Privacy Policy

1. General Provisions

1.1 This Privacy Policy sets out the principles governing the collection, processing and storage of personal data. Personal data is collected, processed and stored by the controller of the personal data, Think King Games OÜ (16474734) (hereinafter referred to as the data controller).

1.2. For the purposes of this Privacy Policy, a data subject is a customer or other natural person whose personal data is processed by a data processor.

1.3. For the purposes of this Privacy Policy, a customer is anyone who purchases goods or services from the website of a data processor.

1.4. The data processor complies with the principles of data processing set out in the legislation, including processing personal data lawfully, fairly and securely. The data controller is able to confirm that the personal data have been processed in accordance with the law.

2. Collection, processing and storage of personal data

2.1. The personal data collected, processed and stored by the data controller are collected through the website.

2.2. By sharing his or her personal data, the data subject grants the data processor the right to collect, organise, use and manage the personal data that the data subject directly or indirectly shares with the data processor when purchasing goods or services from the website, for the purposes specified in the Privacy Policy.

2.3. It is the data subject’s responsibility to ensure that the data he or she provides is accurate, correct and complete. Knowingly providing false information will be considered a breach of the Privacy Policy. It is the data subject’s responsibility to inform the data processor immediately of any changes to the data provided.

2.4. The data controller shall not be liable for any damage caused by the provision of false information by the data subject to the data subject or to third parties.

3. Processing of customers’ personal data

3.1. A data processor may process the following personal data of a data subject:

3.1.1. First name and surname;

3.1.2. E-mail address;

3.2. In addition to the above, the data controller is entitled to collect data about the customer that is available in public registers.

3.3. The legal basis for the processing of personal data is Article 6(1)(a), (b), (c) and (f) of the GDPR:

(a) the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes;

(b) processing of personal data is necessary for the performance of a contract entered into with the involvement of the data subject or for the performance of pre-contractual measures at the request of the data subject;

(c) the processing is necessary for compliance with a legal obligation to which the controller is subject;

(f) the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests override the interests of the data subject or the fundamental rights and freedoms for which the personal data must be protected, in particular where the data subject is a child.

3.4. Processing of personal data for the purposes for which it is processed:

3.4.1. Purpose of the processing – security and safety
Maximum retention period of personal data – according to the time limits specified by law.

3.4.2. Purpose of the processing – processing of the order
Maximum retention period of personal data – 7 years.

3.4.3. Purpose of the processing – to ensure the functioning of the services of the e-shop
Maximum retention period of personal data – 7 years.

3.4.4. Purpose of processing – customer management
Maximum retention period of personal data – 7 years

3.4.5. Purpose of processing – financial activities, accounting
Maximum retention period of personal data – 7 years

3.4.6. Purpose of processing – marketing
Maximum retention period of personal data – 7 years

3.5 The data processor has the right to share the personal data of customers with third parties, such as authorised data processors, accountants, transport and courier companies, companies providing transfer services. The data processor is the controller of the personal data. The data processor transfers the personal data necessary for the execution of payments to the processor Montonio Finance OÜ (14557628).

3.6. When processing and storing personal data relating to a data subject, the data controller shall implement organisational and technical measures to ensure the protection of personal data against accidental or unlawful destruction, alteration, disclosure and any other unlawful forms of processing.

3.7. The data processor shall keep the data subjects’ data for a period depending on the purpose of the processing, but not longer than 7 years.

4. Rights of the data subject

4.1. Data subjects have the right to access and inspect their personal data.

4.2. The data subject has the right to be informed about the processing of his or her personal data.

4.3. The data subject has the right to complete or correct inaccurate data.

4.4. Where a data controller processes personal data of a data subject on the basis of the data subject’s consent, the data subject has the right to withdraw his or her consent at any time.

4.5. To exercise their rights, data subjects can contact the e-shop’s customer support at meelis@thinkking.ee.

4.6. The data subject may lodge a complaint with the Data Protection Inspectorate to protect his or her rights.

5. Final provisions

5.1. These Data Protection Terms and Conditions have been drafted in accordance with Regulation (EU) No 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC / EC (General Data Protection Regulation), the Personal Data Protection Act of the Republic of Estonia and the legislation of the Republic of Estonia and the European Union.

5.2. The data processor has the right to modify the data protection conditions, in part or in full, by informing data subjects of the modifications via the thinkking.ee website.

6. Cookies policy

6.1. The website uses cookies to improve the user experience, analyse web traffic and track user behaviour on the website.

6.2. The website uses a Google Tag (GT) tracker to collect anonymous data about it:

which pages are visited;

how long a visitor stays on the website;

what actions the user performs (e.g. button clicks, filling in forms);

the type of visitor’s device and browser.

6.3. The data collected is used to improve the website and to analyse marketing activities. The data will not be used to identify an individual and will not be transferred to third parties for any purpose other than to provide analytics and advertising services (e.g. Google Analytics, Google Ads).