Privacy Policy

Welcome to GameTrade’s Privacy Policy, overseen by Datara the Keeper, Guardian of Data in our Legal Department. This Privacy Policy explains how GameTrade Limited (“GameTrade,” “we,” “us”) collects, stores, uses, and discloses your Personal Data in connection with the GameTrade Platform (website, mobile site, or mobile application). By accessing or using the Platform, you acknowledge and agree to the collection, use, storage, and disclosure of your Personal Data as outlined in this Policy.

This Policy supersedes prior versions and complies with Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”), including its Data Protection Principles (DPPs), and the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). We may update this Policy, effective upon posting. We will notify you of material changes via email or Platform notifications, providing a 30-day opt-out period. Continued use constitutes acceptance. For questions, contact Datara at [email protected].

Consent

By using the Platform, you consent to the collection, storage, use, and disclosure of your Personal Data as described herein. You may withdraw your consent at any time by contacting us. However, doing so may restrict your ability to use certain features of the Platform or result in the termination of your Account, depending on the nature of the data involved.

Personal Data Definition

“Personal Data” means information that identifies you as an individual, such as name, address, phone number, email, or other identifiers, as defined under the PDPO.

When We Collect Your Personal Data

We collect Personal Data when you register an Account, submit a Seller application, contact our support team, make purchases, sell Items, participate in transactions, respond to surveys or marketing, or engage with loyalty programs such as GT Points.

We may also collect data from third parties (e.g., payment partners, credit agencies) with your consent or as permitted by law.

Information Collection and Use

Personal Information Provided by You

When you register, make purchases, or sell items, you provide Personal Information, including:

• Identity and Contact: Name, email, phone number, billing/shipping address, Hong Kong ID, or passport details (for EKYC).

• Payment Details: Credit card, bank account, or Payment Partner (e.g., PayPal, Payoneer) information.

• Account Details: Username, password, security details.

• Transaction Details: Purchase/sale records, item descriptions, delivery confirmations.

• Content: Reviews, feedback, or user-generated content.

This data is used to verify identities, process transactions, facilitate payouts, and provide support, in line with DPP1 (fair collection) and DPP3 (limited use).

Children and Minors

Users under 18 require parent/guardian consent. We do not knowingly collect Personal Data from minors without such consent. Contact [email protected] for concerns.

Automatically Collected Information

We collect:

• Device Data: IP address, browser type, OS, and geo-location (with consent).

• Usage Data: Clickstream, referring pages, and analytics via tools like Google Analytics.

• Cookies and Trackers: For session management, preferences, and fraud detection (see "Cookies and Tracking Technologies" below).

This information helps us improve Platform performance, enhance user experience, and detect fraudulent activity, in accordance with DPP2 (accuracy and retention).

Other Information

We use anonymized data for research, reporting, and service enhancement.

Use of Personal Data

Personal Data is used to:

• Provide and manage services (e.g., transactions, Account management).

• Communicate support, confirmations, and non-promotional announcements (e.g., maintenance).

• Prevent fraud and comply with legal obligations (e.g., AML/CTF reporting to the Joint Financial Intelligence Unit).

• Conduct marketing (with opt-out options) and create preference profiles.

• Analyze usage for Platform optimization.

We process Personal Data based on one or more legal bases, including your consent, the necessity of fulfilling a contract, compliance with legal obligations, or our legitimate interests. We do so while respecting your rights under the PDPO.

Information Sharing and Disclosure

We do not sell or rent Personal Data but may share it with:

• Service Providers: For operations (e.g., payment processing, analytics), under PDPO-compliant contracts.

• Buyers/Sellers: Limited contact details for transactions (per Terms of Service [insert link]).

• Government authorities or regulators: When required for legal compliance, fraud investigations, or enforcement of data protection laws, including doxxing-related inquiries under the 2021 PDPO amendments.

• In Business Transactions: During mergers/acquisitions, with confidentiality protections.

• With Your Consent: For other specified purposes.

Sharing adheres to DPP3 (use limitations) and DPP4 (security).

Choice and Opt-Out

To opt out of promotional communications, follow email instructions or contact [email protected]. Service-related announcements (e.g., maintenance) are non-opt-out, but you may deactivate your Account via My Account → Settings → Terminate Account, safely clearing your data. To protect your data, we may request identity verification or additional information before processing opt-out or account termination requests.

Links to Other Websites

Third-party links (e.g., payment gateways, social media) are not governed by this Privacy Policy. Review their policies before sharing data.

Storage and Security of Personal Information

Storage

Personal Data may be stored in Hong Kong or other jurisdictions. For international transfers, we implement PDPO-compliant safeguards, such as standard contractual clauses or your explicit consent, to ensure equivalent protection (per DPP3 and DPP4).

Security

We protect data with:

• Encryption (e.g., SSL/TLS).

• Access controls and regular audits.

• EKYC for identity verification.

While we implement robust security measures, no system can guarantee absolute protection. You are responsible for safeguarding your login credentials and notifying us promptly of any suspected breaches. We cooperate with authorities (e.g., JFIU) on fraud investigations.

Cookies and Tracking Technologies

We use:

• Essential Cookies: For login and functionality.

• Analytics Cookies: For anonymized insights (e.g., Google Analytics).

• Marketing Cookies: For personalized ads.

You can manage your cookie preferences through your browser settings or by visiting [insert cookie settings link]. Please note that disabling certain cookies may affect Platform functionality. Opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

Third-party services (e.g., Google, Facebook, X) may collect data via plug-ins, governed by their policies:

• Google: https://policies.google.com/privacy

• Facebook: https://www.facebook.com/privacy/explanation

• X: https://x.com/en/privacy

Your Rights

Under the PDPO (DPP6), you may:

• Access and obtain a copy of your Personal Data.

• Correct inaccuracies.

• Object to processing (e.g., marketing).

• Withdraw consent or request erasure (subject to legal retention).

• Restrict processing in certain cases.

• Request data portability.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days, as required by the PDPO. If you are unsatisfied with our response, you may lodge a complaint with the Privacy Commissioner for Personal Data at https://www.pcpd.org.hk.

Data Retention

We retain Personal Information only as needed for stated purposes or legal obligations (e.g., 7 years for transaction/tax data per Hong Kong’s Inland Revenue Ordinance (Cap. 112)). Anonymized data may be kept indefinitely. We periodically review the data we hold and securely delete or anonymize information that is no longer required for operational or legal purposes.

International Data Transfers

Personal Information may be transferred outside Hong Kong (e.g., to payment partners). Where Personal Data is transferred to jurisdictions outside Hong Kong, we ensure that appropriate safeguards are in place to maintain the level of protection required under the PDPO.

Newsletters and Marketing

Subscribe to newsletters via double opt-in. Unsubscribe via email links or [email protected]. We use tracking pixels to measure engagement with our newsletters. This data is used internally to improve communication and is not shared with third parties.

AML/CTF Compliance

We verify identities via EKYC for AML/CTF compliance, sharing data with JFIU if required. Non-compliance may lead to Account suspension.

Updates to This Privacy Policy

We may update this policy, effective upon posting at [insert website URL]/privacy-policy or via email notification. Material changes will be communicated via email or Platform notifications, and you will be given a 30-day period to opt out. Continued use of the Platform after this period constitutes acceptance of the updated Policy.

Contact Us

For questions, concerns, or to exercise your rights, contact:

Datara the Keeper

Data Protection Officer

GameTrade Limited

Email: [email protected]