DMARKET PRIVACY POLICY

PURPOSE OF THIS POLICY

At DMarket, we are committed to keeping Your information safe and secure. Please read the following Policy so that You understand Your rights in relation to this information, including how Your information will be collected, stored, used and processed.

In providing You with our Website and Application, we naturally collect information about You. This Privacy Policy (“Privacy Policy”) sets out what we collect, how we use, how we store that information, who we might share it with, and the steps we take to make sure it stays private and secure.

This Privacy Policy is inalienable part of DMarket Terms of Use (hereinafter referred to as the “Terms of Use”), available on our Website and in our Application (as amended from time to time). The terms and definitions referred to in this Privacy Policy are specified in the Terms of Use.

Please read the following information carefully to understand our practices regarding Your information and how we will use it. By continuing to use our Website and/or our Application, you acknowledge that You have read, understood and accepted the information described in this Privacy Policy. If any User does not agree with this Privacy Policy in general or any part of it, such User should not access or use the Website, or the Application.

If You agree with this Privacy Policy, you must click on the respective button suggested to You.

COLLECTION, PROCESSING AND USE OF YOUR INFORMATION

Information we collect when You access the Website or the Application

When you visit the Website or access the Application, we collect the information sent to us by Your computer, mobile phone, or other access device. This information includes:

• Your IP address;
• Device information including, but not limited to, identifier, name, and type of operating system;
• Mobile network information;
• Standard web information, such as Your browser type and the pages You access on our Website.

When You log in to the Websites or the Application via Your Steam account, or Your Life Beyond video game account, or Your social network account, we collect from a corresponding third party certain data that may include Your: username, registration data, Your account ID with such corresponding third party, Your subscription, the list of Your In-game items, the number of Your transactions, your trade and the seller links, avatar, and other available public information.

We collect this information in order to:

• Administer our Website or our Application and personalize it for You;
• Monitor and analyze trends, usage and activity in connection with our Website and Services and provide third parties with aggregated and anonymized statistical information about our Users;
• Prevent, deter and investigate violation of this Privacy Policy and/or our Website, and/or our Application, or any fraud and other illegal activities.

When You access the Website or use our Service we may place small data files called cookies on Your computer or other device. We use these technologies to recognize You as our User, customize our Website for You and to monitor usage of our Website. See Section 3 of this Privacy Policy for more information.

Information We collect when You use the Website

When you create an Account at the Website or in the Application, in addition to the information collected when You access our Website or our Application, we also collect Your email.

We collect this information to:

• Verify Your identity;
• Administer our Website or our Application
• Provide, personalize, maintain, and improve Our Services to You;
• Personalize our Website or our Application for You;
• Send You technical notices, support, administrative and marketing messages;
• For customer support;
• Communicate with You about products, services, promotions, events and other news and information we think will be of interest to You;
• In connection with legal proceedings;
• Perform internal operations necessary to provide our Services.

Information we might collect when You perform transactions on the Website or through the Application

Notwithstanding the provisions of Section 6. of the Terms of Use (Funds Deposit and Withdrawal Rules), in certain cases when You want to perform certain transactions on the Website or through the Application (funds deposit or withdrawal), You might be required to go through the KYC (Know-Your-Client) procedure on the Website or in the Application, during which we collect from You the following information and documents:

• Your first and last name;
• Your date of birth;
• Your document ID number;
• Your Tax ID;
• Country, city, street and postal code of Your residence;
• Copy of Your ID document, containing valid identification information about You;
• Copy of You, holding Your ID document;
• Copy of Your payment order document (utility bill, bank documents, etc.).

We collect this information to:

• Verify Your identity;
• Follow international anti-money-laundering and KYC rules and practices;
• Comply with reporting obligations and legal requirements, investigate or address claims or disputes relating to use of the Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries;
• Prevent any fraud or illegal activities;
• To enhance the safety and security of Users and Services;
• Follow requirements on person identification, established by Payment processors;
• For customer support;
• In connection with legal proceedings;
• Perform internal operations necessary to provide our Services.
• Administer our Website and the Application and provide services to You.

We may use Your personal data and other information We collect to detect, investigate and prevent fraudulent transactions and other illegal activities, comply with reporting obligations and legal requirements, develop new products and services and to verify compliance with the Terms of Use. If You do not provide us with any of the requested personal data (if required for certain transactions), You may not be able to use the Website and/or the Application properly.

We may refuse You access to our Service and/or Website, and/or the Application should we, in good faith, have doubts as to validity or authenticity of any personal data You provide.

Data Controller

We are the data controller for the personal data collected in connection with use of Our Services. Where Our Website and the Application contain services of/from various third parties (our partners, vendors, game developers) or links to/from to the websites of such third parties (partner networks, game developers, advertisers, Payment processors, etc.), please refer to the privacy policy of each such third-party to understand how such third party processes Your personal data.

Location Data

When You use a location-enabled device to access our Website or Application and Services, we may collect geographical location data or use various means to determine the location, such as sensor data from Your device that may, for instance, provide data on nearby cell towers and wi-fi access spots.

Notice to parents

We will not knowingly collect personally identifiable information from any person under the age of 13. DMarket encourages parents to instruct their children to never give out personal information when online. Parents who are concerned about the transfer of personal information from their children may contact us by email as specified in “Contact” section of this Privacy Policy.

COOKIES

We use cookies and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies” ) to enhance Your experience using the Website. Cookies are small text files that are placed on Your computer by websites that You visit. They are widely used in order to make websites work, or work more efficiently, and to deliver a better and more personalized Service.

Cookies may be either "persistent" Cookies or "session" Cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

We use the following Cookies:

• Strictly necessary Cookies. These are Cookies that are required for the operation of the Website.
• Analytical/performance Cookies. They allow us to recognize and count the number of Users and to see how Users move around the Website when they are using it. This helps us to improve the way the Website works. We use Google Analytics, Hotjar and Yandex Metrica which are web analytics tools that help us understand how Users engage with the Website. Like many services, Google Analytics, Hotjar and Yandex Metrica uses first-party cookies to track User interactions as in our case, where they are used to collect information about how Users use Our Website and how they use it. This information is used to compile reports and to help us improve Our Website. The reports disclose Website trends without identifying individual visitors. You can opt out of Google Analytics, Hotjar and Yandex Metrica without affecting how You visit Our Website – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page. For more information on opting out of being tracked by Hotjar across all websites you use, visit this Hotjar page and by Yandex Metrica across all websites you use, visit this Yandex page.
• Functionality Cookies. These are used to recognize You when You return to the Website. This enables us to personalize our content for You (for example, Your choice of language).

You can find more information about Cookies and how to manage them at http://www.allaboutcookies.org/. You may control the use of Cookies within your internet browsers’ settings. If you reject or delete certain Cookies, be aware that the performance of the related features and functions of Our Website and Services may be impaired.

HOW WE MIGHT SHARE YOUR PERSONAL DATA

We may share Your personal data where:

• We need to in order to operate our Website, our Application and Service;
• We need in order to perform Your transactions on the Website or in the Application through our partner Payment processors;
• We have a public or legal duty to do so (e.g. to assist with detecting fraud, tax evasion, financial crime prevention, regulatory reporting, litigation or defending legal rights and property, including Our own, investigate or address claims or disputes relating to use of the Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries);
• We have asked for Your permission to share Your information and You have agreed;
• We need to verify Your identity and provide Services to You;
• We notify You and receive Your consent to the sharing.

We may share Your personal data and information with:

• Our subsidiary and affiliated companies if this is required for duly performance of our obligations before the Users and provision of Services to You;
• Companies that we plan to merge with or be acquired by (should such a combination occur, we will notify You and will require that the newly combined entity follow these terms with respect to Your personal data);
• Law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies;
• Our vendors and agents including hosting providers, hired by us to provide Services, game developers;
• Payment processors (for the purpose of Your transactions performance when using the Website and the Application);
• Our partners and vendors that help us to verify Your identity and provide Services to You.

What we will not use Your personal data for:

• We will not provide Your personal data to any other Website or Application users, or third parties other than described in this Privacy Policy without notifying You first.
• We will not sell, share or rent Your personal data to third parties for their direct marketing, other than as described in this Privacy Policy without notifying You first and obtaining Your consent.

Links to Third Party Websites or Services, and Third Party services.

• Our Website and the Application may, from time to time, contain links to and from the websites of our partner networks, game developers, advertisers, Payment processors, etc.
• If You follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any information, including personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before You submit any information or personal data to these websites or use these services.
• Our Website and the Application may also contain services of/from our partners, vendors, game developers.
• In order to provide Services to You and/or for the purpose of duly transactions performance on the Website or in the Application, when You use Our Website or the Application, it, may, from time to time, get and/or collect User’s personal data, such as Your name (username, login) and/or other identifiers from our partners’, vendors’, game developers’ Services. We will not provide this data to any other Website users or third parties other than described in this Privacy Policy without notifying You first. Please note that these services that Our Website may contain have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any information, including personal data that may be collected through these services, such as contact and location data. Please check policies of such services before using these services.
• For the purpose of duly transactions performance on the Website and the Application, Users might be required to provide their personal and payment processing data (such as name, surname, address, copies of ID cards or other identifying documents, residence place confirmation documents, credit card identification data) to the respective Payment processor, including the consent for processing these data by the payment services in order to carry out the requested transactions. Please note that the respective personal and payment processing data provided by You to a third party Payment processor shall be collected, stored and processed solely by the respective Payment processor and not subject to this Privacy Policy. You should read carefully and follow the applicable privacy policies of the Payment processor.

HOW WE KEEP YOUR INFORMATION SAFE

We protect Your information using security standards such as firewalls and data encryption, physical access controls to our premises and information access authorization controls. We also authorize access to Your information only for those employees or contractors who require it to fulfill their job or service responsibilities. 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. Please note that transmission of data or information (including communications by e-mail) over the internet or other publicly accessible networks is not one hundred percent secure. Please note that we are not liable for the security of any data you are transmitting over the internet.

HOW WE TRANSFER YOUR INFORMATION

We store and process Your information using cloud services in various jurisdictions, including the United States of America. As such, the information that we collect from You may be transferred to, and stored in various jurisdictions outside of Your country of residence and outside the European Economic Area ("EEA”). The laws on processing such information, including where such information is classed as “personal data”, in these locations may be less stringent than in Your country. It may also be processed by staff operating outside of Your country or the EEA who work for us, for one of our service providers or one of our business partners. By submitting Your information, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your information is treated securely and in accordance with this Privacy Policy.

HOW WE TRANSFER YOUR INFORMATION

We store and process Your information using cloud services in various jurisdictions, including the United States of America. As such, the information that we collect from You may be transferred to, and stored in various jurisdictions outside of Your country of residence and outside the European Economic Area ("EEA”). The laws on processing such information, including where such information is classed as “personal data”, in these locations may be less stringent than in Your country. It may also be processed by staff operating outside of Your country or the EEA who work for us, for one of our service providers or one of our business partners. We do so to fulfill our agreement with You, such as our Terms of Use, or based on Your prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses. By submitting Your information, You agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your information is treated securely and in accordance with this Privacy Policy.

DATA RETENTION

We may retain Your personal data for a period of time consistent with the original purpose of collection described above or as long as required to fulfill our legal and contractual 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.

YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

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; and
• Not be discriminated against for exercising your rights described above.

Additional Disclosures for California, Colorado or Virginia Residents

We have listed the privacy rights for several U.S. state jurisdictions below, but We understand You may have additional rights in your jurisdiction. You may contact Us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.

Certain state laws require that we detail the categories of personal data that we disclose for certain "business purposes," such as to service providers that assist us with securing our Services or marketing our products.

We may disclose the following categories of personal data for our business purposes, as further described in Section 4. How We Might Share Your Personal Data:

• Identifiers;
• Personal information under California Civil Code section 1798.80;
• Commercial information;
• Internet activity and electronic information; and
• Inferences drawn from any of the above information categories.

Sensitive Categories of personal data:

• Account log-in information;
• Financial account information;
• Geolocation data; and,
• Contents of communications.

Several jurisdictions grant state residents certain rights, including the right to access specific types of personal data, the right to learn how we process personal data, the right to know whether and how we disclose or sell personal data, the right to opt out of any sale of personal data, the right to request deletion of personal data in certain circumstances, and the right not to be denied goods or services for exercising these rights.

Third Party Marketing. California law further permits you to request information regarding the disclosure of your personal information to third parties for the third parties' direct marketing purposes. We do not disclose your personal information to third parties for the third parties' direct marketing purposes.

Do Not Sell My Personal Information. In the preceding twelve months we have not sold personal information for monetary consideration, but we recognize that some state privacy laws define "personal information" in such a way that some sharing of personal information necessary to provide you with personalized ads may be considered a "sale," even if no money is exchanged. Please use our cookie banner or refer to our Cookie Policy on how to opt out of personalized ads.

Authorized Agents. If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information in the "Contact" section below and provide us with a copy of the consumer's written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Additional Disclosures for Data Subjects in the EEA and the U.K.

Residents in the European Economic Area and the United Kingdom (together, for purposes of this section of the Privacy Policy, "EEA"), as well as certain other jurisdictions, are entitled to certain rights and disclosures with respect to their personal data.

Our legal bases for collecting and using your personal data include:

• The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration, providing our Services and products to you, providing customer service to you.
• Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and Services, direct marketing to you, and maintaining, analyzing, and improving our products and Services.
• Compliance with a mandatory legal obligation. For example, maintaining administrative records which are subject to mandatory retention periods. We may also collect your personal data to record your requests to exercise your rights and to verify your identity for such requests.
• Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.

In some countries, and in particular if you are located in the EEA, you may have the right to:

• Access your personal data;
• Correct inaccurate personal data;
• Request erasure of your personal data without undue delay;
• Request the restricted processing of your personal data;
• Request portability of the personal data that you have given us; and
• To object to the processing of your personal data.

To exercise any of these rights, please contact us as set forth in the "Contact" section below and specify which privacy right(s) you wish to exercise. In order to honor your request, we may need to verify your identity and You may be requested by our team to provide the respective confirmation documents and details of the personal data we hold about You.

If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the "Contact" section below.

How to Exercise Your Rights

To exercise your rights, please contact us by using the information in the "Contact" section below. Your personal data may be processed in responding to these rights. 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.

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" section below. You will still continue to receive service-related messages concerning products and Services you have purchased (unless we have indicated otherwise).

UPDATES OR AMENDMENTS TO THIS POLICY

We reserve the right to modify or amend this Privacy Policy at our discretion at any time. Any changes can be viewed in the “Last Updated” field above, so please check the section regularly.

If we make any material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes with a new effective date 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.

CONTACT

If You have any questions concerning this Privacy Policy or want to exercise any of Your rights as specified herein, please feel free to contact us by email at support@dmarket.com.

Data protection inquiries should be addressed at dp@dmarket.com.