Data Controller:GamerPay ApS
Contact information for Data Protection Officer:
Morten Byskov firstname.lastname@example.org
Data protection and data security have first priority at GamerPay.
We process and use personal data only to the extent necessary in order to provide our services.
1.1. When creating a user profile (“Profile”), you are entering into a legal agreement with us about the use of our services on the GamerPay service.
1.2. To administrate your profile while offering our services in compliance with the agreement, we need to process your personal data. We process your personal data pursuant to the GDPR, article 6 (1, para b) to fulfill an agreement with you as registered.
2.1. It is our wish to safeguard the personal data of all our users best possible. Therefore, we have a member discretion policy, which implies that you cannot use or share information about other users obtained through GamerPay or given to you by GamerPay or by other users. Information obtained through GamerPay can only be used for purposes of entering into or completing trades.
We only gather the necessary personal information about you, and therefore we have listed and described to different categories of information below, which we process.
We process the following personal information about you:
3.1 Profile data:
3.2 Technical Data; IP address and connection information
3.3 User information:
3.4 Transactions information:
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. Our support department can rightfully contact you at any time to ensure that you meet our age criteria of 13 years of age in order to utilize the platform. If you are contacted, you may be asked to provide relevant identification documents. The information you share in relation to this is only used to greenlight you as a user and is not used or stored for other purposes.
4.2 Verification of your identity
4.2.1. In order to maintain and strengthen the security and trust at our platform, we need to verify your identity in various contexts. Among other things, it prevents fraud and unauthorized use of our service e.g., other persons use other people’s GamerPay profiles, or when the user has not reached the required age of 13 years.
4.2.2. The specific purposes and basis for treatments constitute:
Routine control of the required age limit of 13 years. Our basis for the process is Article 6 (1)(f) of the GDPR about legitimate interests. Our legitimate interest in checking your age is the natural interest in protecting ourselves and our users on the platform from entering into invalid agreements. The use of GamerPay’s service when you use our service as a payment service and are obliged to verify the seller on the basis of the requirements for customer knowledge procedures followed in chapter 3 of the Money Laundering act (Hvidvaskloven). Our basis for the process Article 6 (1)(c) of the GDPR about treatments which are necessary to comply with legal requirements.
4.2.3. We use Lemonway as a verification service. We require a copy of passport, drivers license or national identity card (with a picture).
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@example.com.
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)
9.1. You can request to receive an exported file of the personal data we hold about you, including any data you have provided to us (data portability). You can also request that we rectify or erase any personal data we hold about you. Please send your request to firstname.lastname@example.org.
9.2. You can always access your information on your profile and edit your information if your address or email has changed. As a user of the platform, you are responsible for having correct and updated information on your profile. To update your information, go to Profile.
9.3 You are welcome to contact us for additional information about our processing and storage of your data. You are also welcome to contact us to update, edit, delete or request information that you cannot administer yourself on your profile.
9.4 We kindly inform you that you cannot exercise your rights in cases where the rightful interests of GamerPay or other parties in favor of the continued processing of your information exceed your interests in the protection of your personal data. For instance, we claim the right to collect debts or investigate fraud.
9.5 If you wish to make a complaint about our treatment of your data, we ask you to contact us directly. If we are not in a position to help you, you can direct your complaint to the Danish Data Protection Agency.
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