Last Modified: May 10, 2019
This Privacy Policy identifies and describes the way the Company handles and protects the information you may provide when you visit this Site and our practices for collecting, using, maintaining, protecting and disclosing that information. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personal information in connection with your use of this Site. If you do not agree with our policies and practices, your choice is to not use the Site. By accessing or using this Site, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. We will indicate the date the policy was last modified at the top of the Privacy Policy.
1.0. Information We Collect
There are two types of information we may collect: “Personally identifiable information” (PII) and non-personally identifiable information (non-PII). PII is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Non-PII is information that cannot identify the individual person and is used in the aggregate to provide general information about the users of the Site. PII: When you engage in certain activities on the Services, such as when you register to use the Services, you may be asked to provide certain information about yourself that we will collect and store. PII may include your full name, address, telephone number(s), and email address that you submit on this Site. It may also include your Steam® account id, link, or similar information that you provide when registering for the Services. Further, we may implement a device fingerprinting system that identifies unique users and that system will create a unique hash for each user (based on predetermined criteria), which will then be stored by the Company (i.e. the hash alone will be stored and it will not be shared with other parties). Non-PII: Non-PII is information that identifies your computer and its navigational patterns through the services provided by this Site (but not a specific user). We may automatically collect Non-PII when you visit the Site, through the use of a variety of tools including cookies (small text files that are stored on a user’s computer for record-keeping purposes and which contain information about that user’s computer), or other available analysis or collection technologies. This type of information can include browser types, domain names and IP addresses.
2.0. How We Use and Share Information
- a. We use the information we collect to (a) provide, maintain, and protect the Services; (b) notify you of promotions, new services and special offers, for example, through e-mails; (c) tailor our product offerings, customer service and overall experience; (d) improve the content, operation, appearance and utility of the Services; (e) conduct surveys, research and evaluations; (f) troubleshoot and resolve disputes and customer service inquiries; (g) gather demographic data and (h) accomplish other administrative tasks.
- b. Cookies: Cookies are small bits of code, usually stored on a user's computer hard drive, which enable a Website to "personalize" itself for each user. Cookies allows us to identify files on your computer and record your preferences and other data about your visit to our website so that when you return to the website we are aware of who you are and can help personalize your next visit here. Please note that cookies may be linked to personal information about you. The use of cookies allows us to keep track of your information and prevents you from having to reenter your information at each connection. We may use cookies to:
- • Compile aggregate data about the site traffic and site interactions in order to offer better site experiences and tools in the future.
- • We may also use third party services that track this information on our behalf.
- You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Each browser has different settings, so look at your browser’s Help menu to learn the correct way to modify your cookies. If you wish to disable cookies, some features may not function properly.
- c. Web Beacons: Pages on our Site may contain “web beacons” (also known as Internet tags, pixel tags and clear GIFs). Web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. We use log files to store the data that is collected through web beacons.
- d. User Profiles: The Company may aggregate PII, Non-PII, Log File information, Web Beacon Information, and Cookie Information in order to create a profile of a user or users of the Site and may be used to market products or services to you, monitor Services activity, help to maintain our customer database, and administer e-mails, surveys or other contests.
- e. Opt-Out: If you decide that you are no longer interested in receiving SMS or email communications from us, you may follow the instructions in our SMS or emails to unsubscribe from our email/SMSlist or by emailing us at: newsletter@shadowpay.com. If you wish to opt-out of disclosure and to be excluded from our mailing list, please email us at: newsletter@shadowpay.com. As to communications from our preferred partners/vendors, affiliated companies, trusted vendors and business partners, please follow the instructions to opt-out in those entities’ communications.
- f. Legal Compliance/Other Information Disclosure: We also reserve the right to disclose your information in good faith as required by law, in response to legal process including law enforcement requests, and with any person or entity that may acquire all or any part of our business or assets, in connection with any change in control of us, a reorganization of our Company, a dissolution or a similar event. and where needed to prevent fraud and to protect the safety, property, or legal rights of our Company, our users, our affiliates, or any other third party. We may also disclose your information to manage and protect our information technology infrastructure and security. We may also disclose your information for any other purpose with your consent. We may share your information with third party service providers or who perform functions for us such as e-mail service providers and database hosting companies. We may share non-PII at any time for any purpose.
Collection of Personal Data
General Provisions
The type of Personal Data we collect depends on how you are interacting with us and which Services you are purchasing or using. In many cases, you can choose whether or not to provide us with Personal Data, but if you choose not to, you may not get full functionality from the Website or its additional Services.
When you visit the Website, you may provide us with the following types of Personal Data: (i) Personal Data that you voluntarily disclose that is collected on an individual basis; (ii) Personal Data collected automatically when you use the Website and its Services; and (iii) Personal Data which we collect from sources other than the Website.
You may always refuse to supply your Personal Data, though this may prevent you from engaging in certain activities and/or obtaining certain Services.
The Website contains links to other third-party websites that may collect Personal Data about you, including through cookies or other technologies. If you use our links to visit another websites you will exit the Website and this Policy will not apply to your use of, and activity on those other websites. You should consult these other websites' privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.
Personal Data You Provide to Us
In order to perform the Services and the functionality of the Extension and the Website we are entitled to ask you to provide Service Provider with your Personal Data, including (but not limited):
1
Processed data:
Purpose:
For association of User with its Steam Account at
https://store.steampowered.com without processing of his/her personal data and to check User’s history of trade offers in Steam account.
2
Processed data:
Pseudonymized steamId of user’s account at
https://store.steampowered.com4
Processed data:
Permission to access third-party sites to transfer non-personalized statistical data about game items
Purpose:
To display information about a game item. To save information for the user about the game items in the Extension in his browser.To compare price characteristics of different sources, including the use of different currencies for clarity. To ensure that additional Extension functions are working properly
5
Processed data:
E-mail address
Purpose:
To provide response when you contact us via Email
Personal Data set out in Article 6.5. hereof is collected only when voluntarily offered, and solely for purposes that are clearly identified at the Website or in this Policy.
Without prejudice to the provisions set out in any other user terms and conditions of Shadowpay Trademanager, in the case you do not provide Service Provider with the Personal Data set out in Article 6.5. hereof, or provide them with inaccurate, misleading or incomplete Personal Data, Service Provider at its sole discretion shall be entitled, without any notice to you, to: impose limitations and restrictions on your use of the Website and/or the Services; and/or suspend or terminate your access to the Website or Extension.
3. Personal Data We Collect Automatically
The Extension automatically collect:
1
Processed data:
Information about your statistics (public statistics from the game) available at
https://store.steampowered.comPurpose:
To show you your progress. To ensure that additional Extension functions are working properly
2
Processed data:
Statistical data about game items available at
https://store.steampowered.comPurpose:
To display information about a game item. To save information for the user about the game items in the Extension in his browser. To compare price characteristics of different sources, including the use of different currencies for clarity. To ensure that additional Extension functions are working properly
Service Provider may collect the Personal Data from you in a variety of ways and circumstances, including, but not limited to, registration at the Website, placement of an order or a request (if applicable), subscription to a newsletter, response to a survey, filling out a form, use of a live chat (if applicable), providing us with feedback on our products or Services. Service Provider shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Website or the Services with any other relevant available information.
Personal Data collected by or transmitted to Service Provider in the course of accessing, interacting and operating of the Website and provision of the Services may include, without limitation, the following Personal Data:
- device information, which may include (but is not limited to) information about the computer or mobile device you use to access the Website, including the hardware model, operating system and version, the web browser you use, and other device identifiers;
- usage information and browsing history, such as, information about how you navigate within the Website, your browsing history and which elements of the Website or which Services you use the most;
- location data, for Services with location-enhanced features. If we need your consent to collect geo-location data, we will collect this separately;
- demographic information, such as, your country, and preferred language;
- usage information. If you use the Website, we will collect metadata about the files you upload for storage and we will record instances in which you have used your private key to authenticate communications;
- information collected by cookies and other tracking technologies. We and our service providers use various technologies to collect information when you interact with the Website, including cookies and web beacons. ‘Cookies’ are small data files that are stored on your device when you visit a website which enable us to collect information about your device identifiers, IP address, web browsers used to access the Website, pages or features viewed, time spent on pages, mobile app performance and links clicked. Web beacons are graphic images that are placed on a website or in an email that is used to monitor the behavior of the user visiting the website or sending the email. They are often used in combination with cookies.
Invitations. If another User sends you an invitation through the Website, Service Provider may receive certain personal information, such as your name, email address, or phone number. If you are an invited guest, we will automatically send you an invitation to our Platform, and, if unanswered, a one-time follow-up invitation. Service Provider stores this contact information only to send these invitations and evaluate their success. You may unsubscribe from future invitations using the instructions in those messages. You may also contact us at csinvhelp@gmail.com to request that we remove this information from our database.
Personal Data collected hereunder in the course of operation of the Website and Extension and provision of the Services may differ depending on whether you access to the Website, Extension or the Services.
The Website does not use cookies
The data subject to may, as stated above, prevent the setting of cookies through our Website at any point of time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. For example, most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
You may also act according to the following:
Opting-Out
As part of our commitment to fair information practices, Service Provider allows you to opt out of the use of information, about your activities on other websites to provide you with Interest-based advertising. You can opt out of Google Analytics by installing Google’s opt-out browser add-on, and out of interest-based Google ads using Google’s Ads Settings. Even if you opt out, you may still receive Service Provider`s advertising. It just means that the advertising you see will not be customized for you.
Refusing Cookies
We and our affiliates honor, Do Not Track (DNT) signals and Do Not Track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. You can limit the collection of your information by disabling cookies on your browser. You may also be able to modify your browser settings to ‘require your permission’ each time a site attempts to set a cookie. However, our Website (and many other websites) rely on cookies to enable certain functionality. If you choose to disable cookies, some of the services available on our Website may not work properly.
Caution regarding automatic Cookie Functionality
Browsers such as Microsoft Internet Explorer allow you to store passwords and login IDs so you do not need to re-enter this information each time you access a web site. Service Provider strongly urges you NOT to use this functionality to prevent unauthorized use of your online banking access code(s). The user is notified that blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all or certain features in our Website
3.0. Unsubscribe, Opt Out or Revoke
You may revoke consent at any time for any use of PII collected from you under this Privacy Policy. To revoke consent, indicate by emailing us at privacy@shadowpay.com. We will remove your PII from our internal programs and further communication from the Company will cease, except for administrative matters.
4.0. ”Do Not Track”
“Do-Not-Track” is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to Do-Not-Track signals.
5.0. How to Access or Modify Your Information
We strive to keep all personal information accurate and complete. You are always fully in control of the information that we maintain to service you. You can change your personal information at any time and as often as necessary. You can also request that information be deleted. Information may be withheld or exempted from deletion if this is required by law or is part of a fraud investigation, or as otherwise as described above in the Use of Information section. You may access and modify your personal information by emailing us at privacy@shadowpay.com.
6.0. Storage and Security
We will retain PII, including user location information, only as long as our business needs require. We will then destroy or render unreadable any such information upon disposal. We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse and alteration of your information under our control. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning. We do not use an SSL certificate. Although we take precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure.Although we have agreements and vetting procedures in place for third parties, we are not responsible for the actions of any third parties that may receive any such information. You should note that the security of your personal information also depends on you. Please do not communicate any information to us through unsecured channels, such as when you are in public areas. Where we have provided you or you have chosen a password, access code, or similar security feature, you must keep the password, access code or security feature confidential. Please do not share your password with anyone. If you believe your password or account has been compromised, please contact us at support.shadowpay.com.
7.0. COPPA (Children Online Privacy Protection Act)
Our Site is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support.shadowpay.com.
8.0. California Online Privacy Protection Act
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@shadowpay.com.
9.0. CAN SPAM ACT
We collect e-mail addresses submitted through the Site. If you do not wish to have your e-mail address or phone number used by the Company to promote our own services or third parties’ products or services, you can opt out by sending us an e-mail stating your opt-out request to newsletter@shadowpay.com. Please note, however, that once your information has already been transferred or sold to third parties, we cannot opt you out of receiving any marketing or promotional e-mails sent by those third parties. You will need to contact the third parties directly to unsubscribe from receiving e-mails from them.
10.0 NON-U.S. VISITORS
This Privacy Policy is intended to cover collection of information on our Site from residents of the United States. If you are visiting our Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States may different from and not be as comprehensive as those in your country. By using our Services, you understand that your information may be transferred to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.
11.0 Changes to Privacy Policy
We may change this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page. The revised Privacy Policy will be effective immediately when posted on the Site. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically to learn of any revisions to this Privacy Policy. Your continued use of the Site after the effectiveness of such revisions will constitute your acknowledgment and acceptance of the terms of the revised Privacy Policy.
12.0 Contacting Us
If there are any questions regarding this privacy policy you may contact us using the information below. privacy@shadowpay.com
The original language of the Privacy Policy is English, whilst there may be a translation thereof. If there are discrepancies between the English text and the text in the other language, the English revision shall prevail.
Privacy policy