Controller and Data Protection Officer
3. The controller of the Customer’s personal data is Gamekeys OÜ, registry code 12526262, address Harju county, Tallinn, Kesklinn city district, Tornimäe 5, 10145.
Principles governing the processing of personal data
5. Gamekeys shall process the personal data provided by the Customer in accordance with the requirements of applicable law and shall always bear in mind the interests, rights and freedoms of the Customer when processing the personal data.
6. The purpose of Gamekeys is to process personal data responsibly and based on best practices, bearing in mind that Gamekeys is always ready to demonstrate that the processing of personal data is compatible with the intended purposes.
7. All the processes, instructions, procedures and activities related to the processing of personal data by Gamekeys are based on the following principles:
7.1. Lawfulness. The processing of personal data has a legal basis, such as consent;
7.2. Fairness. We ensure that the processing of personal data is fair, in particular by requesting that the Customer has sufficient information on how the personal data is processed;
7.3. Transparency. The processing of personal data is transparent for the Customer;
7.4. Purpose limitation. The personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
7.5. Data minimisation. The personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed The processing of personal data by Gamekeys is based on the principle of minimal processing and if personal data are no longer necessary or are no longer necessary for the purpose for which these data were collected, the personal data shall be deleted;
7.6. Accuracy. The personal data shall be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
7.7. Storage limitation. The personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. This means that if Gamekeys wishes to store the personal data longer than necessary for the purpose for which these data were collected, Gamekeys will anonymise the data in such a way that the Customer is no longer identifiable;
7.8. Integrity and confidentiality. The personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
7.9. Data protection by default and by design. Gamekeys ensures that all systems used meet the required technical criteria. Appropriate data protection measures have been planned upon upgrading or designing any information and data systems (e.g. information systems and business processes have been developed based on the prerequisites of pseudonymisation and encryption).
8. When processing personal data, Gamekeys is always guided by the purpose of being able to provide proof of adherence to the aforementioned principles, and additional information on following such principles can be requested by email ([email protected]).
Purposes of the processing of personal data
9. Gamekeys processes the personal data of the Customer for the following purposes:
9.1. To enter into an agreement with the Customer and register him/her as a loyal customer, i.e. to register the Customer as a member of the Gamekeys environment and carry out activities related to the registration, to contact the Customer in connection with the membership, and to identify the Customer if the Customer contacts Gamekeys;
9.2. To provide services to the Customer, including the sale of products and delivery of the ordered products to the Customer;
9.3 To make automated decisions, including profiling of the Customer regarding the Customer’s preferred products, and thereby to provide discounts to the Customer;
9.4 To conduct satisfaction surveys which includes managing and analysing the survey results;
9.5 To send marketing content, promotions and newsletters to the Customer;
9.6 To perform the statutory obligations, including accounting and tax obligations, and the lawful orders of competent public authorities and their bodies.
Processed personal data
10. Gamekeys processes the following personal data:
10.1. in the cases specified in clause 9.1 – the Customer's first and last name, telephone number, email address, username, IP address;
10.2. in the cases specified in clause 9.2 – the Customer's first and last name, telephone number, email address;
10.3. in the cases specified in clause 9.3 – the Customer's first and last name, telephone number, email address, IP address, list of products ordered by the Customer;
10.4. in the cases specified in clause 9.4 – the Customer's first and last name, telephone number, email address; list of products ordered by the Customer, data provided by the Customer in a survey that is revealed by the survey’s results;
10.5. in the cases specified in clause 9.5 – the Customer's first and last name, email address;
10.6. in the cases referred to in clause 9.6 – as prescribed by law or indicated in the orders of state institutions an/or their bodies.
Legal basis of the processing
11. Gamekeys will generally process Customer data for the purpose of performing an agreement entered into with the Customer (see clause 9.2 above) or taking measures prior to entering into the agreement based on the Customer's request (see clause 9.1 above). In this case, the legal basis for the data processing shall be the agreement entered into with the Customer or the Customer’s request for negotiations prior to entering into the agreement.
12. Gamekeys shall only process the Customer's personal data for the purposes of forwarding marketing content and offers and conducting satisfaction surveys and analysing the results if the Customer has given his/her consent (see clauses 9.4 and 9.5 above). In this case, the legal basis for the data processing is the Customer's consent.
13. The basis for making an automated decision is the legitimate interest of Gamekeys (see clause 9.3 above). The legitimate interest of Gamekeys is to provide products that are suitable for the Customer and in accordance with the Customer’s interests. For the most part, Gamekeys shall process the Customer's personal data for the purposes of making automated decisions and profiling in an anonymous and non-personalised form. This minimises the risk to the rights and interests of the data subject.
14. Gamekeys shall process the Customer's personal data to perform its statutory obligations on a case-by-case basis if there is a legal basis (see clause 9.6 above).
Transfer of personal data to third persons
15. Gamekeys does not transfer the Customer's personal data to third parties except:
15.1 To the IT and advertising service providers of Gamekeys insofar as it is necessary for the management of the databases of Gamekeys, provision of services to the Customers, and communication with their Customers (e.g. DigitalOcean);
15.2. To the provider of the email delivery service in cases where Gamekeys forwards marketing content and offers to the Customer (e.g. MailChimp);
15.3 To the providers of the accounting service of Gamekeys and government agencies and their bodies to the extent necessary to fulfill the statutory obligations of Gamekeys.
16. All the processors referred to in Section 15 shall ensure the same level of protection of personal data as Gamekeys. In the event that Gamekeys transfers the Customer’s personal data outside the European Economic Area in the aforementioned cases, Gamekeys shall ensure that there is an appropriate adequacy mechanism for such personal data transfer in the context of the GDPR and that the protection of the Customer’s personal data is ensured on the same level as in the European Union.
Retention of personal data
17. The Customer's personal data shall be retained:
17.1. until the Customer deletes his/her account, insofar as Gamekeys processes personal data provided by the Customer upon creating an account in the Gamekeys environment, and 5 years after the Customer’s last use of his/her account in any way (see clause 9.1 above);
17.2. up to 3 years after the termination of the contractual relationship insofar as Gamekeys processes the Customer's personal data in connection with the provision of the service (see clause 9.2 above);
17.3. insofar as Gamekeys processes the Customer's personal data in connection with a legitimate interest (see clause 9.3 above), Gamekeys shall continue to process the Customer's personal data until the Customer deletes his/her account or 5 years after the Customer's last use of his/her account in any way;
17.4. indefinitely until the Customer withdraws his/her consent insofar as Gamekeys processes the personal data for the purpose of forwarding marketing content and offers (see clauses 9.4 and 9.5 above);
17.5. up to 7 years after the date on which the Customer's accounting source document was generated, insofar as Gamekeys is under a statutory obligation to retain accounting records (see clause 9.6 above).
Rights of the Customer regarding the processing of personal data
18. The Customer has the right to contact Gamekeys [email protected]) at any time to exercise his/her legal rights:
18.1. the right to request access to the personal data relating to the Customer to the extent that cannot be done by logging in to the Customer's account;
18.2. the right to request the correction of the data to the extent that cannot be done by logging in to the Customer's account;
18.3. the right to request the deletion of the data to the extent that cannot be done by logging in to the Customer's account;
18.4. the right to restrict the processing of personal data;
18.5. the right to object to the processing of personal data;
18.6. the right to request the transfer of personal data;
18.7. the right to request that decisions based on automated processing are not made with regard to the Customer;
18.8 the right to withdraw consent;
18.9. the right to lodge a complaint to the Data Protection Inspectorate.
19. We shall respond to the Customer’s inquiries and requests within 30 days as from receiving the request.
20. 12.8. If the Customer has wished to receive newsletters and/or personal offers from Gamekeys, the Customer has the right to opt out at any time by clicking on the relevant link in the offer and the user’s profile or sending a corresponding request to the email address of Gamekeys at [email protected].
22. Cookies are small text files that are downloaded to a user's computer via an e-environment’s server. As a result, the browser can send the cookie information back to the e-environment each time the e-environment is used, in order to allow the same user to be recognised. The Customer can choose to disable cookies in the browser settings.
23. Gamekeys uses session cookies and persistent cookies. Session cookies collect information about the Customer's session and shopping cart.
24. Session cookies are used each time the Customer visits the Gamekeys website and each session cookie is valid until the site is closed. All the session cookies and information collected with them shall be deleted after the Customer ends their visit.
25. Persistent cookies allow to remember the preferences and/or activities of the Customer on the website. Persistent cookies are not deleted when the website is closed and are valid for the duration specified for each persistent cookie. Persistent cookies are stored on the Customer’s device and activated each time the Customer visits the site that created the particular cookie.
Use of information collected with cookies
26. We use the information collected with cookies for the following purposes:
26.1. To provide services to the Customer (e.g. if the Customer so wishes, he/she does not have to enter the username and password every time to the Gamekeys website and the Customer is remembered);
26.2. To improve the services provided by Gamekeys (e.g. Gamekeys can receive information on what the most popular parts of the Gamekeys website are, from which websites Customers arrive to the Gamekeys website, to which website Customers go afterwards, and how long Customers spend on the Gamekeys website);
26.3. To prepare the analysis and statistics of the Gamekeys website usage (e.g. the number of visitors to the site and the effectiveness of the advertising is evaluated);
26.4. For direct marketing purposes (e.g. information about ad offers and content targeted at certain web browsers is collected, thereby generating different target groups; information obtained from cookies is combined with information provided by the Customer)
27. In addition to the aforementioned, the Gamekeys website may contain links to third party websites, products and services, as well as social media extensions (e.g. Facebook plugins, Google Analytics) for marketing and statistics purposes. Such third party services or third party applications are subject to the privacy policies of the third parties.
Refusing and Deleting Cookies
28. Some browsers automatically accept cookies. Some automatically refuse third party cookies and accept first party cookies.
29. Regardless of the Customer's standard browser settings, you do not have to accept cookies, and can refuse or block cookies at any time if you wish, and delete all the cookies stored on your device. For information about refusing or deleting cookies in your browser or mobile device, please refer to your device's user manual and websites http://www.allaboutcookies.org and http://www.youronlinechoices.com