Privacy Policy

SKILLCARRY LIMITED (“SkillCarry”, “we”, “us”, “our”) respects your privacy and takes responsibility for keeping your personal data confidential and secure. This Privacy Policy explains what personal data we collect when you use https://skillcarry.net (the “Platform”), why and on what legal basis we use it, who receives it, how long we keep it and what rights you have.

The Policy forms part of our Terms & Conditions, and capitalized terms used here have the meanings given there. It applies only to data collected on the Platform and its related resources, not to third-party websites we link to.

We process Personal Data only where we have a lawful basis to do so: because it is necessary to perform our contract with you, to comply with a legal obligation, for our legitimate interests, or because you have given consent to a specific activity.

Data controller: SKILLCARRY LIMITED, Flat/Rm B, 5/F, Gaylord Commercial Building, 114-118 Lockhart Road, Wan Chai, Hong Kong, Business Registration Number 77321124. Privacy contact: support@skillcarry.net.

What Personal Data we collect
When we collect it
Why we use it and on what legal basis
Who we share it with
Service messages and marketing
Where data is stored and international transfers
Information visible to others
How we protect data
Your rights
How long we keep data
Cookies and similar technologies
Minors
External content and links
Changes to this Policy
Contact and complaints

1. What Personal Data we collect

What we collect depends on how you use the Platform.

1.1. Account and registration data

email address;
username, nickname or display name;
identifiers received from a social login provider (Google, Discord or Facebook) when you choose to sign in that way;
account ID, role (Customer or Booster), account status, language and currency preferences.

1.2. Booster application and verification data

first and last name, date of birth or confirmation of age;
contact details, including email address and messenger identifiers such as Discord;
residential address, where required;
copies or details of identity documents, where required for verification;
tax, payout and compliance information needed to verify and administer Booster status and payouts.

1.3. Communication data

messages in the Order Chat, including images you attach;
messages sent to support through the website chat, the contact form or email, and the history of those conversations;
your communication preferences and records of consents and opt-outs.

1.4. Order and transaction data

the services or items ordered, options selected, delivery details and Order status;
game-related information you give us so an Order can be delivered, such as region, realm, faction, character name or other in-game identifiers;
transaction amount, date and currency, payment method, payment identifiers, refund and chargeback records, internal transaction records and reconciliation data.

1.5. Payment-related data. We receive limited information from payment providers where they make it available: payment identifiers and status, transaction references, masked card details, card type, expiry date, last four digits, billing details and payment tokens. Full card numbers, CVV/CVC codes and other sensitive authentication data are handled by certified third-party payment providers. SkillCarry does not store them.

1.6. Verification, AML and fraud-prevention data

identity documents and the results of verification;
proof of address, nationality or country of residence, where required;
facial images or liveness-check data, where a verification provider processes them to confirm identity;
sanctions-screening results, risk indicators, fraud signals, transaction-monitoring data, device data, IP address and, where the law requires it, information on the source of funds.

1.7. Technical, device and usage data

IP address and the approximate location (country) derived from it;
browser type and version, operating system, device type, user agent, language settings, time zone and screen parameters;
session identifiers, timestamps, referring domain, pages and paths visited, technical logs and performance data.

1.8. Analytics and marketing data. Subject to your cookie choices: events and feature usage on the Platform, campaign interactions, coupon usage, cookie identifiers, and engagement with our emails.

1.9. Account recovery and disputes. If you lose access to your Account, or if Users disagree about who an Account belongs to, support may ask for a photo or scan of an identity document to confirm the registration data or your rightful possession of the Account.

2. When we collect it

When you visit the Platform. We automatically collect technical data (Section 1.7) to run the website, keep it secure, detect bots and fraud, fix errors and, with your consent, measure usage. On a first visit your IP address is used to work out your country so that we can suggest a language and currency; for this purpose the IP address is sent to a country-lookup service solely to obtain a country code.
When you create or update an Account. We collect your email address, username and, if you use social login, the profile identifier supplied by that provider.
When you place an Order. We process the data needed to administer the Order, payment, possible refunds, delivery, fraud prevention and support. Some payment methods require additional details, such as full name, billing address, country or phone number, which you give directly to the payment provider.
After purchase. Game-specific details you add to an Order are stored so that the Booster can deliver it.
When you chat. Messages in the Order Chat are stored to enable delivery, maintain quality, resolve disputes and enforce the Platform’s rules. They are visible to you, the assigned Booster and SkillCarry support.
When you apply to be a Booster. We collect the data in Section 1.2 to register you, verify your identity, administer payouts and meet legal requirements.
During verification. Where we run KYC, AML or fraud checks, we collect the data in Section 1.6, directly or through a verification provider.
During Campaigns. We may collect coupon codes used, registration details and engagement with a particular promotion.

3. Why we use it and on what legal basis

3.1. Performance of a contract

We process Personal Data where that is necessary to provide the Platform and carry out the Terms & Conditions:

registration, sign-in and Account management;
placing and administering Orders and coordinating delivery;
communication between Customers, Boosters and SkillCarry;
customer support, dispute handling and the Resolution Review;
refunds, chargeback handling and reconciliation of transactions;
registering and verifying Boosters and administering their status and payouts;
sending service and transactional messages.

3.2. Legal obligations

We process Personal Data where necessary to comply with legal, regulatory, tax, accounting, AML/CTF, sanctions, payment, consumer-protection, record-keeping and reporting duties, and to answer lawful requests from competent authorities. This may involve identity-verification data, transaction and payment records, tax and payout information, screening results, fraud-monitoring data, chargeback records and communications.

3.3. Consent

Where the law requires it, we rely on your consent: for non-essential cookies and analytics, certain marketing messages, and participation in surveys or promotions. You can withdraw consent at any time by using the unsubscribe link in a message, changing your cookie choice, or writing to support@skillcarry.net. Withdrawal does not affect processing carried out before it.

3.4. Legitimate interests

We rely on our legitimate interests, balanced against your rights, to:

maintain, secure and improve the Platform;
prevent fraud, abuse, chargebacks, security incidents and breaches of the Terms & Conditions;
produce service analytics, internal reporting and business analysis, subject to any consent or opt-out requirement that applies;
measure the effectiveness of marketing and, where the law allows, show relevant content, subject to your cookie and marketing choices;
keep records of Orders, disputes, support interactions and communications;
enforce our terms and protect SkillCarry, Users, payment partners and third parties;
run internal operations, infrastructure, troubleshooting, audits and compliance reviews;
invite you to review a completed Order;
send service messages and limited non-promotional messages where the law allows.

You may object to processing based on legitimate interests as the law provides, and you may always object to direct marketing.

4.1. We share Personal Data only as far as necessary for the purposes described in this Policy. We do not sell Personal Data. The providers named below are the main ones we use at the date of this Policy; they may change as the Platform develops, and we will update this Policy or give additional notice where the law requires.

Boosters and Customers. The Booster assigned to your Order sees the Order details, the game-related information you provided and the Order Chat. Boosters do not receive your email address or payment data. Customers see the Booster’s nickname and public profile.
Payment providers. Stripe, PayPal, NOWPayments (cryptocurrency payments) and other certified providers we offer at checkout, together with the banks and card schemes they work with. Data shared may include name, email address, billing details, IP address, transaction details, payment identifiers, masked card details, refund and chargeback records, and, for Boosters, payout details. These providers act under their own privacy notices when you pay.
Identity-verification and fraud-prevention providers. Where we use a specialized provider for KYC, AML screening or fraud detection, it receives the identification documents, contact details, device and IP data and transaction information needed for that check.
Analytics. Google Analytics 4 (Google Ireland Limited / Google LLC), only after you accept analytics cookies. It receives cookie-based identifiers, device and browser information and events on the Platform. We do not send it your name, email address, chat content or payment data.
Customer support chat. Tidio provides the chat widget on the website and processes the messages you send through it, your contact details if you provide them, and device and browser data.
Reviews. Trustpilot hosts reviews of SkillCarry. After an Order is completed we may pass your name, email address and an Order reference to Trustpilot so that it can send you a review invitation on our behalf. You can opt out of invitations at any time through the link in the invitation or by contacting us. Anything you publish on Trustpilot is governed by Trustpilot’s own terms and privacy policy.
Email delivery. Our transactional and marketing emails are sent through an email delivery provider (currently Resend), which processes your email address and the content and delivery status of the message.
Social login. If you sign in with Google, Discord or Facebook, that provider learns that you used its login on SkillCarry and sends us the profile data you authorized.
Hosting and infrastructure. The Platform and its databases and backups are hosted with Fornex Hosting S.L. in data centers in Germany. We may use additional hosting, backup, monitoring and security providers, which process data only to keep the Platform running and secure.
Professional advisers such as lawyers, auditors and tax advisers, under duties of confidentiality.
Authorities. We disclose Personal Data to law enforcement, courts and regulators where the law requires it and a valid request with proper documentation has been received.
Business transfers. If SkillCarry is involved in a merger, acquisition or sale of assets, Personal Data may be transferred to the successor, subject to this Policy.

4.2. Contracts with processors. Where a provider processes Personal Data on our behalf, we put in place a data processing agreement or equivalent terms setting out the subject matter, duration, nature and purpose of the processing, the types of data and the parties’ obligations. If a provider cannot demonstrate an appropriate standard of protection, we may suspend or end data sharing with it.

5. Service messages and marketing

5.1. Service messages. We use email, the Order Chat, the website chat and notifications in your Account to send messages about registration, sign-in codes, Orders, delivery, support, disputes, refunds, payments, security alerts, policy updates and compliance checks. These messages are necessary to provide the Platform and cannot be switched off while your Account is active.

5.2. Marketing. Newsletters, promotions, reactivation and similar commercial messages are sent only where the law allows: on the basis of your consent, of the “soft opt-in” for existing customers where available, or of another valid basis. Every marketing message contains an unsubscribe link, and you can also opt out by contacting support. Opting out does not stop service messages.

5.3. Giving us a contact detail for an Order, for support or for security does not by itself mean you agree to receive marketing through that channel. We keep records of consents, opt-ins and opt-outs so that we can honor your choices and demonstrate compliance.

6. Where data is stored and international transfers

6.1. The Platform’s primary servers are located in Germany. SkillCarry itself is established in Hong Kong, and some of our providers and Boosters are located in other countries, so Personal Data may be accessed from, transferred to or stored in countries outside the one where you live, including countries outside the European Economic Area and the United Kingdom.

6.2. Where Personal Data that is subject to the GDPR or UK GDPR is transferred to a country without an adequacy decision, we rely on an appropriate safeguard such as the European Commission’s Standard Contractual Clauses (with the UK addendum where relevant), supported by transfer assessments and supplementary measures where needed. You can ask us for information about the safeguard used for a particular transfer.

6.3. We review our providers, hosting and backup locations and transfer mechanisms periodically to keep protection at an appropriate level.

7. Information visible to others

7.1. To help Users interact, the following may be displayed publicly on the Platform: your nickname; for Boosters, the profile rating, number of completed Orders and success rate; and reviews you choose to publish.

7.2. Everything else in your Account, and everything you share with a Booster during an Order, stays private and is not displayed publicly.

7.3. You are responsible for what you choose to publish. Posting contact details such as a phone number or email address in public areas or in the Order Chat is prohibited by the Terms & Conditions and may lead to your Account being blocked.

8. How we protect data

Secure storage. Data is kept on protected servers, with encryption in transit (HTTPS/TLS) across the whole Platform.
Restricted access. Only authorized staff can access Personal Data, and only as far as their role requires. Access is role-based and administrative actions are logged.
Technical safeguards. Firewalls, monitoring, regular backups, security headers and periodic risk reviews.
Payment security. Card payments are processed by PCI DSS-certified providers; we do not store full card numbers or CVV/CVC codes.
People. Staff and contractors who handle Personal Data are bound by confidentiality and instructed in information security.
Incident response. If a Personal Data breach is suspected or confirmed, we investigate, contain and remedy it and, where the law requires, notify the affected Users and the competent supervisory authorities without undue delay, with information on what happened and what you can do.

What you can do: use a strong, unique password if you sign in with a password; never share sign-in codes; keep the email account linked to SkillCarry secure; and tell support immediately if you notice activity you do not recognize. No system is perfectly secure, and the security of your Account also depends on you.

9. Your rights

9.1. Depending on the law that applies to you, including the GDPR, the UK GDPR and the Personal Data (Privacy) Ordinance of Hong Kong, you have the right to:

access – learn what Personal Data we hold about you and how we use it, and receive a copy;
rectification – have inaccurate, incomplete or outdated data corrected;
restriction – ask us to limit processing in certain circumstances;
erasure – ask us to delete your Personal Data. Transaction history and other data we must keep by law, or need for legal claims and fraud prevention, may be retained;
portability – receive the data you provided in a structured, machine-readable format for transfer to another service;
object – object to processing based on legitimate interests, and at any time to direct marketing;
not be subject to solely automated decisions that produce legal or similarly significant effects, including profiling;
withdraw consent at any time where processing is based on consent;
complain to a supervisory authority (see Section 15).

9.2. How to exercise them. Write to support@skillcarry.net from the email address linked to your Account and tell us which right you wish to exercise. To protect your data against requests made by someone else, we may ask you to confirm your identity; for an erasure request this may include a copy of an identity document. If the information provided is incomplete, the request may be delayed until it is completed.

9.3. We respond to valid requests within 1 (one) month (30 days), unless the law allows an extension for complex or multiple requests, in which case we will tell you.

9.4. Where a request is manifestly unfounded or excessive, in particular because it is repetitive, we may refuse it or charge a reasonable fee, as Article 12(5) GDPR and equivalent rules allow.

9.5. California and other U.S. states. Where applicable, residents may have additional rights to know, access, correct and delete Personal Data and to opt out of its sale or sharing, of targeted advertising and of certain profiling. SkillCarry does not sell Personal Data. To exercise these rights, contact us at the address above. We will not discriminate against you for doing so.

10. How long we keep data

10.1. We keep Personal Data only for as long as we reasonably need it for the purposes described in this Policy. The period depends on the type of data, the purpose, legal requirements, payment-provider rules, dispute and chargeback windows, and fraud-prevention and security needs.

Account data – while the Account is active and for a reasonable period after it is closed where needed for legal, security, dispute-resolution or fraud-prevention purposes.
Transaction, payment, accounting and tax records – for the period required by law, generally 7 (seven) years, or longer where needed for legal claims, audits, chargebacks or regulatory purposes.
Order Chat, support and other communications – up to 3 (three) years after the last interaction, unless a longer period is needed for a dispute, legal claim, fraud prevention, compliance or security.
KYC, AML, sanctions-screening and fraud-prevention data – for the period required by law, regulatory duties, payment-provider requirements, risk management or legal claims.
Analytics data – for the limited time needed for product improvement, diagnostics and reporting. Full IP addresses processed mainly for analytics are kept no longer than 90 (ninety) days unless a longer period is justified by security, fraud prevention, payment risk, or a legal or technical necessity. Aggregated or anonymized data may be kept longer.
Consent and opt-out records – as long as needed to demonstrate compliance.

10.2. When a retention period ends, the data is deleted, anonymized or aggregated, unless the law requires or allows us to keep it.

11. Cookies and similar technologies

We use cookies, local storage and similar technologies to run the Platform, keep it secure, remember your preferences, and, with your consent where required, analyze usage and measure marketing. Non-essential technologies are used only after you have made a choice in the cookie banner, and you can change that choice at any time. Where the law requires it, we honor recognized opt-out preference signals such as Global Privacy Control. Details, including the specific cookies we set, are in our Cookie Policy.

12. Minors

The Platform is intended for people aged 18 (eighteen) or over. A person under 18 may use it only with the documented consent of a parent or legal guardian and any additional verification we request. If we learn that we have collected Personal Data from a minor without that authorization, we will delete it promptly.

13. External content and links

The Platform contains links to third-party websites, for example official game news, and Users may post links in accordance with the Terms & Conditions. Support removes user-posted content and links that pose a security risk when we become aware of them, but we do not control external sites and are not affiliated with them. SkillCarry is not liable for damage, data loss or theft of account data resulting from following external links or using third-party sites. Please read the privacy and security policies of any site you visit.

14. Changes to this Policy

We may update this Policy to reflect changes in the Platform, our practices or the law. Unless a different date is stated, material changes take effect 30 (thirty) days after they are published on this page. We announce material changes by email, by a notice on the website or through the website chat, and where a change requires your consent we will ask for it.

15. Contact and complaints

Questions, requests and complaints about this Policy or our handling of Personal Data:

Email: support@skillcarry.net
Post: SKILLCARRY LIMITED, Flat/Rm B, 5/F, Gaylord Commercial Building, 114-118 Lockhart Road, Wan Chai, Hong Kong

If we have not resolved your concern, you may complain to a data protection authority:

in Hong Kong – the Office of the Privacy Commissioner for Personal Data (PCPD), www.pcpd.org.hk;
in the European Economic Area – the supervisory authority of the country where you live or work, or where you believe the infringement took place. A list is available from the European Data Protection Board;
in the United Kingdom – the Information Commissioner’s Office, ico.org.uk.

By using the Platform you acknowledge that you have read and understood this Privacy Policy. Where we rely on your consent, we ask for it separately.

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