Valas Media

Valas Media - Privacy Notice

Last updated: May 23, 2018


This privacy notice ("Privacy Notice") explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Privacy Notice applies to personal information that we collect through our games, mobile applications and other products ("Games") and website at https://valasmedia.com/ ("Website") (together "Services"). This Privacy Notice also aims to provide you with such information in a transparent manner as regulated by articles 13 and 14 European Data Protection Regulation 2016/679.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the section 1 of this Privacy Notice. We recommend that you read this Privacy Notice in full to ensure you are fully informed.


1. How to contact us?

For any questions about data protection or if you have any requests regarding your personal data, please find below our contact information.

Name of the controller: Valas Media Oy
Address: Syvanojantie 221, 31530 Pyoli, FINLAND
Company registration number: 2265587-6
Email: legal-requests@valasmedia.com
(hereafter "we" or "Valas Media").

2. Name of the data register

Customer register (consisting personal information collected from the players of the Games and visitors of the Website).

3. For what purpose do we collect your personal data?

We will collect and process your personal information only (i) where we need the personal information to perform a contract with you or provide you with the Service, (ii) where the processing is in our legitimate interests and not overridden by your rights, (iii) where we have your consent to do so.

The intended purposes for the processing of personal data are:

  • present our Services and its contents to you;
  • generally operate and improve our Services;
  • respond to your comments and questions and provide customer service;
  • understand you and your preferences to enhance your experience and enjoyment using our Services;
  • carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to analyze user trends and target certain promotions;
  • allow users to play our games or use our applications and create game or application accounts;
  • link or combine it with other information we get from third parties, to help understand your preferences and provide you with better services;
  • provide you with information, products or services that you request from us;
  • to send you push notifications through our mobile games or applications to send you game or application updates, high scores and other service related notifications that may be of importance to you;
  • send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • communicate with you about promotions, rewards, upcoming events, and other news about products and services offered by Valas Media and our selected partners;
  • notify you about changes to our Services or any products or services we offer or provide through it;
  • and for any other purpose with your consent.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details in section 1 of this Privacy Notice.

4. What kind of personal information do we collect and how?

We process the following personal data from you in connection with the Services we provide:

  • information that you provide by downloading and/or installing games and/or applications, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Services;
  • records and copies of your correspondence (including e-mail addresses), if you contact us;
  • details of transactions you carry out through our Services and of the fulfillment of your orders ("IAP" or "in-app purchase"). You may be required to provide financial information before placing an order through our Services. However, we do not collect information about your credit card numbers or any other digital credentials or PIN numbers with respect to your payment methods;
  • information we request when you contact our player support group.
  • information that you choose to provide us when registering, logging into or using our Services through social media services (such as Facebook);
  • location-based information for the purpose of providing you with the correct versions of our Services (including games and applications);

In addition, our outsourcing partners and third party analytics service providers may collect your unique device ID (persistent/non-persistent), IP address, hardware type, media access control ("MAC") address, international mobile equipment identity ("IMEI"), IDFA (Identifier For Advertisers), Android ID (Android device), Google Advertiser ID, and network status (WiFi/3G) the version of your operating system ("OS"), application usage data, hardware type, browser information and in-game information, and your device name. This information is used to understand and analyze usage trends. The situations when we and third party service providers collect Personal Information and other data from you is described below in more detail.

Ad Networks

If we have your explicit consent, we reserve the right to use and disclose the collected for purposes of behaviorally targeted advertising by us or our partners and contractors. Please see our list of partners here. We may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services. These third parties may collect and use data, for such purposes, including but not limited to, data such as IP address, Device ID (persistent/non-persistent), MAC address, installed software, application usage data, hardware type, OS information, browser information, in-game information, IMEI and your device name. The foregoing data may be used and disclosed in accordance with this Privacy Notice and the privacy notice of the third party providing the ad serving technology. If you wish to "opt out" of targeted advertising, go to our Partners page or change the settings of the Game. Please note that if you do not give your concent or you choose to "opt out" it does not mean that you will no longer receive advertising. It just means that the advertising you see displayed will not be customized to you and your interests and may be less relevant to you. In addition, you may see our mobile games advertised in other services. After clicking on one of these advertisements and installing our mobile game, you will become a user of our Service. In order to verify the installs, we may have to share a device identifier with the advertiser.

Mobile Analytics

We use your information to enable analytics provided by third parties such as Google Analytics for Firebase, AppsFlyer, Flurry and GameAnalytics. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving products and services, personalizing content, providing advertising, and making recommendations. We do not link the information we store within the analytics software to any Personal Information you submit within our Services. For more information about our analytics partners, please see the links on our Partners page.

Third Party Tracking Technologies

Our third party analytics and tracking tool service providers use technologies such as cookies, beacons, scripts, tags and other storage technologies to identify a user's mobile device and to "remember" things about your visit, such as your preferences or a user name and password. Information contained in a cookie may be linked to your Personal Information, such as your IP address, User agent, platform, SDK version, anonymous User ID, time stamp, Developer Key, application version, device identifiers such as: IDFA (Identifier For Advertisers), Android ID (Android device), Google Advertiser ID, device model, manufacturer, OS version, in-app events, and network status (WiFi/3G), for purposes such as improving the quality of our Services, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, however in such an event you may not be able to access or use features of the Service.

Attribution

We may feature advertisements served by third parties that deliver cookies to your mobile device so the content you access and advertisements you see can be tracked. Since the third party advertising companies associate your mobile device with IDFA number, they will be able to recognize your mobile device each time they send you an advertisement. These advertisers may use information about your visits to our Service and third party websites and applications in order to measure advertisement performance and to provide advertisements about goods and services of interest to you. This Privacy Notice does not apply to, and we are not responsible for the data collection practices of these third party advertisers, and we encourage you to check their privacy policies to learn more about their use of cookies and other technology. The existence of our Games relies heavily on user acquisition, therefore enabling these kind of measurement cookies is strictly necessary for the game performance.

5. From where do we receive personal information?

We receive data primarily from the following sources: from the data subject himself (for example, when downloading and playing our Game, and using our Services) and from other similar reliable sources.

For the purposes described in this privacy notice, personal information may also be collected and updated from publicly available sources and based on information received from authorities or other third parties within the limits of the applicable laws and regulations. Data updating of this kind is performed manually or by automated means.

6. To whom do we disclose data and do we transfer data outside of EU or EEA?

Your personal information may be disclosed to third parties including third parties located outside the EU/EEA in accordance with applicable legislation and this Privacy Notice. We may use third parties to collect and process personal information on our behalf and in according to our instructions. Nevertheless, we are not liable for the acts and omissions of these third parties, except as provided by mandatory law.

We may disclose to the following categories of third parties the personal information which you provide yourself to the Service or which we collect in the Service:

  • Service providers, such as data storage service providers, which enable us to provide the Service to you;
  • Our advertising and analytics partners which may process your personal data for the purposes described herein and where applicable, working as joint controllers of the processed data together with us. A list of these partners is available on our Partners page;
  • Public authorities, such as law enforcement, if we are legally required to so or if we need to protect our rights or the rights of third parties; and
  • Our subsidiaries and affiliates; or a subsequent owner, co-owner or operator of the Service and their advisors in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our stock and/or assets, or in connection with bankruptcy proceedings, or other corporate reorganization.

Moreover, we may disclose information to third parties in an aggregate format that does not constitute personal information and does not allow identification of individual users.

7. How do we protect your personal information and how long do we store them?

Only those of our employees, who on behalf of their work are entitled to process customer data, are entitled to use a system containing personal information. Each user has a personal username and password to the system. The information is collected into databases that are protected by firewalls, passwords and other technical measures. The databases and the backup copies of them are in locked premises and can be accessed only by certain pre-designated persons.

We store the personal information for as long as is necessary considering the purpose of the processing. Additionally, we retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We regularly assess the need for data retention in light of the applicable legislation periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data. In addition, we take reasonable measures to ensure that the personal information in the register is not incompatible, obsolete or inaccurate considering the purpose of the processing. We rectify or delete such information without delay.

8. What are your rights as a data subject?

You have the following rights as a data subject:

  1. If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the section 1 of this Privacy Notice.
  2. In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the section 1 of this Privacy Notice
  3. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you.
  4. Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  5. You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

9. Third party terms and conditions

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and Valas Media is not liable for any such third parties' use of your Personal Information. Certain Services that Valas Media may offer, such as in-app purchases within our games may use third party services to provide authentication for the Services. In connection with such use, certain personally identifiable user information, such as IP address may be transferred automatically to and from Valas Media.

Such third parties may also use unique session ID's, cookies, APIs, and SDKs in our services to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as IP address (including country of origin), App version, device operating system (including version), device make and model, UDID or other unique device identifier (only in anonymized form - i.e., not associated with any other personally identifiable information), and the current time each time you launch our mobile game application for the purpose of providing their services under their respective privacy policies. Our Privacy Notice does not cover the use of tracking tools from third parties. We do not have access or control over these third parties.

10. Special note about children's privacy

We comply with all applicable laws that are designed to protect children's privacy, such as Children's Online Privacy Protection Act ("COPPA"). See https://www.ftc.gov/tips-advice/business-center/guidance/complying-coppa-frequently-asked-questions for more information.

Our Games are directed to general audience. For clarity, our Games are not intended to children under 13 years of age, therefore no one under 13 years of age is allowed to use or access the Games or provide any personal information to us. We do not knowingly collect or solicit personal information from or direct or target behaviorally targeted advertising to anyone under 13 years of age or knowingly allow such persons to use or access our Games. If you are under 13 years of age, please do not send any information about yourself to us including your name, address, telephone number, or email address.

In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at legal-requests@valasmedia.com.

If we learn that we have inadvertently gathered personal information from children under 13 years of age, we will dispose of that information, or otherwise treat it in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under 13 years of age has provided us with personal information, please contact us at legal-requests@valasmedia.com.

If you have additional questions about our data collection practices related to children under the age of 13, please contact us at legal-requests@valasmedia.com.

11. Changes in our Privacy Notice

Should we make amendments to this privacy notice we will place the amended statement on our Website, with an indication of the amendment date. If the amendments are significant, we may also inform you about this by other means, for example by sending an email or placing a bulletin on our homepage. We recommend that you regularly visit our webpage and notice possible amendments to this privacy notice. Review these privacy protection principles from time to time to ensure you are aware of any amendments made.

Support and feedback
FAQ | Email: support@valasmedia.com

All other inquiries
Email: contact@valasmedia.com

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