Your Privacy Rights as a California Resident (CCPA)
Last updated: Apr 25, 2023
Please, see also our general Privacy Notice. Unless otherwise stated herein, all definitions used in this document have the same meaning as defined in our general Privacy Notice.
1. General Information for California Residents
The California Consumer Privacy Act of 2018, including its amendments such as California Privacy Rights Act “CPRA” (hereinafter together the “CCPA”) establishes specific rights for California residents to control the use of their personal information and requires businesses to provide the consumers with certain information on how their personal information is collected, used and shared. This section provides California residents with information on our personal information collection practices and how consumers can exercise their rights under the CCPA.
If you have any questions regarding your privacy rights as a California resident, please contact us at ccpa-requests@valas.media.
2. What Kind of Personal Information We Collect, Use and Share on California Residents?
The categories of personal information we have collected in the preceding 12 month, the sources where we get the information and purposes for which we use such information when you interact with us are detailed below.
| Categories of Personal Information | Purposes of Use | Sources of Personal Information |
|---|---|---|
|
Commercial Information, such delivery information and information about your transactions and purchases with us or information about your participation to a contest or promotion sponsored by us. |
Perform the services and personalizing your experience on our Games. Commercial purposes, such as facilitating purchases of Games or service, or sending newsletters, marketing, and surveys. |
You, both directly and through your use of the Games Our third party service providers and business partners. |
|
Customer service information, such as information you provide us when you contact our player support group or information that you choose to provide us when registering, logging into or using our Services through social media services (such as Facebook). |
Perform the services, and personalizing your experience on our Games Facilitate Purchases of our Games and services Interact with our customer service or player support. |
You, both directly and through your use of the Games. Social media and other third party accounts. |
|
Usage data and trends, such as information about your browser, network and device, Web pages you visited prior to coming to our website, Your IP address, gameplay data, landing pages, content or ads viewed and clicked, dates and times of access, pages viewed, levels you complete or partially complete, uploads or downloads, access times, error logs, and other similar information. |
Provide you with our Games and services and personalizing your experience on our Games and services Commercial purposes, such as facilitating purchases of our Games or service, or sending promotions, marketing, and surveys Detecting security incidents and secure our Games |
You, both directly and through your use of the Games Our third party service providers and business partners. |
|
Technical Information, such as technical information related to Your mobile device or computer, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier. |
To attribute installs, prevent fraud behavior and optimize campaign performance in user acquisition. |
Our third party service providers and business partners |
|
Technical Identifiers, such as various unique identifiers that generally only identify a computer, device, browser or mobile application. For example, IP address (which may also provide general location information), User agent, IDFA (identifier for advertisers), Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique identifiers. |
To attribute installs, prevent fraud behavior and optimize campaign performance in user acquisition. |
Our third party service providers and business partners. |
|
Engagement Information, such as information relating to the Customer’s ad campaigns and End User actions, such as: clicks on Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, the webpages on Customer’s website visited by an End User, the URL from the referring website, downloads and installations of Applications, and other interactions, events and actions Customers choose to measure and analyze within their application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.). |
To attribute installs, prevent fraud behavior and optimize campaign performance in user acquisition. |
Our third party service providers and business partners. |
|
Geolocation, such as country, state, city and zip code. |
Providing you with the correct versions of our services (including Games and applications) |
You, through your use of our Games and applications. Our third party service providers and business partners. |
We determine the retention period for each of the above listed categories of personal information based on the following factors: (i) the length of time we need to retain the information to achieve the business or commercial purpose for which it was originally obtained, (ii) any legal or regulatory requirements applicable to such information, and (iii) any need for the information based on any actual or anticipated investigation, litigation or claim.
3. “Selling” of Your Personal Information Under CCPA
The CCPA defines a “sale” of personal information very broadly, accordingly it is defined as selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. Thus, not only exchange of personal information for monetary purposes, but also other disclosures of personal information that can be seen as having value.
We do not sell your personal information in exchange for monetary compensation. However, when conducting user acquisition campaigns and working with our attribution partners we may disclose limited pieces of your personal information to attribute installs, prevent fraud behavior and optimize campaign performance. Depending on how you interact with us and which media source you use when installing or re-engaging with our Games the following categories of personal information may be sold:
IDFA (Identifier For Advertisers)
Android ID (Android device)
Google Advertiser ID
network status (WiFi/3G) the version of your operating system
IP address
Device ID (persistent/non-persistent)
installed software
application usage data
hardware type
browser information
in-game information
browser type, device type and model, CPU, system language, memory, OS version, time stamp and zone, device motion parameters and carrier
You have the right to forbid us to “sell” your personal information by using the “Do not sell my personal information” -right you have under CCPA. Using this right means that we will no longer share your above information with our attribution partners for them to attribute installs and optimize campaign performance. If you would like to use this right and opt out of Valas Media’s sharing your above information with our attribution partners for above purposes, you may do so by sending your request at ccpa-requests@valas.media or here. However, even if you opt-out, we may still use information for non-targeted advertising purposes such as analytics and share some of your information with our service providers to provide services on our behalf, such as fraud prevention, measuring the effectiveness and performance of contextual advertisements, providing analytics and aggregate statistics, and similar services that do not involve the sale of your personal information in the meaning of CCPA.
For the sake clarity, we do not knowingly sell the personal information of minors under 16 years of age without affirmative authorization required in accordance with the applicable law.
4. Your Rights Under CCPA
No discrimination. Under the CCPA, you have the right not to receive discriminatory treatment for the exercise of your privacy rights. This means that we will not deny, charge different prices for, or provide a different level of quality of Games or services to you, if you choose to use these rights.
Right to stop selling of your personal information under CCPA. Under CCPA, you have right to opt-out from selling your personal information. If you would like to opt-out of Valas Media use of your information for purposes that may be considered a “sale” under CCPA, “Selling” of your personal information under CCPA, you may do by the means we have explained above in section 3.
Right to know and delete your personal information. You have the right to know (free of charge up to two times in a 12-month period) what categories of your personal information that we collect, use, and share. You may also request the deletion of your information. These requests can be also directed to specific pieces of personal information that we have collected from you. After the deletion of your information we cannot provide you with our Games or services anymore. Please note that it is possible that certain information may be exempt from these requests under applicable law.
How to exercise your “right to know” and “right to deletion” rights? You can exercise these rights by clicking here or submitting your request to ccpa-requests@valas.media. For security purposes, we will verify your identity – including requesting information from you – when you request to exercise your above referred rights. We will request additional information from you to match with our existing records to verify your identity, depending on the nature of the request. Once we have verified your identity, we will respond to your request as appropriate. If we are unable to complete your requests, we will provide you information about the reasons that we could not comply with your request. We always aim to fulfill all verified requests within 45 days in accordance with the CCPA, with a receipt of confirmation of a request in 10 business days. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
Right to use of authorized agents. You may also designate an agent to make the requests described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization.