This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to VIRTUAL EGROUP LLC, 300 S Biscayne Blvd, Suite 1503, Miami, FL 33131, United States.
• “Consent” of Personal data procession shall mean any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• “GDPR” means the General Data Protection 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of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time and as transposed into member-state legislation.
• Country refers to: Florida, United States
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Website refers to Skins Dojo, accessible from https://skinsdojo.com
• You (“your”) means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

In short: We only process Your personal information when we believe it is necessary, and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with Your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect Your rights, or to fulfill our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process Your personal information. As such, we may rely on the following legal bases to process Your personal information”

• Consent. We may process information if you have given us permission (i.e., consent) to use your information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process Your information when we believe it is necessary to fulfill Our contractual obligations to You, including providing Our services or at Your request prior to entering in to a contract with You.
• Legitimate interests. We may process Your information when We believe it is reasonably necessary to achieve Our legitimate business interests and those interests do not outweigh Your interests and fundamental rights and freedoms. For example, We may process Your personal information for some of the purposes described in order to:
  • Send user information about special offers and discounts on Our products and services
  • Analyze how Our Services are used so We can improve them to engage and retain users
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how Our users use Our products and services so We can improve user experience
• Legal obligations. We may process Your information where we believe it is necessary for compliance with Our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our rights, or disclose Your information as evidence in litigation in which we are involved.
• Vital interests. We may process Your information where we believe it is necessary to protect Your vital interests or vital interests of a third party, such as situations involving potential threats to the safety of any person.

Under the GDPR You, as a data subject, have certain rights over the personal data that We hold and process.
At VIRTUAL EGROUP LLC, We are committed to make it easy for You to exercise these rights in the most transparent manner possible. You can exercise any of Your rights in relation to the data that VIRTUAL EGROUP LLC holds about You, by contacting Us through the email address provided at the end of this section.

The following are the specific rights You have over Your personal data We hold and process, namely:

• 1) The right to be informed about Our collection and processing of Your personal data including without limitation the legal basis for the collection and processing, the categories of data, the methods of data use, the envisaged period for which the personal data will be retained. This Privacy Policy should tell You everything You need to know, but You can always contact Us to find out more or to ask any questions.
• 2) The right to access Your personal data We collect about You, commonly referred to as “Subject Access Requests”, which provides You, as the data subject, the right to obtain a copy of Your personal data that We are processing for You Pursuant to GDPR We are required to respond without undue delay to all Subject Access Requests, in practice this means We will consider and act upon any request in accordance with applicable data protection laws. Should You wish to make a Subject Access Request this can be done by contacting the Company using the contact details in Section 9.
• 3) The right to have Your personal data rectified if any of Your personal data that We collect and process is in any way inaccurate or incomplete.
• 4) The right of erasure (otherwise known as “the right to be forgotten”), i.e. the right to ask Us to delete or otherwise dispose of any of Your personal data that We process. Please note that this is not an absolute right, and We may not be able to comply with Your request as We may be legally obliged to continue to retain Your personal data for a specific period
• 5) The right to restrict (i.e. prevent) the processing of Your personal data by us.
• 6) The right to object to Us processing Your personal data for a particular purpose or purposes. Please note that the right to object only applies in certain circumstances and will depend on the purposes or legal basis for the processing.
• 7) The right to data portability. This only applies where You have provided personal data to Us directly, the legal basis for Us processing Your personal data is i) consent or ii) for the performance of a contract and We are processing Your data using automated means. In such instances You have the right to receive Your personal data (or request that We transfer it to another Controller) in a structured, commonly used and machine-readable format.
• 8) Rights relating to automated decision-making and profiling. We do not use Your personal data in this way.
• 9) The right to lodge a complaint with any relevant Data Protection Authority, in particular in the member State of Your residence, place of work or the place of processing Your personal data.

If You wish to exercise any of the aforementioned rights, please contact Us. We request that in the first instance You contact us at any time via info@skinsdojo.com. We shall promptly consider Your request and respond to You in accordance with the requirements of GDPR accordingly.

The Personal data can be processed only after receiving clear “Consent” of Personal data procession from user.

This Policy applies only to the Website and Services and We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. On such sites, the user may collect or request other personal information, and other actions may be performed.

The user’s consent to the processing of personal data is valid indefinitely from the moment of acceptance of terms of this Policy in full.

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Address, State, Province, ZIP/Postal code, City
• Steam login, username, icon, other information You made public on Steam
• Data on the use of Our services, links, transactions
• Payment Data
• Live Chat Data
• Data requested as part of a KYC process
• Usage Data

Payment Data

This data is collected when You are making a deposit or withdrawal of funds on Skins Dojo. All transactions are carried out using third-party services. All payment data is stored by GMPays and Stripe. You may find their privacy notice link(s) here: https://gmpays.com/en/privacy and https://stripe.com/privacy

KYC Data

This data is collected when You are going through a Know Your Customer (KYC) process, as part of Your additional Skins Dojo account verification. We are using SumSub as Our KYC tool and all the data that is a part of this process is stored by SumSub. You can find their privacy notice link here: https://sumsub.com/privacy-notice-service/

Live Chat Data

This data is collected when You are contacting us through Our live chat widget on Skins Dojo. We are using tawk.to as Our Support tool, and all the data that is a part of this process is stored by tawk.to. You can find their privacy notice link here: https://www.tawk.to/privacy-policy/

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
• Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
• Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering Your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account:to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and Your experience.

When and with whom do we share Your personal information?

We may share Your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for Us or on Our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard Your personal information. This means that they cannot do anything with Your personal information unless We have instructed them to do it. They will also not share Your personal information with any organization apart from Us. They also commit to protect the data they hold on Our behalf and to retain it for the period We instruct. Examples of categories of third parties We may share personal information with are as follows:

• Data Analytics Services.
• Payment Processors.
• Communication & Collaboration Tools.
• KYC Processing Tools.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service. You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us. Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us. When You provide Your personal data through Our Website, this information is transmitted across the internet securely using industry standard encryption. Your personal data will be held encrypted on secure servers. Where any third parties process Your personal data on Our behalf, We require that they have appropriate technical and organizational measures in place to protect this personal data. However, while We strive to use commercially acceptable means to protect Your Personal Data, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Although we will do our best to protect Your personal information, transmission of personal information to and from our Services is at Your own risk. You should only access the Services within a secure environment.

In short: Yes, if you a resident of California, you are granted specific rights regarding access to your personal information. This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Skins Dojo and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the Privacy Policy. This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

• 1) every individual who is in the State of California for other than a temporary or transitory purpose and
• 2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

Categories of personal information collected, disclosed or sold

Information we collect: the categories of personal information we collect

How we collect information: what are the sources of the personal information we collect?

Will your information be shared with anyone else?

Sale of your personal information

Your right to opt out of the sale of personal information

Instructions to opt out of the sale of personal information

What are the purposes for which we use your personal information?,

We may use your personal information to allow the operational functioning of Skins Dojo and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes. We may also use your personal information for other reasons such as for commercial purposes, as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage. We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.