Privacy Agreement

Last updated: May 6, 2025

Your privacy matters to us. This Privacy Agreement ("Agreement") explains what information we collect, how and why we use it, and how we manage it when you use PRIMERY SKINS services. Processing of personal data is governed by the EU General Data Protection Regulation 2016/679 (GDPR) and applicable data protection laws. By continuing to use our Services, you confirm that you have read and understood this Agreement.

01

Data Controllers

The joint data controllers are:

CS VIRTUAL TRADE LTD — registered under Cyprus law. Registration number: HE 389299. Address: Spyrou Araouzou & Koumantarias, 705, Fayza House, 1st floor, 3036, Limassol, Cyprus.

G2G Marketplace Limited — registered in Hong Kong. Registration number: 3064044. Address: 8F, 30 Hollywood Road, Central, Hong Kong.

Hereinafter collectively referred to as "we" or "PRIMERY SKINS".

02

Privacy Contact

For any questions regarding the processing of your personal data or exercising your rights, please contact our Data Protection Officer at: hello@primeryskins.com

03

Scope of This Agreement

This Agreement applies to all PRIMERY SKINS services, including:

  • The PRIMERY SKINS platform (primery-skins.ru) and mobile app
  • CS:GO Skins Wiki
  • 3D viewer
  • PRIMERY SKINS Blog
  • Browser extensions
  • Other services that link to this Agreement
04

How We Collect Your Data

Personal data is any information that can identify you — directly (e.g., your name or email) or indirectly (e.g., your language or currency preference).

We collect data directly from you or receive it from our partners.

When you visit our sites, we automatically collect technical data and usage statistics via cookies — our own or set by partners. This helps us keep the service running correctly, analyze how you use it, remember your preferences, and personalize content and ads. See our Cookie Policy for details.

05

What Data We Process

Device and Location Data

When you visit our Sites, we collect your IP address, location data (country, city), and information about your device and browser.

Account Data

When you log in via Steam or social networks, we receive your account ID (Steam ID), avatar, username, list of virtual items, and other public information. You may add more details to your profile manually. Account data also includes: registration date, number of trades, subscription status, Steam64ID, trade link, and seller link.

Usage Data

We collect information about how you interact with the service: personal settings, trade history, cart, payments, refunds, subscriptions, search queries, page views, comments, likes, support requests, and suggestions for improvement.

Contact Details

Email address and Telegram.

KYC Data (Identity Verification)

To prevent fraud and enable the withdrawal feature, we may request: your full name, ID document number and a copy of it, a selfie holding your ID, a partially obscured photo of your bank card, a video of your face, and proof of address (utility bill or bank statement). Verification is performed by us or contracted services solely for identification purposes.

Payment Data

When you make a payment, your card details go directly to the payment provider (e.g., PayPal), which processes them under its own privacy policy. We only receive the partial card number and issuer information. We may request your address to generate receipts.

Survey Data

When you participate in research, we collect your responses and respondent profile (gender, age, education, occupation, location). Results are published in aggregate, anonymized form only — unless otherwise agreed in writing.

06

Why and On What Basis We Process Your Data

We process your data for the following purposes:

  • Providing and personalizing the Sites and Apps — based on contract
  • Delivering services and processing payments — based on contract
  • Diagnosing and fixing technical issues — based on contract
  • Conducting marketing research and showing personalized ads — based on your consent
  • Developing new features and improvements — based on legitimate interests
  • Complying with law and responding to government requests — based on legal obligation
  • Preventing fraud and resolving disputes — based on legitimate interests
  • Business planning and analytics — based on legitimate interests

If processing is based on your consent, you may withdraw it at any time by contacting us at hello@primeryskins.com or following the instructions in our Cookie Policy.

Data may be aggregated and anonymized. Such data does not identify you and is not subject to this Agreement.

07

Who We Share Your Data With

We may share your data with the following categories of recipients:

  • Payment services — to process transactions
  • Analytics and marketing platforms — to analyze service usage and deliver personalized content
  • Government bodies, auditors, consultants — to fulfill legal requests and tax obligations
  • Other service providers — involved in delivering the purposes described in this Agreement
  • Affiliated entities — for service delivery
08

How Long We Keep Your Data

Your personal data is retained for as long as needed to fulfill the contract, comply with applicable law, and pursue our legitimate interests. Once data is no longer needed for these purposes, we delete it.

Upon account deletion or at your request, data is deleted or anonymized within 30 days. Exceptions include:

  • If financial transactions were made under your account — relevant data is kept for 180 days after the last transaction
  • If there are unresolved disputes or claims — until they are fully settled
  • If required by legal, tax, or audit obligations — for the applicable retention period
  • If necessary to prevent fraud or protect user safety

KYC data (documents, photos, videos, proof of address) is retained for 3 months to support chargeback appeals and dispute resolution.

09

Your Rights as a Data Subject

As a data subject, you have the following rights:

  • Access — request a copy of your personal data and information about how it is processed
  • Rectification — request correction or updating of inaccurate data
  • Erasure — request deletion of your data if it is no longer needed, was processed based on consent, or there is no legal basis for retaining it
  • Objection — object to processing in specific situations, including for direct marketing purposes
  • Objection to automated decisions — request a manual review of decisions made automatically
  • Data portability — receive your data in a machine-readable format (XML, CSV) or request its transfer to another controller
  • Right to complain — file a complaint with the data protection authority in the country where you live or work

California residents may also request information about categories of data collected, sources, purposes of use, and disclosures to third parties. California residents under 18 may request removal of content they posted on our sites.

To exercise any of these rights, contact us at: hello@primeryskins.com. We may need to verify your identity before fulfilling your request.

10

Commercial Use of Data

We do not sell personal data in the traditional sense. However, under the CCPA, the use of third-party cookies may qualify as a "sale".

We share the following categories of data — identifiers, internet activity, and statistics — with Google Analytics, Yandex.Metrica, Amplitude, Facebook, TikTok, and VKontakte. Data is shared solely for analytics and marketing purposes. To opt out, please contact support.

11

Data Security Incidents

If we become aware of a data breach that may put your rights and freedoms at risk, we will notify the relevant supervisory authority within 72 hours. If notification within that timeframe is not possible, the reasons for the delay will be included in the report.

12

Protection of Minors' Data

We do not knowingly collect or process data from children without parental or guardian consent. For the purposes of this Agreement, a child is any person under 13 (US) or 16 (EU) — or the minimum age set by applicable law.

If you believe your child has submitted data to us without your knowledge, please contact us at: hello@primeryskins.com

13

International Data Transfers

To achieve the purposes described in this Agreement, we may transfer personal data to controllers and processors located outside the European Union (EU) or European Economic Area (EEA).

Transfers are made using Standard Contractual Clauses (SCCs) approved by the European Commission. All partners processing data on our behalf have adopted SCCs and are required to uphold privacy, security, and lawful processing standards.

14

Updates to This Agreement

We reserve the right to update this Agreement from time to time. The latest version is always available on our website. Continued use of the service after changes are published constitutes acceptance of the updated terms. We recommend reviewing this document periodically.

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