PRIVACY POLICY

PRIVACY POLICY – aceclutch.org

Effective Date: 17/04/2026

This Privacy Policy describes how aceclutch.org (the “Website”, “we”, “us”, “our”) collects and processes personal information when you access our services, including the purchase and transfer of digital in-game items.

By using the Website, you acknowledge that your personal data will be handled as described in this Policy.

1. DATA CONTROLLER

The entity responsible for processing personal data is:

MIKHPETECH LTD Company No. 16774228 Registered in England and Wales Registered office: 10 Fenchurch Avenue, London, England, EC3M 5BN

Contact email: info@aceclutch.org

2. TYPES OF DATA WE PROCESS

We may collect and process the following categories of information:

Personal and Contact Information

Includes details such as your name, email address, and billing-related information provided during transactions.

Transaction Records

Information relating to your purchases, including order details, confirmations, and history of activity on the Website.

Payment Information

Payment data is handled by external payment providers. We do not store full card numbers or sensitive payment credentials.

Steam and Trade Data

Your Steam username, trade link, and information required to complete item transfers.

Technical Data

Automatically collected data such as:

● IP address

● Browser type and version

● Device and operating system

● Referral URLs and interaction data

Communication Data

Any information you provide when contacting support or communicating with us.

Verification Data

Where required, we may process identity verification information (e.g., ID documents, proof of address) to comply with legal and regulatory obligations (AML/KYC requirements).

3. METHODS OF COLLECTION

We obtain personal data through:

● Direct interactions (e.g., account use, purchases, support requests)

● Automated technologies (e.g., cookies and analytics tools)

● Third-party providers, including payment processors and fraud-prevention services

4. PURPOSES OF PROCESSING

We use personal data for the following purposes:

● To process and complete transactions, including delivery of digital items via Steam

● To provide customer support and respond to inquiries

● To maintain, secure, and improve Website functionality

● To detect and prevent fraud, abuse, and unauthorized activity

● To comply with legal and regulatory requirements, including financial and anti-money laundering obligations

● To enforce our Terms and policies

We only process data where there is a valid legal basis, such as contractual necessity, legal compliance, or legitimate interest.

We process personal data on the following legal bases:

Contractual necessity – to provide the requested services, including account access, transactions, and delivery of digital items

Legal obligation – to comply with applicable laws, including anti-money laundering and regulatory requirements

Legitimate interests – to maintain platform security, prevent fraud, improve services, and ensure

proper operation of the Website, provided such interests are not overridden by your rights

Consent – for marketing communications and the use of non-essential cookies, where applicable

 

5. DATA SHARING

We may share your data with trusted third parties where necessary, including:

● Payment service providers, banks, and card networks

● Technical vendors (hosting, analytics, infrastructure, communications)

● Platforms required to complete transactions (e.g., Steam/Valve)

● Legal, regulatory, or governmental authorities where required by law

We do not sell or rent your personal data to third parties.

Sensitive payment details are processed exclusively by authorised payment providers and are not stored by us.

6. COMMUNICATIONS

We may contact you via email for:

● Transaction confirmations and updates

● Service-related notifications

● Security alerts

● Marketing messages (only if you have opted in)

You may unsubscribe from marketing communications at any time. Service-related communications may still be sent where necessary.

7. COOKIES AND TRACKING TECHNOLOGIES

The Website uses cookies and similar technologies to ensure proper functionality, improve user experience, analyse usage, and support marketing activities.

Strictly necessary cookies are used to enable core functionality of the Website and do not require user consent. All other cookies, including analytics and marketing cookies, are used only with your prior consent.

Upon your first visit, you will be presented with a cookie banner allowing you to accept or reject non-essential cookies, or manage your preferences. You may withdraw or modify your consent at any time through the cookie settings available on the Website or via your browser.

Further details regarding the types of cookies used, their purposes, and retention periods are available in our Cookie Policy.

8. DATA RETENTION

We retain personal data only for as long as necessary:

● Transaction and financial records: up to 6 years (for legal and accounting purposes)

● KYC/AML data: minimum 5 years or longer if required by law

● Support communications: as needed to resolve issues and maintain records

● Cookies and analytics data: according to their lifecycle or until deleted

9. YOUR RIGHTS

Under applicable data protection laws (UK GDPR), you have the right to:

● Access your personal data

● Request correction of inaccurate information

● Request deletion of your data

● Restrict or object to certain processing

● Receive your data in a portable format

● Withdraw consent where applicable

To exercise your rights, contact: info@aceclutch.org

You may also file a complaint with the UK Information Commissioner’s Office (ICO): https://www.ico.org.uk

Age Restriction

Our services are intended for individuals aged 18 or older. We do not knowingly collect personal data from individuals under this age. If we become aware that such data has been collected, we will take appropriate steps to delete it.

10. INTERNATIONAL DATA TRANSFERS

Your data may be transferred outside the UK or EEA, including to payment providers or financial institutions. Where such transfers occur, we ensure appropriate safeguards are implemented (e.g., Standard Contractual Clauses).

11. DATA SECURITY

We implement appropriate technical and organisational measures to protect personal data, including:

● Encryption where applicable

● Restricted access controls

● Monitoring systems for fraud prevention

Despite these measures, no system can be guaranteed to be completely secure.

Certain transactions and activities on the Website may be subject to automated decision-making processes, including fraud detection and payment authorization carried out by third-party payment providers or security systems.

These processes may analyse factors such as transaction patterns, location data, or risk indicators to prevent fraud and ensure compliance with legal obligations.

Where such processing produces legal or similarly significant effects, you have the right to request human intervention, express your point of view, and contest the decision by contacting us at info@aceclutch.org.

12. POLICY CHANGES

We reserve the right to update this Privacy Policy. Any changes will be published on this page with a revised effective date.

Continued use of the Website indicates acceptance of the updated Policy.

13. CONTACT DETAILS

MIKHPETECH LTD
10 Fenchurch Avenue London, England, EC3M 5BN
Company No. 16774228

Email: info@aceclutch.org