ELDORADO MARKET PRIVACY POLICY
Last modified: April 1, 2019
1. Introduction
This Privacy Policy describes your privacy rights regarding use, storage, sharing, and protection of your Personal Information by Eldorado Market ("Eldorado"), operating the website Eldorado.gg ("Site"). It applies to the Site and all related sites, applications, services and tools where this policy is referenced, regardless of how you access or use them, including mobile devices. This policy does not apply to the practices of third parties that Eldorado does not own or control, or to individuals that we do not employ or manage. This policy may change from time to time, so please check back periodically.
2. Scope and Consent
2.1.Subject to the requirements of applicable laws, Eldorado strives to provide a consistent set of privacy practices throughout the global Site’s trading community. By using our Site, you acknowledge that you have read and accepted this Privacy Policy, the Site’s Terms, and all of the Site’s Policies, and you expressly consent to our collection, storage, use and disclosure of your Personal Information ("Personal Information") as described in this Privacy Policy.
2.2.Personal Information generally includes information that can be associated with a specific person and could be used to identify that person. We do not consider Personal Information to include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to identify a specific person.
2.3.There may be places throughout the Site that may link you to other websites that do not operate under this Privacy Policy. When you click through to these websites, this Privacy Policy no longer applies. Eldorado recommends that you examine the privacy statements for all third party websites to understand their procedures for collecting, using, and disclosing your Personal Information. The policy that applies on any of our domains or sub- domains is always the policy that appears in the footer of each website.
3. Amendments
Eldorado may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms automatically take effect 30 days after they are initially posted on the Site. Additionally, Eldorado will notify you via email of any material changes to this Privacy Policy.
4. Collection of Personal Information
4.1.You can browse the Site without telling us who you are. If you choose to provide us with Personal Information, you consent to the transfer and storage of that information to our servers. We may collect other information that is provided to us by your web browser. This may include the browser you used to come to our website, the Uniform Resource Locator ("URL") of the website that you just visited before visiting our website, which pages on our website you visit, any search terms you entered, which URL you go to next, and your Internet Protocol ("IP") address.
4.2 We may collect and store the following Personal Information:
Name, surname, date of birth, personal identification code, image, email address, physical address, phone number, physical contact information, and sometimes financial information (including respective financial account data);
Transactional information based on your activities on the Site (such as information to facilitate buying and selling);
Community discussions, chats, dispute resolution, correspondences through the Site, and correspondences sent to us;
Computer sign-on data, statistics on page views, traffic to and from the Site, and cookies information;
Other information, including IP address and standard weblog information, and supplemental information from third parties.
4.3. You can choose not to provide information to us, but in general some information about you is required in order for you to: register as a member; purchase products or services; complete a profile; participate in a survey, contest, or sweepstakes; ask us a question; or initiate other transactions on our site.
4.4. We may receive or collect supplemental information about you from third party sources and add it to your account information. This may include, but is not limited to, demographic, navigation information, additional contact information, credit check information, and additional information about you from credit bureaus, social networks, consumer behavior firms, or other sources, as permitted by law.
4.5.Transfer and Storage of Personal Data. We may transfer your Personal Information to the U.S., to any Eldorado’s affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our products or providing any Personal Information for any of the purposes stated below, you consent to the transfer and storage of your Personal Information, whether provided by you or obtained through a third party, including the hosting of such Personal Information on our servers.
5. Use
5.1.Our primary purpose in collecting Personal Information is to provide you with access the Site/or use of our services, applications and tools, provide you with requested customer service and relevant information about your account and our services, and to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your Personal Information to:
Provide the services and customer support you request;
Prevent, detect, and investigate, fraud, security breaches, potentially prohibited or illegal activities, and enforce our Terms of Service and Policies;
Customize, measure, and improve Site’s services, content, and advertising;
Contact you, either via email or telephone, to resolve disputes, collect fees, troubleshoot problems with your account or our sites, services, applications or tools, or for other purposes authorized by law;
Protect our rights, property, and safety, including that of our employees, Users, or others;
Contact you, either via email or telephone, to inform you about our services and those of our corporate family, deliver targeted marketing, service updates, and promotional offers based on your communication preferences;
Compare information for accuracy, and verify it with third parties;
Contact you via telephone, email, or text (SMS) messages (if applicable) as authorized for purposes described in this Privacy Policy; and
Provide you other services requested by you as described when we collect information.
5.2.In case you consent, we will send you marketing messages via email and/or leave a notification in an Account to inform you on the news and offers we think might be important and/or beneficial to you.
5.3.Also, if we already have provided services to you and you do not object we will inform you about our other products that might interest you including other information related to such.
5.4.You may opt-out of receiving marketing messages at any time. You may do so by:
choosing the relevant link in any of our marketing messages;
contacting us via means provided Contact section of the Site.
5.5.Upon you having fulfilled any of the provided actions we will update your profile to ensure that you will not receive our marketing messages in the future.
5.6.The opt-out of the marketing messages will not stop you from receiving messages directly related to the provision of services.
5.7.Please note that we do not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent.
5.8. We also process Personal Information for Eldorado’s legitimate interest. Eldorado has considered this processing to be necessary for the purposes of the legitimate interest pursued by Eldorado, which Eldorado has considered outweighing data subject’s interest of protection of the personal data. Example of purpose for such processing is to establish, exercise and defend legal claims, prevent fraud and similar crimes and to gather evidence.
6. Storage of Personal Data
6.1. Your Personal Data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. In any case it shall be kept for no longer than:
account data will be retained for no longer than 5 years following your last update on the account;
transaction data will be retained for no longer than 10 (years following the end of provision of services;
AML data will be retained as long as it is necessary to comply with the related legal requirements;
messaging data will be retained for as long as your Account is active, unless you withdraw your consent earlier;
correspondence data will be retained for no longer than 6 months following the end of such communication.
6.2. In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. I. e. usage data will be retained for as much as will be necessary for the relevant processing purposes.
6.3.Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Our Disclosure of Your Information
7.1. Eldorado may disclose Personal Information to comply with legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with this Privacy Policy and applicable laws and regulations. As stated above, we do not disclose your Personal Information to third parties for their marketing purposes without your explicit consent.
7.2.We may also share your Personal Information with:
Members of our affiliates to provide joint content and services (like registration, transactions, and customer support), to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches, and to guide decisions about their products, sites, applications, services and tools, and communications. Our affiliates may use this information to send you marketing communications only if you have consented to their services and will use your Personal Information in compliance with their Privacy Policy as well as ours;
Service providers who help with our business operations (such as, but not limited to, payment processing, fraud investigations, bill collection, affiliate and rewards programs);
Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to);
Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose Eldorado, you, or any other User of the Site to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, ZIP code, telephone number, email address, User ID history, IP address, fraud complaints, bidding and listing history, and anything else we may deem relevant to the investigation;
Credit bureaus with which we may report information about your account, including information on late payments, missed payments, or other defaults on your account;
Other business entities, should we plan to merge with or be acquired (whether through an asset sale or otherwise) by that business entity. (Should such a combination occur, Eldorado will require that the new combined entity follow this Privacy Policy with respect to your Personal Information. If your Personal Information will be used contrary to this policy, you will receive prior notice, and will be given the opportunity to withdraw your consent to the collection, storage, and transfer of your Personal Information);
Other Site’s Users, whether located in your country of residence or outside of your country of residence, as authorized by you.
8. Information You Share on the Site
8.1.Your User Name is displayed throughout the Site (and so available to the public), and is connected to all of your activity on the Site. Other people can see your items for sale, storefronts, feedback, ratings, and associated comments. Notices sent to other community members about suspicious activity and policy violations on our sites refer to User Names and specific items. So if you associate your name with your User Name, the people to whom you have revealed your name will be able to personally identify your activities on the Site.
8.2.If you access our sites from a shared computer or a computer in an internet café, certain information about you, such as your User Name, activity, or reminders from Eldorado, may also be visible to other individuals who use the computer after you.
8.3.If you use a message board, blog, or chat room on the Site, you should be aware that any personally identifiable information you submit there may be read, collected, or used by other Users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.
9. Using Information from the Site
9.1. The Site enables you to share financial and Personal Information (such as the name of your in-game character) to complete transactions and collect payments. We encourage you to disclose your privacy practices and respect the privacy of other Users. We cannot guarantee the privacy or security of your information and therefore we encourage you to evaluate the privacy and security policies of your trading partner before entering into a transaction and choosing to share your information. To help protect your privacy, we allow only limited access to other Users' contact, shipping and financial information to facilitate your transactions and collect payments. When Users are involved in a transaction, they may have access to each other's name, User ID, email address and other contact and shipping information. In all cases, you must give other Users a chance to remove themselves from your database and a chance to review what information you have collected about them.
9.2.You agree to use User information only for:
Site’s transaction-related purposes that are not unsolicited commercial messages; or
Using services offered through the Site (such as fraud complaints); or
Other purposes that a User expressly chooses.
10. Cookies, Web Beacons, and Similar Technologies
10.1.The Site uses cookies and other technologies that are essentially small data files placed on your computer, tablet, or mobile phone (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools. The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. In order to help you better understand this Policy and our use of such technologies, we have provided the following definitions:
Cookies: Small text files placed in the memory of your browser or device when you visit a website or view a message. Cookies allow us to recognize a particular device or browser.
Web beacons: Single pixel image files that allow a website to count Users who have visited a particular page or accessed certain cookies. Web beacons may be placed on specific pages across the Site. When a visitor accesses these pages, a notice of that visit is generated which may be processed by Eldorado or by our vendors. These web beacons work in conjunction with cookies.
Service providers: Companies that help Eldorado with various aspects of our business, such as site operations, services, applications, advertisements and tools. We use some authorized service providers to help us to serve you relevant ads on our services and other places on the Internet. These service providers may also place cookies on your device via our services (third party cookies). They may also collect information that helps them identify your device, such as IP-address, ID for Advertising (IDFA), or other unique or device identifiers.
10.2.When you visit or interact with our Site, services, applications, tools, or messaging, we or our authorized service providers may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, and safer experience.
10.3. The Site uses cookies to:
Allow you to enter your password less frequently during a session;
Provide information that is targeted to your interests;
Promote and enforce trust and safety;
Offer certain features that are only available through the use of cookies;
Measure promotional effectiveness.
10.4. You are free to block, delete, or disable Cookies and similar technologies if your device so permits. You can manage your cookies and your cookie preferences in your browser or device settings. In addition, if you do not want to associate your anonymous cookie information with your visits to pages containing web beacons, depending on the browser used, you can set your browser to turn off cookies.
10.5. Keep in mind that if you decline cookies or other similar technologies, you may not be able to take advantage of certain Site features, services, applications, or tools. You may also be required to re-enter your password more frequently during your browsing session. For more information on how you can block, delete, or disable these technologies, please review your browser or device settings.
11. No Spam, Spyware, Phishing, or Spoofing
11.1.We do not tolerate spam. You are not licensed to contact other Site’s Users or add them to a mail list (email or physical) without their express consent. In addition, you may not use our communication tools to send spam or otherwise send content that would violate our Terms of Service. We may automatically scan and/or manually filter messages to check for spam, viruses, phishing attacks, and other malicious activity or illegal or prohibited content. To report spam or spoof emails related to the Site, please forward the email to [email protected].
11.2.Eldorado may, but is not obligated, to send you strictly service-related announcements on occasions when it is necessary to do so. For example, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications since they are not promotional in nature and are necessary to maintain the quality of our service. If you do not wish to receive them, you may have the option to deactivate your account.
12. Account Protection and Security
12.1. Your information is stored on our servers. We protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use include firewalls, data encryption, and information access authorization controls. However, it is possible that third parties may unlawfully intercept or access transmissions or private communications, and other Users may abuse or misuse your Personal Information that they collect from the Site. Therefore, although Eldorado works very hard to protect your privacy, we do not guarantee, and you should not expect, that your Personal Information or private communications will always remain private.
12.2. Data Breach Response. If ever an unauthorized person or entity obtains access to any of our customers Personal Information, Eldorado will notify all affected customers and relevant government authorities within 72 hours after having become aware of such breach.
12.3.Your password is the key to your account. Use unique numbers, letters, and special characters and do not disclose your Account password to anyone. If you do share your password or your Personal Information with others, remember that you are responsible for all actions taken and financial commitments made in the name of your account. If you lose control of your password, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify Eldorado and change your password.
12.4.Upon your request, we will close your account and remove your Personal Information from view as soon as reasonably possible, based on your account activity and in accordance with applicable law. We do retain Personal Information from closed accounts in order to comply with state and federal laws, deter fraud, collect any outstanding debts, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and Policies, and take other actions otherwise permitted by law. Over time, Eldorado may no longer have an ongoing legitimate business need to process your personal information. At that time, we will either delete your personal information or anonymize it.
13. Accessing, Reviewing and Changing Your Personal Information
13.1. We take steps to ensure that the Personal Information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. You can see, review and change most of your Personal Information, including opt-in and opt-out communications preferences, by logging in to your Account. Generally, we will not manually modify your Personal Information. You must promptly update your Personal Information if it changes or is inaccurate. Once you make a public posting, you may not be able to change or remove it.
13.2.At any time, you can request information about the personal data we collect, request that we correct personal data, or request that we stop processing your personal data in certain ways. To contact us about these rights, please send an email to [email protected].
14. Applicable Laws
14.1. Eldorado will protect your Personal Information in accordance with the laws of the Republic of Lithuania. In addition, data privacy laws of the European Union, including the General Data Protection Regulation, apply to EU citizens and transactions that occur within EU member states.
14.2.If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is supervised by State Data Protection Inspectorate of the Republic of Lithuania, registered office at A. Juozapavičiaus St. 6, LT-09310, www.ada.lt.
If you have any questions, comments, or requests related to this privacy policy or the collection, storage, transfer and use of your personal information, please send an email to [email protected].