3. Cases in which Overgear collects and processes Personal DataWe collect your Personal Data in specific cases during your interaction with our Website and Services, including:
- Website Visits: When Users visit the Website or use the Platform, we may automatically collect technical data, including IP address, device and browser information, session identifiers, pages visited, URLs or paths, timestamps, cookies and similar identifiers, performance data and security logs. We use this data for Website functionality, security, fraud prevention, bot detection, troubleshooting, analytics, product analytics, error tracking and service improvement. IP addresses and technical logs used for security, fraud prevention, payment risk checks, abuse prevention or compliance may be retained for a period reasonably necessary for those purposes, including where required by payment providers or applicable law. IP addresses and similar technical data used primarily for product analytics are subject to separate retention limits and, where technically feasible, may be anonymised, truncated, discarded or aggregated.
- Account Creation and Updates: When registering or updating your Overgear Account, we collect your email address, username, and social network profile (if registered via social login).
- Chat Communications: Your messages exchanged in Online Chat are stored to facilitate the provision of Seller Services, maintain quality, and ensure compliance with platform rules.
- Order Placement: We process Personal Data necessary to administer Orders, payments, refunds, delivery coordination, fraud prevention and customer support. Certain payment methods may require additional information, such as full name, billing address, country, city, phone number, postcode, payment identifiers, or other payment-related details required by the relevant payment provider.Payments are processed through certified third-party payment service providers, acquiring banks, payment processors, card schemes or other payment partners. Full card numbers, CVV/CVC codes and other sensitive payment authentication data are processed by such certified third-party providers and are not intentionally stored by Overgear. Overgear may receive and securely store limited payment-related data necessary for transaction administration, refunds, chargebacks, reconciliation, fraud prevention and compliance, such as the payer’s name, billing details, transaction references, payment status, payment method, payment identifiers, masked card details, card type, card expiry date, last four digits, payment tokens, chargeback records and refund records. Where Users choose to save payment credentials for future transactions, such processing is carried out in accordance with applicable payment provider rules, PCI DSS requirements, and Overgear’s Agreement on the Storage and Usage of Credentials on File or equivalent payment credentials terms..
- Post-Purchase Information: Additional game-specific details (e.g., server or character names) provided after placing an Order are stored securely to enable efficient delivery of services.
- Identity Verification, Fraud Prevention & KYC: We may collect and process Personal Data including full name, date of birth, contact information, residential address, proof of address, biometric data (such as facial images or liveness check data), geolocation data (IP address), government-issued identification documents, transaction history, payment-related data, source-of-funds or source-of-wealth information, device data, risk signals, screening results, fraud indicators and other relevant information required to comply with Know Your Customer (KYC), Anti-Money Laundering (AML), fraud prevention, and AML/CFT regulations. Data is securely processed and transferred through GDPR-compliant third-party providers such as Sumsub and Sift.
- Online Forms and Data Collection (Jotform): We may collect and process Personal Data via online forms powered by Jotform for purposes such as identity verification, Seller recruitment, service delivery, processing requests for exercising data subject rights (including GDPR Right to Erasure requests), and compliance with legal obligations. Collected data typically includes name, surname, usernames, email addresses, phone numbers, messenger contacts, birthdates, identity document copies (e.g., passports), and other necessary data. Jotform securely processes and stores data under GDPR-compliant standards, with international data transfers protected by Standard Contractual Clauses (SCCs).
- Marketing & Analytics: With your explicit consent, we collect and transfer Personal Data to marketing and analytics partners for Website usage analysis and advertising campaign management. Data collected and transferred includes IP addresses, cookies, device and browser identifiers, behavioral metrics, and other interactions with our Website and advertisements. Such data processing is performed by third-party providers including Maestra, Mixpanel, Hotjar, Google Analytics, Facebook Ads, Bing Ads, Google Ads, Red Tracker, and other services as detailed in Section 2.4 of this Privacy Policy. We may use self-hosted PostHog within the EEA for product analytics and event-based analytics. Such analytics may include account-linked identifiers, including internal user IDs, email addresses, nicknames, User roles or account types, where reasonably necessary for product analytics, internal reporting, technical diagnostics, feature usage measurement, fraud or abuse detection, customer support or improvement of the Platform. We do not intentionally send payment card data, sensitive authentication data, KYC documents, passwords, private chat content, full account credentials or other sensitive information to product analytics tools.
- Technical Infrastructure & Security: To ensure the stability, security, and performance of our technical infrastructure, we collect technical data including IP addresses, device and browser metadata, technical logs, and session details. This data is processed by trusted third-party providers (e.g., Datadog) implementing stringent security measures and international safeguards, such as Standard Contractual Clauses (SCCs), to guarantee data protection.
- Booster-specific Data Collection and Processing: To register, verify identity, manage payouts, and deliver Booster (Seller) services, Overgear collects and processes Personal Data including full name, residential address, date of birth, contact information (email, WhatsApp, Telegram, Skype, Discord), copies of identification documents (such as passports), and payment processing details (name, phone number, payment card details). Payment card details are securely processed exclusively through certified payment service providers and stored in compliance with the applicable data protection and PCI DSS standards. Overgear processes this data strictly to fulfill contractual obligations, facilitate secure transactions, perform identity verification, and ensure compliance with relevant regulatory requirements.
- Phone Numbers, WhatsApp, SMS and Messaging Contacts: We may request that Users provide phone numbers, WhatsApp numbers or other messaging contact details for urgent, emergency, order-related, customer support, delivery coordination, dispute resolution, refund, payment, security, compliance or account-related communications. Such data may be collected through the Platform, order forms, delivery details forms, Intercom workflows, customer support chats, WhatsApp, SMS or similar communication channels. Where providing a phone number is optional, Users may choose not to provide it. Where a phone number is necessary for a specific service, order type, delivery coordination, fraud prevention, security, compliance or customer support process, we will inform Users accordingly at or before the point of collection.
During promotional activities—such as Special Campaigns (in accordance with the Overgear Bonus Policy), marketing events, and similar initiatives—we may collect additional User data specifically to manage and track event participation. Such data may include:
- Promotional codes and registration details;
- Engagement metrics and user interactions specific to events or campaigns.
This Personal Data is securely transmitted to trusted third-party analytics and marketing platforms (such as Maestra and Mixpanel) solely for processing and analytical purposes. Such transfers are performed in strict compliance with applicable data protection laws, including GDPR, and subject to the same rigorous safeguards as applied to our standard data processing operations.
Data processing for promotional and marketing purposes is conducted exclusively with your explicit consent. You have the right to withdraw this consent or opt out at any time by contacting our Customer Service at
support@overgear.com.Controller Information: All Personal Data of users is legally stored and managed in compliance with data processing legislation, including GDPR and the Law on Personal Data Protection.
OVERGEAR LIMITED is the controller for storage and processing of Personal Data, registered to an address Diagorou 4, Kermia Building, 3rd floor, office 304, 1097, Nicosia, Cyprus.
4. Storage and processing of Personal DataOvergear stores and processes Personal Data using secure infrastructure and trusted hosting, cloud, backup, infrastructure and technical service providers selected with regard to data protection, security, reliability and operational requirements.
OVH is Overgear’s primary hosting and infrastructure provider for the Platform. Personal Data may also be stored, backed up, or otherwise processed through other hosting, cloud, backup and infrastructure providers used by Overgear from time to time, including but not limited to:
- OVH;
- DigitalOcean;
- Contabo;
- UltaHost;
- AWS, including for backup and disaster recovery purposes;
- other authorised hosting, cloud, backup, infrastructure or technical service providers.
The specific hosting, cloud, backup and infrastructure providers, data centre locations and regions used by Overgear may vary depending on technical, security, operational, compliance and business requirements.
Where Overgear uses self-hosted tools, including self-hosted PostHog for product analytics, such tools are configured on infrastructure controlled by Overgear or its authorised hosting providers.
Some service providers may process Personal Data in jurisdictions outside the EEA where necessary for the purposes described in this Privacy Policy, including hosting, backups, customer support, payments, KYC/EKYC, fraud prevention, sanctions screening, analytics, product analytics, marketing automation, infrastructure monitoring, security, workflow automation and other operational or compliance purposes. International transfers are handled in accordance with Section 5 of this Privacy Policy.
Overgear applies appropriate technical and organisational measures designed to protect Personal Data against unauthorised access, loss, misuse, alteration, disclosure or destruction.
5. International Data TransfersPersonal Data may be transferred to, stored in, or accessed from countries outside the EEA where necessary for the purposes described in this Privacy Policy, including where Overgear uses hosting, cloud, backup, infrastructure, payment, KYC/EKYC, fraud prevention, analytics, product analytics, customer support, marketing, security, communication, workflow automation or other service providers located in or providing services from other jurisdictions.
Where Personal Data is transferred outside the EEA, Overgear relies on appropriate transfer mechanisms and safeguards as required by applicable data protection laws, including adequacy decisions, Standard Contractual Clauses, transfer impact assessments, supplementary safeguards, or other lawful transfer mechanisms where applicable.
Overgear periodically reviews its service providers, hosting locations, backup locations and transfer mechanisms to maintain an appropriate level of protection for Personal Data.
6. Publicly Available DataTo encourage interaction between Users, the following data may be publicly displayed on our Website:
- Your nickname;
- Personal Profile rating;
- Reviews left by other Users;
- Total number of transactions and success rate.
Additional Points:- Any other data you provide in your personal Profile or share with a Seller during a Deal will remain private and is not subject to public display under this Privacy Policy.
- You are solely responsible for the Personal Data you choose to publish. Please be mindful that sharing sensitive contact details (such as phone numbers or email addresses) in public areas may lead to your Account being blocked, in accordance with our User Agreement.
- We take steps to secure the privacy of all correspondence between Buyers and Sellers conducted via our Website. However, you should always exercise caution when sharing personal information.
7. Data Protection and Security MeasuresOvergear employs comprehensive security practices to protect your Personal Data in compliance with GDPR and applicable data protection laws. Our security framework includes:
- Secure Data Storage: Data is stored securely and processed automatically on protected servers.
- Restricted Data Access: Only authorized Overgear personnel can access your data strictly to provide and enhance services.
- Technical Safeguards: Utilization of encryption, firewalls, and ongoing risk assessments.
- Staff Training: Mandatory information security training for all employees.
- Payment Security: Payments are processed through certified third-party payment service providers, acquiring banks, payout providers or other payment partners. Overgear does not intentionally store full payment card numbers, CVV/CVC codes or sensitive authentication data. Limited payment-related data may be processed for order administration, refunds, chargebacks, reconciliation, fraud prevention and compliance.
Security Incident Response: In the event of a suspected or confirmed Personal Data breach, Overgear will take appropriate steps to investigate, mitigate and remediate the incident and, where required by applicable law, notify affected Users and competent supervisory authorities.
8. Users’ rights regarding their Personal Data and the WebsiteIn compliance with GDPR, you have the following rights regarding your Personal Data:
8.1. Right to Access: You may request information about what Personal Data we store and how we use it.
8.2. Right to Rectification:You may ask us to correct, update, or delete your Personal Data if inaccurate, incomplete, or outdated.
8.3. Right to Restriction of Processing:You may request that we restrict data processing, such as unsubscribing from marketing communications.
8.4. Right to Erasure (“Right to be Forgotten”):You may request complete deletion of your Personal Data. Note that transaction history or data necessary for legal compliance may be retained.
8.4.1. To exercise your right to erasure under Article 17 of the GDPR, please complete our
Erasure Request Form. The form requires you to provide your full name, contact details, and the necessary identification documents (e.g., a copy of your passport, driver’s license, or national ID) to verify your identity. Once we receive your complete request along with all required documentation, we will review your submission and respond within 1 (one) month. Please note that if the provided documentation is incomplete, your request may be delayed until sufficient evidence is submitted.
8.5. Right to Data Portability: You may request a structured, machine-readable copy of your data for transfer to another service provider.
8.6. Right to Object: You may object to data processing for purposes including direct marketing, research, or analytics.
8.7. Right Against Automated Decision-Making: You have the right to oppose decisions based solely on automated processing, including profiling.
8.8. Right to Lodge a Complaint: If you believe your GDPR rights have been violated, you may file a complaint with the relevant supervisory authority.
8.9. Right to Managing Consent: You have the right to manage or withdraw your consent for processing activities at any time. You can do so by contacting Customer Support at
support@overgear.com.To exercise these rights, contact us at
support@overgear.com or use our dedicated online form. Overgear responds to all valid GDPR-related requests within 30 (thirty) days, unless legally permitted extensions apply.
8.10. Overgear reserves the right to refuse any request for data erasure or access that is manifestly unfounded or excessive, in accordance with Article 12(5) of the GDPR. In such cases, we may charge a reasonable fee for processing the request. This measure is implemented to ensure that processing such requests does not impose an undue burden on our systems and to protect the rights and freedoms of other Users.
8.11. California Residents (CCPA): Where applicable, California residents may have additional rights under California privacy laws, including rights to know, access, delete, correct and opt out of certain uses or disclosures of Personal Information. Overgear does not sell Personal Data in the ordinary meaning of “sale.” To exercise applicable rights, please contact us at
legal@overgear.com.8.12. If you have concerns or complaints regarding Overgear’s compliance with personal data protection laws, you have the right to contact the relevant supervisory authority:
Office of the Commissioner for Personal Data Protection (Cyprus)Website: http://www.dataprotection.gov.cyEmail: commissioner@dataprotection.gov.cy
Phone: +357 22 818456
9. Disclaimer Regarding External Content and LinksUsers of Overgear may post content and links to external resources in accordance with our User Agreement. To safeguard Personal Data, our Customer Service team monitors compliance with these provisions and removes any user-posted content (or User-Generated Content) or links that pose a security risk to other Users. Please note that while we review such submissions for potential threats, we do not re-moderate posted products, auctions, or online chats once they have been approved.
By posting or interacting with external content, you acknowledge that Overgear is not affiliated with these external resources and does not endorse their content or practices. Consequently, Overgear expressly disclaims any direct or indirect liability for any damages, data loss, or account data theft that may result from following external links or engaging with content on third-party sites. Users are strongly advised to exercise caution and review the privacy and security policies of any external sites they visit, as Overgear does not control or guarantee the practices or content of such sites.
10. Data Breach NotificationIn the event of a data breach or unauthorized access to Personal Data, Overgear will promptly notify affected Users and the relevant regulatory authorities in accordance with applicable law. We will take immediate steps to investigate the incident, mitigate its effects, and prevent future breaches. Detailed information and recommendations will be provided to affected Users as soon as possible.
11. Account Security and ProtectionTo safeguard your Account, we recommend that you:
- Use strong, unique passwords and change them regularly.
- Enable two-factor authentication, if available.
- Keep your login credentials confidential.
- Immediately notify Customer Support if you suspect any unauthorized activity.
While Overgear employs robust security measures, you are also responsible for maintaining the security of your Account.
12. Advertising and Marketing CommunicationsWhere permitted by applicable law, Overgear may use Personal Data to send marketing, promotional, reactivation, upsell, cross-sell, newsletter or similar commercial communications by email, SMS, WhatsApp, Intercom, Maestra or other channels.
Such communications will be sent only where permitted by applicable law, including on the basis of consent, soft opt-in where legally available, or another applicable lawful basis.
Users may opt out of marketing communications at any time by using the unsubscribe or opt-out instructions included in the relevant message, replying with an applicable opt-out keyword where supported, adjusting communication preferences where available, or contacting Customer Support.
Opting out of marketing communications does not prevent Overgear from sending service-related, transactional, security, legal, compliance, account-related or order-related communications that we are permitted or required to send.
Users may opt out of marketing communications, targeted advertising, sale or sharing of Personal Data, profiling, or similar processing activities where such rights are available under applicable law.
Overgear will provide appropriate opt-out mechanisms, including through cookie settings, privacy preference tools, unsubscribe links, Customer Support, or other methods made available on the Platform.
Opting out of marketing, targeted advertising or personalization does not prevent Overgear from sending service-related, transactional, security, legal, compliance or account-related communications where such communications are necessary or permitted by applicable law.
13. Cookies and Tracking TechnologiesOvergear uses cookies, web beacons, pixels, tags, SDKs and similar tracking technologies to operate the Website and Platform, improve service quality, analyze User behavior, measure Website and Platform performance, support product analytics, remember User preferences, ensure security, prevent fraud, and, where permitted, deliver personalized content or advertising.
Depending on the User’s location and applicable law, certain Cookies and similar technologies may be used only after the User has provided consent, while others may be used under an opt-out model where legally permitted.
Users may manage or change their Cookie Preferences through the cookie banner, cookie preference center, browser settings, device settings, or other tools made available on the Website.
Location-Based Consent and Opt-Out MechanismsDepending on the User’s location and applicable law, Overgear may apply different cookie consent, preference management and opt-out mechanisms.
Where prior consent is required by applicable law, non-essential Cookies and similar tracking technologies will be used only after such consent is obtained.
Where applicable law allows an opt-out model, Overgear may use certain analytics, advertising, product analytics or similar technologies by default, provided that Users are given clear information and an effective opportunity to opt out.
The specific categories of technologies enabled by default may vary depending on the User’s location, applicable law, and Overgear’s internal compliance settings. For example, in certain jurisdictions Overgear may enable analytics technologies by default while keeping advertising, retargeting, personalization or similar technologies disabled until the User makes a choice.
Where required by applicable law, Overgear will honor applicable opt-out preference signals, such as Global Privacy Control or other legally recognized universal opt-out mechanisms.
For more detailed information, please refer to our
Cookie Policy.
14. Data Retention and Deletion We retain Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including account administration, order administration, customer support, dispute resolution, refund processing, fraud prevention, security, compliance, accounting, tax, AML/CTF, sanctions screening, legal claims and enforcement of our Terms and Conditions.
Retention periods may vary depending on the type of data, purpose of processing, applicable legal requirements, payment provider rules, dispute or chargeback periods, fraud prevention needs, security requirements and operational necessity.
Account-related information is generally retained while the Account remains active and for a reasonable period after deactivation where necessary for legal, security, dispute resolution, fraud prevention or compliance purposes.
Transaction, payment, accounting and tax-related records may be retained for the period required by applicable law, generally up to 5 (five) years or longer where required by law or necessary for legal claims, audits, chargebacks or regulatory purposes.
Chat, support and communication data may be retained for up to 3 (three) years after the last interaction, unless a longer period is necessary for dispute resolution, legal claims, fraud prevention, compliance or security purposes.
KYC/EKYC, AML/CTF, sanctions screening and fraud prevention data may be retained for the period required by applicable law, regulatory obligations, payment provider requirements, risk management, fraud prevention or legal claims.
Analytics and product analytics data, including data processed through self-hosted tools such as PostHog, may be retained for a limited period necessary for product improvement, technical diagnostics, feature usage analysis, business analytics, internal reporting, error tracking, security and fraud or abuse detection.
Where PostHog or similar product analytics tools process IP addresses primarily for product analytics, Overgear seeks to minimise such processing by disabling IP storage, truncating, anonymising, discarding, aggregating or shortening retention where technically feasible.
Full IP addresses processed primarily for product analytics should not be retained longer than necessary for the relevant purpose. Unless a longer period is justified by security, fraud prevention, payment risk, legal, compliance or technical necessity, such data should be retained for no longer than 90 (ninety) days.
Aggregated, anonymised or non-identifiable analytics data may be retained for a longer period for statistical, product improvement, reporting and business analytics purposes.
Consent, opt-in and opt-out records may be retained as necessary to demonstrate compliance with applicable laws, platform rules and internal compliance procedures.
Upon expiration of applicable retention periods, Personal Data will be deleted, anonymized or aggregated unless continued retention is required or permitted by applicable law.
15. Privacy Policy ChangesOvergear reserves the right to modify or update this Privacy Policy at any time to reflect changes in our Services, practices, or legal requirements. In the event that no specific effective date is provided, any material changes will automatically become effective 30 (thirty) days after being posted on this page. We will communicate any material changes to you via email, prominent notices on our Website, and through our Online Chat. Your continued use of our Services after the effective date constitutes your acceptance of the revised terms. We remain committed to respecting our Users’ rights and ensuring transparency in how your Personal Data is managed.
16. Contact InformationIf you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Customer Support at:
- Email: support@overgear.com
- Postal Address: Diagorou 4, Kermia Building, 3rd Floor, Office 304, 1097 Nicosia, Cyprus
If your concerns about personal data protection compliance are not addressed satisfactorily, you have the right to lodge a complaint with your local supervisory authority:
- Office of the Commissioner for Personal Data Protection (Cyprus)
- Website: http://www.dataprotection.gov.cy
- Email: commissioner@dataprotection.gov.cy
- Phone: +357 22 818 456
By using Overgear’s Website and Services, you acknowledge that you have read, understood, and agree to the collection and use of your Personal Data as described in this Privacy Policy.