Privacy Policy

The following Policy sets out how ABATURION LTD (“we”, “us”, “the Company”) handles personal information gathered through tradenear.net (the “Platform”). We adhere to the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Accessing the Platform after reading this Policy signifies your acknowledgement of and agreement to the practices described.

A. PURPOSES AND LEGAL GROUNDS FOR PROCESSING

We process personal data only where a valid legal basis exists under UK GDPR. The table below summarises our principal processing activities:

B. CATEGORIES OF INFORMATION WE HOLD

Depending on your interactions with the Platform, we may collect and retain the following categories of personal data:

(i) Contact and identity details: name, email address, and billing information provided during checkout or account setup.

(ii) Steam profile data: your Steam username, Steam ID, trade URL, and trade history, obtained via Steam authentication and essential for delivering purchased items.

(iii) Order and transaction records: details of every purchase including item type, price, payment confirmation, and fulfilment status.

(iv) Payment information: processed exclusively by our PCI DSS certified payment provider. We do not receive, store, or access raw card numbers, CVV codes, or expiry dates.

(v) Verification documentation: identity papers and address evidence collected solely when a compliance or KYC trigger is activated.

(vi) Technical and device data: IP address, browser type, operating system, device identifiers, session duration, and navigation data recorded automatically upon Platform access.

(vii) Correspondence: records of communications submitted through our support channels or contact interfaces.

(viii) Cookie data: information gathered via cookies and tracking technologies as described in our Cookie Policy.

C. SOURCES OF PERSONAL DATA

(i) Directly from you at the point of order placement, account interaction, or when contacting support.

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

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

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

D. PAYMENT PROCESSING AND 3D SECURE

All payment transactions executed on the Platform are processed solely by our authorised third-party payment service provider, which holds current PCI DSS certification. The Company has no access to raw cardholder data at any stage. Sensitive payment credentials are handled entirely within the payment provider’s secure infrastructure.

Card payments are subject to 3D Secure (3DS) authentication where required under the applicable payment method or card scheme. This verification step confirms cardholder identity with the issuing bank before a transaction is approved. Where a transaction is subject to automated risk evaluation, you may request manual review by contacting info@tradenear.net

E. DISCLOSURE TO THIRD PARTIES

We do not sell, lease, or exchange your personal data. Sharing occurs only in the circumstances listed below:

(i) Payment providers and acquiring banks, for transaction processing, authentication, and fraud monitoring.

(ii) Steam (Valve Corporation), to the extent necessary to execute item delivery via trade offer.

(iii) Infrastructure and technology partners engaged for hosting, analytics, and customer communications, operating under data processing agreements that preclude independent use of your data.

(iv) Regulatory authorities and law enforcement, where disclosure is required by law, regulation, or court order.

(v) Professional advisers including solicitors and accountants, subject to professional confidentiality obligations.

F. CROSS-BORDER DATA TRANSFERS

Your data is primarily processed within the United Kingdom. Where third-party partners operate internationally, transfers outside the UK or EEA are underpinned by appropriate legal safeguards, which may include UK Government adequacy decisions, International Data Transfer Agreements (IDTAs), or Standard Contractual Clauses. Contact info@tradenear.net for information on specific transfer safeguards.

G. RETENTION SCHEDULES

(i) KYC and AML records: minimum five (5) years from the conclusion of the business relationship, in compliance with Regulation 40 of the MLRs 2017 and the Proceeds of Crime Act 2002.

(ii) Order and financial records: up to six (6) years for accounting and regulatory compliance.

(iii) Support communications: up to three (3) years, or longer where a dispute or legal matter is unresolved.

(iv) Cookie and analytics data: per the applicable tool’s retention cycle or until cleared via browser settings.

Data is securely deleted or anonymised upon expiry of the applicable retention period, in line with our internal disposal procedures.

H. SECURITY

We apply proportionate technical and organisational safeguards including encryption in transit and at rest, strict role-based access controls, and ongoing security review processes. No internet transmission is entirely risk-free; you bear responsibility for safeguarding your own account credentials.

I. YOUR RIGHTS AS A DATA SUBJECT

UK GDPR grants you the following rights. Submit requests to info@tradenear.net; we will respond within one calendar month.

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

(ii) Rectification — correct inaccurate or incomplete records.

(iii) Erasure — request deletion where no lawful basis for retention remains.

(iv) Restriction — limit our use of your data in specific circumstances.

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

(vi) Objection — object to processing founded on legitimate interests.

(vii) Withdrawal of consent — where processing is consent-based, revoke at any time without affecting prior lawful processing.

(viii) Complaint — lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk.

The Platform is intended for users aged 18 and over. We do not knowingly process data belonging to minors.

J. COOKIES AND POLICY UPDATES

Our use of cookies is described in our Cookie Policy, available at COOKIE POLICY. This Privacy Policy is reviewed periodically; material revisions are published with an updated effective date. Continued Platform use following any revision constitutes acceptance.

ABATURION LTD • tradenear.net • info@tradenear.net

Registered in England and Wales • Company No: 17358825