BRAINYQ LTD (hereinafter - “we”, “us”, “CSkinMasters”, “the Company”) have created this Privacy Policy to help you understand what data we collect, what we use it for and how you can exercise your rights. Reading Privacy Policy is very important, so we hope you will give it time and attention.

Privacy and security of our Users and visitors are of greatest importance for us. The Company is committed to protecting the data you share with us. This Privacy Policy explains how we process information that can be used to identify individuals directly or indirectly (hereinafter - the “Personal Data”) collected using https://cskinmasters.com/.

For the purposes of this Policy, we define the term “User” as a person who has created personal account with us and the term “Visitor” as an individual who visits https://cskinmasters.com/.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using CSkinMasters.net.

Unless specified otherwise, all Data requested by CSkinMasters is mandatory and failure to provide this Data may make it impossible for us to provide its services. In cases where the Company specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact Data Controller at support@cskinmasters.net.

Any use of Cookies – or of other tracking tools – by us or by Data Controllers of third-party services used by the Company serves the purpose of providing the Services required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through https://cskinmasters.com/ and confirm that they have the third party's consent to provide the Data-to-Data Controller.

We adhere to the following principles to protect your privacy:

• principle of purposefulness - we process Personal Data fairly and in a transparent manner only, aiming to achieve determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of data processing.
• principle of minimalism - we collect Personal Data only to the extent necessary to achieve determined purposes. We do not keep Personal Data if it is no longer needed.
• principle of restricted use - we use Personal Data for all other purposes only with the consent of the data subject or if permitted by a competent authority.
• principle of data quality - we always keep Personal Data up-to-date and complete in order to achieve the end purpose of the data processing more efficiently.
• principle of security - security measures shall be applied in order to protect Personal Data from unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures.
• principle of individual participation - our Users and Visitors shall be notified of data collected in connection with them. They shall be granted access to their Personal Data and have the right to demand a correction of inaccurate or misleading data.

1. Data we collect and purposes of data processing

1.1. Visitors

We may collect, record, and analyze information of Visitors to https://cskinmasters.com/.

We also record Usage Data. It is information collected automatically through our website, which can include: the IP addresses or domain names of the computers utilized by the Users who use CSkinMasters, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page) and the details about the path followed with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

We use this information in aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you. When combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.

Processing this information is relied on our legitimate interests. It is necessary for managing and running our business to efficiently and effectively provide quality services including client support, developing and improving services, determining who may be interested in them.

We may process information only if there is a legitimate interest. We do so after having considered:

a) whether the same objective could be achieved through other means;

b) whether processing (or not processing) data might cause you harm;

c) whether you would expect us to process your data and consider it reasonable for us to do so.

For example, CSkinMasters may process your data for the following purposes:

a) To create anonymous, aggregated statistics about the use of our website, products, services and other programs, which we may share with third parties and/or make available to the public.

b) To develop and improve new and existing products and services, recommendations, advertisements and other communications, and learn more about our users’ preferences in general.

When you contact us, whether by telephone or email, you give us your implicit consent because you reasonably expect us to reply. We collect the data you give us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of the organization of our client support service. We keep personally identifiable information associated with your message, such as your name, email address and mobile telephone number, so as to be able to track our communications with you in order to provide you with high quality service.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to use cookies.

1.2. Users

In order to provide services to our Users, we collect their Personal Data. During the creation of your account on our website, you provide us with your email and Steam Trade URL.

We process this information on the basis that there are an Agreement (When you complete the registration of an account on our website an Agreement is formed between you and us) between us, legal obligations, and our legitimate interests.

This information is used by us to identify our Users, provide you with services, prevent fraud, create and manage User accounts, payments and withdrawals, respond to any User complaints, prevent and detect improper use of our systems, prevent crime, detect, investigate, and report crime, manage risk for us and our Users, comply with any laws and regulations that apply to us, provide you with billing, mailings, notification, support, marketing actions, the ability to restore account in case of loss, and to meet other obligations. Additionally, we may use it in order to provide you with suggestions and advice on services and how to obtain the most from using our website. We use such data in ways you would reasonably expect and which have a minimal privacy impact.

Processing of Personal Data for marketing purposes is relied on the consent obtained from you.

2. Compliance with General Data Protection Regulation (GDPR)

For Visitors and Users located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR).

CSkinMasters processes Personal Data as a Controller, as defined in the GDPR:

The Company, with which, you as a User, have entered into an agreement when you created your User account at our Website, will be the Controller of User Data, as outlined above in the “User” section.

Also, the Company will be the Controller for Visitor Data, as outlined above in “Visitor” section.

Our Privacy Policy have to be compliant with the laws of every country or legal jurisdiction within which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our website.

3. The rights of Users

Users may exercise certain rights regarding their Data processed by Data Controller. In particular, Users have the right to do the following:

a) Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

b) Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

c) Access their Data. Users have the right to learn if Data is being processed by Data Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

d) Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

e) Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, Data Controller will not process their Data for any purpose other than storing it.

f) Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from Data Controller.

g) Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

h) Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

When we receive any request to access, edit or delete personally identifiable information, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Where Personal Data is processed for the purposes of the legitimate interests pursued by Data Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification by contacting us at email support@cskinmasters.net.

Any requests to exercise User rights can be directed to Data Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by Data Controller as early as possible and always within one month.

4. Data Retention

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

We will keep your data for the period that you are a User of CSkinMasters. If you are no longer a User of CSkinMasters, we will keep your data for the minimum length of time required to comply with the purposes set out in this policy and relevant legal or regulatory obligations.

Therefore:

a) Personal Data collected for purposes related to the performance of a contract between Data Controller and the User shall be retained until such contract has been fully performed.

b) Personal Data collected for the purposes of the Data Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by Data Controller.

The Data Controller may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Any information about the Visitors is deleted on an annual basis. Your information will be deleted if you did not communicate with the support team for more than 12 (twelve) months.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

5. Information Security

The Company strictly follows generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When we or our contractors process your information, we also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.

There is no 100% secure method of transmission over the Internet or electronic storage. We therefore cannot guarantee its absolute security.

6. Use of site by children

We do not provide services or market for children. The Service is not directed to people under the age of 18. Users declare themselves to be adults according to their applicable legislation.

We collect data about all Users and Visitors regardless of age and we do not expect that some of those users and visitors will be children.

7. Application of this Privacy Policy

This Privacy Policy is applicable to https://cskinmasters.com/privacy. Our website may contain links to other websites. Once you are redirected to another website, this Policy is no longer applicable. This version of the Privacy Policy is effective as of 08th September 2024.

We assume that all Visitors and Users have carefully read this Privacy Policy, understand its contents, and agree to the terms and conditions stated in the Privacy Policy above. If one does not agree with this Privacy Policy, they should refrain from using https://cskinmasters.com/.

8. Changes and Updates to our Privacy Policy

We may update this Privacy Policy from time to time, so please review it frequently. All changes to this Privacy Policy are effective upon being posted on this page.

If any material changes are made to this Privacy Policy, we will make reasonable efforts to inform you in advance by email or notice on the website. When we change this Policy in a material manner, we will let you know via email prior to the changes becoming effective and update the ‘effective date’ at the top of this page.