Privacy Policy

This Privacy Policy explains how LOREM IPSUM HOLDINGS LTD ("Company", "we", "us", "our") collects, uses, discloses, and protects personal data when you access or use https://facet.example/ (the "Website") and the Services offered through it, including the purchase and trading of CS2 and Dota 2 skins.

We are committed to protecting your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR).

By using the Website, you acknowledge that you have read and understood this Privacy Policy.

The data controller responsible for your personal data is:

LOREM IPSUM HOLDINGS LTD, a company registered in England and Wales under company number 00000000, with its registered office at 1 Lorem Street, Ipsum, LI1 1AA ("Lorem Ipsum", "we", "us", "our").

For any privacy-related questions or requests, please contact us at support@facet.example.

We may collect and process the following categories of personal data:

• Account and Identity Data – such as your Steam account identifiers and display name, the email address you choose to add for notifications, and account preferences.
• Order and Transaction Data – such as your purchase history, order details, Steam Trade URL, Steam account identifiers, and transaction records.
• Selling and Balance Data – when you sell Items to us: the Items offered and received, quotes, the public contents of your Steam inventory that you ask us to read, your account balance and its ledger, and the status history of each sale.
• Payout Data – when you request a payout: the account holder name and the destination you provide (bank account number, payment card number or cryptocurrency wallet address), the amount, and the status of the request. Payout destinations are stored encrypted and shown to our payout staff only for as long as needed to execute the transfer; they are deleted from our systems 30 days after a request is completed, returned or cancelled.
• Identity Verification Data – where anti-money-laundering rules require it (payouts above the threshold published in our Selling & Payout Policy): your full legal name, document type and number, issuing country, and the images of the identity document and selfie you upload. These images are stored in encrypted storage, are visible only to our compliance staff, and are deleted as soon as a decision on your verification is made; the decision and the declared name are retained for our AML records.
• Payment Data – limited payment-related information necessary to process your Order. We do not collect or store your full payment card details for purchases; these are processed directly by our PCI-DSS compliant third-party payment providers.
• Technical Data – such as your IP address, browser type and version, device information, operating system, and other technology on the devices you use to access the Website.
• Usage Data – information about how you use the Website, including pages visited, features used, and interactions with our Services.
• Communications Data – records of correspondence if you contact us, including support requests and any information you choose to provide.
• Marketing and Preferences Data – your preferences in relation to receiving marketing communications from us.

We do not knowingly collect special category data (such as health, racial or ethnic origin, or religious belief data) and ask that you do not submit such information to us.

We use your personal data for purposes including:

• creating and administering your User Account;
• processing and fulfilling your Orders, including dispatching Steam Trade Offers;
• processing payments and preventing fraudulent transactions;
• buying Items from you, crediting and paying out your balance, and verifying your identity where anti-money-laundering and sanctions laws require it (our legal obligation);
• communicating with you about your Orders, Account, or support requests;
• maintaining the security, integrity, and proper functioning of the Website;
• complying with our legal and regulatory obligations, including tax, accounting, and anti-fraud obligations;
• improving and personalising the Website and our Services;
• sending marketing communications, where you have consented or where otherwise permitted by law, and always with the option to opt out.

We process your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and other applicable data protection laws. Depending on the context in which your data is collected and used, we rely on one or more of the following legal bases:

• Performance of a Contract – we process personal data where it is necessary to provide our Services, fulfil your Orders, manage your Account, and perform our obligations under these Terms.
• Consent – where required by law, we process your personal data based on your consent, for example for certain marketing communications or non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Legal Obligation – we may process your personal data where necessary to comply with applicable legal, tax, or regulatory obligations, including anti-money laundering and fraud prevention requirements.
• Legitimate Interests – we may process your personal data where it is necessary for our legitimate business interests, provided that such interests are not overridden by your rights and freedoms. This may include improving our Services, ensuring the security of the Website, preventing fraud, and analysing usage trends.

Where we rely on legitimate interests, we ensure that such processing is proportionate and that appropriate safeguards are in place to protect your rights.

We may share your personal data with:

• Payment Service Providers – PCI-DSS compliant third parties who process your payment on our behalf.
• Valve Corporation / Steam – to the extent necessary to deliver Items to you via Steam Trade Offer.
• Service Providers – third parties who provide IT, hosting, analytics, customer support, or similar services to us, acting on our instructions.
• Professional Advisers and Authorities – such as legal, accounting, or regulatory bodies, where necessary to comply with our legal obligations or to protect our rights.
• Business Transfers – if we are involved in a merger, acquisition, financing, or sale of assets, personal data may be transferred as part of that transaction, subject to appropriate safeguards.

We do not sell your personal data to third parties.

Your personal data may be transferred to, stored, and processed in countries outside the United Kingdom and the European Economic Area (EEA), where data protection laws may differ from those in your jurisdiction.

Where such transfers occur, we will ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable data protection laws, including the UK GDPR. These safeguards may include the use of approved Standard Contractual Clauses, UK adequacy regulations, or other legally recognised transfer mechanisms.

We take reasonable steps to ensure that any third parties processing your personal data outside the United Kingdom provide an adequate level of protection consistent with applicable data protection standards.

By using the Website and submitting your personal data, you acknowledge that your information may be transferred internationally as described in this section.

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, tax, or reporting requirements. When your personal data is no longer needed, we will securely delete or anonymise it in accordance with our internal retention practices and applicable law.

Subject to applicable law, you have the right to:

• request access to the personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data in certain circumstances;
• request restriction of processing of your personal data in certain circumstances;
• object to our processing of your personal data, including for direct marketing purposes;
• request portability of your personal data in certain circumstances;
• withdraw your consent at any time, where processing is based on consent.

To exercise any of these rights, please contact us at support@facet.example. We may need to verify your identity before responding to your request.

If you are unhappy with how we handle your personal data, you also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO), or with your local data protection authority if you reside in the EEA.

We use cookies and similar technologies on the Website. For further information, please see our Cookie Policy.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, misuse, or alteration. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

The Website and Services are not intended for individuals under the age of 18. We do not knowingly collect personal data from anyone under 18. If we become aware that we have collected personal data from a person under 18, we will take steps to delete such information.

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any updates will be published on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at:

LOREM IPSUM HOLDINGS LTD
1 Lorem Street, Ipsum, LI1 1AA
Email: support@facet.example