Política de Privacidade

Effective Date: 02.07.2026

1. Introduction

This Privacy Policy ("Privacy Policy") explains how ARPS LOOP LTD, a company duly incorporated under the laws of the Republic of Cyprus (the "Company", "Platform", "Farmskins", "we", "our", or "us"), collects, uses, stores, shares, protects, and otherwise processes personal data when you access or use the Farmskins website and related services (the "Platform").

We are committed to protecting your privacy and processing your personal data in a lawful, fair, and transparent manner.

By accessing or using the Platform, creating an account, or otherwise interacting with our services, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy should be read together with our Terms of Service, Cookie Policy, and any other legal notices published on the Platform.

2. Data Controller

For the purposes of applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the data controller is:

ARPS LOOP LTD

Republic of Cyprus

Email: [email protected]

For any questions regarding this Privacy Policy or the processing of your personal data, please contact us using the contact details above.

3. Scope of this Privacy Policy

This Privacy Policy applies to:

• visitors of the Platform;
• registered users;
• purchasers of digital goods;
• individuals contacting our customer support;
• individuals whose personal data we process in connection with providing our services.

This Privacy Policy applies only to information processed by the Company and does not govern third-party websites or services that may be linked from the Platform.

4. Categories of Personal Data We Collect

Depending on how you use the Platform, we may collect and process the following categories of personal data.

4.1. Account Information

• Steam ID;
• Steam profile URL;
• Steam nickname;
• Steam avatar;
• Steam account information made publicly available through Steam;
• Platform account identifier;
• username.

4.2. Contact Information

• email address;
• customer support correspondence;
• communication preferences.

4.3. Technical Information

• IP address;
• browser type and version;
• operating system;
• device identifiers;
• language settings;
• time zone;
• screen resolution;
• referring URLs;
• pages visited;
• clickstream information;
• date and time of access;
• server logs.

4.4. Transaction Information

We may process information relating to your purchases and use of our services, including:

• transaction identifiers;
• purchased digital items;
• order history;
• payment status;
• refund information;
• fraud prevention records.

We do not collect or store full payment card numbers or CVV codes. Payment card information is processed directly by licensed payment service providers.

4.5. Identity Verification Information

Where required by law or for fraud prevention purposes, we may process information collected during identity verification procedures, including KYC or AML checks conducted by authorized third-party providers.

4.6. Marketing Information

Where permitted by applicable law, we may process:

• subscription preferences;
• consent records;
• marketing communication history.

4.7. Cookies and Similar Technologies

We collect information through cookies, pixels, local storage, and similar technologies as described in this Privacy Policy and our Cookie Policy.

5. How We Collect Personal Data

We collect personal data:

• directly from you;
• through your Steam account when you authenticate using Steam;
• automatically when you use the Platform;
• from payment service providers;
• from fraud prevention providers;
• from analytics providers;
• from identity verification providers where legally required;
• from publicly available sources where permitted by law.

6. Legal Bases for Processing (GDPR)

Where the GDPR applies, we process your personal data on one or more of the following legal bases under Article 6 GDPR.

Performance of a Contract

Processing is necessary to:

• create and manage your account;
• authenticate your Steam account;
• provide purchased digital goods;
• process transactions;
• provide customer support;
• enforce our Terms of Service.

Compliance with Legal Obligations

We process personal data where required by applicable laws, including obligations relating to:

• anti-money laundering (AML);
• counter-terrorist financing (CTF);
• fraud prevention;
• accounting;
• taxation;
• regulatory reporting;
• legal requests from competent authorities.

Legitimate Interests

We may process personal data where necessary for our legitimate interests, including:

• improving our services;
• ensuring Platform security;
• detecting fraud;
• preventing abuse;
• resolving disputes;
• defending legal claims;
• maintaining business records;
• improving website performance;
• protecting users and the Platform.

Whenever we rely on legitimate interests, we ensure that your rights and freedoms are appropriately balanced.

Consent

Where required by law, we process personal data based on your consent, including:

• marketing communications;
• non-essential cookies;
• certain analytics technologies.

You may withdraw your consent at any time without affecting the lawfulness of processing carried out before such withdrawal.

7. Purposes of Processing

We use personal data for the following purposes:

• creating and managing user accounts;
• authenticating users through Steam;
• providing access to Platform services;
• delivering purchased digital goods;
• processing payments;
• preventing fraud and unauthorized activity;
• complying with AML and KYC obligations;
• maintaining Platform security;
• communicating with users;
• responding to customer support requests;
• maintaining transaction records;
• complying with legal obligations;
• improving Platform functionality;
• conducting statistical analysis;
• performing internal audits;
• protecting our legal rights;
• preventing misuse of the Platform;
• enforcing our Terms of Service;
• sending service-related communications;
• sending marketing communications where permitted by law;
• administering promotions and campaigns;
• complying with requests from competent governmental authorities.

We do not use your personal data for purposes incompatible with those described in this Privacy Policy unless otherwise permitted or required by applicable law.

8. Cookies and Similar Technologies

The Platform uses cookies and similar technologies, including pixels, web beacons, local storage, and software development kits (SDKs), to ensure the proper operation of the Platform, improve user experience, enhance security, analyze website traffic, and provide certain personalized features.

Cookies are small text files placed on your device when you visit a website. Some cookies are necessary for the Platform to function properly, while others help us understand how visitors use our services or remember your preferences.

We may use the following categories of cookies:

Strictly Necessary Cookies

These cookies are essential for the operation and security of the Platform. They enable core functionality such as user authentication, fraud prevention, account security, session management, and technical operation of the website. These cookies cannot be disabled through our cookie preferences because the Platform would not function correctly without them.

Functional Cookies

These cookies remember your preferences, including language settings, interface customization, and other choices that improve your user experience.

Analytics Cookies

Analytics cookies help us understand how visitors interact with the Platform, identify technical issues, improve performance, and develop new features. These cookies collect information in an aggregated or pseudonymized form where possible.

Advertising and Marketing Cookies

Where permitted by applicable law, these cookies may be used to measure advertising effectiveness, prevent advertising fraud, and personalize marketing communications.

You may manage your cookie preferences at any time through your browser settings or through our Cookie Consent Center available at:

https://farmskins.com/consent

Depending on your jurisdiction, non-essential cookies will only be activated after obtaining your consent where required by applicable law.

Additional information regarding cookies is available in our Cookie Policy.

9. Analytics Services

To better understand how users interact with the Platform and to improve our services, we use analytics technologies provided by trusted third-party service providers.

These services may collect information including:

• IP address (where permitted);
• browser type;
• operating system;
• device information;
• session duration;
• pages visited;
• click behavior;
• referring website;
• interaction with Platform features;
• approximate geographic location derived from IP address.

Google Analytics

The Platform uses Google Analytics, a web analytics service provided by Google LLC.

Google Analytics helps us analyze website traffic, measure user engagement, improve Platform performance, detect technical issues, and generate statistical reports.

Google may process certain information in accordance with its own Privacy Policy.

Where required by law, Google Analytics is activated only after obtaining your consent.

Other Analytics Providers

We may also use additional analytics, security monitoring, fraud detection, and performance monitoring services to improve the operation, stability, and security of the Platform.

Such providers process data only in accordance with applicable contractual obligations and applicable data protection legislation.

10. How We Share Personal Data

We do not sell your personal data for monetary consideration.

We may disclose personal data only where necessary for the purposes described in this Privacy Policy or where required by applicable law.

Personal data may be shared with the following categories of recipients:

Payment Service Providers

To process payments securely and comply with applicable financial regulations.

Identity Verification Providers

To conduct KYC, AML, fraud prevention, sanctions screening, and identity verification procedures where required.

Fraud Prevention Providers

To detect suspicious activity, prevent fraud, chargebacks, abuse of the Platform, and unauthorized transactions.

Hosting and Cloud Infrastructure Providers

To host the Platform and securely store Platform data.

Customer Support Providers

To assist with customer communications and technical support.

Analytics Providers

To analyze Platform usage, improve services, and monitor technical performance.

Professional Advisers

Including auditors, accountants, legal advisers, consultants, insurers, and other professional service providers.

Government Authorities

Where disclosure is required by applicable law, court order, subpoena, regulatory request, or lawful request from competent governmental authorities.

Corporate Transactions

If the Company undergoes a merger, acquisition, restructuring, financing, sale of assets, or similar corporate transaction, personal data may be transferred to the acquiring or successor entity, subject to applicable law.

All third-party service providers are required to process personal data only in accordance with applicable contractual obligations and applicable data protection legislation.

11. International Transfers of Personal Data

Due to the international nature of our business, personal data may be transferred to, processed in, or accessed from countries outside the European Economic Area ("EEA") or your country of residence.

Where personal data is transferred internationally, we implement appropriate safeguards in accordance with applicable data protection laws, including, where applicable:

• Standard Contractual Clauses approved by the European Commission;
• adequacy decisions adopted by competent authorities;
• contractual confidentiality obligations;
• technical and organizational security measures;
• other lawful transfer mechanisms recognized under applicable law.

By using the Platform, you acknowledge that your personal data may be processed in jurisdictions where data protection laws may differ from those of your country of residence. We take reasonable steps to ensure that appropriate safeguards remain in place for such transfers.

12. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy or as otherwise required or permitted by applicable law.

Retention periods depend on the nature of the information and the legal obligations applicable to us.

For example, we may retain personal data for the following purposes:

• maintaining user accounts;
• providing Platform services;
• fraud prevention;
• chargeback investigations;
• dispute resolution;
• customer support;
• accounting and tax compliance;
• AML and KYC compliance;
• regulatory reporting;
• enforcing our legal rights;
• defending legal claims.

When personal data is no longer required, we securely delete, anonymize, or otherwise dispose of it in accordance with applicable legal requirements and our internal retention policies.

Where deletion is not immediately possible due to backup systems or legal retention obligations, the data will remain securely stored and isolated from further processing until deletion becomes possible.

13. Marketing Communications

Where permitted by applicable law or where you have provided your consent, we may send you information regarding:

• Platform updates;
• promotional campaigns;
• special offers;
• new products or services;
• newsletters;
• marketing communications.

You may withdraw your consent or unsubscribe from marketing communications at any time by:

• clicking the "Unsubscribe" link included in our marketing emails;
• updating your account preferences (where available);
• contacting us at [email protected].

Withdrawal of your marketing consent will not affect service-related communications that are necessary for the operation of your account, security notifications, transaction confirmations, or other communications required to provide the Platform or comply with applicable law.

14. Security of Personal Data

We are committed to protecting your personal data and implement appropriate technical and organizational measures designed to safeguard personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, or any other unlawful form of processing.

Such measures may include, where appropriate:

• encryption of data in transit using secure communication protocols;
• access controls based on the principle of least privilege;
• authentication and authorization mechanisms;
• monitoring and logging of security-related events;
• vulnerability management and regular security testing;
• secure backup procedures;
• internal policies governing access to personal data;
• employee confidentiality obligations;
• contractual safeguards with third-party service providers.

While we strive to protect your personal data using commercially reasonable security measures, no method of transmission over the Internet or method of electronic storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.

15. Personal Data Breaches

If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will respond in accordance with applicable data protection laws.

Where required by applicable law, we will:

• notify the competent supervisory authority within the applicable legal timeframes;
• notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms;
• take appropriate measures to investigate, contain, mitigate, and remediate the effects of the breach.

16. Your Rights Under the GDPR

If the GDPR applies to the processing of your personal data, you may have the following rights, subject to applicable legal limitations.

Right of Access

You may request confirmation as to whether we process your personal data and obtain access to such data.

Right to Rectification

You may request correction of inaccurate or incomplete personal data.

Right to Erasure

You may request deletion of your personal data where one of the legal grounds under Article 17 GDPR applies.

Right to Restriction of Processing

You may request that processing of your personal data be restricted under certain circumstances.

Right to Data Portability

Where applicable, you may receive your personal data in a structured, commonly used and machine-readable format and request its transmission to another controller.

Right to Object

You may object to processing based on our legitimate interests, including processing for direct marketing purposes.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with the competent data protection supervisory authority in your country of residence or with the competent supervisory authority in the Republic of Cyprus if you believe that your personal data has been processed unlawfully.

17. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you may have certain rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), subject to applicable legal exceptions.

These rights may include:

• the right to know the categories and specific pieces of personal information we collect;
• the right to know the categories of sources from which personal information is collected;
• the right to know the business or commercial purposes for collecting, using, or disclosing personal information;
• the right to know the categories of third parties with whom personal information is shared;
• the right to request deletion of personal information;
• the right to request correction of inaccurate personal information;
• the right to obtain a copy of personal information in a portable format;
• the right to limit the use and disclosure of sensitive personal information where applicable;
• the right to opt out of the sale or sharing of personal information;
• the right not to receive discriminatory treatment for exercising your privacy rights.

We do not sell your personal information for monetary consideration.

We also do not knowingly share personal information for cross-context behavioral advertising in a manner that requires an opt-out under applicable California law. If our practices change in the future, we will provide any notices and opt-out mechanisms required by applicable law.

California residents may exercise their rights by contacting us using the contact details provided in this Privacy Policy.

We may verify your identity before processing your request.

18. We may verify your identity before processing your request

To exercise any of your rights under applicable privacy laws, including the GDPR or the CCPA/CPRA, you may contact us at:

Email: [email protected]

When submitting a request, please provide sufficient information to allow us to verify your identity and process your request securely.

We will respond within the timeframes required by applicable law.

In certain circumstances, we may refuse or limit a request where permitted or required by applicable law.

19. Children's Privacy

The Platform is intended only for individuals who are legally permitted to use our services under the applicable laws of their jurisdiction.

We do not knowingly collect personal data from children where prohibited by applicable law.

If we become aware that we have collected personal data from a child in violation of applicable law, we will take reasonable steps to delete such information without undue delay.

If you believe that a child has provided us with personal data, please contact us immediately.

20. Third-Party Websites

The Platform may contain links to third-party websites, applications, or services that are not owned or controlled by the Company.

We are not responsible for the privacy practices, security, content, or policies of third-party websites or services.

We encourage you to review the privacy policies of every third-party website you visit.

21. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes in applicable laws or regulations;
• changes to our business operations;
• new Platform functionality;
• improvements to our privacy practices;
• security enhancements.

Where required by applicable law, we will notify users of material changes by appropriate means, including through the Platform or by email.

The "Effective Date" at the beginning of this Privacy Policy indicates the date on which the current version became effective.

Continued use of the Platform after the effective date of an updated Privacy Policy constitutes acknowledgment of the updated Privacy Policy to the extent permitted by applicable law.

22. Contact Us

If you have any questions regarding this Privacy Policy, the processing of your personal data, or if you wish to exercise any of your rights, please contact us:

ARPS LOOP LTD

Email: [email protected]

We will make reasonable efforts to respond to your inquiry promptly and in accordance with applicable law.