Privacy Policy

PRIVACY POLICY AND DATA PROCESSING STATEMENT

Last Updated: April 2026

1. Introduction and Scope

This Privacy Policy ("Policy") outlines the data practices of Trade Frogs LLC (hereinafter referred to as "The Entity," "we," "us," or "our") concerning the collection, utilization, storage, and disclosure of Personal Information gathered through our suite of digital products and services, including our primary website (e.g., www.tradefrogs.com) and associated online platforms (collectively, the "Services").

By accessing or utilizing our Services, you acknowledge that you have read, understood, and consented to the terms set forth in this Policy. Should you disagree with any part of this document, you must immediately cease all engagement with our platform. This Policy is limited to the data processing activities of The Entity and does not govern the practices of third parties or entities not owned or controlled by us.

2. Information We Collect and Methods of Collection

We obtain Personal Information from three primary categories of sources: information you provide directly, data obtained from third parties, and information collected automatically.

A. Information Provided Directly by You

We collect data that you or your authorized agents furnish to us when engaging with our Services or our third-party service providers (e.g., Stripe):

1. Account Registration and Contact Details: Your electronic mail address and cellular telephone number when establishing a user profile on our platform.
2. Identity Verification (KYC): For the explicit purpose of fraud mitigation and security, we require you to complete a Know Your Customer (KYC) procedure through our designated service provider (e.g., Stripe). This process entails the collection of a copy of your identity documentation and a live facial scan.
   • Biometric Data: Accordingly, we collect and process biometric information—specifically, your facial geometry—derived from your identity document and scan, which serves as a unique identifier. This data is processed solely for fraud prevention and is neither shared nor sold to other third parties for their independent use.
3. Transaction Details: Information concerning the digital assets or items you propose to trade, purchase, or sell, as well as the trade offers you issue or receive.
4. Financial and Payment Data: Details necessary to finalize transactions, including credit/debit card numbers, crypto wallet addresses, and related cryptocurrency details, collected via our payment processor (e.g., Stripe).
5. Affiliate Program Participation: Data necessary for the administration of the Affiliate Program, including your email address, details regarding your social media accounts (such as content focus and follower count), payment processing information for earnings disbursement, and metrics related to referred users and associated transactions.
6. Support and Communication: Any content, inquiries, or information (including Steam Account details when relevant) shared when creating a support ticket or contacting us via email.

B. Information Gathered from Third-Party or Public Sources

1. Steam Integration: When you utilize your Steam account to log into our Services, we receive a unique numeric identifier that links us to your Steam Community Profile. Based on your Profile Privacy Settings, this integration allows us to collect data such as your profile name, avatar, background images, location, public name, friends list, Steam Level, group memberships, showcases, comments, and game-related details (e.g., owned games, play time, achievements, and your in-game status in games like CS2).
2. Social Media Interaction: When you visit or engage with our official pages on third-party platforms (e.g., Discord, X, Google), we may receive information such as your profile name, reactions, and comments. The privacy policies of these platform providers govern their data collection practices.
3. Public Records and Sources: We may collect supplemental Personal Information from publicly accessible sources, including governmental agencies, public information databases, or industry groups, and may combine this information with the data we already possess.

C. Automatically Collected Technical Information

Through the use of cookies and similar tracking technologies, we and our partners may automatically log information regarding your device, browser, and activity on our Services:

• Device and Network Data: IP address, general geographic location (e.g., city/state), operating system type and version, device manufacturer and model, browser type, and screen resolution.
• Usage Data: The referring website, pages viewed, engagement duration and frequency, search history, and settings within the Services.

3. In-Game Communication Disclaimer

The Entity explicitly states that we do not monitor or record your in-game communications, including voice or text chats, within the Counter-Strike 2 (formerly CS:GO) game environment. Accordingly, we bear no responsibility or liability for content generated through such communications, even if related to transactions on our platform.

4. How We Utilize Personal Information (Purposes of Processing)

We process your Personal Information for the following legitimate business purposes:

1. Provision of Core Services: To process transactions, manage and administer your account, offer technical support, respond to inquiries, and manage the Affiliate Program.
2. Security and Risk Mitigation: To actively monitor, detect, and prevent fraudulent activity, improper behavior, and illegal activities.
3. Service Enhancement and Customization: To analyze usage trends, monitor website traffic, personalize your user experience, recognize your preferences, and continuously improve our service offerings.
4. Marketing and Promotion: To transmit special offers, promotional materials, service updates, and survey invitations, subject to your required consent.
5. Protection of Rights and Interests: To enforce our Terms of Service, defend against legal claims, and safeguard the rights and property of The Entity, our users, and third parties.
6. Regulatory and Legal Compliance: To adhere to all applicable laws, court orders, regulatory obligations, and requirements related to litigation or investigations.

5. Disclosure and Sharing of Personal Information

We do not engage in the sale of your Personal Information to third parties for their direct marketing benefit. We disclose or share data only when necessary and for the purposes delineated in this Policy:

• Corporate Affiliates: Sharing of data with our parent company, subsidiaries, or other companies within The Entity's corporate family for operational management.
• External Service Providers: Sharing necessary information (which may include contact details, transaction data, and biometric information) with vendors that perform tasks on our behalf, such as identity verification, payment processing, data hosting, IT support, and customer service.
• Business Partners and Advertisers: Certain partners are authorized to deploy tracking technologies (cookies) on our Services. This allows them to collect data related to your browser/device interaction to deliver relevant advertisements, as detailed in our Cookie Notice. (Except for this type of sharing, we do not sell any of your information.)
• Professional Advisors: Disclosure to our professional consultants, including legal counsel, auditors, and accountants.
• Law Enforcement and Government Entities: Disclosure in response to lawful subpoenas, court orders, or requests from regulatory agencies or law enforcement, or to prevent illegal or harmful activity.
• Corporate Restructuring: In the event of a merger, acquisition, sale of assets, or bankruptcy, your Personal Information may be transferred as part of the business assets. The acquiring entity remains bound by the provisions of this Policy.

6. Data Retention Policy

We retain Personal Information only for the duration reasonably necessary to fulfill the purposes described herein and to comply with our legal, accounting, and regulatory obligations.

• Biometric Data Retention: Notwithstanding other provisions, biometric information is retained for a maximum period of three (3) years following your last interaction with us.
• We take reasonable measures to delete information once its intended purpose or any applicable legal retention requirement has expired.

7. Your Privacy Rights

Depending on your jurisdiction (e.g., California, UK, EEA), you may be entitled to the following rights concerning your Personal Information:

• Right to Know: The right to inquire whether your data is being processed, the categories of data collected, and whether it is sold or disclosed.
• Right to Access: The right to request and receive a copy of the specific pieces of Personal Information we maintain about you.
• Right to Correct: The right to request the rectification of any inaccurate or incomplete Personal Information.
• Right to Deletion: The right to request the erasure of your Personal Information, subject to certain legal exceptions.
• Opt-Out of Sale/Targeting: The right to opt-out of the processing of your data for the purposes of targeted advertising, the sale of data, or profiling that produces legal or similarly significant effects.
• Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time (non-retroactive).

• Marketing Opt-Out: You may unsubscribe from promotional email communications by utilizing the "unsubscribe" link provided in each email. However, we reserve the right to continue sending you mandatory administrative communications (e.g., Policy updates, account notifications).
• Exercising Rights: All requests to exercise these rights must be submitted to us via the contact details provided below. We will verify your identity or the authorization of your agent before proceeding with the request. We reserve the right to deny requests where legally permitted and will provide an explanation of the denial. You have the right to appeal a denial within sixty (60) days.
• California Residents (Shine the Light): California Civil Code Section 1798.83 allows California residents to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. Requests can be submitted using the contact information below.
• Do Not Track: Our Services currently do not recognize or respond to "Do Not Track" signals transmitted by web browsers.

8. Users Located Outside the United States

Our Services are hosted and operated within the United States (US). If you access the Services from outside the US, your Personal Information will be transferred to, stored, and processed in the US, where data protection laws may differ from those in your jurisdiction. By using the Services, you consent to this international transfer, storage, and processing.

Supplemental Notice for UK/EEA Users:

• Controller Information: Trade Frogs LLC, located at 74 East Glenwood Avenue #333 Smyrna, DE, 19977 US, is the Data Controller.
• Legal Basis for Processing: We rely on the following legal bases for processing Personal Information:
  • Contractual Necessity: For providing the Services, managing your account, and processing transactions.
  • Legitimate Interests: For enhancing and improving our Services, fraud prevention, ensuring security, protecting our legal rights, and—where applicable—tailoring your experience.
  • Legal Obligation: For complying with all statutory and regulatory requirements.
  • Consent: Where required by law (e.g., for certain marketing communications or customization).
• Additional Rights (GDPR/UK GDPR): You also have the right to restriction of processing, the right to object (based on legitimate interest), and the right to data portability. You retain the right to lodge a complaint with your competent supervisory data protection authority.
• International Transfers (EEA/UK): Transfers outside the EEA/UK are managed through mechanisms recognized by the European Commission or UK Government, such as Standard Contractual Clauses (SCCs), to ensure an adequate level of data protection. You may request a copy of these agreements.

9. Children's Privacy

Our Services are not designed for or intentionally directed at children under the age of sixteen (16) in the United States, or the corresponding age threshold in the child's jurisdiction. If you, as a parent or guardian, become aware that your child has provided Personal Information without appropriate consent, please contact us so that we may endeavor to delete the information promptly.

10. External Website Links

Our Services may contain links to third-party websites or applications not operated or controlled by The Entity. We are not responsible for the content, practices, or policies, including the privacy practices, of these external sites. Your interaction with any third-party link is governed by that third party's own terms and policies.

11. Information Security

We are committed to maintaining the confidentiality and integrity of your Personal Information. We have implemented and maintained appropriate organizational, technical, and physical security measures, policies, and rules designed to protect the data under our control from unauthorized access, loss, misuse, or unlawful disclosure.

12. Policy Revisions

We reserve the right to amend, modify, or update this Privacy Policy at any time. We encourage users to review this Policy periodically. If we implement material changes, we will notify you either through a notice posted on this page or through your account/email. The revised version will become effective immediately upon posting (as indicated by the "Effective Date").

13. Contact Information

Should you have any questions regarding our data handling procedures, wish to exercise any of your privacy rights, or file a complaint regarding our management of your Personal Information, please reach out to us:

Email: [email protected]

Postal Address:

Trade Frogs LLC
74 East Glenwood Avenue #333
Smyrna, DE, 19977
United States

When communicating with us, please ensure you include the email address associated with your account, the specific Service you are inquiring about, and a detailed description of your request. We commit to responding to all reasonable requests in a timely manner.