Osidio Services Limited ("We", "Company") is dedicated to protecting your personal data and maintaining the highest standards of privacy. This Privacy Policy ("Policy") serves as a comprehensive guide to our data handling practices.

This Policy explains:

• What personal data we collect
• How and why we collect your data
• The purposes for which we use your information
• Your rights regarding your personal data

We invite you to read this document carefully, as it covers all personal data collected through our Website, including product purchases and communications via our website and email. This Policy is an integral part of our Terms and Conditions and should be interpreted in conjunction with those terms.

Responsibility for data processing

As the primary data controller, we bear the main responsibility for processing your personal data in accordance with this Policy. In certain situations, data protection responsibilities may be shared with third parties, whose roles are detailed in subsequent sections. We operate in full compliance with Regulation (EU) 2016/679 (GDPR), ensuring the protection of natural persons' personal data and facilitating the free movement of such data.

For any questions, please contact us at [email protected] or our legal address.

Personal data collection practices

We are committed to the principle of data minimization, collecting only the personal information necessary for the purposes outlined in this Policy. Our data collection practices are carefully designed to respect your privacy while enabling essential service functionality.

1. Third-party data collection

When you sign in to our Website using your Steam user account, we receive personal data from Valve Corporation, the Steam platform owner. This information includes your Steam ID, username, and user picture. These details enable us to identify your Steam profile and access publicly available information associated with your Steam account, such as your virtual items inventory.

It is important to understand that we do not control or bear responsibility for Valve Corporation's additional uses of your personal data. We strongly recommend reviewing Valve's Privacy Policy to fully understand their data handling practices.

2. Personal data collection

We collect your email address during the account registration process on our Website. Upon signing in, we automatically create your Account and assign you a unique Consumer ID, which will serve as a reference point for your Account throughout our platform.

Data automatically collected

When you access, use, and navigate our Website, we automatically gather the following personal information:

• Your IP address, location information, mobile operator or internet provider details.
• Operating system, browser type and version, screen resolution, time zone, language settings, device model and manufacturer.
• Browsing interaction details, number of pages visited, interface interactions, website navigation patterns.
• Traffic source information, the origin from which you accessed our Website.

We collect additional data through cookies, as detailed in our comprehensive Cookie Policy. Our use of cookies helps improve your browsing experience and site functionality.

Transaction data collection

We record information related to your product transactions, including:

• Deposit details
• Product purchases through the Website
• Product transfers to your Steam user account
• Payment Information Handling

While we do not directly process payments, we receive transaction information from our payment providers, specifically:

• Unique transaction ID
• Payment instrument used
• Your IP address associated with the transaction
• contact information processing

When you communicate with us through the Website or via email, we collect:

• Your full name
• Email address
• Any additional voluntary information you choose to share

Cookies usage

We use cookies to access and store information. Our Cookie Policy provides comprehensive details about our cookie technologies and offers options for cookie preferences.

What are the purposes and legal bases for processing personal data?

Purpose (why we use Your personal data)	Categories of personal data used for the relevant purpose	The legal basis for processing
Providing you with access to the Website functionality	Data automatically collected, Cookie data	Legitimate interest: Ensuring you can access and use the Website (Article 6(1)(f) of the GDPR).
Maintaining the correct operation and ensuring the security of the Website	Data automatically collected, Cookie data	Legitimate interest: Ensuring the proper functioning of the Website and protection against threats (Article 6(1)(f) of the GDPR).
Improving the performance of the Website	Data automatically collected, Cookie data	Legitimate interest: Analyzing interaction effectiveness to improve the user experience (Article 6(1)(f) of the GDPR).
Communication with you during your use of the Website	Contact data	Legitimate interest: Communicating with users and fulfilling a contract (Article 6(1)(f) of the GDPR).
Registration and administration of Your Account	Account data	Performance of a contract: Necessary to create and manage your account.
To provide you with purchased Products	Account data, Payment data	Performance of a contract: Ensuring payment and product delivery (Article 6(1)(b) of the GDPR).

How long will we store Your personal data?

We are committed to storing your personal data for no longer than necessary to achieve the purposes outlined in this Policy. In the event of any dispute with you, we will retain your personal data for as long as required to resolve the matter.

• Regarding data automatically collected during your visits to the Website, we will store this information for 14 months from your last visit.
• For your Account data and Transaction data, we will retain this information only for as long as necessary to maintain your active account. If you do not use your Account for 6 months, we will erase this data.
• Your Contact data will be stored only for the duration of our communications with you. Once the purpose of our communication is fulfilled, we will remove this data.
• We will retain your Payment data for up to 6 years from the date we provided you with the Products, to enable consumer dispute resolution and address any potential issues that may arise.
• The storage period for cookie data is defined in our Cookie Policy, according to the specific type of cookie.

Your privacy rights

Right to access (Article 15 of the GDPR): You have the right to obtain confirmation from us about whether your personal data is being processed, and if so, to obtain a copy of that personal data.

Right to erasure (Article 17 of the GDPR): You have the right to request the erasure (removal) of your personal data. We will remove your personal data upon your request if:

1. The data is no longer necessary for the purposes for which it was collected;
2. You have withdrawn your consent (if consent was the basis for processing) and there are no other legal grounds for continued processing;
3. We are not required by applicable law to retain the data;
4. The data has been processed unlawfully;
5. Erasure is required or permitted by law.

Right to object to processing based on legitimate interest (Article 21 of the GDPR): You have the right to object to the processing of your personal data that is based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests and rights, or if the processing is necessary for the establishment, exercise, or defense of legal claims.

Right to restriction (Article 18 of the GDPR)

You have the right to request that we restrict the processing of your personal data under the following circumstances:

1. If you object to processing based on our legitimate interest, we shall restrict all processing of such data until the verification of the legitimate interest.
2. If you have claimed that your personal data is incorrect, we must restrict all processing of such data until the verification of the accuracy of the personal data.
3. If the processing is unlawful, you can oppose the erasure of personal data and instead request the restriction of the use of your personal data.
4. If we no longer need the personal data but it is required by you to defend legal claims.

Right to lodge a complaint with the supervisory authority (Article 77 of the GDPR)

You can always contact us for any issue concerning the processing of your personal data, including complaints. Nevertheless, if you suppose that your rights under applicable data protection legislation have been violated, you can lodge a complaint either:

• With the Commissioner for Personal Data Protection of the Republic of Cyprus (jurisdiction of our incorporation). The website of the Commissioner is http://www.dataprotection.gov.cy/.
• With the data protection authority of the country of your habitual residence or place of work. You can find the list of all EU Data Protection Authorities on the website of the European Data Protection Board: https://edpb.europa.eu/about-edpb/board/members_en.

Exercising Your Rights

We take data protection seriously and have dedicated support staff to handle requests related to your rights. You can reach them at [email protected].

Children's data

Our Website is not intended for children, and we do not intentionally collect personal data from individuals under 18 years old.

Sharing Your Personal Data

To ensure the proper operation of the Website, we may share your personal data with third parties, including:

1. Our contractors, subcontractors, and external consultants: We may engage third parties to service the Website, and accordingly, transfer your personal data to them. We guarantee that these persons have a contractual obligation with us to process your personal data in accordance with this Policy and applicable law.
2. Website Hosting Providers: We use the services of hosting providers and host our Website on their servers. In this regard, they may have access to your personal data, but in encrypted form.

Analytics and IT service providers: We may also use the services of companies that help us analyze the operation of the Website, your interaction with it, and assist us in monitoring and preventing any external threats to the Website. We currently use the services of the following providers:

• Cloudflare: Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA) helps us optimize the operation of the Website and ensure its protection. Please read more in Cloudflare Privacy Policy. The United States does not provide an adequate level of personal data protection, so standard contractual clauses (SCC) apply to the transfer of your personal data to Cloudflare.
• Google: Google Ireland Limited (Gordon House, Barrow Street, Dublin, D04 E5W5, Dublin, 368047, Ireland) provides Google Analytics services. Google LLC (1600 Amphitheater Parkway, Mountain View, CA 94043, USA) provides reCAPTCHA services. Please read more in Google Privacy Policy. The United States does not provide an adequate level of personal data protection, so standard contractual clauses (SCC) apply to the transfer of your personal data to Google LLC.
• Login4play: We use Login4play services to identify your Steam community profile and access information about your Steam account. For this purpose, we share your Steam data with login4play.com.

Cookie Policy

What are Cookies?

Cookies are small data files stored on your computer or mobile device that contain information such as your preferred language or website settings. These cookies may be transmitted back to us upon your next visit to our Website, depending on the cookie's lifespan.

Which Cookies do we use?

We use various types of cookies, each with a specific purpose and expiration timeframe. You can find detailed information about the cookies we use and their functions in the table below.

Name of the Cookie	Type	Expiration time	Purpose of use	Status
_ga	Analytics Cookies	2 years	Collect information on how visitors interact with the website to improve and enhance the user experience.	Optional
1P_JAR	Analytics Cookies	1 month	Collect information on how visitors interact with the website to improve and enhance the user experience.	Optional
_cfduid	Security Cookie	1 month	Security feature deployed to protect the website.	Strictly necessary
uuid	Essential Cookie	1 month	Unique identifier to ensure the uniqueness of created applications, libraries, objects, components and services.	Strictly necessary
PHPSESSID	Essential Cookie	Session	Helps identify your browser.	Strictly necessary

How can You disable or delete Cookies?

Certain cookies, such as Essential and Security cookies, are strictly necessary for technical reasons and do not require your consent. However, you can manage your optional Analytics cookies through our cookie settings or by adjusting your browser's settings to block or delete cookies. Instructions for managing cookies on popular browsers can be found in the manual for your specific browser.

• Google Chrome
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

Do We make updates to this Policy?

Yes, we will update this Policy as necessary to ensure compliance with relevant laws and regulations. The current version of the Policy will always be available on our Website, so please review any updates regularly.