Privacy Notice for Traders Using Our Marketplace

  1. About the eNDX:GO Marketplace

eNDX:GO is an eSports Trading Game that creates a virtual in-game market for the players of the interactive video game Counter-Strike:Global Offensive.  It is operated and run by eNDX:GO Ltd. (eNDX, We, Us, Our) a company registered in the British Virgin Islands (BVI) under company number 2095517 with a registered office at Trinity Chambers, Road Town, Tortola.

This privacy notice explains how we collect, retain and process your personal data when you register as a user (a Trader), and when you use the Marketplace and what your rights are over your personal data.   You can access the Marketplace via the web address: ENDX.gg.

We are usually a "Controller" of personal data which means that we are responsible for the use of the personal data that we collect about you.  If you have any questions, comments or complaints about this privacy notice or its contents, please contact us using the details below:

Post: ENDX:GO Ltd, Trinity Chambers, Road Town, Tortola, British Virgin Islands

Email: ops@endx.gg 

  1. Third-party links

The Marketplace may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to process personal data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave the Marketplace, we encourage you to read the privacy notice of every website you visit.

  1. Third-party trade marks

All third party trade mark and other proprietary rights are hereby acknowledged.

  1. Types of Personal Data we Collect

When we refer to "personal data" we mean information about a living individual from which that individual can be identified.  This means that information about organisations is not personal data.

When you use the Marketplace as a Trader we collect a range of personal data about you, including for example:

  1. Full name.
  2. Email address.
  3. Phone number.
  4. Your password for your account.
  5. Details of your buying and selling of ENDX Coins.
  6. Details of your buying and selling of Player Tokens.
  7. Details of the ENDX Coins and Player Tokens held by you.
  8. Last 4 digits of your payment card.
  9. Personal data that you choose to include within your posts on the Marketplace  including on the Trade Pit within the Marketplace.
  10. Details of your communications with us and our communications with you.
  11. Your marketing preferences.
  12. Technical information about your use of the Marketplace (for example, the makes and models of any devices you use to log on, operating system version, version of the Marketplace that you are running, IP address, analytics about your usage of the Marketplace, your login data, browser type and version, time zone setting and location, browser plug-in types and versions).

At eNDX we take our obligations to avoid the facilitation of money laundering very seriously, and if you wish to use our platform you are obliged to assist us in this effort; therefore, and in accordance with our Anti-Money Laundering Policy, and in order to fulfil our legal and regulatory obligations to  know our clients, we may collect the identification documents and information that you provide to Jumio as part of our procedures for I.D. verification.  Such documents and information are likely to contain personal data about you.  

Please contact us if the personal data that you give to us changes so that we can update our records.

We also collect, use and share aggregated data (such as statistical or demographic data) for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate technical information about how you use the Marketplace to calculate the percentage of users accessing a specific Marketplace feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this notice.

Children are not permitted to use the Marketplace, you must be 18.  We do not knowingly process personal data relating to children or anyone under that age.

Special categories of personal data

We do not routinely collect and we do not solicit any special categories of personal data or any information about criminal convictions and offences via the Marketplace.  Special categories of personal data is information about an individual's race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.  

If you fail to provide your personal data

Where we need to collect personal data by law, or under the terms of a contract we have or are entering into with you and you fail to provide that data when requested, we may  not be able to perform the contract we have or are trying to enter into with you.  In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

  1. How we Collect your Personal Data

We collect personal data from a number of different sources, for example:

  1. From you directly, for example when you register an account on the Marketplace, when you purchase ENDX Coins or trade Player Tokens on the Marketplace, when you contact us.
  2. From third-party service providers, such as Jumio the third-party I.D. verification service provider who assist with our I.D. Level 2 verification process that you are required to satisfy in order to purchase Player Tokens.
  3. From automated technologies, for example when you interact with the Marketplace we may automatically collect technical information about your device and your use of the Marketplace such as the pages of the Marketplace you have visited and how long you visited them for.

  1. How we use your Personal Data

We use your personal data where we have a legal basis to do so, for example because:

  1. It is necessary for us to process the personal data to perform a contract that we are about to enter into or have entered into with you.
  2. It is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  3. We need to comply with a legal or regulatory obligation.
  4. We have your consent.

We may process your personal data for more than one legal basis depending on the specific purpose for which we are using your data.  Please contact us using the contact details above if you would like information about the specific legal basis we are relying on.

  1. Purpose for which we use your Personal Data

We process the personal data that we collect about you for the following purposes:

  1. To process your application for an account with us on the Marketplace.
  2. To enable you to access the services in the Marketplace.  For example, to operate the Trade Pit within the Marketplace and to facilitate your buying and selling of ENDX Coins and Player Tokens.
  3. To keep records of your buying, selling and holding of ENDX Coins and Player Tokens.
  4. To create, update and maintain our order book.
  5. To keep records of your use of the Marketplace.
  6. To store ENDX Coins, the Marketplace and all of the Player Tokens traded on the Marketplace on a proprietary ENDX Ethereum blockchain.
  7. To remove your access to the Marketplace and to close your account.  
  8. If required, to liquidate your positions on the Marketplace.
  9. To enable you to access the services of other organisations that use the ENDX Group technology underpinning the Marketplace (for example, if you wish to access an exchange operated using ENDX Group technology and you would like us to (and we are able to) share your personal data with that exchange).
  10. To communicate with you, including receiving communications from you and responding to your enquiries.
  11. To send direct marketing to you.
  12. To administer and protect the Marketplace and our business.
  13. To adapt and/or improve the Marketplace, our services and customer experiences.
  14. To comply with the law or a regulatory requirement or guidelines (including, for example, to comply with any and all relevant regulations and guidelines for the prevention of money laundering and the funding of terrorism).

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details above.

  1. Direct Marketing

If you no longer wish to receive direct marketing from us you may unsubscribe at any time on the Marketplace by clicking to "opt out".

  1. Disclosure of Personal Data use your Personal Data

  1. In order to purchase ENDX Coins and to use them to purchase Player Tokens on the Marketplace, you will first need to satisfy our Level 2 I.D. verification processes and sign up through two-factor email verification.  We work with a third-party called Jumio who carries out the I.D. verification process for us.  When you wish to remove your funds from ENDX:GO you will be asked to provide certain information to Jumio which you must provide in order to access those funds.  Jumio processes your personal data as a Processor for us.
  2. All Player Tokens issued for use on the Marketplace are minted within the Bailiwick of Guernsey and held by ENDX Exchange Ltd (a company within the ENDX Group) on trust on your behalf with the intention that only you may direct them to be traded exclusively on the Marketplace.  ENDX Exchange Ltd holds your Player Tokens in a cryptographic electronic wallet which is particular to you and which will allow you to store and engage in transactions using ENDX Coins and Player Tokens when you have directed those purchases by means of purchases via us. ENDX Exchange Ltd processes your personal data as a Processor for us.
  3. We use a third-party payment provider called Truelayer to process your payments when you purchase ENDX Coins.  When you pay for ENDX Coins on the Marketplace you will automatically be taken to our payment provider's webpage and you will be asked to enter your payment details.  We do not disclose your personal data to this payment provider, but when making a payment to this payment provider you may give personal data to them.  Truelayer processes your personal data as a processor.  
  4. If you want to use the services of other organisations that use the technology underpinning the Marketplace (for example, if you wish to access an exchange operated and run by a company within the ENDX Group) you may be able to transfer to them directly through the Marketplace in which case, if you do so, we will transfer your personal data to them.  Even if the other organisation is in the ENDX Group it may process your personal data as a separate, independent, Controller.  Please visit that organisation's privacy policy for further information about how they process personal data.
  5. There may be other occasions where we share your personal data with other third parties, for example:
  1. With third party processors who provide support services to us (for example, IT support and security providers).
  2. With our professional advisors, such as our auditors and solicitors.
  3. With legal, regulatory, judicial and law-enforcement agencies with whom we may need to share personal data in order to comply with our legal or regulatory obligations.   This may include, for example, credit bureaus and agencies in order to assist in the prevention of fraud and financial crimes.
  4. To any actual or prospective purchaser of the whole or part of our business assets or organisation.
  1. Some of these organisations may be located outside of the UK, the EU and Guernsey.

  1. Transfers of Personal Data

If we transfer personal data outside of Guernsey to a country that is not in the UK or the EEA  we take steps to ensure a similar degree of protection is afforded to it in that country by putting safeguards in place, for example by using contract terms that have been approved by an appropriate data protection authority.

  1.  Keeping Personal Data Secure

We know that you provide your personal data in good faith and expect it to be looked after. We take the security of your personal data seriously and we have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  

  1.  Blockchain

ENDX Coins, the Marketplace and all of the Player Tokens that are traded upon the Marketplace are recorded upon a proprietary ENDX Ethereum blockchain (the Blockchain).  Player Tokens are digital assets that may be traded on the Marketplace in accordance with our terms and conditions, and every ENDX Coin and each Player Token that is minted and traded, and the details of every transaction, are irrevocably and immutably recorded on the Blockchain.  The information stored within the Blockchain may include data that is pseudonymised.  Pseudonymisation removes information that identifies an individual and replaces it with a reference, for example a reference number.

  1.  Data Retention

Under data protection laws, we cannot retain your personal data in a form that identifies you for longer than is necessary to fulfil the purposes for which we collected it.  This may include for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirement.

The data that we store via Blockchain (including pseudonymised data) may be stored via the Blockchain forever.

We may anonymise personal data which means that it is no longer associated with you.  We do this for statistical or research purposes so we can improve the services we offer to you.  We can use anonymous data indefinitely without further notice to you.

  1.  Your Rights

Your personal data belongs to you and you have a number of rights over it.  You can:

  1. Ask us for details of the personal data we hold and process about you (usually this is called a subject access request).
  2. Ask that any inaccurate information we hold about you is corrected.
  3. Ask that we delete personal data that we hold about you.
  4. Ask that we stop using your personal data for certain purposes.
  5. Ask that we do not make decisions about you using completely automated means.
  6. Withdraw your consent (where consent is a lawful basis used for processing).
  7. Ask that we give you a copy of the personal data that we hold about you, or (where it is technically feasible for us to do so) that we give this personal data to a third party chosen by you, in a commonly-used, machine-readable, format.

These rights are not available to everyone all of the time, for example even if you ask us to delete personal data that we hold about you it may continue to be stored via Blockchain forever.  Some are subject to exemptions, and so we may not always be able, or required, to comply with your request to exercise these rights.  For more information about your rights in the UK please read this.

To exercise your rights please contact us using the contact details above.  We would be grateful if you could provide us with as much information as you can so we can respond as soon as we can.  Sometimes we may need proof of your identity (for example, your passport or driving licence) before we can fully respond so we can be sure we are giving the correct personal data to the correct individual.

We usually respond to data subject requests within one month, but it can take longer if your request is particularly complex or if you have a number of requests.  You will not usually have to pay a fee, but we reserve the right to charge a fee if your request is clearly unfounded, repetitive, or excessive.  Alternatively, we may refuse to comply with your request.

  1.  Questions & Complaints

If you have any questions or complaints about our processing of your personal data, please contact us using the contact details above.  

If, after speaking with us, you are not happy with how we are processing your personal data, you have the right to complain to the relevant supervisory authority.  

Last updated: 27 October  2022