Privacy and Cookie Policy

1. Terms and definitions

Policy means this Personal Data Processing Policy.
You, Your, and Personal Data Subject mean our counterparty under the Public Offer, who may be an individual using the Website to receive services.
Personal Data means any information relating to an identified or identifiable individual.
Personal Data Processing means any action or set of actions performed on personal data, with or without automated means, including collection, recording, organization, storage, updating, use, transfer, anonymization, blocking, deletion, and destruction.
Automated Personal Data Processing means processing personal data using computer technology.
Personal Data Confidentiality means the requirement not to distribute Personal Data without the Personal Data Subject's consent or another lawful basis.
Personal Data Anonymization means actions that make it impossible to determine which individual the personal data relates to without additional information.
Transfer means a payment transaction performed by the User on the Website.
Website means the Company's website at https://xgod.club/en.
Cookies means a small text file placed by the Website on the User's computer or device when visiting sections of the Website or using its functions.

2. Scope and grounds for personal data processing

This Policy applies to relations between the Company and the User concerning personal data processing during use of the Website and provision of the Company's services, arising from acceptance of the Public Offer at https://xgod.club/en/public-offer.

The basis for personal data processing is the User's consent. Without acceptance of this Policy, the Company cannot fully perform its obligations under the agreements it enters into.

3. Duration of the Policy and personal data processing

Once accepted, the Policy remains in effect indefinitely.
The Company processes Personal Data while the Personal Account exists. After its deletion, data may be retained for the period necessary to meet legal obligations and resolve disputes.
The Company may amend the Policy at any time. After making changes, the Company publishes the amended Policy on the Website. Continued use of the Website after changes constitutes acceptance of the revised Policy.

4. Basis, purposes, and principles of the Policy

This Policy describes personal data processing during use of the Website and provision of the Company's services.

The main purpose of the Policy is to give the User a clear understanding of the legal basis for personal data processing, the categories of data collected, retention periods, data transfers, and the User's rights as a personal data subject.

The Company processes personal data lawfully and fairly, limits processing to specific purposes, ensures data accuracy, and retains data no longer than those purposes require, unless the Policy provides for a different period.

5. Personal data collected

When the User signs in through Steam, the Company receives the User's Steam ID, public name, and profile image. The User may also provide an item trade link.
After Authorization, the Personal Account and Website services become available to the User. The Company processes the account data needed to provide these services.
When creating a payment, the Website submits the selected payment method, amount, and, where required by that method, an email address or item trade link. The Website also submits a promo code when applying one. The Website interface has no fields for entering a bank card number, expiry date, or card security code.
During use of the Website, the Company automatically collects technical data: IP address, sign-in data, browser type and version, time zone, browser plugins, operating system, platform, and information about Website visits.
In exceptional cases, the Company may request additional personal data after notifying the User in advance and requesting additional consent.
If the User provides third parties' personal data, they warrant that they have all necessary consents and documents for the lawful transfer and processing of that data.

6. Rights of the personal data subject

The User may obtain information about the Company, its location, and whether personal data is held, and may review that data.
The User may request that personal data be updated, blocked, or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose.
Information about whether personal data is held is provided in an accessible form and does not include other subjects' personal data.
The User or their legal representative may access personal data by applying in person or submitting a written request.
The Company responds to a request within 30 days of receiving it. Depending on the complexity and number of requests, this period may be extended to 60 days.
The User may withdraw consent to personal data processing, restrict its methods and forms, and prohibit distribution of data without consent.
The User may challenge the Company's actions or inaction before the competent authority or in court and protect their rights and legitimate interests.

7. Transfer of personal data

To achieve its processing purposes, the Company may transfer personal data to payment partners, credit institutions, fraud prevention institutions, and government authorities.

Transfer of information may be mandatory, for example for IP addresses, operating systems, geographic data, equipment identifiers or types, usage channels, payment authorization, identification, and verification, or optional for other information.

8. Retention of personal data

The Company retains personal data for the period necessary for the processing purposes, taking into account the periods specified in this Policy and the requirements of applicable law.

9. Cookies

The Website uses Cookies. When the Website is visited, the browser sends the server information about the date and time of the visit, browser type, language settings, and operating system.
Functional and technical Cookies help the Website work properly, recognize returning Users, and remember preferences.
Browser local storage also saves which notifications have been read and which promotions the User has hidden.
Browser local storage saves interface settings. If the User arrives through a link with a source or partner code, each code may be stored independently for up to 30 days or until successfully signing in through Steam.
Session Cookies are stored until the browser is closed. Persistent Cookies are stored until they expire or the User deletes them.
The User may accept or reject Cookies by changing their web browser settings.

10. Final provisions

If one or more provisions of the Policy are found invalid or unenforceable, they are deemed replaced by valid provisions as close as possible in meaning. The Policy cannot be invalidated in its entirety.

11. Company details

Transtrade LLC (ОсОО «Транстрейд»)
Company address: Kyrgyz Republic, Bishkek, Leninsky District, 66 Kalyk Akiev Street
State registration number: 310961-3301-ООО
Tax identification number: 9909710251

12. KYC/AML data

Verification-related processing must have an applicable lawful basis and comply with this Policy. Disclosure to banks, payment providers, appointed verification providers, or competent authorities is permitted only where supported by an appropriate lawful basis and limited to what is necessary.

Retention periods, recipients, and arrangements for any international transfers must be determined before the relevant processing begins. Data must not be retained longer than necessary for the stated purposes and applicable requirements.

The purposes, grounds and scope of verification, information submission process, and temporary restrictions are described in the Offer: https://xgod.club/en/public-offer.