Effective Date: 7th April 2026
Privacy Summary
At 99 HP Tech Limited, operator of Skins.com, your privacy is our priority. We collect only the personal data we need to provide our services, keep your account secure, and meet legal requirements. We never sell your information. You have the right to access, correct, or delete your data, and to control how it’s used. We protect your information with strong security measures and only share it with trusted partners or authorities when required by law. For full details, please read the policy below.
1. Introduction
This Privacy Policy (“Policy”) sets out how 99 HP Tech Limited (“we”, “our”, “us”), a company incorporated in Hong Kong and operator of Skins.com, collects, uses, stores, and discloses personal data.
We are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and, where applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the UK GDPR, and other relevant laws. Depending on your country of incorporation or residency there may be other data protection legislation applicable to you.
The term “Personal Information” in this Privacy Policy refers to personal data as defined under the GDPR and GDPR UK, ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Your use of Skins.com constitutes your acknowledgment that you have read and understood this Policy.
2. Categories of Personal Data Collected
Certain categories of personal information we collect are deemed sensitive data, such as biometric information or financial account information. Skins.com would obtain consent prior to collecting this category of personal information.
In order to provide our services to you, we may collect, hold and process some or all the following personal data:
Identification Data: full name, date of birth, nationality, government-issued ID details.
Contact Data: email address, phone number, postal address.
Account & Transaction Data: username, password, activity, purchase history, trade records.
Financial Data: payment card details, bank account information.
Technical Data: IP address, device identifiers, browser type, operating system, cookies, and similar technologies. For more details on our use of cookies and similar technologies, please see our Cookie Policy
Communications Data: customer support interactions, chat logs, and correspondence.
We may also collect information about you from affiliates (by ‘affiliates’ we mean other companies that Skins.com has a contractual relationship with) who provide us with services such as ‘name screening’ and biometric data (your image in a photo and video form, your voice (as part of our Know Your Client (KYC) checks. We may also make recordings of any video calls we hold with you) to help verify your identity which in turn allows us to improve the safety of our services. This includes being able to detect and respond quickly to any fraud or security risks.
Skins.com our marketing partners, or analytics or service providers, use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer and track users’ movements around websites and applications, and gather demographic information about Skins.com user base, with respect to the following purposes:
To assist Skins.com in providing Services to you.
To store your preferences and other information and to track activity on the Skins.com platform.
To better understand the effectiveness of Skins.com promotional campaigns.
To deliver information specific to your interests on additional web sites.
Skins.com may receive individual as well as aggregated customer reports based on the use of these technologies by these partners or service providers.
3. Purposes of Processing
We process personal data for the following purposes:
Account registration and administration, including but not limited to “Know Your Customer” and customer due diligence procedures, authentication, and management.
Provision of services, including in-game item trading and marketplace operations.
Payments and settlement. Vilnius IT Solutions, UAB, a company registered in Lithuania, company registration number 304988128 is responsible for receiving Buyers payments, maintaining User’s balance, payouts to Suppliers, calculating and remitting applicable taxes (including VAT), handling chargebacks, refunds, and transaction‐related disputes.
Compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) obligations.
Fraud detection, prevention, and investigation.
Marketing and promotional communications (subject to consent).
Analytics, service improvement, and product development.
4. Legal Basis for Processing (where GDPR and GDPR UK are applicable)
We must have a legal basis (a valid legal reason) for using your personal data. Under GDPR and GDPR UK our legal basis will be one of the following:
Performance of a contract with you.
Compliance with legal obligations to which we are subject.
Legitimate interests pursued by us or a third party, provided such interests are not overridden by your rights.
Consent, where required by law (e.g., for marketing).
5. Does Skins.com make automated decisions about me?
We may use automated systems to make decisions about you in connection with fraud prevention, anti-money laundering (AML), and counter-terrorist financing (CTF) obligations. These systems analyze transaction patterns, identity verification data, and other relevant information to detect suspicious activity and ensure compliance with applicable laws.
Where such decisions have a legal or similarly significant effect on you, you have the right to request human intervention, express your point of view, and contest the decision. You can do so by contacting us at privacy@skins.com.
Automated decision-making is essential to maintaining the integrity and security of our platform, and we apply safeguards to ensure fairness, accuracy, and transparency in these processes.
6. Third parties
Skins.com may partner with a third party to either display advertising in the Skins.com application or on the Skins.com website, or to manage Skins.com advertising on other sites. Skins.com third party partners may use technologies such as cookies to gather information about your activities while using the application or website and other sites to provide you advertising based on your browsing activities and interests.
In addition, Skins.com automatically gathers and stores in log files certain information, such as Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Skins.com does not link this automatically collected data to other information we collect about you. Skins.com as well as our third-party partners may use local storage to store content information and preferences.
Our network infrastructure involves computers, cloud-based servers, and third-party service providers in multiple jurisdictions. The Personal Information that Skins.com collects from you may be transferred to, and stored at, a destination outside of Hong Kong. It may also be processed by persons operating outside of Hong Kong on behalf of Skins.com, our affiliate(s), or one of our service providers, providing transaction processing, payment detail verification, as well as other Services-related support.
We take commercially reasonable steps to protect your Personal Information in line with this Privacy Policy, whether it is handled inside or outside Hong Kong. Our Services may not be appropriate or available in all jurisdictions. By using the Services or providing your Personal Information, you agree that it may be transferred to, stored in, and processed in countries outside Hong Kong, which may have different data protection laws from your own.
7. Skins.com Browser Extension
We may offer a browser extension to support certain marketplace features, including trade tracking, trade verification, and account/session connectivity for users of the Skins.com platform. The extension is intended solely to help users monitor and verify trades across supported Skins.com and Steam-connected workflows.
If you choose to install and use the browser extension, we may collect and process only the limited data necessary to provide those features, such as:
account and session status relating to our services, including whether you are logged in;
trade-related information required to identify, display, and update active trade status and verification workflows;
limited Steam page data and Steam session or authentication state strictly required to support Steam-connected trading features; and
local extension data stored in your browser, such as connection state, cached session details, and active trade records.
This information is used only for the purposes of:
detecting account and session status;
enabling trade tracking and trade verification features;
displaying the extension interface on supported pages;
synchronizing trade and connection status with Skins.com services; and
maintaining extension functionality across browser sessions.
The browser extension does not collect more information than is necessary for these purposes. In particular, it is not used to collect unrelated browsing history, the contents of unrelated websites, keystrokes, passwords, card details, or personal communications.
Data collected through the extension is not sold or shared with third parties and is used only by us to operate, maintain, and improve trade tracking and related extension functionality across the platform.
The extension may communicate with our servers, including real-time services, in order to retrieve or update trade status, verification status, and connection state. The extension does not download or execute remote code. All executable extension code is packaged and delivered as part of the extension installation or update.
Where required for its functionality, the extension may request browser permissions such as host access, cookies access, scripting access, storage access, and alarm-based background processing. Such permissions are used solely in connection with the extension’s stated trade tracking, trade verification, and session-management features.
You may stop this processing at any time by disabling or uninstalling the browser extension. Once disabled or removed, the extension will no longer have access to the browser-based data required to support extension-dependent features. As a result, we may not be able to continue providing full access to certain services or functionality, including trade tracking, trade verification, and other Steam-connected marketplace features.
8. Data Sharing and International Transfers
We may share personal data with:
Third-party service providers under binding confidentiality agreements.
Payment processors, banks, and financial institutions.
Regulatory bodies, law enforcement agencies, and courts.
Affiliates and subsidiaries.
The merchant, Vilnius IT Solutions, UAB, a company registered in Lithuania, acts as the data controller for payment information and processes personal data in accordance with Lithuanian law, the EU General Data Protection Regulation (GDPR), and other applicable data protection laws. Skins.com (99 HP Tech Limited), incorporated in Hong Kong, continues to operate and maintain the marketplace platform, provide technology infrastructure, and oversee governance and compliance strategy, but does not act as Merchant or hold customer funds.
Where data is transferred outside Hong Kong, we ensure appropriate safeguards are in place, such as contractual clauses or equivalent legal protections. If this is not possible, for example because we are required by law to disclose information, we will ensure the sharing of that information is lawful.
For UK and EEA residents only: As we provide an international service, it may be necessary to transfer your personal data outside the United Kingdom or the European Economic Area (EEA) to deliver our services.
For example, we may transfer your personal data to meet global legal and regulatory obligations, or to provide ongoing support services. This may include sharing your personal data with fraud-prevention agencies, partner banks, and marketplaces based outside the United Kingdom or EEA.
We will take all reasonable steps to ensure that your personal data is handled securely and in accordance with this Privacy Policy and applicable data protection laws.
9. Personal Data Breach
If we become aware of a personal data breach, meaning any unauthorized access to, loss, or disclosure of personal data, we will assess the potential impact on your rights and freedoms. If the breach is likely to result in significant risk (whether physical, material, or non-material), we will notify the relevant data protection authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach.
If notification cannot be made within 72 hours, we will document the reasons for the delay and submit the notification as soon as possible thereafter. Where required by law, we will also inform affected individuals and provide details about the nature of the breach, the steps we are taking, and how they can protect themselves.
10. Data Retention
The amount and type of information collected by Skins.com will be limited to that which is necessary to provide Skins.com Services, and the information shall be retained only for as long as may be necessary for the fulfilment of the purpose for which the information is collected.
We retain personal data for as long as necessary to fulfil the purposes outlined in this Policy or as required by applicable law. For example, certain transaction records may be retained for at least five years to comply with PDPO and AML obligations.
11. Data Subject Rights
Subject to applicable law, you have the right to:
Access your personal data.
Request correction or deletion of your personal data.
Object to processing or request restriction of processing.
Withdraw consent at any time (where processing is based on consent).
Request data portability.
Requests should be submitted to our Data Protection Officer (see Section 10).
12. Children’s privacy
The platform, application, and Services are not directed at or intended for use by children under the age of 18. Skins.com will not knowingly collect or maintain Personal Information from children under the age of 18. If we obtain actual knowledge that we have collected Personal Information from a child under the age of 18, we will promptly delete it, unless we are legally required to retain such information.
13. Security Measures
We implement technical and organizational measures to protect personal data, including:
Encryption in transit and at rest.
Secure storage systems.
Access controls and authentication protocols.
Regular security audits and monitoring.
14. Changes to This Policy
We may update this Policy from time to time. The latest version will be posted on Skins.com with the effective date.
15. Contact Information
Data Protection Officer
privacy@skins.com
99 HP Tech Limited
UNIT 2A, 17/F Glenealy Tower
No.1 Glenealy Central
HONG KONG SAR
Vilnius IT Solutions, UAB
Ateities g. 31B -101
LT-06326, Vilnius
Lithuania