Last updated: October 2, 2019
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.
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
(hereafter "we" or "Valas Media").
Customer register (consisting personal information collected from the players of the Games and visitors of the Website).
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:
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.
We process the following personal data from you in connection with the Services we provide:
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.
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.
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.
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.
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.
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 also use third parties to collect and process personal information on our behalf and in accordance 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:
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.
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.
You have the following rights as a data subject:
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
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.
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 firstname.lastname@example.org.
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 email@example.com.
If you have additional questions about our data collection practices related to children under the age of 13, please contact us at firstname.lastname@example.org.
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.