Privacy Policy

Effective Date: 21/11/2025

1. General Provisions

1.1. This Privacy Policy (hereinafter - the “Policy”) describes how SKYNEX LTD, a company registered in England and Wales under company number 16866353, operating the website https://elysiumskins.com (hereinafter - the “Service”, the “Company”, “we”, “us”, or “our”), collects, uses, stores, shares, and protects personal data of users (hereinafter - the “User”).

1.2. The Company acts as the data controller for the purposes of applicable data protection law. The Company’s registered address is 85 Great Portland Street, First Floor, London, England, W1W 7LT.

1.3. The Company processes personal data in accordance with the applicable laws of the United Kingdom, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. For Users located in the European Economic Area (EEA), personal data is also processed in accordance with the General Data Protection Regulation (EU GDPR), where applicable.

1.4. By using the Service, the User acknowledges that their personal data may be processed in accordance with this Policy. If the User does not agree with this Policy, they must discontinue using the Service.

1.5. The Service is intended only for Users who meet the applicable minimum age requirements set out in the Company’s Terms of Service. By using or registering for the Service, the User confirms that they meet the applicable age requirement.

2. Data We Collect

The Company may collect and process the following categories of personal data:

  • Identification data - Steam ID, username, avatar, email address, and other account-related identifiers.
  • Financial and transaction data - transaction history, payment identifiers, payout-related information, and limited transaction metadata. Payment card or wallet details are processed by third-party Payment Service Providers (PSPs); the Company does not store full card details.
  • Verification and compliance data where applicable, information and documents submitted for identity verification, anti-money laundering, fraud prevention, payout review, or compliance purposes, in accordance with the Company’s KYC and AML Policy.
  • Technical data - IP address, browser type, device type, operating system, cookies, and similar technical identifiers.
  • Log and usage data - login history, account activity, interaction with the Service, and security-related event logs.
  • Support and communication data - communications with customer support, complaints, inquiries, and related correspondence.

The Company only collects personal data that is necessary to operate the Service, provide support, maintain security, meet legal obligations, and improve the Service.

3. Purposes of Processing

    The Company may process personal data for the following purposes:

  • providing access to the Service and its features;
  • creating, maintaining, and securing User accounts;
  • performing contractual obligations, including purchases, sales, exchanges, and related transaction support;
  • processing payments and payouts through third-party PSPs;
  • conducting fraud prevention, risk management, account security, and abuse prevention checks;
  • carrying out verification, compliance, and payout control procedures in accordance with the Company’s KYC and AML Policy;
  • complying with legal, regulatory, tax, accounting, and reporting obligations;
  • improving the functionality, performance, usability, and security of the Service;
  • communicating with Users regarding account matters, service notices, support requests, disputes, and policy updates;
  • protecting the legitimate interests of the Company, where such interests do not override the rights and freedoms of the User.

4. Automated Processing and Profiling

The Company may use automated systems and tools to:

  • detect fraud, abuse, suspicious transactions, and security threats;
  • assess payment, transaction, and payout-related risks;
  • support compliance checks, including AML, sanctions, and fraud prevention screening;
  • protect User accounts and the integrity of the Service.

Such automated processing is used to support security, compliance, and operational decision-making.

Where required by applicable law, the User may have the right to request human review of a decision that significantly affects them.

5. Legal Bases for Processing

The Company processes personal data on one or more of the following legal bases, as applicable:

  • performance of a contract - where processing is necessary to provide the Service, maintain the User’s account, facilitate transactions, or respond to service-related requests;
  • compliance with legal obligations - where processing is required to comply with applicable law, regulation, lawful request, accounting obligations, fraud prevention obligations, or compliance requirements;
  • legitimate interests - where processing is necessary for fraud prevention, service security, risk management, dispute handling, service improvement, and protection of the Company’s business, provided such interests do not override the User’s rights and freedoms;
  • consent - where the User has given consent for specific processing activities, such as optional cookies or certain communications, and such consent may be withdrawn at any time.

6. Data Retention

The Company retains personal data only for as long as necessary for the purposes for which it was collected, including to satisfy legal, regulatory, tax, accounting, security, fraud prevention, dispute resolution, and operational requirements.

Retention periods may include:

  • account data - retained for as long as the account remains active and for a reasonable period thereafter where necessary for legal, security, or operational reasons;
  • transaction and payment-related data - retained for up to 5 years or longer where required by law, regulation, fraud prevention needs, dispute handling, or audit requirements;
  • verification and compliance data - retained in accordance with the Company’s KYC and AML Policy and applicable legal requirements;
  • activity and security logs - retained for as long as reasonably necessary for monitoring, fraud prevention, security, and technical analysis;
  • support communications - retained for as long as necessary to address the request, dispute, complaint, or related legal and operational matters.

After the applicable retention period expires, personal data will be deleted, anonymized, or securely archived where permitted or required by law.

7. Data Sharing

The Company may share personal data with the following categories of recipients where necessary and lawful:

  • Payment Service Providers (PSPs) - for payment processing, payout processing, fraud prevention, payment verification, and related financial operations;
  • identity verification, compliance, and fraud prevention providers - where necessary for KYC, AML, payout controls, sanctions screening, security review, or suspicious activity handling;
  • hosting, cloud, analytics, and IT service providers - to support the operation, maintenance, monitoring, and security of the Service;
  • professional advisers - including auditors, legal advisers, consultants, and compliance specialists;
  • regulators, law enforcement bodies, courts, and competent authorities - where required by law, lawful request, regulatory obligation, or legitimate compliance necessity;
  • other service providers and contractors - where necessary for customer support, technical infrastructure, security, or business operations.

The Company does not sell Users’ personal data to third parties for marketing purposes.

8. Cookies and Tracking Technologies

The Service uses cookies and similar tracking technologies for the following purposes:

  • authentication and session management;
  • website functionality and performance;
  • security and fraud prevention;
  • analytics and service improvement;
  • optional tools or integrations, where applicable and lawfully used.

Where required by applicable law, non-essential cookies will only be used with the User’s consent. Users can manage cookie preferences through the cookie banner, where available, or through their browser settings.

For more detailed information, Users should refer to the Company’s Cookie Policy.

9. User Rights

Subject to applicable law, Users may have the following rights in relation to their personal data:

  • the right to access personal data;
  • the right to rectify inaccurate or incomplete personal data;
  • the right to request erasure of personal data, where applicable;
  • the right to restrict processing in certain circumstances;
  • the right to object to processing in certain circumstances;
  • the right to data portability, where applicable;
  • the right to withdraw consent at any time where processing is based on consent;
  • the right to lodge a complaint with a competent data protection authority.

Requests relating to personal data may be submitted to [email protected].

10. Withdrawal of Consent

Where processing is based on the User’s consent, the User may withdraw that consent at any time by contacting the Company at [email protected] or by using the relevant privacy controls, where available.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. It also does not affect processing carried out on legal bases other than consent.

11. Data Security

The Company implements appropriate technical and organizational measures designed to protect personal data.The Company implements appropriate technical and organizational measures designed to protect personal data against unauthorized access, misuse, disclosure, alteration, loss, or destruction. Such measures may include:

  • encryption of data in transit where appropriate;
  • access controls and internal access limitations;
  • system monitoring and security controls;
  • backups and resilience measures;
  • fraud prevention and abuse detection tools;
  • internal procedures for incident response and breach handling.

No method of storage or transmission is completely secure. However, the Company takes reasonable steps to protect personal data in accordance with applicable law and industry practice.

12. International Data Transfers

Where personal data is transferred outside the United Kingdom or the EEA, the Company will take appropriate steps to ensure that such transfers are carried out in accordance with applicable data protection law. Such safeguards may include:

  • adequacy regulations or adequacy decisions;
  • standard contractual clauses;
  • international data transfer agreements;
  • other lawful transfer mechanisms recognized under applicable law.

13. Children

The Service is not intended for individuals who do not meet the applicable minimum age requirements under the Company’s Terms of Service.

The Company does not knowingly collect personal data from children below the applicable minimum age. If the Company becomes aware that such personal data has been collected inadvertently, it will take reasonable steps to delete it.

Parents or guardians who believe that a child has provided personal data to the Service may contact the Company at [email protected]

14. Contact Information

SKYNEX LTD

Company number: 16866353

Registered address: 85 Great Portland Street, First Floor, London, England, W1W 7LT

Tel: +44 748 884 8326

Email: [email protected]

Website: https://elysiumskins.com

Users may contact the Company regarding privacy matters, data protection requests, or this Policy by email at [email protected].

15. Changes to this Policy

The Company reserves the right to amend, update, or revise this Policy at any time.

Any updated version will be published on the Service with the effective date clearly stated. Continued use of the Service after publication of an updated version constitutes the User’s acknowledgment of the revised Policy.