Privacy Policy
03/03/2026
1.1. Privacy Policy
Before consenting to the Processing of Your Personal Data or providing Your Personal Data through any form on our Website, We kindly ask You to review this Privacy Policy carefully. This will ensure that You fully understand the Privacy Policy under which We operate. This Privacy Policy is applicable to Your use of our Services, as outlined in our Privacy Policy.
This Privacy Policy details when, where, and why We collect and process Personal Data from the Users of the Website, how We use this Data, the circumstances under which We may share it with others, Your rights regarding Your Personal Data, and the measures We take to protect it.
1.2. Definitions
The following definitions are used in this Privacy Policy:
“Consent of the Data Subject/User” refers to any voluntary, specific, informed, and clear expression of the Data Subject/User’s wishes, given through a statement or clear affirmative action, indicating their agreement to the processing of their Personal Data.
“Company” refers to IN-GAME SOLUTIONS PTE. LTD., a private limited company that owns the Website (https://lis-skins.com/), registration number 202435257H, with its registered office and principal place of business at: 135 Middle Road, #02-27, Bylands Building, Singapore (188975), (hereinafter We, Us, Our, or LisSkins).
“Data Subject” refers to any identified or identifiable natural person as the User of the Website whose Personal Data is being processed by the Data Controller.
“Data Controller” refers to us as the Company that collects, uses, transfers and processes Your Personal Data.
“Personal Data” refers to any personal information about You that, alone or combined with other information, enables the Data Controller to identify You as an individual.
“Processing of the Personal Data” refers to any action taken with Your Personal Data, whether automated or manual, including collection, recording, organization, structuring, storage, modification, retrieval, consultation, use, sharing, transmission, dissemination, alignment, restriction, deletion, or destruction.
Other terms, including but not limited to “User”, User Account and “Services” shall have the meanings assigned to them in our Privacy Policy, unless otherwise defined herein.
This Privacy Policy, together with the Cookie Policy, the Terms of Use, and where applicable, the relevant Rules and Additional Terms applicable to Our Services forms an integral part of our User Agreement, which You accepted upon registering Your User Account or will accept before completing Your registration on our Website. We strongly recommend that You read our Privacy Policy carefully before registering Your User Account and using our Services.
1.3. General
This Privacy Policy sets out and describes the way in which We collect and process Your Personal Data, which You provide, or You are requested to provide to Us in connection with using our Website and Services.
We respect Your privacy and are committed to protecting Your Personal Data and processing it in accordance with the applicable laws, including:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or GDPR); and
Personal Data Protection Act 2012 of Singapore (PDPA).
By registering and clicking “I agree” on the Website, You have agreed to be bound by this Privacy Policy, which forms part of the User Agreement as indicated in the Terms of Use.
1.4. What Personal Data We Collect
We mainly collect Your Personal Data to provide You with our Services and to comply with regulatory requirements. We are required by law to collect specific information from You, including documents for verifying Your identity in connection with Your use of our Services. As a result, We must retain certain information about You to comply with our legal obligations. Additionally, We may process some of Your Personal Data to send You promotions and offers related to our Services that We believe may be of interest to You. However, You can opt out of such marketing communications at any time if You wish.
Personal Data that We request or may request from You in the frame of the provision of the Services:
Account Information: Name, email address and Steam details (login, username, icon, other information You made public on Steam), payment details.
Profile Information: Photos, personal details, descriptions and all information that You make public on the Internet.
Transaction Information: Details of purchases, sales, and interactions on the Website.
Date of Birth;
• Telephone Number;
• Country of Citizenship;
• Country of Residence;
• ID/Passport Number.
• Information Collected Automatically
We may collect certain information automatically when You use the Website, which may include:
• Usage Data: information about Your interaction with the Website, such as pages visited, browsing activity, and search queries;
• Device Information: technical information such as Your IP address, browser type, device type, operating system, and approximate location based on Your device settings.
For more information about the use of cookies and similar technologies, please refer to our Cookie Policy.
• Third-Party Information
We may collect information about You from third parties, such as social media Websites or payment processors, when You connect their services to our Website.
We encourage You to review privacy policies of such third parties thoroughly before cooperating with them.
Additional Data that we may collect and process during Your activity on our Website:
• Type of Access Device You use, Your Access Device unique identifier, serial number or Access Device ID.
• IP address of Your Access Device, Your operating system and browser type.
• Information related to Your usage, product interactions, performance, diagnostics, crash data, search and browsing history, and location data from the devices You have purchased or use to access our Services.
• Anti-fraud data (e.g., detection of VPN/proxy usage, multi-accounting monitoring/geolocation).
• Details about how You use our Services (identify Your activity on our Website), such as to differentiate You from other users, remember Your preferences and enhance Your experience. This information also helps us improve our Services.
1.5. How We Use Your Personal Data
We may process Your Personal Data for the following purposes:
• To verify Your identity for Your registration on the Website (that You can create Your User’s Account) in relation to Your access to the Services.
• To provide You with the information, products, offers regarding our Services as well as to send You marketing and promotional materials.
• To deliver, improve, and develop Our Services.
• To communicate with You, including to offer You targeted advertisements and Services.
• To process Your transactions (for example Withdrawals and Deposits).
• For system administration and internal operations, including troubleshooting, testing, statistical analysis, surveys, data analysis, research, and audits.
• To authenticate Your access to Our Website and Services and to differentiate You from other Users.
• To monitor Your use of Our Website and Services, improving User experience and ensuring content is displayed optimally for You and Your Access Device.
• To conduct marketing analysis, enabling Us to assess trends and the effectiveness of Our advertising and marketing efforts (this may include using Your Personal Data to evaluate, analyse, or predict aspects like Your preferences, interests, or location, if you opt-in).
• To provide customer support and maintain a high level of customer Services.
• To Communicate with You regarding Your User Account, orders and support inquiries.
• To promote safety and security by monitoring for fraud, investigating suspicious or potentially illegal activities, or enforcing Our Privacy Policy.
• To ensure the safety and security of Our Website and Services.
• To comply with applicable laws and regulations.
1.6. With Whom We May Share Your Personal Data
We may share Your Personal Data with:
• Service Providers: We may share information with vendors, consultants, payment providers, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out processing activities for Us. The partner’s use of Personal Data will be subject to appropriate confidentiality and security measures.
• Legal Authorities: We may share information in response to a request for information if We believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements.
• To Enforce Our Policies and Rights: We may share Your information with third-party service providers, professional advisors, payment service providers, and law enforcement or regulatory authorities if We believe that Your actions are inconsistent with Our Terms of Use, User Agreement, other relevant Rules, Additional Terms and policies of LisSkins, or to protect the rights, property, and safety of the Company, its Users, or others.
Additionally, we may utilize open-source information, such as public records, government registries, databases, and social media platforms (including Facebook, LinkedIn, etc.), as permitted or required by law.
We take reasonable steps to ensure that our service providers and other contractors provide at least the same level of protection for Your Personal Data as we do.
1.7. Direct Marketing and Opt-Out
From time to time, We may use Your Personal Data to notify You about our Services or new products, or promotional activities that we believe may be of interest or benefit to You. This may be done through email, sms or phone.
Additionally, we may reach out to You regarding the management and administration of Your User’s Account. These communications can occur through any of the contact methods You provided during registration. Please note that these account-related communications do not affect Your opt-in or opt-out preferences for direct marketing notifications.
If You no longer wish to receive marketing or promotional materials from us whether in general or in a specific format, You can withdraw Your consent at any time, such as by clicking the “unsubscribe” link at the bottom of our marketing emails or by contacting our support team via email to: [email protected].
1.8. Legal Basis for Processing Your Personal Data
We will only handle Your Personal Data when there is a legitimate legal basis to do so. The appropriate legal basis depends on the specific reasons for which Your Personal Data is collected and used. Typically, the legal grounds will include:
• Consent: When You agree to provide Your Personal Data in the frame of accessing the Website and using the Services, as well to receive marketing communications from us. Based on Your consent We process Your Personal Data.
• Legitimate Interests:
We may process Your Personal Data based on our legitimate interests (including our business interests), provided that such interests are not overridden by Your rights and freedoms.
In particular, we may rely on this legal basis to:
• understand our Users and conduct market research;
• promote our Services, including sending You promotional emails, SMS, or push notifications about our Services, special offers, and new products (where You have not opted out or where otherwise permitted by applicable law);
• improve the functionality, usability, and overall user experience of our Website and Services;
• maintain the security and integrity of our Services;
• prevent fraud, abuse, and unauthorized activities;
• verify Account authenticity and User identity;
• prevent multi-accounting, identity theft, and other fraudulent activities;
• detect VPN/proxy usage and other security risks;
• ensure compliance with our Terms of Use, User Agreement, Privacy Policy and where applicable, the relevant Rules and Additional Terms applicable to the Services.
• Performance of a Contract:
We process Your Personal Data where it is necessary for the performance of the User Agreement with You or to take steps at Your request prior to entering into the User Agreement.
• Legal Obligations:
We may process Your Personal Data where such processing is necessary to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) and other financial crime prevention obligations.
This includes:
• retaining KYC documentation for identity verification purposes;
• monitoring transactions to detect suspicious or potentially unlawful activities;
• reporting to regulatory, supervisory, or law enforcement authorities where required by applicable law.
Vital Interests:
We may process Your Personal Data where such processing is necessary to protect Your vital interests or those of another Users.
This may include:
• responding to emergency situations where there is a risk of harm to an individual;
• protecting Users from serious security threats or unlawful activities that may cause significant harm;
• sharing information with competent authorities where necessary to prevent or mitigate such risks.
1.9. Fraud Prevention and Security
We are committed to ensuring the security of the provision of our Service and preventing fraudulent activities, including but not limited to:
• Multi-accounting;
• Identity theft;
• Unauthorized access;
• Money laundering.
To detect, prevent, and mitigate fraudulent activities, We process and monitor the following types of Personal Data:
• IP address and geolocation – to identify suspicious login attempts, VPN/proxy usage, and unauthorized account access.
• Device ID and browser fingerprinting – to detect duplicate accounts and prevent unauthorized account sharing.
• Behavioral data – to identify suspicious behavioral patterns and prevent collusion.
• Deposit and withdrawal history – to prevent financial fraud and ensure AML compliance.
This Data processing is based on our Legitimate Interest (as stated above in Clause 1.8.) to maintain the integrity of our Services and comply with regulatory obligations where applicable.
If We detect fraudulent activity, We reserve the right to suspend or terminate User Account, restrict Your access to the Services, and report violations to relevant authorities.
1.10. Your Rights
Since we handle Your Personal Data, it’s essential that You are aware of Your rights as the User of Our Services.
Below, We outline Your rights and how they pertain to the Data We process.
• Right of Access: You have the right to request access to the Personal Data We hold about You and to receive a copy of such data. We will provide this information free of charge, except where requests are manifestly unfounded or excessive, in which case We may charge a reasonable fee.
• Right to Rectification: If the information We hold about You is inaccurate or incomplete, You have the right to request that it be corrected without undue delay.
• Right to Withdraw Consent: Where We process Your Personal Data based on Your consent, You have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of Your Personal Data where one of the following grounds applies: (i) the data is no longer necessary for the purposes for which it was collected; (ii) You withdraw Your consent (where processing is based on consent); (iii) You object to processing and there are no overriding legitimate grounds; or (iv) the data has been processed unlawfully. This right is subject to legal and regulatory retention obligations.
• Right to Object: Where We process Your Personal Data based on legitimate interests, including profiling, You have the right to object. We will cease processing unless We can demonstrate compelling legitimate grounds that override Your rights and freedoms, or where processing is required for legal claims.
• Right to Restriction of Processing: You have the right to request that We restrict the processing of Your Personal Data in certain circumstances. Where processing is restricted, We may store Your Personal Data but will only process it:
- with Your consent;
- for the establishment, exercise or defence of legal claims;
- for the protection of the rights of another natural or legal person; or
- for reasons of important public interest.
• Right to Lodge a Complaint: If You are dissatisfied with how We process Your Personal Data, You have the right to lodge a complaint with a competent supervisory authority in the EU Member State of Your habitual residence, place of work, or place of the alleged infringement.
• To exercise any of the above rights, please contact us at [email protected].
1.11 Transfers to Third Countries
Your Personal Data may be transferred to, stored, and processed in countries outside of Your country of residence, including countries that may not provide the same level of data protection.
Where such transfers occur, We take reasonable steps to ensure that the recipient provides a standard of protection comparable to that required under applicable data protection laws, including the Personal Data Protection Act 2012 of Singapore.
Where required under applicable law, including the GDPR, We implement appropriate safeguards such as the use of Standard Contractual Clauses approved by the European Commission or transfers to jurisdictions recognized as providing an adequate level of data protection.
1.12. Security of Personal Data
You acknowledge that data transmission over the Internet is not entirely secure and may involve certain risks. While We implement appropriate technical and organizational measures to protect Your Personal Data, We cannot guarantee absolute security of information transmitted to Us.
Once We receive Your Personal Data, We take reasonable steps to protect it against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Such measures include the use of secure systems, access controls, encryption, and secure communication protocols (such as SSL/TLS).
By using our Services or providing Us with Personal Data, You agree to receive electronic communications from Us relating to security, privacy, and administrative matters.
You are responsible for maintaining the confidentiality of Your User Account credentials and for the security of the devices You use to access the Services. We recommend that You log out of Your User Account after each session, especially when using shared devices.
1.13. Special Category of Personal Data
We do not collect any Special Categories of Personal Data about You, such as details about Your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership, health information, or genetic and biometric data. However, based on our experience, We recognize that You may voluntarily provide such data during communication with us at Your discretion.
Please note that although We process Your personal documents, such as passports or ID cards, the images contained in them are not technically processed in a way that would enable us to identify any of the aforementioned data. Therefore, such documents are not to be considered special category of data.
1.14. Children
Our Services are not intended for individuals under the age of 18 or who have not reached the age required to enter into legally binding agreements in their jurisdiction (as specified in our Terms of Use). We do not knowingly collect Personal Data from individuals who do not meet these requirements.
We are dedicated to preventing children from accessing our Services and do not accept their information for User Account registration. However, parents and legal guardians are responsible for supervising their children’s online activities, including the use of appropriate parental control tools.
1.15. Third-Party Websites and Services
Our Website, Services and other products, may contain links to or allow access to third-party websites, products, and services. When You click on these links, You are leaving our Website and are subject to the privacy policies of those third parties. We are not responsible for the privacy practices, information, or content provided by these external websites and services. This Privacy Policy applies only to Personal Data collected directly by Us through Our Website and Services. We encourage You to review the privacy policies of any third-party websites You visit.
1.16. Data Retention Term
The duration for which We retain Your Personal Data depends on applicable legal, regulatory, and operational requirements.
In particular, We may be required to retain certain Personal Data for a minimum period of at least 5 years in accordance with applicable anti-money laundering and counter-terrorism financing laws and regulations, including the Monetary Authority of Singapore (MAS) Notice PS-N06 and relevant guidance issued by the Suspicious Transaction Reporting Office (STRO), Singapore.
Where no specific retention period is required by law, We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected.
When Your Personal Data is no longer required, We will securely delete or anonymize it.
However, there are exceptions:
• Investigations and Fraud Prevention: Where We are required to investigate or reasonably suspect fraudulent, unlawful, or abusive activity, We may retain Your Personal Data for a longer period to prevent such activity and to cooperate with competent authorities.
• Legal Disputes: In the event of a legal dispute, We will retain Your Personal Data for the duration of the dispute and as necessary for the establishment, exercise, or defence of legal claims.
• User Account Deletion: If You request account deletion, We will securely delete or anonymize Your Personal Data, unless retention is required by applicable law or regulatory obligations.
1.17. Contact Details
While We strive to be as clear and transparent as possible, if You need any clarification about this Privacy Policy, please feel free to reach out. We are happy to provide You with any additional information You may need. Please contact us by email to [email protected] or by the Website customer support chat function.
03/03/2026
1.1. Privacy Policy
Before consenting to the Processing of Your Personal Data or providing Your Personal Data through any form on our Website, We kindly ask You to review this Privacy Policy carefully. This will ensure that You fully understand the Privacy Policy under which We operate. This Privacy Policy is applicable to Your use of our Services, as outlined in our Privacy Policy.
This Privacy Policy details when, where, and why We collect and process Personal Data from the Users of the Website, how We use this Data, the circumstances under which We may share it with others, Your rights regarding Your Personal Data, and the measures We take to protect it.
1.2. Definitions
The following definitions are used in this Privacy Policy:
“Consent of the Data Subject/User” refers to any voluntary, specific, informed, and clear expression of the Data Subject/User’s wishes, given through a statement or clear affirmative action, indicating their agreement to the processing of their Personal Data.
“Company” refers to IN-GAME SOLUTIONS PTE. LTD., a private limited company that owns the Website (https://lis-skins.com/), registration number 202435257H, with its registered office and principal place of business at: 135 Middle Road, #02-27, Bylands Building, Singapore (188975), (hereinafter We, Us, Our, or LisSkins).
“Data Subject” refers to any identified or identifiable natural person as the User of the Website whose Personal Data is being processed by the Data Controller.
“Data Controller” refers to us as the Company that collects, uses, transfers and processes Your Personal Data.
“Personal Data” refers to any personal information about You that, alone or combined with other information, enables the Data Controller to identify You as an individual.
“Processing of the Personal Data” refers to any action taken with Your Personal Data, whether automated or manual, including collection, recording, organization, structuring, storage, modification, retrieval, consultation, use, sharing, transmission, dissemination, alignment, restriction, deletion, or destruction.
Other terms, including but not limited to “User”, User Account and “Services” shall have the meanings assigned to them in our Privacy Policy, unless otherwise defined herein.
This Privacy Policy, together with the Cookie Policy, the Terms of Use, and where applicable, the relevant Rules and Additional Terms applicable to Our Services forms an integral part of our User Agreement, which You accepted upon registering Your User Account or will accept before completing Your registration on our Website. We strongly recommend that You read our Privacy Policy carefully before registering Your User Account and using our Services.
1.3. General
This Privacy Policy sets out and describes the way in which We collect and process Your Personal Data, which You provide, or You are requested to provide to Us in connection with using our Website and Services.
We respect Your privacy and are committed to protecting Your Personal Data and processing it in accordance with the applicable laws, including:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation or GDPR); and
Personal Data Protection Act 2012 of Singapore (PDPA).
By registering and clicking “I agree” on the Website, You have agreed to be bound by this Privacy Policy, which forms part of the User Agreement as indicated in the Terms of Use.
1.4. What Personal Data We Collect
We mainly collect Your Personal Data to provide You with our Services and to comply with regulatory requirements. We are required by law to collect specific information from You, including documents for verifying Your identity in connection with Your use of our Services. As a result, We must retain certain information about You to comply with our legal obligations. Additionally, We may process some of Your Personal Data to send You promotions and offers related to our Services that We believe may be of interest to You. However, You can opt out of such marketing communications at any time if You wish.
Personal Data that We request or may request from You in the frame of the provision of the Services:
Account Information: Name, email address and Steam details (login, username, icon, other information You made public on Steam), payment details.
Profile Information: Photos, personal details, descriptions and all information that You make public on the Internet.
Transaction Information: Details of purchases, sales, and interactions on the Website.
Date of Birth;
• Telephone Number;
• Country of Citizenship;
• Country of Residence;
• ID/Passport Number.
• Information Collected Automatically
We may collect certain information automatically when You use the Website, which may include:
• Usage Data: information about Your interaction with the Website, such as pages visited, browsing activity, and search queries;
• Device Information: technical information such as Your IP address, browser type, device type, operating system, and approximate location based on Your device settings.
For more information about the use of cookies and similar technologies, please refer to our Cookie Policy.
• Third-Party Information
We may collect information about You from third parties, such as social media Websites or payment processors, when You connect their services to our Website.
We encourage You to review privacy policies of such third parties thoroughly before cooperating with them.
Additional Data that we may collect and process during Your activity on our Website:
• Type of Access Device You use, Your Access Device unique identifier, serial number or Access Device ID.
• IP address of Your Access Device, Your operating system and browser type.
• Information related to Your usage, product interactions, performance, diagnostics, crash data, search and browsing history, and location data from the devices You have purchased or use to access our Services.
• Anti-fraud data (e.g., detection of VPN/proxy usage, multi-accounting monitoring/geolocation).
• Details about how You use our Services (identify Your activity on our Website), such as to differentiate You from other users, remember Your preferences and enhance Your experience. This information also helps us improve our Services.
1.5. How We Use Your Personal Data
We may process Your Personal Data for the following purposes:
• To verify Your identity for Your registration on the Website (that You can create Your User’s Account) in relation to Your access to the Services.
• To provide You with the information, products, offers regarding our Services as well as to send You marketing and promotional materials.
• To deliver, improve, and develop Our Services.
• To communicate with You, including to offer You targeted advertisements and Services.
• To process Your transactions (for example Withdrawals and Deposits).
• For system administration and internal operations, including troubleshooting, testing, statistical analysis, surveys, data analysis, research, and audits.
• To authenticate Your access to Our Website and Services and to differentiate You from other Users.
• To monitor Your use of Our Website and Services, improving User experience and ensuring content is displayed optimally for You and Your Access Device.
• To conduct marketing analysis, enabling Us to assess trends and the effectiveness of Our advertising and marketing efforts (this may include using Your Personal Data to evaluate, analyse, or predict aspects like Your preferences, interests, or location, if you opt-in).
• To provide customer support and maintain a high level of customer Services.
• To Communicate with You regarding Your User Account, orders and support inquiries.
• To promote safety and security by monitoring for fraud, investigating suspicious or potentially illegal activities, or enforcing Our Privacy Policy.
• To ensure the safety and security of Our Website and Services.
• To comply with applicable laws and regulations.
1.6. With Whom We May Share Your Personal Data
We may share Your Personal Data with:
• Service Providers: We may share information with vendors, consultants, payment providers, and other service providers (but not with advertisers and ad partners) who need access to such information to carry out processing activities for Us. The partner’s use of Personal Data will be subject to appropriate confidentiality and security measures.
• Legal Authorities: We may share information in response to a request for information if We believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements.
• To Enforce Our Policies and Rights: We may share Your information with third-party service providers, professional advisors, payment service providers, and law enforcement or regulatory authorities if We believe that Your actions are inconsistent with Our Terms of Use, User Agreement, other relevant Rules, Additional Terms and policies of LisSkins, or to protect the rights, property, and safety of the Company, its Users, or others.
Additionally, we may utilize open-source information, such as public records, government registries, databases, and social media platforms (including Facebook, LinkedIn, etc.), as permitted or required by law.
We take reasonable steps to ensure that our service providers and other contractors provide at least the same level of protection for Your Personal Data as we do.
1.7. Direct Marketing and Opt-Out
From time to time, We may use Your Personal Data to notify You about our Services or new products, or promotional activities that we believe may be of interest or benefit to You. This may be done through email, sms or phone.
Additionally, we may reach out to You regarding the management and administration of Your User’s Account. These communications can occur through any of the contact methods You provided during registration. Please note that these account-related communications do not affect Your opt-in or opt-out preferences for direct marketing notifications.
If You no longer wish to receive marketing or promotional materials from us whether in general or in a specific format, You can withdraw Your consent at any time, such as by clicking the “unsubscribe” link at the bottom of our marketing emails or by contacting our support team via email to: [email protected].
1.8. Legal Basis for Processing Your Personal Data
We will only handle Your Personal Data when there is a legitimate legal basis to do so. The appropriate legal basis depends on the specific reasons for which Your Personal Data is collected and used. Typically, the legal grounds will include:
• Consent: When You agree to provide Your Personal Data in the frame of accessing the Website and using the Services, as well to receive marketing communications from us. Based on Your consent We process Your Personal Data.
• Legitimate Interests:
We may process Your Personal Data based on our legitimate interests (including our business interests), provided that such interests are not overridden by Your rights and freedoms.
In particular, we may rely on this legal basis to:
• understand our Users and conduct market research;
• promote our Services, including sending You promotional emails, SMS, or push notifications about our Services, special offers, and new products (where You have not opted out or where otherwise permitted by applicable law);
• improve the functionality, usability, and overall user experience of our Website and Services;
• maintain the security and integrity of our Services;
• prevent fraud, abuse, and unauthorized activities;
• verify Account authenticity and User identity;
• prevent multi-accounting, identity theft, and other fraudulent activities;
• detect VPN/proxy usage and other security risks;
• ensure compliance with our Terms of Use, User Agreement, Privacy Policy and where applicable, the relevant Rules and Additional Terms applicable to the Services.
• Performance of a Contract:
We process Your Personal Data where it is necessary for the performance of the User Agreement with You or to take steps at Your request prior to entering into the User Agreement.
• Legal Obligations:
We may process Your Personal Data where such processing is necessary to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) and other financial crime prevention obligations.
This includes:
• retaining KYC documentation for identity verification purposes;
• monitoring transactions to detect suspicious or potentially unlawful activities;
• reporting to regulatory, supervisory, or law enforcement authorities where required by applicable law.
Vital Interests:
We may process Your Personal Data where such processing is necessary to protect Your vital interests or those of another Users.
This may include:
• responding to emergency situations where there is a risk of harm to an individual;
• protecting Users from serious security threats or unlawful activities that may cause significant harm;
• sharing information with competent authorities where necessary to prevent or mitigate such risks.
1.9. Fraud Prevention and Security
We are committed to ensuring the security of the provision of our Service and preventing fraudulent activities, including but not limited to:
• Multi-accounting;
• Identity theft;
• Unauthorized access;
• Money laundering.
To detect, prevent, and mitigate fraudulent activities, We process and monitor the following types of Personal Data:
• IP address and geolocation – to identify suspicious login attempts, VPN/proxy usage, and unauthorized account access.
• Device ID and browser fingerprinting – to detect duplicate accounts and prevent unauthorized account sharing.
• Behavioral data – to identify suspicious behavioral patterns and prevent collusion.
• Deposit and withdrawal history – to prevent financial fraud and ensure AML compliance.
This Data processing is based on our Legitimate Interest (as stated above in Clause 1.8.) to maintain the integrity of our Services and comply with regulatory obligations where applicable.
If We detect fraudulent activity, We reserve the right to suspend or terminate User Account, restrict Your access to the Services, and report violations to relevant authorities.
1.10. Your Rights
Since we handle Your Personal Data, it’s essential that You are aware of Your rights as the User of Our Services.
Below, We outline Your rights and how they pertain to the Data We process.
• Right of Access: You have the right to request access to the Personal Data We hold about You and to receive a copy of such data. We will provide this information free of charge, except where requests are manifestly unfounded or excessive, in which case We may charge a reasonable fee.
• Right to Rectification: If the information We hold about You is inaccurate or incomplete, You have the right to request that it be corrected without undue delay.
• Right to Withdraw Consent: Where We process Your Personal Data based on Your consent, You have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.
• Right to Erasure (Right to be Forgotten): You have the right to request the deletion of Your Personal Data where one of the following grounds applies: (i) the data is no longer necessary for the purposes for which it was collected; (ii) You withdraw Your consent (where processing is based on consent); (iii) You object to processing and there are no overriding legitimate grounds; or (iv) the data has been processed unlawfully. This right is subject to legal and regulatory retention obligations.
• Right to Object: Where We process Your Personal Data based on legitimate interests, including profiling, You have the right to object. We will cease processing unless We can demonstrate compelling legitimate grounds that override Your rights and freedoms, or where processing is required for legal claims.
• Right to Restriction of Processing: You have the right to request that We restrict the processing of Your Personal Data in certain circumstances. Where processing is restricted, We may store Your Personal Data but will only process it:
- with Your consent;
- for the establishment, exercise or defence of legal claims;
- for the protection of the rights of another natural or legal person; or
- for reasons of important public interest.
• Right to Lodge a Complaint: If You are dissatisfied with how We process Your Personal Data, You have the right to lodge a complaint with a competent supervisory authority in the EU Member State of Your habitual residence, place of work, or place of the alleged infringement.
• To exercise any of the above rights, please contact us at [email protected].
1.11 Transfers to Third Countries
Your Personal Data may be transferred to, stored, and processed in countries outside of Your country of residence, including countries that may not provide the same level of data protection.
Where such transfers occur, We take reasonable steps to ensure that the recipient provides a standard of protection comparable to that required under applicable data protection laws, including the Personal Data Protection Act 2012 of Singapore.
Where required under applicable law, including the GDPR, We implement appropriate safeguards such as the use of Standard Contractual Clauses approved by the European Commission or transfers to jurisdictions recognized as providing an adequate level of data protection.
1.12. Security of Personal Data
You acknowledge that data transmission over the Internet is not entirely secure and may involve certain risks. While We implement appropriate technical and organizational measures to protect Your Personal Data, We cannot guarantee absolute security of information transmitted to Us.
Once We receive Your Personal Data, We take reasonable steps to protect it against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. Such measures include the use of secure systems, access controls, encryption, and secure communication protocols (such as SSL/TLS).
By using our Services or providing Us with Personal Data, You agree to receive electronic communications from Us relating to security, privacy, and administrative matters.
You are responsible for maintaining the confidentiality of Your User Account credentials and for the security of the devices You use to access the Services. We recommend that You log out of Your User Account after each session, especially when using shared devices.
1.13. Special Category of Personal Data
We do not collect any Special Categories of Personal Data about You, such as details about Your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political opinions, trade union membership, health information, or genetic and biometric data. However, based on our experience, We recognize that You may voluntarily provide such data during communication with us at Your discretion.
Please note that although We process Your personal documents, such as passports or ID cards, the images contained in them are not technically processed in a way that would enable us to identify any of the aforementioned data. Therefore, such documents are not to be considered special category of data.
1.14. Children
Our Services are not intended for individuals under the age of 18 or who have not reached the age required to enter into legally binding agreements in their jurisdiction (as specified in our Terms of Use). We do not knowingly collect Personal Data from individuals who do not meet these requirements.
We are dedicated to preventing children from accessing our Services and do not accept their information for User Account registration. However, parents and legal guardians are responsible for supervising their children’s online activities, including the use of appropriate parental control tools.
1.15. Third-Party Websites and Services
Our Website, Services and other products, may contain links to or allow access to third-party websites, products, and services. When You click on these links, You are leaving our Website and are subject to the privacy policies of those third parties. We are not responsible for the privacy practices, information, or content provided by these external websites and services. This Privacy Policy applies only to Personal Data collected directly by Us through Our Website and Services. We encourage You to review the privacy policies of any third-party websites You visit.
1.16. Data Retention Term
The duration for which We retain Your Personal Data depends on applicable legal, regulatory, and operational requirements.
In particular, We may be required to retain certain Personal Data for a minimum period of at least 5 years in accordance with applicable anti-money laundering and counter-terrorism financing laws and regulations, including the Monetary Authority of Singapore (MAS) Notice PS-N06 and relevant guidance issued by the Suspicious Transaction Reporting Office (STRO), Singapore.
Where no specific retention period is required by law, We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected.
When Your Personal Data is no longer required, We will securely delete or anonymize it.
However, there are exceptions:
• Investigations and Fraud Prevention: Where We are required to investigate or reasonably suspect fraudulent, unlawful, or abusive activity, We may retain Your Personal Data for a longer period to prevent such activity and to cooperate with competent authorities.
• Legal Disputes: In the event of a legal dispute, We will retain Your Personal Data for the duration of the dispute and as necessary for the establishment, exercise, or defence of legal claims.
• User Account Deletion: If You request account deletion, We will securely delete or anonymize Your Personal Data, unless retention is required by applicable law or regulatory obligations.
1.17. Contact Details
While We strive to be as clear and transparent as possible, if You need any clarification about this Privacy Policy, please feel free to reach out. We are happy to provide You with any additional information You may need. Please contact us by email to [email protected] or by the Website customer support chat function.
