, Profile picture
3.2 Technical Data; IP address and connection information
3.3 User information; Name, email, address, nationality, date of birth, phone number, and KYC documentation (passport, ID card, driver's license).
3.4 Transaction Information: IBAN, payment card details.
3.5 We do not process any special categories of personal information about you (art.9), such as racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
You should avoid providing us with any special categories of personal information, when reaching out to us.
4.1. To use the platform, you must be at least 13 years old. We may request identification to confirm this.
4.2 Identity verification is required under EU anti-money laundering rules (AML). Our basis for processing is GDPR Articles 6(1)(c) and 6(1)(f).
4.3 We use Lemonway as our regulated payment and KYC partner. Documents are processed securely and stored only for compliance purposes.
In order to create a GamerPay Profil, you must sign up with Steam. When signing up with Steam, the login from your Steam Account is utilized to create your profile on our platform. When you sign up or log in with Steam, we collect, store and use your Steam data in compliance with your privacy settings on Steam and this Privacy Policy. Your consent for this is given, when you accept to use your Steam login to sign up, or when you log in with Steam.
To read more about Steams data policy, clickhere.
GamerPays service enables you to transfer and receive money to and from other GamerPay users. Our basis for processing your personal information (see 3), as either a buyer or seller, using our services, is Article 6(1)(f) of the GDPR about legitimate interest. Our legitimate interest is in providing you the service you are requesting GamerPay.
5.2.1 In order to deliver the service, we process your user information and the information from the skin in relation to trades. For safety reasons, we also collect the IP addresses of both the seller and the buyer when processing monetary transactions. We ask you to be aware that your profile information (see 3.1) is shared with the buyers and/or sellers that you trade with. Other information is not available to be accessed by others other than GamerPay.
5.2.2 As a seller
In order for us to facilitate a trade between you and the buyer, we are processing your personal information in order to provide the service. When receiving payments for skins sold, you will be required to inform us of your account- and registration number or IBAN of your bank account. It is only allowed to receive payments on your own account due to anti-money laundry regulation.
5.2.3 As a buyer
When you choose to buy skins, we ask you for your cardholder data (card number, expiration date, and CVV number). When you make a payment, the amount can be withdrawn directly from your card. To safely process the transactions, we use a secure third party service, called Lemonway.
5.3.1 In connection to your continuous use of our service, we process all data related to your profile as necessary to provide and improve our service. In order for us to provide you with the best possible support and continuously improve our services, it is necessary for us to process the following categories of user information; technical information and transaction information (see 3), and any other information you may provide us when requiring our support. Our basis for processing your information is our legitimate interest providing you with great service and support (GDPR par. 6(1)(f)).
5.3.2. We offer you our support services from our support team, should you have any questions or problems on our service. In relation to cases in our support department, we process all information given to us by you as well as your user information and your profile data, should it be of relevance.
5.3.3. Information processed in or given by our support department is safely stored with a third party service that delivers our support system.
5.3.4. All information related to a transaction, deemed relevant to the danish acts on bookkeeping, anti-money laundry and payments will be stored for 5 years, as we are obligated to comply with these laws
5.4.1 We use your user information (see 3) to target our content and advertising to your interests. This happens on our own platform as well as on social media, so you can receive relevant marketing material. We process your information based on your consent to do so (GDPR Article 6(1)(a). We process your information in pursuant to our legitimate interest in marketing our services (GDPR par. 6(1)(f)).
5.4.2 We use your email address to send you newsletters and other direct marketing material, if you have given us your consent to do so.
5.4.3 You are free to withdraw and adjust your marketing consent at any given time.
5.4.4 On social media it is only your email that is used in an encrypted form. This is not direct marketing as described in paragraph 5.4.2, and your information is not used independently by social media. We must inform you that the social media platforms and their potential partners have the possibility, independently of us, to use their own information about you for marketing targeted towards you, if they are entitled to according to their terms and conditions, and if you have given your consent through your privacy settings with the social media platforms or in your internet browser.
All data listed above is used by us in anonymized or sodomized forms for statistical purposes in order to improve our service. Our basis for this is the GDPR, article 6 (1, para f) on our legitimate interest, which does not in principle exceed the consideration of your personal rights.
We share data with third parties, only if necessary to provide our service. Third parties should be understood as the following:
7.1. To protect your data against accidental or illegal destruction, loss, changes, unauthorized access or transfer in compliance with the data protection regulations in Denmark and in the EU, we store all personal data with our secure data processing partners.
7.2. Our data processing partners are located within the EU or in the US with companies that have joined the US Privacy Shield agreement. Partners may also be located in third countries with companies that process data in compliance with the standard contractual clauses of the European Commission.
7.3. All our employees are bound by confidentiality, and we have restricted the access to personal data to what is strictly necessary.
8.1. You can ask us to close down your profile at any time. To do so, you can contact us by email at [email protected].
8.2. Your user information and profile information are stored for 3 months after the closure of your profile.
8.3. If there are ongoing transactions or support cases on the platform involving your profile, the 3 months are calculated from the closure date of the last open support case.
8.4. Regardless of all information given prior, your profile will not be closed until all ongoing transactions and support cases are finished.
8.5. All information related to a transaction, deemed relevant to the danish acts on bookkeeping, anti-money laundry and payments will be stored for 5 years, as we are obligated to comply with these laws (See section 5.3.4)
You have the following rights under the GDPR:
To exercise these rights, contact [email protected].
Supervisory Authority:
Data Protection Ombudsman (Finland)
GamerPay only uses strictly necessary cookies. Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors.
We use cookies solely to provide, secure, and improve our service.
Since the number and names of cookies may change, the table below may be updated from time to time.
| Service Provider | Cookie name | Description | Expiration* |
|---|---|---|---|
| GamerPay | gpToken | This cookie is used to log you in | three months |
| GamerPay | consent | This cookie is used to store the given consent | three months |
| GamerPay | next-i18next | This cookie is used to determine the language of the site | session |
* The expiration dates for the cookies listed above generally apply on a rolling basis.
In the event of a merger, acquisition or sale of our business, your data may be transferred to the new controller. Following the acquisition of GamerPay by Social First Oy, all user rights and protections remain unchanged.
We maintain our right to make changes to the Privacy Policy at any time. If the changes made to the Privacy Policy are substantial, we will inform you in an email or directly on the GamerPay service.
This Privacy Policy was last updated November 7th 2025.