Privacy Policy

This Privacy Policy explains how F.N. FACTORY NEW TECHNOLOGIES LTD ("JungleSkins", "we", "us" or "our") collects, uses, shares and protects personal data when you use the website jungleskins.io, including the pre-launch page and its waitlist (the "Site"), and what rights you have. We process personal data in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679, the "GDPR") and the data protection law of the Republic of Cyprus.

1. Who we are

The controller of your personal data is F.N. FACTORY NEW TECHNOLOGIES LTD, a company registered in the Republic of Cyprus under registration number HE 497685, with its registered office at MITSI BUILDING 3, Floor 2, Flat/Office 206, Archiepiskopou Makariou III 1-7, 1065 Nicosia, Cyprus.

For any question about this policy or your personal data, or to exercise your rights, email [email protected] with "Privacy" in the subject line, or write to us at the address above.

2. The personal data we collect

Steam account data

You sign in with Steam. Steam confirms your Steam ID to us; we never see your Steam password. We then obtain your public Steam profile name and avatar from Steam, and we refresh them each time you sign in.

Data you give us

• Your confirmation at sign-in that you are 18 or older (or of legal age where you live) and that you accept our Terms of Use and this Privacy Policy. We record the version you accepted, the time and the IP address used.
• Your Steam trade URL, which you provide so that we can exchange trade offers with you for skin deposits and withdrawals.
• If you add balance with a payment method, the email address you give at checkout, to which we send the confirmation of your purchase.
• Any referral code you apply, and any giveaway you create, including social media links you add to it.
• The messages you send to our support team and the information in them.
• If we ask you to verify your identity under our AML Policy: your identity document, a selfie, proof of address and, where requested, information about the source of your funds or wealth. Without requested verification data we may not process withdrawals.

Account, transaction and game data

We record your use of the Site to provide it and keep it secure, including:

• your balance and transaction history: skin deposits, case openings, case battles, Upgrader and Slide play, sales, exchanges, withdrawals, XP purchases, rewards, giveaways, leaderboard results and referral commissions or bonuses;
• your inventory, including the items you hold and their values;
• your level and XP, favourite cases and the provably fair seeds used for your games;
• for skin deposits and withdrawals: the Steam asset IDs of the items, trade offer details and the Steam IDs of the trading accounts involved; and
• account controls, such as restrictions, reviews of withdrawals and notes made by our staff.

Technical and security data

• When you sign in, we record the IP address and browser user agent used, together with the time the session was created, when it was last active and when it expires. You can see your signed-in devices in the Security section of your profile.
• For some game actions, we store the IP address of the request with the transaction record.
• Our servers keep logs of the requests made to them, which include the IP address, browser user agent, requested address and time.

Waitlist (pre-launch page)

If you join the waitlist, we collect your email address, which form you used, the country that our hosting provider derives from your IP address, and the time you signed up. Your IP address is used only to limit repeated sign-ups and is not stored with your waitlist entry.

Data we do not collect

We do not ask for your real name, postal address, phone number or date of birth (unless you are asked to verify your identity), and we do not receive your full payment card details. We do not use analytics or advertising cookies, tracking pixels, social media plugins or device fingerprinting. Payment providers may collect device data on their payment pages to prevent fraud.

3. Why we use your data and our legal bases

• To record your age confirmation and your acceptance of our Terms of Use and this Privacy Policy. Legal basis: performance of our contract with you (Article 6(1)(b)) and our legitimate interest in proving your acceptance and age confirmation (Article 6(1)(f)).
• To provide the Site and your account (signing in, your balance, games, inventory, sales, exchanges, deposits and withdrawals, and customer support). Legal basis: performance of our contract with you (Article 6(1)(b) GDPR).
• To show other users your public profile and results (see section 4). Legal basis: performance of our contract with you, as these are social features of the Site, and our legitimate interest in operating them (Article 6(1)(f)).
• To keep the Site and your account secure and to prevent fraud and abuse, including detecting multiple accounts, collusion, chargebacks and reversed trades, and reviewing withdrawals. Legal basis: our legitimate interests in protecting the Site, our users and our business (Article 6(1)(f)).
• To comply with legal obligations, including anti-money laundering and sanctions requirements, accounting and tax law, and requests from competent authorities. Legal basis: compliance with a legal obligation (Article 6(1)(c)) and, where a measure is not strictly required by law, our legitimate interest in preventing financial crime (Article 6(1)(f)). Staff compare your selfie with your document by eye; we use no facial recognition.
• To remember your preferences, such as your language and display currency. Legal basis: our legitimate interest in providing the Site as you have set it up (Article 6(1)(f)).
• To manage the waitlist and send you one email when the Site opens. Legal basis: your consent (Article 6(1)(a)), which you can withdraw at any time.
• To establish, exercise or defend legal claims. Legal basis: our legitimate interests (Article 6(1)(f)).

We do not send marketing messages to players and we do not sell your personal data.

Automated checks

Every withdrawal is checked automatically against your account's withdrawal allowance, which caps the total value the account can withdraw. A withdrawal above it is held for manual review by our staff; the check does not on its own refuse a withdrawal or close your account. You can ask us to explain or reconsider any decision about your account.

4. What other users can see

Other users and visitors to the Site can see your Steam profile name and avatar with your results in the live drops feed, case battles, Slide rounds, giveaways and leaderboards. Your public profile shows your name, avatar, level, XP and the date you joined ("Member since"). If you create a giveaway, its details, including any social media links you add, are public. You can change your Steam name and avatar on Steam; we update them the next time you sign in.

5. Who we share your data with

We share personal data only as needed for the purposes above:

• Valve Corporation (Steam). We use Steam for sign-in, to obtain your public profile, and to send and receive trade offers. Valve processes this data as an independent controller under its own privacy policy.
• Our CS2 item trading partner, which supplies and receives skins and sends the Steam trade offers for deposits and withdrawals. It receives your Steam trade URL, the asset IDs and values of the items and an internal reference for the transaction. It is located in the United States. We transfer this data to it because the transfer is necessary to deliver the items you ask us to withdraw or accept as deposits (Article 49(1)(b) GDPR).
• Infrastructure providers, which host the Site, its databases and logs and provide network security, including Cloudflare, which provides content delivery, DNS and protection against attacks for the Site and hosts the pre-launch page and its waitlist. They act as our processors under written contracts.
• Image hosts. Steam avatars and item images are loaded by your browser directly from Steam's content delivery network and from other image hosts, which receive your IP address and browser information as part of the request.
• Payment service providers. If you add balance with a payment method, the payment service provider processes your payment details under its own terms and privacy policy. We receive confirmation of the payment, its amount and a transaction reference.
• Authorities, advisers and others where the law requires it, including law enforcement, regulators, the Unit for Combating Money Laundering (MOKAS) and courts; our professional advisers and auditors; and a buyer or successor of our business in the event of a merger, acquisition or reorganisation.

6. International transfers

Some of our service providers, including those that host the Site, process personal data outside the European Economic Area, including in the United States. Except for the transfer to our item trading partner described above, when we transfer personal data outside the European Economic Area, we rely on an adequacy decision of the European Commission (including the EU-US Data Privacy Framework, where the recipient is certified under it) or on the European Commission's standard contractual clauses. You can ask us for a copy of the relevant safeguards.

7. How long we keep your data

• Account, transaction and game data, acceptance records and session records: for as long as your account is open and for five years after it is closed, so that we can meet our anti-money laundering, accounting and tax obligations and deal with legal claims, or longer where the law requires.
• Verification data: for five years after the end of our business relationship with you, or longer where the law or a competent authority requires it.
• Server logs: for up to 90 days, unless we need them longer to investigate a specific security incident.
• Support messages: for up to two years after your request is resolved, unless they are part of your account records.
• Waitlist: until we send the launch email, after which we delete the waitlist within 90 days; earlier if you ask us to remove you.

When we no longer need personal data, we delete or anonymise it.

8. Cookies and local storage

We use only cookies and browser storage that are needed for the Site to work or to remember choices you make. We do not use analytics or advertising cookies, so we do not ask for cookie consent. If this changes, we will ask for your consent first.

• player_session (cookie): keeps you signed in. It holds an opaque reference to your session and expires when the session ends: after 30 days without activity and at most 90 days after you sign in.
• NEXT_LOCALE (cookie): remembers your language. Expires after one year.
• display_currency (cookie): remembers the currency in which you prefer to see prices. Expires after one year.
• Local storage: your sound settings, your saved Slide targets and when we last showed you the sign-up offer. Session storage: the page to return to after you sign in with Steam. On the pre-launch page, local storage remembers that you have joined the waitlist.

Cloudflare, which protects the Site, may set strictly necessary security cookies to distinguish people from automated traffic. You can block or delete cookies in your browser settings, but if you block the session cookie you will not be able to sign in.

9. Your rights

Under the GDPR, you have the right to:

• access the personal data we hold about you and receive a copy of it;
• have inaccurate data corrected;
• have your data erased, where there is no longer a legal ground for us to keep it;
• restrict our processing of your data in certain circumstances;
• receive the data you provided to us in a structured, machine-readable format and have it transmitted to another controller (data portability);
• object to processing based on our legitimate interests;
• withdraw your consent at any time, where we rely on consent, without affecting processing carried out before you withdraw it; and
• not be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

To exercise your rights, email [email protected]. We may ask you to confirm that you control the Steam account linked to your JungleSkins account before we act on your request. We respond within one month, which we may extend by two further months for complex requests; we will tell you if we do. Some data must be kept for legal reasons even if you ask us to delete it, as described in section 7.

10. Complaints

If you are not satisfied with how we handle your personal data, please contact us first. You also have the right to lodge a complaint with a supervisory authority, in particular in the EU country where you live or work or where the alleged infringement took place. Our lead supervisory authority is the Commissioner for Personal Data Protection of the Republic of Cyprus:

• Office of the Commissioner for Personal Data Protection, 15 Kypranoros Street, 1061 Nicosia, Cyprus (P.O. Box 23378, 1682 Nicosia)
• Email: [email protected]
• Telephone: +357 22 818 456
• Website: www.dataprotection.gov.cy

11. Security

We protect your personal data with appropriate technical and organisational measures. The Site is served only over encrypted connections (HTTPS), your session is held in a cookie that scripts on the page cannot read, and access to personal data is limited to authorised staff who need it. No transmission over the internet is completely secure, however. The security of your account also depends on you: keep your Steam account secure, enable Steam Guard, and contact us immediately if you believe your account has been compromised.

12. Children

The Site is only for people aged 18 or over. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we will close the account and delete the data, except where the law requires us to keep it. If you believe that we hold data about someone under 18, contact us at [email protected].

13. Changes to this policy

We may update this policy from time to time. We will post the updated policy on the Site and change the "Last updated" date above. If we make material changes, we will tell you on the Site before they take effect.

14. Contact

F.N. FACTORY NEW TECHNOLOGIES LTD, MITSI BUILDING 3, Floor 2, Flat/Office 206, Archiepiskopou Makariou III 1-7, 1065 Nicosia, Cyprus. Email: [email protected].