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> tracer/legal/privacydoc · PRV-01
LEGAL // PRIVACY POLICY

Privacy Policy

> last updated 2026-09-29 · operated by TRAFFIXORA OÜ · registry code 17543319 · Maakri tn 19/1, 10145 Tallinn, Estonia

1.

data controller

TRAFFIXORA OÜ (registry code 17543319), Maakri tn 19/1, 10145 Tallinn, Estonia ("TRACER") is the data controller. Contact: privacy@tracer.auction.

2.

what we collect

datasourcepurpose
Steam ID, display nameSteam OpenIDAccount creation & auth
Email addressEmail sign-in / onboardingSign-in codes, receipts, support
Trade URLOnboarding formSkin delivery via Steam
Discord handleOptional inputSupport escalation
IP address, connection country, user agentAutomaticSecurity, fraud prevention & sanctions checks
Payment reference (card handled by provider)Payment providerWallet top-ups (once card payments are live)
Legal name, ID document, addressSeller verification (KYC)Identity checks before seller payouts
Bank details (holder, IBAN, BIC, bank country)Seller verification (KYC)Seller payouts by bank transfer
Order historyPlatform activityService delivery & disputes
3.

how we use your data

  • ▸Process purchases and deliver items
  • ▸Send transactional emails (receipts, trade updates)
  • ▸Prevent fraud and meet legal record-keeping and anti-money-laundering obligations
  • ▸Refuse access to the site, sign-up and sign-in from Russia, Belarus, Iran, North Korea, Syria, Cuba, based on the country of your connection, and refuse new accounts for email addresses registered there (sanctions compliance)
  • ▸Improve the platform (anonymous analytics only)
4.

data sharing

  • ▸TM Market (market.csgo.com) — the supplier that fulfils catalogue purchases. Receives your Steam trade URL (which contains your Steam account number and trade token) and the item you bought, so the seller can send it to you.
  • ▸DMarket — only for items listed by TRACER users: the seller's Steam ID and trade URL when the item is deposited into our custody account. Item names are also sent to DMarket to look up recent sale prices, with no personal data.
  • ▸Payment provider — to process card top-ups once they are live (card data goes to the provider, not to us)
  • ▸Law enforcement — when required by law

We never sell, rent, or share your data for advertising purposes.

Identity documents submitted for seller verification are stored privately. They are never published at a public web address, and only authorised staff reviewers can open them, through a signed-in staff account.

5.

data retention

Account data is retained while your account is active. Order records are kept for 7 years for legal record-keeping compliance. You can request deletion at any time — we will erase all non-legally-required data within 30 days.

6.

your rights

  • ▸Access — request a copy of your data
  • ▸Rectification — correct inaccurate information
  • ▸Erasure — delete your account and data
  • ▸Portability — export your data in machine-readable format
  • ▸Objection — opt out of non-essential processing

You may also lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee), our lead supervisory authority, or with the data protection authority in the EU country where you live.

Email privacy@tracer.auction to exercise any right. We respond within 30 days.

7.

cookies

See our Cookie Policy for details on what cookies we use and how to manage them.

8.

changes

We will notify you of material changes via email 14 days before they take effect.