Privacy Notice

Last updated: Oct 22, 2026

This privacy notice ("Privacy Notice") explains who we are, how we collect, share and use personal information that we collect through our games, mobile applications and other products ("Games") and website at https://valas.media ("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. Data Controller Information and 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: PL 9, 00101 Helsinki, FINLAND

Company registration number: 2265587-6

Email: legal-requests@valas.media

(hereafter "we" or "Valas Media").

2. Name of the Data Register

Customer register (consisting of personal information collected from the players who interact with our Games and Website).

3. What Data Do We Process and What Is the Purpose and the Legal Basis of Processing the 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 and (iii) where we have your consent to do so, as described below.

Purpose of Processing Legal Basis Personal Data
The main purpose of processing personal data is to make the Services work (to allow you to play our Games, operate and verify payments and respond to your questions and provide you player support.). The processing is based on the performance of a contract. Contact information (such as name and email address).

The content of our messages and other content you submit when you use the Service or interact with the Games (such as contacting player support).

Data you provide in connection with surveys, promotions, sweepstakes, competitions and other events.

Our payment service providers will collect your payment details in connection with any purchases you make through the Games / Services.
To enhance and make the Games and Services more suitable (i.e. develop and improve the Games and player experience) to you and to maintain the customer relationship between us and you.

To understand usage trends and to customize your Service and Game experience.

Send you information relating to updates, security alerts and support messages.		 The processing is in our legitimate interests and not overridden by your rights. Data about your use of the Games, such as game progress information, gameplay data, purchases you make and your interactions with the Game.

Your IP address and mobile device identifiers (such as your device ID).

Data about your device, such as device name and operating system, browser type and language, internet service provider and mobile carrier.

Approximate location data (as derived from IP address).

The content you access in connection with the Games and your online behavior within the Games.
To request and deliver advertising, including optional rewarded ads; select ads through mediation and bidding; measure ad performance; prevent fraud and abuse; and, where you consent, personalize advertising. Your consent where required by applicable law. For processing that does not require consent, we may rely on our legitimate interests in delivering, measuring and securing non-personalized or limited advertising, provided that those interests are not overridden by your rights. This does not replace any consent required for storing or accessing information on your device or for other advertising processing. IP address; advertising and device identifiers (such as Google Advertising ID or IDFA, where available); app and device information; approximate location derived from IP address; advertising requests and bidding-related information; privacy choices and consent status; and ad-interaction data, such as ads requested or viewed, impressions, clicks, timestamps and, where applicable, reward completion.
With your consent, we may process your data for additional purposes. Your Consent. Such personal data categories will be transparently informed to you at the moment we ask your consent.

We use crash reporting services, including Firebase Crashlytics and, in some Games or versions, Unity's diagnostic services, to identify and fix crashes and errors. Reports may include installation and session identifiers, stack traces, exception messages, logs, app and device information and recent gameplay events preceding an error. Our reporting providers may transfer, store and process this information in the United States and other countries where they or their service providers operate, where data protection laws may differ. See section 6 for information about international transfers and safeguards, and our Partners page for provider privacy information.

Crash reporting settings and available privacy choices vary by Game, version and region. Depending on the Game, these choices may be provided through privacy or analytics settings or an in-game privacy message. Where reporting is based on your consent, you can withdraw it through the available in-game privacy options or by contacting us using the details in section 1. Advertising privacy choices do not necessarily change crash reporting. Changes to reporting settings may take effect from the next app launch and do not erase reports already sent or recall uploads already started. Crash information may remain on your device while reporting is disabled and may be sent if reporting is later enabled.

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. From Where Do We Receive Personal Information?

We receive data primarily from the following two sources:

  1. From you / player of our Games (for example, when downloading and playing our Games, contacting our player support and otherwise using / interacting with our Services) either by automatic means or when you submit data to us by yourself; and
  2. we also use third-party analytics and advertising partners, as listed on our Partners page, to supplement information we have about you, who process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data.

5. To Whom Do We Disclose Data?

Apart from us, your data can be accessed by others / third parties only in the following situations:

Our third party service providers

Valas Media uses third party partners and subcontractors who help us to provide the Games and Services to you. Where a provider acts as our data processor, it processes personal data on our instructions under the applicable data processing agreement, for tasks such as hosting, attribution, analytics and fraud prevention. Some partners act as independent data controllers for particular processing activities, as explained below and in their privacy information. Their role depends on the service, configuration and applicable law.

Advertising

Some Games use third-party advertising services to provide advertising, which may include optional rewarded ads and other ad formats. These services may include advertising mediation, which selects between participating advertising sources, and bidding, through which sources compete for ad opportunities. Sources may include advertising exchanges, which make ad opportunities available to participating advertising buyers. Games may also request ads directly from an advertising source. The mediation providers, advertising sources and information about their participating partners are identified on our Partners page and, where required, in the in-game consent flow.

When advertising software runs or an ad is requested or displayed, the mediator, advertising sources and their participating partners may collect or receive the advertising data described in section 3. Bidding can involve sending information to participating bidders to evaluate an ad opportunity. A bidder may receive information even if it does not win the auction or no ad is ultimately displayed.

These advertising services operate through software included in the Games and may use local storage, device identifiers and similar technologies. They use information for ad selection, delivery, measurement, reporting and fraud prevention and, where permitted by applicable law and your privacy choices, personalized advertising. Unity (including its ironSource services) and Google act as independent data controllers for relevant advertising processing and may also process information for purposes described in their own privacy policies (Unity and Google), including improving their advertising services. Participating exchange buyers and other advertising technology providers may also act as independent controllers for their own processing. Different roles may apply to particular features or legally restricted processing. Provider information, privacy policies and links to available privacy choices are provided on our Partners page and, where required, in the in-game consent flow.

Advertising privacy choices

Accepting our Terms of Service, reading this Privacy Notice or choosing to watch a rewarded ad does not itself give consent to optional advertising data processing. Where your consent is required, we obtain it before starting the relevant advertising software or allowing it to collect or share personal data. You can withdraw consent through the privacy options in the Game or by contacting us using the details in section 1.

Non-personalized or limited ads may still involve personal data and storing or accessing information on your device. We request these ads only where the necessary consent or other legal permissions are in place. Device-level tracking permissions, including Apple's app tracking permission, are separate from any other consent required by applicable law.

Other companies working for us and public authorities

In order to verify payments (with payment providers such as Apple Pay and Google Play) and combat fraud and illegal activity, we may process and disclose data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

Partners listed on our Partners page

The Service includes features and services provided by our partners. A current list of our in-app service providers, advertising partners and user acquisition partners is available at our Partners page. These partners may process personal data in connection with the provision of app functionality, advertising, analytics, crash reporting, remote configuration, purchases, login, attribution, fraud prevention and related services.

We also use AppsFlyer for mobile attribution and measurement of our user acquisition campaigns. Depending on the app, campaign and configuration, AppsFlyer may process attribution-related data on our behalf and may send attribution-related or in-app event postbacks to our user acquisition partners as configured by us for purposes such as attribution, campaign measurement, fraud prevention and campaign optimization.

These partners operate under their own privacy policies where applicable. We encourage you to review their privacy policies and available privacy choices on our Partners page.

6. International Data Transfers

Our Games are operated globally and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this section 6 and following section 7 of the Privacy Notice.

If you are a resident of the European Union (“EU”) or the European Economic Area ("EEA") we may transfer personal data outside the EU/EEA when our trusted third party service providers or partners are established there. To the extent personal data is transferred to a country outside of the EU/EEA, we will use the required established mechanisms that allow the transfer to these third countries, such as the Standard Contractual Clauses approved by the European Commission.

This may include transfers involving the advertising mediator, participating bidders, advertising sources and their partners. Independent controllers are responsible for safeguards for the transfers they make. Their processing locations and applicable safeguards are described in their privacy information linked from our Partners page. You can contact us for information about the safeguards applicable to transfers for which we are responsible, including how to obtain a copy where applicable.

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.

Advertising partners acting as independent controllers determine retention for the data they process under their own privacy policies and applicable law. Their retention criteria and privacy request options are available through the links on our Partners page. A request to delete data held by us does not automatically delete all data separately held by an independent controller; we will handle our own obligations and assist with directing your request to the relevant partner where appropriate.

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 the processing, that is based on legitimate interest, 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 receiving push notifications. We may send you push notifications through our Games. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.
  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 can review or change advertising privacy choices through the privacy options provided in the Games and through your device settings, including settings for advertising identifiers and app tracking. Our Partners page links to Unity's and Google's privacy information and request options. You can also review Google advertising choices in My Ad Center. These choices may apply to a particular app, device, browser or account; changing one setting may not change all of them. You can contact us using the details in section 1 to exercise your rights in relation to our processing.
  6. If you believe there is a problem with the way we are handling your personal data, you have a right to file in a complaint to your national data protection authority in the EU/EEA, for instance the Finnish Data Protection Ombudsman (www.tietosuoja.fi). You may also file in a complaint to the data protection authority in any other EU country where you live, work, or where you think the alleged violation has occurred.

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

9. Age Requirement

Our mobile games are intended only for individuals who are at least 18 years old. No person under 18 may use or access our mobile games or provide personal information through them. We do not knowingly collect or solicit personal information from anyone under 18 or knowingly allow such persons to use or access these Games.

If we learn that we have collected personal information from a person under 18, we will delete it as quickly as possible. If you are a parent or guardian and believe that a person under 18 has provided us with personal information, please contact us at legal-requests@valas.media.

10. Changes in our Privacy Notice

Should we need to make amendments to this Privacy Notice in response to changing legal, technical or business developments 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 within our Games or by sending an email or placing a bulletin on our homepage. Where a change to our processing requires your consent, we will obtain that consent before the relevant processing takes place. Nevertheless, we recommend that you regularly visit our webpage and notice possible amendments to this Privacy Notice.

11. Your Privacy Rights as a California Resident (CCPA)

If you are a California resident, please visit our CCPA page for special disclosures pertaining to California residents.