Privacy Policy

This Policy explains how DOM POUCH LTD ("we", "us", "the Company") handles the personal data we collect through swapyard.net (the "Platform"). We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. By continuing to use the Platform after reading this Policy, you confirm that you understand and accept the practices set out below.

A. WHY WE PROCESS YOUR DATA & OUR LEGAL BASIS

We only process personal data where we have a proper legal basis to do so under UK GDPR. Here's a summary of what we do and why:

B. WHAT WE COLLECT

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

(i) Contact and identity details — your name, email address, and billing information given at checkout or when setting up your account.

(ii) Steam profile data — your Steam username, Steam ID, trade URL, and trade history, obtained via Steam login and needed to deliver your purchases.

(iii) Order and transaction records — what you bought, the price, payment confirmation, and delivery status.

(iv) Payment details — handled entirely by our PCI DSS-certified payment provider. We never receive, store, or see your full card number, CVV, or expiry date.

(v) Verification documents — ID and proof of address, but only collected when a compliance or KYC check is triggered.

(vi) Technical and device data — your IP address, browser type, operating system, device identifiers, session length, and browsing activity, gathered automatically when you use the Platform.

(vii) Correspondence — records of anything you send us through support or contact channels.

(viii) Cookie data — as described in our Cookie Policy.

C. WHERE YOUR DATA COMES FROM

(i) Directly from you, when you place an order, manage your account, or contact support.

(ii) Automatically, through server logs, analytics tools, and cookies as you browse the Platform.

(iii) Through Steam, when you log in using your Steam credentials.

(iv) From trusted third parties, including payment processors, fraud-prevention services, and sanctions-screening providers.

D. PAYMENTS & 3D SECURE

Every payment made on the Platform is handled entirely by our authorised third-party payment provider, which holds current PCI DSS certification. We never have access to raw card data at any point — sensitive payment information stays within the payment provider's own secure systems.

Card payments may be subject to 3D Secure (3DS) checks, depending on the payment method or card network. This step lets your bank confirm it's really you before the payment goes through. If a transaction is automatically flagged as risky, you can ask for a manual review by emailing info@swapyard.net.

E. WHO WE SHARE YOUR DATA WITH

We never sell, rent, or trade your personal data. We only share it in these situations:

(i) With payment providers and banks, to process payments, verify identity, and monitor for fraud.

(ii) With Steam (Valve Corporation), where necessary to deliver your item via trade offer.

(iii) With technology partners who help with hosting, analytics, and customer communication — all bound by agreements that stop them from using your data independently.

(iv) With regulators or law enforcement, where we're legally required to disclose information.

(v) With professional advisers, such as lawyers or accountants, who are bound by confidentiality rules.

F. SENDING YOUR DATA ABROAD

Most of your data stays within the United Kingdom. Where our partners operate internationally, any transfer outside the UK or EEA is protected by appropriate safeguards — which might include UK Government adequacy decisions, International Data Transfer Agreements (IDTAs), or Standard Contractual Clauses. Email info@swapyard.net if you'd like more detail on the specific safeguards that apply.

G. HOW LONG WE KEEP YOUR DATA

(i) KYC and AML records — kept for at least five (5) years after our relationship with you ends, in line with Regulation 40 of the MLRs 2017 and the Proceeds of Crime Act 2002.

(ii) Order and financial records — kept for up to six (6) years for accounting and regulatory purposes.

(iii) Support correspondence — kept for up to three (3) years, or longer if a dispute is still unresolved.

(iv) Cookie and analytics data — kept for whatever period the relevant tool allows, or until you clear it through your browser.

Once the relevant retention period ends, we securely delete or anonymise the data in line with our internal procedures.

H. HOW WE KEEP YOUR DATA SAFE

We use a combination of technical and organisational measures — including encryption both in transit and at rest, role-based access controls, and regular security reviews — to protect your information. No method of transmission over the internet is completely risk-free, so you're also responsible for keeping your own account details secure.

I. YOUR RIGHTS

Under UK GDPR, you have the following rights. Send any request to info@swapyard.net, and we'll respond within one calendar month:

(i) Access — get a copy of the personal data we hold about you.

(ii) Rectification — have inaccurate or incomplete data corrected.

(iii) Erasure — ask us to delete your data where there's no legal reason left for us to keep it.

(iv) Restriction — limit how we use your data in certain circumstances.

(v) Portability — get your data in a machine-readable format.

(vi) Objection — object to processing that's based on our legitimate interests.

(vii) Withdrawing consent — where processing relies on consent, withdraw it at any time, without affecting anything already processed lawfully.

(viii) Complaints — raise a complaint with the Information Commissioner's Office at www.ico.org.uk.

The Platform is intended for people aged 18 and over. We don't knowingly collect data from anyone younger than that.

J. COOKIES & UPDATES TO THIS POLICY

Our approach to cookies is set out in our Cookie Policy, available at swapyard.net/cookie-policy/. We review this Privacy Policy from time to time, and any significant changes will come with an updated effective date. If you keep using the Platform after a change, that means you accept it.

DOM POUCH LTD • swapyard.net • info@swapyard.net

Registered in England and Wales • Company No: 17380032