Privacy Policy

Last updated: 2026-03-01
Website: tophry.sk

This Privacy Policy explains how :siteName (“we”, “us”, “our”) collects, uses, shares, and protects personal data when you access or use our website, products, and services (the “Service”). Where applicable, we comply with the EU General Data Protection Regulation (GDPR) and other relevant privacy laws.

Related: Cookie Policy

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1) Scope & definitions

This Privacy Policy applies to individuals who access, browse, or use our Service, including when you create an account, place an order, contact support, participate in promotions, submit reviews, or subscribe to marketing communications.

“Personal data” means any information relating to an identified or identifiable natural person. “Processing” means any operation performed on personal data (e.g., collection, storage, use, disclosure).

If you do not provide certain data that is required to provide the Service (e.g., billing/shipping details), we may not be able to fulfill your order or provide certain features.

2) Data controller & contact

The data controller is:

GG agency s.r.o.
J.Hašku 18, 915 01 Nové Mesto nad Váhom, Slovenská republika
ID / VAT: IČO: 52964574 / DIČ: 2121215195 / IČ DPH: SK2121215195

Privacy contact: support@tophry.sk

3) What personal data we process

The personal data we process depends on how you use the Service. Typically, we may process:

• Identity & contact data: name, surname, email, phone, billing and/or shipping address, country, date of birth (if required for age verification).
• Account data: account ID, login credentials (password stored as a secure hash), settings and preferences, consent records.
• Transaction data: orders, purchased items, order number, invoices, refunds, chargebacks, delivery method, support history related to orders.
• Payment / financial data: payment method and payment status; card details are typically processed by payment providers (we generally do not store full card numbers).
• Technical data: IP address, device identifiers, browser type/version, operating system, time zone, logs, and security events.
• Usage data: pages viewed, clicks, session activity, interactions, error logs, performance metrics.
• Marketing & communications data: newsletter subscription, preferences, your communications with us, and campaign performance events (if enabled).
• User-generated content: product reviews, ratings, comments, and content you submit to the Service (where applicable).

We may also process aggregated or anonymized data (statistics) that does not identify you. Please do not send special categories of personal data (e.g., health data) via the Service. If we ever need such data for a specific reason, we will ask separately and provide additional information.

4) How we collect / receive data

• Directly from you: when you create an account, place an order, contact support, fill in forms, participate in promotions, or subscribe to marketing.
• Automatically: when you use the Service, we collect technical/usage data via logs, cookies, and similar technologies (see Cookie Policy).
• From third parties: for example, payment providers (payment confirmation, fraud signals), email delivery providers, analytics providers (e.g., GA4), advertising partners (e.g., Meta Pixel) if enabled by consent, or other vendors necessary to deliver the Service.

5) Purposes & legal bases

We process personal data only when we have a lawful basis. Below is an overview (examples):

Purpose	Examples	Data categories	Legal basis
Account management	Create/login, manage settings, save preferences	Identity & contact, account, technical	Contract (GDPR Art. 6(1)(b)); legitimate interests (Art. 6(1)(f))
Order fulfillment	Process orders, deliver products/services, communicate about orders	Identity & contact, transaction, technical	Contract (Art. 6(1)(b))
Payments & fraud prevention	Payment processing, refunds, chargebacks, fraud detection	Transaction, payment/financial, technical, usage	Contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f))
Customer support	Resolve issues, handle complaints, warranty/returns (if applicable)	Identity & contact, transaction, communications	Contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f))
Legal & compliance	Accounting/tax records, responding to lawful requests, dispute handling	Identity & contact, transaction, communications	Legal obligation (Art. 6(1)(c)); legitimate interests (Art. 6(1)(f))
Security	Protect accounts, prevent abuse, investigate incidents	Technical, usage, account	Legitimate interests (Art. 6(1)(f))
Analytics & performance	Measure usage, improve UX, fix errors (only if enabled/consented where required)	Technical, usage	Consent (Art. 6(1)(a)) for non-essential cookies; legitimate interests (Art. 6(1)(f)) where allowed
Marketing	Newsletter, promotions, personalized offers (only if enabled/consented where required)	Identity & contact, marketing preferences, usage	Consent (Art. 6(1)(a)) and/or legitimate interests (Art. 6(1)(f)) where permitted

We may use limited forms of profiling (e.g., fraud signals, product recommendations). We do not intend to make decisions based solely on automated processing that produce legal effects about you without appropriate safeguards.

5a) Newsletter

If you subscribe to our newsletter, we send you e-mails about deals, news and game pre-orders. Customers who created an account with us receive commercial communications about similar products based on our legitimate interest (GDPR Art. 6(1)(f) and the applicable rules for existing customers); other subscribers receive them based on the consent given in the subscription form (GDPR Art. 6(1)(a)).

We process your e-mail address, language, date and source of subscription (form, registration, account), for form sign-ups also your IP address (abuse prevention), and records of each e-mail sent.

Click measurement: links in the newsletter go through our server (tophry.sk/nl-klik.php), which records which link or product was clicked so we know which offers interest you. We do not track e-mail opens and use no cookies or tracking pixels for this.

You can unsubscribe at any time with one click in the footer of every e-mail, in your account settings (Language and currency → Newsletter) or on the newsletter unsubscribe page. After unsubscribing we send you no more newsletters; order e-mails (keys, invoices) are still delivered. We keep subscription data while you are subscribed and, after unsubscribing, only a record of the opt-out so we do not e-mail you by mistake.

5b) Website traffic statistics

To see how our website is used (which pages are visited, where visitors come from, which campaigns work), our own server records each page view: time, page address, the website you came from, campaign name from the link (utm parameters), device type, browser, IP address and whether you are logged in. A visitor is identified by a code derived from the IP address, browser and day, which changes every day. We use no cookies and no external analytics service for this.

Legal basis: our legitimate interest in measuring traffic and protecting the website (GDPR Art. 6(1)(f)). The IP address and browser are deleted after 90 days, aggregated counts are kept for at most 3 years. The approximate location of an IP address is determined from a local database (DB-IP); the IP is not sent to any third party.

6) Cookies & similar technologies

We use cookies and similar technologies to ensure core functionality (login, cart, security), and—if you allow—analytics and marketing tags. Details, categories, typical cookie names, and your choices are explained in our :cookiePolicy.

7) Who we share data with

We do not sell your personal data. We may share it only as needed to run the Service:

• Service providers / processors: hosting, infrastructure, monitoring, email delivery, customer support tools, analytics/marketing (only if enabled/consented where required), and security vendors.
• Payment providers: to process payments and prevent fraud.
• Professional advisors: accounting, auditors, legal counsel.
• Authorities: where required by law, regulation, legal process, or to protect rights/safety.
• Corporate transactions: if we sell/transfer/merge parts of our business or assets, personal data may be transferred as part of that transaction (with appropriate safeguards).

Where third parties act as our processors, they may process personal data only under our instructions and with appropriate confidentiality and security measures.

8) International transfers

Some providers may process data outside the European Economic Area (EEA). Where applicable, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) and additional measures required by law.

9) Data retention

We keep personal data only as long as necessary for the purposes described above, including meeting legal, accounting, or reporting obligations. Retention depends on the type of data and purpose.

Processing	Typical retention (example)
Account data	For as long as the account is active; certain records may be archived after closure for legal claims / compliance.
Orders & transactions	For the duration of the contractual relationship and then archived for the duration of applicable limitation periods (e.g., evidentiary purposes).
Invoices & accounting records	As required by applicable tax/accounting laws (often up to 10 years in many jurisdictions—adjust to your local requirements).
Support requests	As needed to resolve the request; then retained for a limited period to keep records and defend legal claims.
Security logs	For a limited period appropriate for security monitoring and incident investigation (typically weeks/months).
Fraud detection signals	Typically short-term retention (e.g., up to 30 days); in exceptional cases and where justified, retention may be longer for evidentiary needs.
Marketing	Until you unsubscribe/withdraw consent or for a limited period after last interaction (commonly up to 3 years—adjust to your rules).

10) Your rights

Depending on your location and applicable law (including GDPR), you may have the right to:

• Access your personal data.
• Rectify inaccurate or incomplete data.
• Request deletion (where applicable).
• Restrict processing in certain cases.
• Data portability (where applicable).
• Object to processing based on legitimate interests, including direct marketing.
• Withdraw consent at any time (where processing is based on consent).

To exercise your rights, contact us at :email. We may need to verify your identity before fulfilling your request (for example, to protect your account and prevent unauthorized access).

You also have the right to lodge a complaint with your local data protection supervisory authority. We would appreciate the chance to handle your concerns first—please contact us before filing a complaint.

11) Updating your data

It is important that the personal data we hold about you is accurate and up to date. If you have an account, you can update certain information through your account settings. You can also contact us to request updates or corrections.

12) Third-party links

The Service may contain links to third-party websites, plug-ins, or applications. If you follow those links, third parties may collect or share data about you. We do not control third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policies of every website you visit.

13) Security

We use appropriate technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, or alteration. However, no transmission or storage system is guaranteed to be 100% secure.

If you have reason to believe that your data is no longer secure, please notify us immediately at :email.

14) Children

Our Service is not intended for children. If local law requires parental consent for certain processing (e.g., account creation), we may ask for age confirmation and/or require consent from a parent or guardian where applicable.

15) Changes to this policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated “Last updated” date.

16) Contact

If you have questions about this Privacy Policy or requests regarding your personal data, contact us at: :email.

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