Privacy Notice

Last updated: Apr 8, 2024

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 Prosessing	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.
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.

Purpose of Prosessing

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.

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.

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:

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
we also use third-party partners data analytics providers (such as AppsFlyer, Unity and Google) 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. These third parties may process your data only at and according to our instructions and to perform tasks such as hosting, user acquisition, analytics and fraud prevention, however only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to process your data.

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.

Attribution partners

The Service includes features from our partners, such as functionalities through application programming interfaces (APIs) or software development kits (SDKs). A list of these partners is available at https://valas.media/partners.

These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices. For more information on our partners and the opt-outing available: https://valas.media/partners.

Please note, that as we also use partners to perform services for us as processors, such as AppsFlyer for attribution. These partners do not use your data for additional purposes and possible opt-outs made by you can also affect these partners.

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.

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:

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.
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
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.
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.
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. 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 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@valas.media.

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@valas.media.

If you have additional questions about our data collection practices related to children under the age of 13, 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. We will always obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. 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.