Privacy Policy

Effective Date: 14 April 2026

This Privacy Policy explains how SUPERSAFE LLC-FZ, licence no. 45000977, with its registered address at FDRK2334, Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates (“Supersafe,” “we,” “us,” or “our”), collects, uses, stores, discloses, and otherwise processes personal data when you access or use supersafe.gg, create an account, buy or sell digital goods, contact support, submit verification materials, receive communications, or otherwise interact with our marketplace and related services (collectively, the “Platform”).

This Privacy Policy applies to personal data that we process as a controller in connection with the Platform. In some cases, third parties such as payment processors, verification providers, analytics providers, communications providers, or other service providers may process personal data under their own privacy notices and contractual roles.

By accessing or using the Platform, you acknowledge that you have read this Privacy Policy.

1. Scope

This Privacy Policy applies to personal data we collect and process when you:

1. access, browse, or use the Platform;
2. create, secure, or manage an account;
3. place, receive, manage, or dispute an order;
4. publish listings, deliver digital goods, or receive payout;
5. contact customer support or submit an appeal, complaint, or report;
6. complete seller onboarding, payment verification, identity verification, or compliance review;
7. subscribe to updates, alerts, or promotional communications; or
8. otherwise communicate or interact with us in connection with the Platform.

This Privacy Policy does not apply to third-party websites, games, applications, payment services, or platforms not controlled by Supersafe, even if they are linked from or referenced on the Platform.

2. Personal Data We Collect

We collect personal data from four principal sources: directly from you, automatically from your use of the Platform, from other users involved in a transaction, and from third parties that support payment, verification, analytics, security, or legal compliance.

2.1 Information you provide directly

Depending on how you use the Platform, we may collect:

Account and profile information

• name or display name;
• username;
• email address;
• password-related or authentication-related data;
• account preferences;
• country or region;
• communication preferences.

Order and transaction information

• listing activity;
• purchased or sold items;
• order numbers;
• order status;
• pricing, fees, taxes, and refund information;
• transaction history;
• order chat messages;
• delivery details;
• dispute submissions;
• evidence submitted in connection with an order.

Payment and payout information

• billing name and billing contact information;
• masked payment method details;
• payment status;
• payout method details;
• bank, wallet, or payout destination details where applicable;
• tax or invoicing information where required.

Seller onboarding and compliance information

• business name;
• business region;
• business and account operating details;
• tax registration information where required;
• identity verification materials where required;
• sanctions, fraud, or compliance screening information;
• beneficial owner or authorized representative information where required for seller onboarding, payout review, or legal compliance.

Support and trust-and-safety information

• support ticket content;
• uploaded attachments;
• screenshots;
• screen recordings;
• dispute evidence;
• complaint history;
• moderation reports;
• communications with customer support, trust and safety, or legal/compliance review.

Communications and marketing information

• subscription status;
• email confirmation status;
• communication preferences;
• responses to surveys, forms, or promotional messages.

2.2 Information collected automatically

When you access or use the Platform, we may automatically collect:

• IP address;
• approximate location inferred from IP address;
• browser type and version;
• device type and operating system;
• language settings;
• referring and exit URLs;
• page views and navigation paths;
• timestamps;
• session identifiers;
• log data;
• security signals;
• crash and performance information;
• cookie identifiers and similar online identifiers.

2.3 Information received from other users

Where you are involved in a transaction, another user may provide information about you that is necessary to complete, verify, or dispute that transaction, including order-related communications, delivery confirmations, or supporting evidence.

2.4 Information received from third parties

We may receive personal data from:

• payment processors and payout providers;
• identity verification and fraud-prevention providers;
• analytics and communications providers;
• cloud, infrastructure, and security providers;
• public and official sources used for sanctions or compliance review;
• legal advisers, regulators, law enforcement, or courts;
• corporate affiliates involved in operating the Platform.

3. Sensitive Data and Verification Data

We do not intentionally request personal data that is not reasonably necessary for Platform operations, fraud prevention, dispute handling, legal compliance, or security.

Where necessary for seller onboarding, high-risk transaction review, payout release, fraud prevention, or legal compliance, we may collect or receive:

• government-issued identification information;
• date of birth;
• identity verification results;
• proof-of-address information;
• sanctions-screening or restricted-party screening results;
• selfie, liveness, or account-control verification materials;
• device or authentication verification information.

If biometric or liveness verification is used through a third-party verification provider, Supersafe may receive the verification result, extracted fields, risk indicators, and related metadata needed to approve, reject, or further review the verification event. Raw biometric templates or verification media may be stored by the third-party provider or by Supersafe only to the extent necessary for the stated purpose, contractual controls, fraud prevention, dispute handling, or legal compliance.

We do not use sensitive personal data to infer personal characteristics for advertising or profiling.

4. How We Use Personal Data

We use personal data only for defined operational, contractual, security, support, compliance, and commercial purposes.

4.1 To create, maintain, and secure accounts

We use account, authentication, and technical data to create and administer accounts, authenticate users, maintain account settings, protect login sessions, detect unauthorized access, and secure the Platform.

4.2 To operate the marketplace and perform transactions

We use listing, order, delivery, payment, payout, support, and dispute information to facilitate marketplace transactions, administer protected checkout, release or hold funds, process refunds, investigate transaction issues, and perform our contractual and platform functions.

4.3 To review sellers and manage payout risk

We use seller onboarding, verification, compliance, payout, and transaction data to review seller eligibility, assess risk, administer payout holds or reserves, release payouts, and protect the Platform and its users from fraud or loss.

4.4 To prevent fraud, abuse, and unauthorized activity

We use technical, account, order, verification, and behavioral information to detect fraud, account compromise, payment abuse, listing abuse, sanctions risk, chargeback risk, refund abuse, and other harmful or unlawful conduct.

4.5 To provide support and resolve disputes

We use support communications, order history, uploaded evidence, account data, and transaction records to answer questions, investigate complaints, resolve disputes, enforce our policies, and maintain a record of support interactions.

4.6 To communicate with you

We use your contact information to send account notices, transaction updates, security alerts, policy changes, verification requests, support responses, and other operational communications.

4.7 To send marketing and promotional communications

Where permitted by law, we may use your contact information and communication preferences to send product updates, marketplace announcements, promotions, or related communications. You may opt out of marketing communications at any time.

4.8 To improve the Platform

We use analytics, usage, device, and feedback information to understand how the Platform is used, improve features, monitor performance, test changes, and maintain service quality.

4.9 To comply with law and protect rights

We may use personal data to comply with applicable law, respond to legal requests, enforce our Terms and policies, defend legal claims, protect users, and investigate suspected misconduct.

4.10 To support corporate transactions

We may use and disclose relevant information in connection with financing, merger, acquisition, restructuring, insolvency, asset sale, or similar corporate activity, subject to appropriate confidentiality safeguards.

5. Legal Bases for Processing

Where applicable law requires a legal basis for processing, Supersafe processes personal data on one or more of the following grounds:

• performance of a contract or steps taken at your request before entering into a contract;
• compliance with legal obligations;
• Supersafe’s legitimate interests in operating, securing, improving, and defending the Platform, preventing fraud, administering disputes, and managing business risk; and
• consent, where consent is required by law, including for certain marketing or non-essential cookie activities.

Where we rely on legitimate interests, we do so only where those interests are not overridden by your rights and freedoms under applicable law.

Where we rely on consent, you may withdraw that consent at any time, although withdrawal does not affect processing already performed before withdrawal.

6. Automated Screening, Risk Review, and Decision Support

Supersafe may use automated systems, scoring tools, rules-based logic, and similar technologies to support:

• fraud detection;
• suspicious login or payment review;
• sanctions and compliance screening;
• transaction-risk analysis;
• payout-risk assessment;
• abuse prevention;
• support routing and triage;
• seller review and trust scoring.

These tools may influence whether an order is paused, whether additional verification is requested, whether a payout is held, or whether an account or listing is restricted pending review.

Where required by applicable law, Supersafe will provide a means to request human review of a material decision.

7. How We Share Personal Data

We do not sell personal data for money.

We may disclose personal data only as described below or as otherwise permitted or required by law.

7.1 Service providers and processors

We may share personal data with service providers that help us operate the Platform, including providers of:

• payment processing;
• payout processing;
• hosting and cloud infrastructure;
• analytics;
• communications;
• customer support systems;
• fraud prevention;
• identity verification;
• security and monitoring;
• legal, accounting, audit, and insurance services.

These providers may process personal data only for the purposes authorized by Supersafe, subject to contractual and legal safeguards.

7.2 Transaction counterparties

Where necessary to complete a transaction or resolve a dispute, we may share limited order-related data between Buyers and Sellers, including order communications, delivery status, order evidence, and other information reasonably required for performance or dispute handling.

7.3 Corporate affiliates

We may share personal data with our affiliates where reasonably necessary to operate the Platform, manage support, administer transactions, reduce risk, or comply with law.

7.4 Authorities and legal recipients

We may disclose personal data to regulators, courts, law enforcement, tax authorities, payment providers, or other lawful recipients where required or permitted by law, or where reasonably necessary to protect rights, investigate misconduct, or preserve the integrity of the Platform.

7.5 Corporate transactions

We may disclose personal data in connection with financing, due diligence, merger, acquisition, reorganization, asset transfer, or insolvency proceedings, subject to appropriate confidentiality measures.

7.6 Analytics, attribution, and similar providers

Subject to applicable law and your privacy or cookie choices, we may share online identifiers, device information, and usage information with analytics, attribution, or similar service providers to help us understand usage, performance, and campaign effectiveness.

8. International Transfers

Supersafe may process personal data in countries other than the country where you are located.

Where applicable law requires safeguards for cross-border transfers, Supersafe will use an appropriate lawful transfer mechanism, which may include:

• an adequacy decision;
• standard contractual clauses;
• a UK-approved addendum or equivalent transfer mechanism; or
• another transfer mechanism recognized under applicable law.

By using the Platform, you understand that your information may be transferred to and processed in jurisdictions with data-protection laws different from those in your home jurisdiction, subject to applicable safeguards where required.

9. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to comply with law, prevent fraud, resolve disputes, enforce agreements, and defend legal claims.

Unless a longer period is required or justified, we generally apply the following retention logic:

• Account information: for as long as the account remains active and for a reasonable period after closure.
• Order and transaction records: for as long as necessary for transaction administration, dispute handling, accounting, tax, fraud prevention, chargeback exposure, and legal compliance.
• Support and dispute records: for as long as necessary to resolve the matter and preserve evidence relevant to claims, fraud review, or policy enforcement.
• Verification and compliance materials: for as long as necessary for verification, fraud prevention, payout review, dispute handling, legal compliance, or defense of legal claims.
• Technical and security logs: for as long as reasonably necessary for security, fraud detection, troubleshooting, and service integrity.
• Marketing preferences and opt-out records: for as long as needed to honor communication preferences and demonstrate compliance.

Supersafe may retain data longer where required by law, where a dispute or claim remains open, where fraud or abuse is suspected, or where retention is reasonably necessary to establish, exercise, or defend legal rights.

Supersafe may also aggregate, anonymize, or de-identify information and retain such information where it no longer identifies an individual.

10. Cookies and Similar Technologies

Supersafe uses cookies and similar technologies to:

• keep the Platform secure;
• maintain sessions and user preferences;
• remember consent choices;
• measure usage and performance;
• improve functionality;
• support analytics; and
• where permitted, support attribution, communications, or promotional activity.

Detailed information about the cookies and similar technologies used on the Platform, including categories, controls, and your choices, is provided in our Cookie Policy and any cookie settings or consent tools made available on the Platform.

11. Marketing Communications

If you subscribe to updates or promotional messages, we may send you product updates, platform news, offers, or similar communications.

You may opt out of marketing communications at any time by:

• using the unsubscribe link in the message;
• changing account communication settings where available; or
• contacting us using the contact details set out below.

Operational or transactional messages are not marketing communications and may still be sent even if you opt out of promotional messages.

12. Your Rights

Depending on where you are located and the law that applies, you may have the right to:

• request access to personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request deletion of personal data in certain circumstances;
• request restriction of processing in certain circumstances;
• object to certain processing, including certain processing based on legitimate interests or direct marketing;
• withdraw consent where processing is based on consent;
• request portability of certain personal data where applicable;
• request human review of certain automated decisions where applicable;
• lodge a complaint with a supervisory authority, regulator, or other competent body; and
• be free from unlawful discrimination for exercising privacy rights where such protection applies.

These rights are not absolute. Supersafe may deny, limit, or defer a request where permitted by law, including where the request is excessive, repetitive, unverified, legally restricted, or would adversely affect the rights of another person or the integrity of a fraud, security, or legal investigation.

13. California and Similar U.S. State Privacy Disclosures

If you are a resident of California or another U.S. state that provides specific privacy rights, you may have rights to know, access, correct, delete, and opt out of certain uses or disclosures of personal data, as well as the right not to be discriminated against for exercising those rights.

In the preceding 12 months, the categories of personal data Supersafe may have collected and disclosed for business or commercial purposes include:

• identifiers;
• contact information;
• account information;
• commercial and transaction information;
• internet or network activity information;
• geolocation data inferred from IP address;
• user-submitted support or dispute materials;
• professional or business information submitted for seller onboarding;
• sensitive personal information such as credentials, identity-verification information, or payout details where reasonably necessary for Platform operations, fraud prevention, verification, or legal compliance.

Supersafe does not sell personal data for money. If our use of analytics, attribution, advertising, or similar technologies is deemed “sharing” or “targeted advertising” under applicable law, Supersafe will provide any consent or opt-out mechanism required by law.

Where legally required, Supersafe will honor valid opt-out preference signals for the relevant browser or device to the extent technically supported and legally required.

14. Security

Supersafe uses reasonable technical, organizational, and administrative measures designed to protect personal data against unauthorized access, misuse, disclosure, alteration, or destruction.

These measures may include:

• access controls;
• role-based permissions;
• authentication controls;
• audit logging;
• encryption in transit where appropriate;
• security monitoring;
• vendor diligence;
• fraud-detection tools; and
• controlled support and review workflows.

No system can be guaranteed to be completely secure. You are responsible for protecting your account credentials and for notifying Supersafe promptly if you suspect unauthorized use of your account.

15. Children’s Privacy

The Platform is not directed to children who are not legally permitted to use the Platform under applicable law. Supersafe does not knowingly collect personal data from children in violation of applicable law.

If Supersafe becomes aware that it has collected personal data from a child in a manner prohibited by law, Supersafe will take reasonable steps to delete, restrict, or otherwise handle that information as required.

16. Third-Party Services and External Platforms

Listings, digital goods, and transactions on the Platform may relate to third-party games, publishers, issuers, app providers, software providers, payment providers, or wallet services. Those third parties operate under their own terms and privacy notices.

Supersafe is not responsible for the privacy practices of third-party services that it does not control.

17. Changes to This Privacy Policy

Supersafe may update this Privacy Policy from time to time to reflect changes in the Platform, legal requirements, service providers, verification processes, or data practices.

If Supersafe makes a material change, the updated Privacy Policy will be posted with a new effective date and, where required by law, additional notice will be provided.

Your continued use of the Platform after the effective date of an updated Privacy Policy is subject to that updated version, except to the extent applicable law requires a different form of notice or consent.

18. Contact Us

If you have questions about this Privacy Policy, your personal data, or a privacy-related request, you may contact us at:

Email: [email protected]

Postal Address: SUPERSAFE LLC-FZ Licence No. 45000977 FDRK2334, Compass Building Al Shohada Road Al Hamra Industrial Zone-FZ Ras Al Khaimah United Arab Emirates