Policy & Agreement
Information we collect:
Depending on how you interact with BestPoints, collection and processing of personal data varies.
When you contact BestPoints, by contacting our customer support team for technical issues or contacting BestPoints legal team with any questions or inquiries, BestPoints may receive and process any personal information that you provide to us such as your name, your company’s name and email address. BestPoints may use the information you provide via app for its business’ purposes, such as responding to your inquiries or support requests, for marketing or to contact you in the course of offering you with any of the Services and/or with the BestPoints newsletter. BestPoints retains the information collected via the app for so long as you use the Services or until you choose to unsubscribe from the BestPoints mailing list (you can unsubscribe from newsletter from your profile settings in the app) or until BestPoints deletes your personal information pursuant to a request from you.
As required under applicable law, BestPoints will use identifiable information to enforce terms, policies and legal agreements, to comply with court orders and warrants, and assist law enforcement agencies, to collect debts, prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Services, and to take any action in any legal dispute and proceeding.
BestPoints commits to process personal information solely for the purposes described in this policy.
Here are the types of information that we may collect from you:
- Your name and surname
- E-mail address
- Steam trade url
- Device identifiers (a device identifier is a string of numbers and letters unique to your smartphone or tablet assigned by the manufacturer or platform provider), such as
- Google Advertising ID (GAID), or Android ID in its absence (or MAC address, in the absence of both), for Android devices
- Firebase Cloud Messaging token (used for push notifications)
- Information about the device itself, including
- Whether it is a smartphone or tablet or emulator
- User agent
- IP address
- Timestamp and duration (i.e., when the device connected to our services began and how long the connection lasted, for a given session)
- Location-related information – We infer the perceived general location of the device based on:
- The IP address used to access our services
- Location-related device settings, such as the device’s country code, language setting
- Ad-related information – We collect information about the ads you view, such as:
- What the ad offer is about;
- What type of ad it is (e.g., text, image, or video);
- Which ad placement is involved (i.e., where the ad offer is displayed within the mobile app in which you accessed it); and
- Whether you respond to the ad’s “call to action” – for example, did you click through to the advertiser’s website?
How we use the collected information:
- We track your web activity for marketing purposes
- We collect personal information for marketing purposes and communication.
- We process personal information by sending them to integrated Email and CRM systems for marketing and nurturing purposes.
- We save personal information in our systems for analysis purposes.
- Your behavior and web activity can be used for marketing purposes such as profiling, and marketing analysis.
What we do with the information we gather:
- We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
- Internal record keeping.
- We may use the information to improve our products and services.
- To fulfill orders for services through one of the platforms offered by the Company;
- Enable good customer service, like managing your requests, correcting incorrect information or sending information you requested e.g. newsletter;
- Information on ordering a service is stored and analyzed, as well as the basis for offers and discounts as well as promotion of both general and targeted nature;
- In order to manage customer profiles, conduct analyses and market research;
- For system administration and for obtaining statistical data about the behavior and patterns of our users, this does not identify any individual but occurs at aggregated level;
- To develop, deliver and improve our products and services through analysis of your behavior on our websites and app.
- Personal data is also used for analysis to perform segmentation/profiling, in order to develop targeted offers and services;
- To send you information and promotion via SMS, email, app, push or other digital contact routes such as social media since you have an active customer relationship with us;
- To contact you via app, SMS, email or post about other offers, promotions or services that we believe may be of interest to you, please note that you may decline this promotion at any time;
- To provide you with relevant recommendations, offers, and custom services based on what other people with similar behaviors have been interested in, what you have chosen for service, looked at and shown interest in;
- To help us develop our site and app to be more useful and to enhance your user experience of the platforms offered through the Company by customizing the display of the services to the device being used;
- To send important messages as communication about changes in our terms and policies;
The Service is hosted in the United States. We will comply with GDPR requirements providing adequate protection for the transfer of personal information from Europe to the U.S. Also, we may transfer your data to the U.S., the EEA, or other countries or regions deemed by the European Commission to provide adequate protection of personal data in connection with storage and processing of data, fulfilling your requests, and operating the Service.
Depending on your selected registration / authentication method, third parties (as laid out in section 3 of this policy) may provide registration and authentication services. In this case, this App will be able to access some Data, stored by these third party services, for registration or identification purposes.
BestPoints may share your personal information and/or social-demographic information, including, without limitation, a unique identification number (“UID”), postal code, region, province, gender, marital status, education, ethnicity/race (where permitted by applicable law), employment related information, non-personally identifiable information on household members, consumer product and service usage and ownership (e.g., computers, cars, mobile devices, video games, etc.), home ownership, pet ownership, employment information (e.g., title, role, travel, industry, etc.), and social grade, with third party sample/market research companies (individually each a “Third Party MR Company” and collectively the “Third Party MR Companies”) for the following purposes:
- Identifying client survey opportunities that you may be eligible for through the Third Party MR Companies; and
- Disclosing such data elements to clients of the Third Party MR Companies for audience measurement services; and
- Appending such data elements to completed client surveys and delivering the appended survey data to clients of the Third Party MR Company(ies) for analytical or research purposes; and
We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances, we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
Legal basis, storage, and disclosure of personal data
By submitting data to the Company, you provide your permission for the Company to register and store information about which service purchased and processing the specified personal data for the specified purposes. As a legal basis for treatment, the Company will refer to the fulfillment of agreements, legitimate interest or consent. If the Company uses legitimate interest as a basis, it will only be done for the purposes stated above. Please note that you can at any time withdraw your consent by contacting us, for contact details, just go in our contact us section.
The treatment is in accordance with current legislation and means that personal data are not retained for a longer period than necessary for the purpose of the treatment. The Company will store your personal data as long as you are a customer with us. For marketing purposes, information older than 3 years is not used. This implies that data will be erased when they are no longer relevant or necessary for analysis or direct marketing for the purposes for which they have been collected. Some information may be retained longer when required due to other legal requirements. However, all handling of personal data always ensures high security and confidentiality.
What are your rights?
- Right to access:
- You have the right to request information about the personal data we hold on you at any time. You can contact BestPoints and we will provide you with your personal data via e-mail.
- Right to portability:
- Whenever BestPoints processes your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.
- Right to rectification:
- You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.
- If you have a BestPoints account you can edit your personal data under your account page.
- Right to erasure:
- You have the right to erase any personal data processed by BestPoints at any time except for the following situations:
- you have an ongoing matter with Customer Service
- you have an open order which has not yet been shipped or partially shipped
- you have an unsettled debt with BestPoints, regardless of the payment method
- if you are suspected or have misused our services within the last four years
- if you have made any purchase, we will keep your personal data in connection to your transaction for book-keeping purposes
- Your right to object to processing based on legitimate interest:
- You have the right to object to processing of your personal data that is based on BestPoints’ legitimate interest. BestPoints will not continue to process the personal data unless we can demostrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.
- You have the right to erase any personal data processed by BestPoints at any time except for the following situations:
- Your right to object to direct marketing:
- You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.
- You can opt out from direct marketing by the following means:
- following the instruction in each marketing emails by editing the settings of your BestPoints account
- By contacting us via contact us section
A cookie is a small text file that is saved to, and, during subsequent visits, retrieved from your computer or mobile device. If you use our services, we will assume that you agree to the use of such cookie.
We use permanent cookies to store your choice of start page and to store your details if you select “Remember me” when you log in.
We use session cookies for example when you use the product filtration function, to check whether you are logged in or if you put an item in your shopping bag.
We use both first- and third-party cookies to collect statistics and user data in aggregate and individual form in analysis tools to optimize our site and to present you with relevant marketing material.
Some third-party cookies are set by services that appear on our pages and are not in our control. They are set by social media providers such as Twitter, Facebook, Snapchat, Pinterest and Instagram and relate to the ability of users to share content on this site, as indicated by their respective icon.
We also use third-party cookies which performs cross-site tracking in order for us to give you marketing in other sites/channels.
What types of personal data do we process?
We will only connect your cookie ID to your personal data submitted and gathered in relation to your account, if you are logged in to your account.
Who has access to your personal data?
Data that is forwarded to third parties is only used to provide you with the services mentioned above, analysis tool in order to collect statistics to optimize our site and present you with relevant material.
What is the legal ground to process your personal data?
We will only connect your cookies to your personal data if you are logged in to your BestPoints account.
If you are logged in to your account the legal ground is based on our legitimate interest.
Accessing Your Personal Information
At any time, you may contact BestPoints at: firstname.lastname@example.org and request to access the personal information that BestPoints keeps on you. BestPoints may need to ask you to provide certain credentials to make sure that you are who you claim to be. If you find that the information on your account is not accurate, complete or updated, then please provide BestPoints the necessary information to correct it.
At any time, you may contact BestPoints at: email@example.com to receive a copy of the personal information that BestPoints keeps about you, and to verify the accuracy of the data.
If you’d like BestPoints to delete data that you have provided via the App, please contact BestPoints at firstname.lastname@example.org and BestPoints will respond in a reasonable time.
Please be advised that BestPoints may retain and use your personal information as necessary to comply with its legal obligations, resolve disputes and enforce BestPoints’ agreements.
In addition, after BestPoints deletes your personal information, residual copies may take a period of time before they are deleted from BestPoints’ active servers and may remain in its backup systems.
This deletion will not change or delete personal information which may have already been shared with third parties, as permitted in this Policy or any other agreement between you and BestPoints. BestPoints may redact from the data which it will make available to you, any personal information related to others.
Your EU Data Subject Rights
In operating the App, BestPoints processes data as a controller (as such terms are defined in the GDPR). As a controller, BestPoints is committed to fulfill data subjects’ (‘Users’) GDPR rights.
As an EU resident, you may:
- Access the data that BestPoints keeps about you. BestPoints may need to ask you to provide us certain credentials to make sure that you are who you claim you are. If you find that the data is not accurate, complete or updated, then you may provide us with the necessary information to rectify it.
- Contact us if you want to withdraw your consent to the processing of your personal information. Exercising this right will not affect the lawfulness of processing based on consent before its withdrawal.
- Request to delete or restrict access to your personal information. BestPoints may postpone or deny your request if your personal information is in current use for providing the Services or due to other legitimate purposes, such as compliance with regulatory requirements associated with BestPoints.
- If you exercise one (or more) of the above-mentioned rights, in accordance with the provisions of applicable law, you may request to be informed that third parties that hold your personal information, in accordance with this Policy, will act accordingly.
- You may ask to transfer your personal information in accordance with your right to data portability.
- You may object to the processing of your personal information for direct marketing purposes.
- You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
- You have a right to lodge a complaint with a data protection supervisory authority.
BestPoints does periodical assessments of its data processing and privacy practices, to make sure that BestPoints complies with this policy, to update the policy when needed, and to verify that the policy is displayed properly and accessible.
If you have any concerns about the way BestPoints process your personal information, you are welcome to contact BestPoints’ data protection officer at: email@example.com.
BestPoints will look into your enquiry and make good-faith efforts to resolve any existing or potential dispute with you. If you remain unhappy with the response you received, you can also refer the matter to the data protection authorities appropriate for your country.
BestPoints is concerned about safeguarding the confidentiality of your personal information. BestPoints and its hosting services implement systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.
For example, BestPoints limits access to this information to authorized personnel who need to know that information in order to operate, develop or improve the App.
These measures provide sound industry standard security. However, although BestPoints makes efforts to protect your privacy, BestPoints cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
From time to time, BestPoints may update this policy. If the updates have minor if any consequences, they will take effect 7 days after BestPoints posts a notice on the App. Substantial changes will be effective 30 days after BestPoints’ notice was initially posted.
Until the new policy takes effect, you can choose not to accept it and terminate your use of the App. Continuing to use the App after the new policy takes effect means that you agree to the new policy.
Note that if BestPoints needs to adapt the policy to legal requirements, the new policy will become effective immediately or as required.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Please contact BestPoints’ Data Protection Officer at: firstname.lastname@example.org for further information.
How to contact us:
For further information about personal data management or if you have any questions, feel free to contact us at:
Lubelskie, Łęczna 21-010
NIP (TIN): 5050131787
KRS (NCR): 0000912801
Legal form: Limited Liability Company
Incorporated on 21 July 2021
Contact Customer service:
- Email: email@example.com
- Phone: +48 736 856 621