Privacy Policy

We are committed to your privacy and security. This document contains our policies for collecting, storing, using and disclosing personal data from you or about you that we collect through this website. Personal data is defined as any information that identifies an individual (such as a name, email address or billing details) which may be used on its own or in combination with other identifiers to identify the individual.

This document is intended to comply with the requirements of GDPR.

About us

HRK Game website is operated by HRKdistribution OÜ, a private company incorporated under the laws of Estonia under company registration number 14160799 and having its registered office at Laki 25-411, Tallinn, 12195, Estonia (further - “HRK Game”, “we”, “us”, “our”)

The website www.hrkgame.com lists downloadable game titles and other downloadable content. We sell official keys on the site to unlock, access and download the content from a platform that is not ours, but that of the developer or publisher (therefore we are not claiming ownership).

This privacy notice applies to:

The following privacy notice applies to individuals who visit our website. Its goal is to explain how we collect and process your personal data through your use of the website. We collect your personal data when you visit our website, attempt to register with us, contact us, share reviews or purchase items through our website and ask for marketing.

If you are an HRK Game partner, this privacy notice applies to you the same as any other user of the website. However, we will process certain personal data relating to you in order to perform our partnership agreement with you.

It's important that you read this privacy notice together with any other privacy notices we have for specific occasions when we're collecting or processing personal data about you so that you are aware of how and why we're using it.

Links to third-party websites

When you click on links or enable connections to third-party sites, they may be able to share data about you. We do not control these third-party websites and are not responsible for their privacy notices. Furthermore, when leaving our site, we encourage you to read the privacy policies of every website visited. For details concerning cookies served by third parties.

Types of personal data we process

“Personal Data” is any information about an individual that will allow us to distinguish that person from other individuals, such as their name, contact details or location. It does not include anonymized data.

In this Privacy Notice, we use the term "processing" to refer to all activities involving your Personal Data, including those related to collecting, handling, storing, sharing, accessing and using it.

The personal data we collect about you will depend on the activities that have been performed through our website. Typical types of personal information include:

ID and contact data includes your name, address, email address, date of birth and any personal information provided in communications with us.

Financial Data includes information necessary for processing payments and fraud prevention, HRK Game does not save your credit card numbers. If you pay us via your credit/debit card, we process your card details via our payment service providers. (Braintree, PayPal, Zen)

Transaction Data typically includes payments and other details related to our products or services, and in the case of HRK Game partners, this data also includes administration-related information.

We use technical information including IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform to provide the necessary services.

Usage Data may include information about how you use the website, including services viewed or searched for. For example, page response times will be measured and download errors logged. Length of visit to a webpage as well as interactions such as scrolling, clicks, and mouse-overs are tracked.

Marketing and Communications Data includes your preferences in receiving marketing communications, such as which contact information you would like us to use when communicating with you, and your communication preferences.

We also collect, use, and share aggregated data like statistics on groups or trends. Although these are not considered personal information in law because they do not directly reveal who you are, aggregate data is derived from your personal data. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect this aggregated data with personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data and put it in accordance with your privacy notice.

We do not collect any personal data that is considered sensitive, like ethnic or religious information, or health-related. Nor do we collect any information about criminal convictions or offences. Please do not provide on the website or in any communications with us any special categories of personal data and/or personal data relating to criminal records.

If you choose not to provide the personal data we need, then we may be unable to carry out an obligation.

How we collect your personal information

When interacting with us, you will provide us with your contact details as well as personal and financial information. You can also share personal data when we interact by post, phone, email or social media. This includes personal information, like your name and email address, that you provide on surveys, when you contact us for feedback on our products or online shopping experience.

This policy covers all automated technologies or interactions, which include:

As you interact with our website, we collect Personal Data including details about your device, browsing actions and patterns (i.e. searches), sections viewed, traffic data (weblogs), weblogs (other communication), and any resources accessed. Personal Data is collected using cookies.

Third-Party Data: We receive personal data relating to you from third party sources, as set out below.

(a) Data regarding your product key activation date from Developers. 

(b) Technical Data for data analysis purposes from Google Analytics.

(c) Identity and Contact Data, Financial Data and Transaction Data from providers of payment services such as PayPal, Braintree and Zen.

(d) Identity and Contact Data from publicly available sources such as a registrar of companies.

(e) Identity and Contact Data (your email address and name) when you log in using the services such as Google, or Facebook.

(e) Steam User Data when you log in using your Steam Account.

How your personal data is used by us

This is a description of the ways we typically process your personal data and the legal grounds on which we rely to do so:

Purpose / activity

Type of Data

Grounds for processing

To allow you to create and manage a user account on our website, including managing your public profile wish list products of interest, preferences, feedback, product reviews and survey responses, connecting with other website members and sharing games with your friends.

Identity and Contact Data

Profile Data

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

Necessary for our legitimate interests of enabling users to create and develop personalised accounts, to facilitate purchases and recording of product and service preferences, for running our business and to develop new business.

To check your age eligibility to buy certain Codes, to process and deliver your order including managing payments, fees, charges and refunds; processing HRK Credits and gift card credits; and collecting and recovering money owed to us.

Identity and Contact Data

Profile Data

Financial Data

Transaction Data

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests to administer our services, to collect sums due to us and to keep our records updated.

To respond to queries submitted through the website, telephone, social media or other means and to manage our relationship with you including: (i) product and service support; (ii) notification of changes to our services, terms of sale, cookies policy, privacy notice or other policies; (iii) user feedback, product review and survey facilities; (iv) user complaints and disputes; (v) administering your marketing and communication preferences; (vi) administering your data protection, privacy and other rights.

Identity and Contact Data

Profile Data

Financial Data

Transaction Data

Technical Data

Usage Data

Marketing and Communications Data

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests for responding to user queries, attracting new users, affiliates and partners, running our business and to develop new business, keeping our records updated and to gauge consumer satisfaction with our services and/or the codes they purchase.

To administer and protect our business, products, services, networks, systems, the website and data and property hosted on or made available through the website including implementing and monitoring security measures, troubleshooting, data and usage analysis, testing, system maintenance, support, reporting and hosting of data.

Identity and Contact Data

Profile Data

Financial Data

Transaction Data

Technical Data

Usage Data

Proof of Identity (Including a Photo ID with selfie)

Marketing and Communications Data

Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract.

Necessary to comply with a legal obligation.

Necessary for our legitimate interests for running our business, IT systems administration, network security, to identify and/or prevent fraud, to collate statistical business to enhance our services and business, and in the context of a business reorganisation or group restructuring exercise.

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Identity and Contact Data

Technical Data

Usage Data

Marketing and Communications Data

Necessary for our legitimate interests to study how users use our services, to develop them, to grow our business, to inform our marketing strategy and output and to conduct marketing.

To use data analytics to monitor usage of the website, to measure the performance of the website and to optimise the website, to improve our services, marketing strategy and output, user interactions, relationships and experiences.

Technical Data

Usage Data

Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.

To make suggestions and recommendations to you about products or services that may be of interest to you, including product recommendation engine and by way of news updates and other communications and to observe the readership of our news updates and other communications through the use of tracking technologies.

Identity and Contact Data

Technical Data

Usage Data

Marketing and Communications Data

Steam User Data

Necessary for our legitimate interests to develop our products and services, direct market and grow our business.

We utilize the Steam Web API provided by Valve Corporation to allow users to log in to our service using their Steam account credentials. By logging in this way, you consent to share your basic Steam profile data (such as username and avatar) with our service as needed to identify you and link your account. 

We will not store your Steam password or other private account details. We may store your Steam ID and other publicly available profile data in order to recognize you on future visits. You can revoke our access to your Steam data at any time by logging out of our service.

We don't rely on consent as legal grounds for processing your data, but before we market our services to you via email or text message, we'll ask for your permission.

We would like to send you marketing information, such as service updates, upcoming game releases and other news via email. If you consent to receive this type of communication, we may use mobile push notifications (in app) too.

In order to unsubscribe from this mailing list, follow the instructions in the "leave" section below. Should you have any other privacy-related questions or concerns, please contact us using the information set out in our Privacy Policy Explanation.

If you agree as part of our cookies framework, we will use certain technologies that allow us to see whether news updates and other communications we send to you have been viewed and read. As explained in section 6 above, we use this information for our legitimate interests to develop our products and services, direct market and grow our business.

Disclosure of your personal data

Except as set out in this privacy notice, we do not disclose personal data about any individual to third parties. We will share personal data only with the third-party organizations listed below and only for purposes outlined in section 6 of this document.

Companies that provide products and services to us such as professional advisors, IT systems suppliers and support, data storage, IT developers, web hosting, analytics companies.

We will disclose personal data when legally obligated to do so by governmental authorities, law enforcement or to protect our rights.

Our company may transfer or sell its assets. In the event of a sale, merger, or other transfer (hereinafter collectively “Change”) to a new owner, that Privacy Notice will no longer apply and you should consult the privacy notice of the acquiring entity for information on how your personal data may be used.

Any third party we share your personal data with is required to keep it secure and comply with the law. We do not permit our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Unless prohibited by applicable law, we will notify you when your personal data may be provided to third parties in ways other than listed above and will give you the option to prevent

Data Transfer

We are located in Estonia and so your personal data will be received and processed by us in Estonia. It may be necessary for us to disclose some of your personal data to our trusted suppliers who provide us with products or services that help us provide you with the service we contract them to deliver for you. All other suppliers directly involved in processing your data reside

Keeping your information up to date

It is important that our records are up-to-date. Some changes like a new phone number, email address, or address may not get updated automatically. You can update your personal information on your account settings page and we will make the change for you within 24 hours.

Data risk & security

We take multiple measures to ensure your personal data is secure. We will never share or use your information without getting consent first—and only for the purposes outlined in this policy. If you are aware of any security breaches, please let us know immediately by contacting us using the contact information provided at the end of this document under section "Contact Us."

Retention of personal data

We will not retain your personal data for longer than necessary to fulfill the purposes we collected it for. In the event of a complaint or legal dispute, we may retain some of your personal data for a longer period. We determine an appropriate retention period for personal data based on the amount, nature and sensitivity of the personal data, potential risk of harm from unauthorized use or disclosure of your personal data, our goal in collecting the information, as well as any legal obligations we have to retain it.

The legal rights you have

Under certain circumstances, by law, you may have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. This enables you to ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal data to perform a contract with you.

Right to withdraw consent: If you provide your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you wish to withdraw your consent, we will take steps to ensure we no longer process your personal data for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.

In order to exercise one or more of your rights in respect of your personal data, please contact us in writing using the information provided in section 13 below. We will need you to provide us with information to identify you on our records, we will also need proof of your identity and address and the information to which your request relates.

Please note that the settings page of your user account enables you to update, manage and download certain of your personal data and to disable your user account and delete [all] personal data associated with your user account.

You have the right to make a complaint to the data protection supervisory authority. However, we would appreciate the chance to deal with your concerns before you contact the supervisory authority and therefore ask you please contact us in the first instance using the information provided in the section below.

Contact us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us through the support and contact us links on our website or by logging into your user account. Additionally, you can send us an email to [email protected]

Changes to this privacy notice

We will change this privacy notice from time to time and any changes will be contained in a revised privacy notice posted on the website. This version of the privacy notice was last updated on 7th August 2021.

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