Privacy Policy

1. Overview

This Privacy Policy explains how WOW Skins (operated by Cyber Wagon Limited) collects, uses, stores, and protects your personal information when you use our Counter-Strike 2 (CS2) skins marketplace at www.wowskins.market ("Services").

1.1 Scope

In this Privacy Policy, the terms "WOW Skins," "Company," "we," and "us" refer to Cyber Wagon Limited and its subsidiaries and affiliates.

This notice describes how WOW Skins and its subsidiaries and affiliates collect and use personal data. Please note that websites, apps, features, or other services owned and operated by WOW Skins may contain links to digital properties owned and operated by other companies. This Privacy Policy does not apply to websites and services owned and operated by unaffiliated third parties.

1.2 Data Controller and Processing

Cyber Wagon Limited is the data controller for the personal data collected in connection with use of WOW Skins' Services.

Data Processing: WOW Skins operates and processes data in the United Kingdom and the EU. We process data in accordance with applicable data protection laws and regulations, including but not limited to the UK GDPR and EU GDPR. We implement appropriate technical and organizational measures to ensure the security and confidentiality of your personal data.

1.3 Relationship with Steam

WOW Skins has no affiliation, endorsement, or sponsorship relationship with Valve Corporation or the Steam platform. We are an independent third-party marketplace platform.

2. Data Collection

2.1 The Data We Collect

WOW Skins collects:

• Data provided by users to WOW Skins, such as during account creation
• Data created during use of our website and Services, such as log data, location, app usage, and device data
• Data from other sources, such as WOW Skins partners

The following data is collected by or on behalf of WOW Skins:

2.1.1 Data Provided by Users

This includes:

User Profile: We collect data when users create or update their user profile, such as their WOW Skins marketplace accounts. This may include their name, email, country, and birthdate.

Payment Information: We work with third-party payment processors to handle payment transactions. We do not directly store complete payment card details. Payment processors may collect payment information (including related payment verification information) necessary to process transactions. Please refer to our payment processors' privacy policies for details on how they handle payment data.

Identity Verification (KYC): When required for compliance purposes, we use third-party identity verification service providers to verify user identity. These third-party providers process and store identity documents and verification data on our behalf. We do not directly store sensitive identity documents such as passports, driver's licenses, or government-issued IDs. We only receive and retain verification results (approved/rejected status) and basic identity information necessary for compliance with applicable laws.

Commercial Information: We may collect information about Services purchased, obtained, or considered.

Demographic Data: We may collect basic demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.

User Content: We collect the information users submit when they contact WOW Skins customer support, provide ratings, or otherwise contact WOW Skins. This may include feedback or other communications collected by users.

2.1.2 Data Created During Use of Our Website and WOW Skins Marketplace

This includes:

Location Data: WOW Skins may collect general location data (such as country or city level) during your use of the WOW Skins Services for security and service improvement purposes.

Usage Data: We collect data about how users interact with our Services. This includes data such as access dates and times, type of browser, and third-party sites or services used before interacting with our Services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Policy.

Device and Log Data: We may collect data about the devices used to access our Services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, and mobile network data.

Communications Data: We enable users to communicate with each other and WOW Skins through WOW Skins' Services. To provide this service, WOW Skins receives some data regarding the communications, including the date and time of the communications. WOW Skins may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and Services, and for analytics.

2.1.3 Data from Other Sources

This includes:

User feedback.

Users participating in our referral programs. For example, when a user refers another person, we receive the referred person's personal data from that user.

Users or others providing information in connection with claims or disputes.

WOW Skins business partners through which users create or access their WOW Skins account, such as payment providers, social media services.

Publicly available sources.

Marketing service providers.

Information from our affiliates.

WOW Skins may combine the data collected from these sources with other data in its possession.

3. How We Use Personal Data

WOW Skins collects and uses data to provide and improve (including providing updates to) its marketplace Services. We also use the data we collect:

• To enhance the safety and security of our users and Services, including, but not limited to, to prevent and combat fraud, phishing, scams and bots
• To verify and authenticate certain information or data, such as website domains
• To improve and enhance user experiences
• For customer support
• For research and development
• To enable communications between users
• To send marketing and non-marketing communications to users
• In connection with legal proceedings

WOW Skins does not sell or share user personal data with third parties for their direct marketing, except with users' consent.

WOW Skins uses the data it collects for purposes including:

3.1 Providing Services and Features

WOW Skins uses the data we collect to provide, personalize, maintain, and improve our products and Services. This includes using the data to:

• Provide the Services
• Create and update users' accounts
• Offer, process, or facilitate payment for our Services
• Enable features that allow users to share information with other people, such as when users refer a friend to WOW Skins
• Enable features to personalize users' WOW Skins accounts
• Enable Accessibility features that make it easier for users with disabilities to use our Services
• Perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends

3.2 Safety and Security

We use personal data to help maintain the safety, security, and integrity of our Services and users. This includes:

• Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities

3.3 Customer Support

WOW Skins uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

• Direct questions to the appropriate customer support person
• Investigate and address user concerns
• Monitor and improve our customer support responses and processes

3.4 Research and Development

We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes, and develop new features and products.

3.5 Marketing

WOW Skins may use the data we collect to market our Services to our users. This includes sending users communications about WOW Skins Services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of WOW Skins' Services, and user preferences and settings.

3.6 Non-Marketing Communications

WOW Skins may use the data we collect to inform users of changes to our terms, services, or policies; or send other communications that aren't for the purpose of marketing the services or products of WOW Skins or its partners.

3.7 Legal Proceedings and Requirements

We may use the personal data we collect to investigate or address claims or disputes relating to use of WOW Skins' Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

3.8 Automated Decision-Making

We use personal data to make automated decisions relating to use of our Services. This includes:

• Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm WOW Skins, its users, and others

To object to a decision resulting from these processes, please contact us using the information in the "Contact Us" section below.

4. Data Sharing and Disclosure

Some of WOW Skins' products, Services, and features require that we share data with other users or at a user's request. We may also share data with our affiliates, subsidiaries, and partners for legal reasons or in connection with claims or disputes.

WOW Skins may share the data we collect:

4.1 At a User's Request or for Jointly-Offered Services

This includes sharing data with:

• Other people at the user's request
• Users participating in WOW Skins' referral program
• WOW Skins service and platform partners

For example, if a user requests a service through a partnership or promotional offering made by a third party, WOW Skins may share certain data with those third parties.

4.2 With the General Public

Questions or comments from users submitted through public forums such as WOW Skins blogs and WOW Skins social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4.3 With WOW Skins Subsidiaries and Affiliates

We share data with our subsidiaries and affiliates to help us provide our Services or conduct data processing on our behalf.

4.4 With WOW Skins Service Providers and Business Partners

WOW Skins provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners.

These include:

• Cloud storage providers
• Marketing partners and marketing platform providers, including social media advertising services
• Data analytics providers
• Research partners, including those performing surveys or research projects in partnership with WOW Skins or on WOW Skins' behalf
• Vendors that assist WOW Skins to enhance the safety and security of our Services
• Consultants, lawyers, accountants, and other professional service providers
• Insurance and financing partners

4.5 For Legal Reasons or in the Event of a Dispute

WOW Skins may share users' personal data if we believe it's required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our terms of use and/or terms of service, user agreements, or other policies; to protect WOW Skins' rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our Services.

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

4.6 With Consent

WOW Skins may share a user's personal data other than as described in this notice if we notify the user and they consent to the sharing.

5. Anonymized And Aggregated Data

We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of the Services and their features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit. Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.

6. Cookies And Third-Party Technologies

WOW Skins and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. WOW Skins uses cookies and similar technologies for purposes such as:

• Enabling you to initiate, accept, and manage skins transactions through WOW Skins
• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our Services

We may also allow others to provide audience measurement and analytics services for us. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

6.1 Cookie Management

You may wish to restrict the use of cookies. Please be aware that some of the features of our Site may not function correctly if you disable cookies.

Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, please refer to your browser's help documentation.

6.2 Personalized Advertising

You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative's Consumer Opt-Out link, the DAA's Consumer Opt-Out link for browsers, or the DAA's opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

7. Do-Not-Track Signals

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

8. Children

Our websites and Services are not directed at individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information, please contact us using the contact details provided in the "Contact Us" section below. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.

9. Data Retention

We may retain your personal data for a period of time consistent with the original purpose of collection (see the "How We Use Personal Data" section above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for personal data on the basis of the amount, nature, and sensitivity of the personal data being processed, the potential risk of harm from unauthorized use or disclosure of the personal data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your personal data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of or access to such data.

10.1 Specific Retention Periods

• Account Data: Retained while account is active plus 7 years (financial compliance)
• Transaction Records: 7 years from transaction date
• Identity Verification Data: 5 years from account closure (as required by applicable financial regulations)
• Marketing Communications: Until unsubscribe or account deletion
• Support Communications: 3 years from last interaction
• Security Logs: 2 years for fraud prevention purposes

10. Your Rights Relating to Your Personal Data

10.1 Your Rights

You may have certain rights relating to your personal data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

• Access your personal data held by us
• Know more about how we process your personal data
• Erase or delete your personal data, to the extent permitted by applicable data protection laws
• Restrict our processing of your personal data, to the extent permitted by law
• Object to our processing of your personal data. Where we process your personal data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection
• Opt-out of certain disclosures of your personal data to third parties
• Not be discriminated against for exercising your rights described above

10.2 Additional Rights Under GDPR

If you are located in the European Economic Area or the United Kingdom, under GDPR you have the following additional rights:

Right of Access: You can ask us to provide you with information about our processing of your personal information and give you access to your personal information.

Right to Rectification: If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified.

Right to Erasure: You can ask us to delete or remove personal information where:

• There is no lawful reason for us continuing to store or process it
• You have successfully exercised your right to object to processing
• We are required to erase your personal information to comply with local law

Note that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

Right to Restrict Processing: You can ask us to suspend the processing of your personal information if:

• You want us to establish the information's accuracy
• You need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims
• You have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it

Right to Object: Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel that it impacts on your fundamental rights and freedoms.

Right to Data Portability: You have the right, in certain circumstances, to ask us to provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to Withdraw Consent: Where we are relying on consent to process your personal information you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

Right to Lodge a Complaint: Although we urge you to contact us first to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.

10.3 Limitations on Rights

Please note that some of these rights may be limited where we have an overriding interest or a legal obligation to continue to process the personal information or where certain exemptions apply.

10.4 How to Exercise Your Rights

To exercise your rights, please contact us using the information in the "Contact Us" section below and specify which privacy right(s) you wish to exercise. We may need to verify your identity in order to honor your request.

We will respond to all legitimate requests in a timely manner and in accordance with applicable laws, and will contact you if we need additional information from you in order to honor your request or verify your identity.

10.5 Your Preferences for Marketing Communications

We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the "Contact Us" section below. You will still continue to receive service-related messages concerning products and Services you have purchased (unless we have indicated otherwise).

11. How We Secure Your Personal Data

We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information.

11.1 Security Measures

We implement comprehensive security measures:

• Encryption: Data encrypted in transit and at rest
• Access Controls: Role-based access with multi-factor authentication
• Security Assessments: Regular penetration testing and vulnerability assessments
• Staff Training: Comprehensive privacy and security training programs
• Incident Response: Established breach notification and response procedures

However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of personal information obtained through the websites, we cannot ensure or warrant the security of any information you transmit to us.

12. Changes to This Privacy Policy

We may change our Privacy Policy at any time. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version.

12.1 Notification Process

For material changes:

• Website Notice: Updated policy posted with prominent notification
• Email Notice: Direct notification to registered users
• Advance Notice: 30 days before changes take effect
• Continued Use: Ongoing use constitutes acceptance of changes

13. Contact Us

If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details:

Email: support@wowskins.market

13.1 EU Users

For EU users regarding GDPR matters: Although we urge you to contact us first to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.

13.2 Governing Law

This Privacy Policy is governed by:

• United Kingdom Law: Data Protection Act 2018 and UK GDPR
• EU Users: GDPR provisions apply where they provide greater protection
• US Users: Applicable federal and state data protection laws, including but not limited to the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other applicable state privacy laws