Privacy Policy

PRIVACY POLICY — skinharbor.org

Effective Date: May 7, 2026

1. CONTROLLER IDENTITY AND SCOPE OF POLICY

● Purpose of Document: This Privacy Policy serves to transparently articulate how skinharbor.org collects, processes, defends, and discloses your personal data when you interact with our digital platform to acquire or trade in-game skins. Utilizing our ecosystem establishes your active agreement to these data practices.

● Data Controller Designation: The entity legally responsible for the safeguarding and processing of your data is SYNVEX LTD, a corporation registered in England and Wales under Company No. 17048214.

● Privacy Communications: All inquiries regarding your data rights or this policy should be addressed directly to info@skinharbor.org

2. EXHAUSTIVE CATEGORIES OF COLLECTED DATA

● Biographical and Contact Data: Foundational information including your legal name, electronic mail address, and physical billing coordinates.

● Transactional Records: Comprehensive histories detailing your platform orders, digital receipts, and authenticated payment confirmations.

● Compliance and Regulatory Data: Sensitive documentation such as government-issued identity proofs, residency verification, and birth dates, which are strictly required by payment partners and regulators to satisfy Anti-Money Laundering (AML) and Know Your Customer (KYC) laws.

● Trading and Steam Metadata: Digital identifiers essential for service delivery, including your active Steam moniker, unique trade URLs, and real-time delivery status logs.

● Digital Footprints (Technical Data): Background metrics captured during browsing, encompassing your IP address, device specifications, browser type, operating system configurations, and distinct cookie identifiers.

● Payment Processing Data: High-security payment details, which are handled and encrypted directly by authorized third parties. We emphatically state that we do not store full credit or debit card numbers on our servers.

● Support Correspondence: The contents of all written communications and inquiries transmitted to our customer service desk via email or digital forms.

3. DATA ACQUISITION METHODOLOGIES

● Active User Submissions: We collect data that you intentionally provide when navigating the checkout process, registering a new account profile, or communicating with our support team.

● Passive Technological Tracking: We automatically aggregate technical footprints and behavioral data utilizing cookies, analytical SDKs, and similar tracking technologies as you move through the Website.

● Third-Party Data Relays: We receive necessary transactional updates and compliance signals from authorized external payment processors, including but not limited to Stripe, PayPal, and WooCommerce.

4. LEGAL JUSTIFICATIONS AND PURPOSES OF PROCESSING

● Service Fulfillment: Your data is primarily processed to flawlessly execute your commercial orders and ensure the successful delivery of CS2 assets via Steam’s trade infrastructure.

● Regulatory Adherence: A massive portion of processing is dedicated to satisfying overriding legal obligations, including tax accounting, anti-terrorism financing rules, payment scheme directives, and robust AML/CTF regulations.

● Security and System Improvement: We heavily analyze platform data to debug software errors, deploy analytical models, fortify network security, and proactively neutralize fraud vectors.

● User Communication: We process contact data to dispatch critical transaction receipts, platform updates, and responses to support tickets.

● Contractual Enforcement: Data is leveraged to enforce the rules established within our overarching Terms of Service, ensuring all processing remains strictly proportionate to preventing fraud and fulfilling orders.

5. DISCLOSURE OF INFORMATION AND VENDOR INTEGRATION

● Financial Ecosystem Partners: To secure transactions and combat financial crime, your data is securely transmitted to acquiring banks, major card networks, and payment processors handling chargebacks and AML screenings.

● Platform Operations: We share limited data points with specialized technical providers responsible for server hosting, communications routing, customer support interfaces, and behavioral analytics.

● Asset Transfer Partners: Specific trading data must be shared with Valve Corporation and the Steam network to successfully execute trade offers.

● Legal and Advisory Disclosures: We will surrender data to professional legal advisers, regulatory bodies, or law enforcement agencies if legally mandated or necessary to defend our corporate integrity.

● Commercial Safeguards: We operate under a strict policy that prohibits the sale of any personal user data. All payment processing is siloed within authorized providers (e.g., Stripe, PayPal), ensuring SYNVEX LTD neither accesses nor archives full payment card details.

6. RETENTION LIFECYCLES FOR PERSONAL DATA

● Taxation and Accounting Archives: To remain compliant with international financial reporting standards, records pertaining to orders and monetary transactions are preserved for a duration of up to 6 years.

● Financial Crime Compliance (AML/KYC): Documentation collected for identity verification is archived for a non-negotiable minimum of five years, extending further if specifically demanded by financial regulators.

● Customer Support Records: Logs of correspondence are retained solely for the period required to fully address your queries and maintain historical context for future assistance.

● Technological Metrics: Cookies and accumulated analytics data remain active strictly for their programmed lifecycles or until you proactively purge them from your device.

7. COMMUNICATION PROTOCOLS AND MARKETING

● Core Service Alerts: We mandate the use of your email to transmit essential order confirmations, trade status updates, and critical security notices regarding your account.

● Promotional Materials: Marketing campaigns and newsletters are exclusively dispatched to users who have explicitly opted in. While marketing consent can be revoked at any time, mandatory service emails will continue unaffected.

8. DATA SECURITY AND ALGORITHMIC DECISIONS

● Infrastructure Fortification: We deploy a combination of rigorous organizational policies and technical safeguards, including data encryption and strict access controls, to shield your information. However, users must recognize that no digital system is impenetrable, and the responsibility for credential confidentiality remains with the user.

● Automated Fraud Screening: Transactions are routinely subjected to automated risk assessments by banks and fraud-monitoring algorithms, which may autonomously approve or decline a payment. You possess the absolute right to contest an automated rejection and request a manual human review of the decision.

9. STATUTORY RIGHTS UNDER UK GDPR

● Data Subject Entitlements: The UK GDPR legally empowers you with the right to access, accurately correct, or demand the complete erasure of your personal data.

● Processing Control: You may actively restrict or formally object to specific processing activities, request your data in a structured, portable format, and immediately withdraw any previously granted consent.

● Escalation Avenues: To execute these rights, you must contact info@skinharbor.org. If unsatisfied with our response, you retain the right to lodge a formal complaint with the UK’s Information Commissioner’s Office (ICO) at www.ico.org.uk.

● Minor Protection: Our platform is constructed strictly for individuals aged 18 and older. We do not intentionally harvest data from children; if such data is discovered, please notify us immediately to facilitate its permanent deletion.

10. INTERNATIONAL TRANSMISSIONS AND POLICY REVISIONS

● Cross-Border Relays: Due to the global nature of payment processing, your data may occasionally be transferred to technical or banking partners operating outside the

UK/EEA. In these instances, we enforce robust legal safeguards, relying on adequacy decisions or implementing Standard Contractual Clauses to guarantee continuous protection.

● Document Updates: This Privacy Policy is reviewed and updated periodically. All material alterations will be published on this exact page alongside a revised effective date. Your continued utilization of our services implies unequivocal acceptance of the modified policy.

● Corporate Details: SYNVEX LTD, 5 Kew Road, London, United Kingdom, TW9 2PR. Digital Contact: info@skinharbor.org.