PRIVACY POLICY

Ungrinding collects Users' Personal Data on a voluntary basis and in compliance with current Personal Data protection legislation, including the General Data Protection Regulation (hereinafter referred to as the “GDPR”). Please review the following list of the Data we may request at certain stages of the sign-up proceedings or during your use of the website:

• Information necessary to create an account: e-mail or social media profiles.
• Information necessary to accredit a User as a Seller: First Name, Last Name;
• Age;
• Phone Number;
• Data received in the course of your use of the Ungrinding website and services: Computer parameters and characteristics;
• IP-address and geographic position;
• Cookie files submitted by your browser;
• Hardware event data including those of any malfunctions and your activity on the website; also your browser type, properties and language settings, date and time of a request and the URL used to access the website;
• Information collected by the e-mail newsletter service provider.

We reserve the right to store payment information provided by the User in the course of actualizing transactions on the website in order to act on Guarantor and Transaction Safety provisions as per User Agreement. The term Payment Information includes only the payment amount, transaction date and number and contact details necessary to identify a payment. We do not store data regarding your bank cards or any other payment system used by you to pay for services on our website. In case a User loses access to their Ungrinding account or in the case of conflict between Users, Ungrinding Customer Service is entitled to request a photocopy / scan / photo of an ID (citizen passport, driver's license) to validate registration data or the User's rightful possession of the Ungrinding account.

The main reason we ask users to provide their personal data is due to the necessity of its availability in order to provide you with services and full access to website functionality, transaction processing, withdraw money from the Ungrinding Wallet balance to payment systems or personal bank account, and to be able to receive personalized emails from Ungrinding. Using this website, we collect personal data several times:

• When you visit and browse website your IP address will be saved. It is necessary action to prevent fraud and in order to improve security and website performance;
• Data will be erased after 9 months, because many payment systems, for example PayPal, require you to save this information and may request the data on the payments made;
• When posting messages in a chat area all message history will be saved. It is necessary to provide the seller's services, to improve the quality of services, and to ensure compliance with the rules for all parties;
• If you create a new account, we will save the Personal Data provided by you: email, social network profile (if logged with Social Login), username;
• If you change your profile, we will update the Data in our database.

Data collected during the order placement procedure Currently, for the most payment methods there is no need to enter additional personal data other than that is provided during registration. However, for certain payment methods, if required by the payment system, the following data is required: 1. QIWI: phone number; 2. VISA / MASTERCARD (through a payment gateway Unlimit or Stripe): Name, Surname, address, country, city, phone number, postcode. Additional Personal Data that you provide during the order placement procedure will be stored in our database We do not have access to your payment data (credit card, etc.), all transactions and payment data are well-protected, received and processed by certified payment systems. Personal Data collected after the purchase If you provide additional in-game information after placing an order, using the “Order Details” form (for example, server and character name), it will be stored in our database in order to accelerate delivery of services. You can also provide this information in our chat. User's email address provided during the sign-up proceedings can be used to inform you on your order progress. It can also be used for password recovery or for any other instances where we are legally required to contact you. For emails that are sent from this website we are using Mailchimp. We will never use it for any marketing activities unless you subscribe to our newsletter. Personal Data collected during the Seller sign-up proceedings (only for boosters) For boosters identification purposes and to ensure the platform security, when applying to sign-up as a booster we request following information: address, name, surname, e-mail address, phone number, username, WhatsApp, Telegram, Skype, Discord, birth date, copy of the passport. Personal Data collected during the processing of payments (only for boosters) For the implementation of technical capacity of making payments to your payment details and to meet all the requirements of payment systems we collect and store the following personal data: phone number, name, surname, card number. All personal data of users is stored and managed in accordance with the Law on Personal Data Protection. YASHA LIMITED is the controller for storage and processing of personal data, registered to an address NICOLAOU PENTADROMOS CENTRE, 9th Floor, Flat / Office 908TH, 3025, Limassol, Cyprus.

Ungrinding has one data center that collect personal data: 1. Servers in Frankfurt data center (Germany) are operated by Hetzner. Ungrinding reserves the right to share your Personal Data with its partner companies, payment systems and Ungrinding controlled services and websites. Your Personal Data can also be submitted to the law enforcement agencies provided a proper request supported by necessary paperwork. Your geographic position may be shared with our advertising partners.

To provide User interaction, only the following information is revealed for the public: your nickname, your Profile's personal rating and reviews left by other Users, the total number of deals and the rate of successfully completed deals. Any data provided by you in your Personal Profile or shared with a Seller in the course of a deal are not an object of the website's Privacy Policy. You are completely responsible for your personal data. Moreover, sharing contact details may result in Ungrinding blocking your account in accordance with the User Agreement. However, on our part, we secure the privacy of any correspondence between a Buyer and a Seller conducted via our website.

We enforce a strict Personal Data Protection policy and provide the security of that data in accordance with the Personal Data Protection legislation. All Personal Data received by the website is stored in a separate, secure server and is processed automatically. Your Personal Data may only be accessed to provide services to you, and to improve the quality in compliance with the objectives listed in Provision 3 of the current document, provided all other means of data processing are impossible. All Ungrinding staff have undergone training and follow the informational security regulations necessary when working with Users' data. We employ up-to date means to prevent anyone from stealing or gaining unsanctioned access to your Personal Data. Nevertheless, in case our security system is hacked and Personal Data are stolen, we do not bear any material responsibility. Any payment operations are conducted solely through payment service providers' secure gateways.

Every Ungrinding User can correct their Personal Data provided during the sign-up proceedings or to verify their account. To do that, contact our Customer Service. If the Customer Services rules your claim legitimate and reasonable, your request will be granted. 6.1. Right to access your personal information For example, request the complete list of Personal Data used by Ungrinding. You are entitled to learn what personal information we have and how it is being utilized. Once we receive a request from you and verify you as the claimer, in accordance with the Law on Personal Data Protection, we will grant your request within 30 (thirty) calendar days. 6.2. Right to rectify your personal information You can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing. 6.3. Right to restrict the use of your personal information For example, you can cancel your subscription to newsletters, personal offers, promotional activities, and personalized content, but keep your subscription to important notification on at any moment. 6.4. Right to request that your personal information is erased This includes all personal information provided by you during the sign-up proceedings and collected by us in the course of your utilization of our website and services. When a corresponding request is filed, all the Personal Data including User's e-mail, Cookies, IP-address and computer parameters are deleted from our servers. The exception is the history of your deals, disputes and Customer Service addresses as this information is related to at least one Party and cannot be deleted without the consent of all the Parties involved. This operation entails termination of any collaboration with the User since any further service provision to them is impossible. According to GDPR, Ungrinding is obliged to identify your personality before executing the procedure of full user's data erasure. It is necessary to fill in the FORM to initiate the procedure. 6.5. Right to data portability (in certain specific circumstances) Transferring any User Personal Data by personal request is regulated by the personal data legislation. Transferring any Personal Data to a third party without saving it and providing the access to it necessary for providing services is considered a Personal Data deletion and entitles us to terminate our services to you with no notice. Providing technical accessibility to User's Personal Data in order to receive our services in case of a data transfer to a third party is the responsibility of the User. 6.6. Right to object to processing of your personal information. You can object to certain types of data processing and stop Ungrinding from continuing to process your personal data in certain situations:

• Direct marketing;
• The processing of personal data for statistical purposes related to historical or scientific research;
• The processing of data for tasks in the public interest;
• The exercising of official authority invested in you.

6.7. Right not to be subject to an automated decision You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. 6.8. Right to lodge a complaint with a supervisory authority According to Art. 77 GDPR you have the right to lodge a complaint with a supervisory authority. If you believe that the processing of personal data concerning you is contrary to the GDPR, you have the right to complain to a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement, without prejudice to any other administrative or judicial remedy the alleged infringement. Ungrinding staff follows the Personal Data legislation and has no right to change your Personal Data without your consent.

Ungrinding Users are entitled to post content and links to outside resources. Their actions are regulated by the User Agreement, and our Customer Service monitors the adherence of its Provisions. For that reason, one of the measures taken by us to provide Users' Personal Data security is upon detection deleting any user-posted links or content posing security risks for other users. We do not re-moderate any posted products or auctions and do not moderate Users' online chats. That is why we disclaim any responsibility and direct or indirect liability to the User in case they are subject to any damage or Ungrinding account data theft occurring when they follow an external link posted by another User on the website, in the online chat, in the comments or any associated resources. Ungrinding is not associated with any external resource and is not obliged to repair any possible loss entailed by any action taken on an external resource.

Our Privacy Policy may get changed or updated as our services develop and improve. Nevertheless, we pledge to respect the rights of Ungrinding Users. You can always learn about Privacy Policy updates on this page. The most important changes will be delivered to you via e-mail or website notifications, as well as via the Ungrinding online chat.