Last updated: 28 August 2024
Table of Contents
1. Introduction
This Privacy Policy describes how VOLKA ENTERTAINMENT LIMITED (“VOLKA”, “we”, “us”, or “our”) collects and uses your personal data, and your rights and choices concerning your personal data.
This Privacy Policy applies when you use our Service which comprises VOLKA’s game (the “Game”), website, and related services. By accepting this Policy, you agree to our collection, storage, use, disclosure, transfer (including cross-border transfer) of your personal data as stated in the Policy. If you are at all concerned about the way we use your personal data, please refrain from using our Service.
We may change this Privacy Policy from time to time, in which case we will notify you. If you do not agree to the then-current version of our Privacy Policy, you must stop using our Service.
If you are a California, Virginia, Colorado, Connecticut, Utah, Oregon or Texas resident, please review our United States Privacy Notice.
The data controller: VOLKA ENTERTAINMENT LIMITED
Address: 3, Kleopatras Street, 3042 Limassol, Cyprus
Email: info@volkagames.com
Data Protection Officer
Address: 3, Kleopatras Street, 3042 Limassol, Cyprus
Email: privacy@volka.com
2. Definitions
For the purposes of this Policy:
- “personal data” means any information relating to an identified or identifiable natural person
- “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- “controller” means the natural or legal person, public authority, agency, or other body which determines the purposes and means of the processing of personal data
- “processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller
3. Data We Collect and How
We collect personal data that you provide to us directly when creating an account or communicating with us. When you use our Service, including any chat feature, we will collect information about the ways in which you use and interact with our Service. We may also collect or receive information about you from third parties connected to our Service.
Data you give us
- Contact information: name, email address.
- Player profile and account information: name, username, password, email address, profile photo, language.
- Communications to the Service: messages sent to the support team and other correspondence with us, your public posts or comments in our official page, game reviews and feedback you submit about our Service, messages or information sent through any chat features within the Service to other users.
Data we collect automatically
- Game-related data: Game ID (created by VOLKA and used to identify your account), gameplay data, including game progress, levels, session length, in-game purchases, game preferences, interactions with other players, other in-game activities.
- Technical data: IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, language, browser plugin versions.
- Usage data: date and time of activity on our Service, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks, and mouse-overs), referring/exit pages and URLs.
The collection of this information involves the use of cookies and similar technologies. For more information about how we use cookies and similar technologies and how you can manage or disable them, please read our Cookies Policy.
Data we obtain from third-party sources
- Data from third-party platforms if you choose to link them to our Service (Facebook, Google, app stores). For example, if you access the Game from your Facebook account, we may receive any information from your Facebook profile that you or Facebook shares with us. Such information may include your Facebook user identification number (Facebook ID number) and information about your use of the Game. If you access the Game from your Google account, we may receive your Google email address and avatar. The information we receive depends on your privacy settings on these third-party platforms. We advise you to carefully read their terms of service and privacy policy so that you understand how they use your personal data and what might be shared, and if necessary, to modify your privacy settings directly on their service.
- Data from advertising and analytics providers we work with. These third parties may set and read their own cookies and similar technologies to collect information through our Service and provide us with demographic data, analytics, and other aggregated data. These data do not directly or indirectly identify any individual.
4. How We Use Your Data
We use your personal data for various purposes. You can access some parts of our Service without giving us your personal data. However, to create an account and play our Game, you will need to provide your personal data.
We will use your personal data under several legal bases including to perform our contract with you (i.e., our Terms of Service), to comply with a legal obligation, to pursue our legitimate interests (provided that these are not overridden by your interests or rights), or with your consent.
We have listed the purposes for which we will use your personal data and the legal bases we rely upon to do so in the table below.
| PURPOSE | LEGAL BASIS |
| To create your game account and allow you to play our Game and use our Service. | Performance of contract |
| To enable in-game purchases. | Performance of contract |
| To respond to your questions, comments, requests, and complaints as well as to provide player support. | Performance of contract |
| To send you related information, security alerts, and other notices; notify you of updates, changes to our terms and policies; inform you about new products and services, promotions, contests or special events. | (a) Your consent (in the case of promotional communications via email) (b) Performance of contract (c) Legitimate interests – keeping you updated about our Service; promoting our Service and keeping you interested in it |
| Monitoring, troubleshooting, testing, system maintenance, technical support. | (a) Performance of contract (b) Legitimate interests – running our business; increasing the functionality of the Service and user friendliness; improving the quality of our Service; ensuring that users have the best possible experience when using our Service |
| To better understand how you use our Service, your behaviour and preferences; develop and enhance the Game and gaming experience; provide chat features as part of the Service; personalise player experience. | (a) Your consent (b) Legitimate interests – keeping our Service updated and relevant; improving our Service; providing the best possible experience to our users |
| To deliver and target advertising; measure the effectiveness of our advertising. | (a) Your consent (b) Legitimate interests – promoting our Service; attracting new users and re-engaging our current users; increasing the amount of revenue generated via in-game purchases; improving our advertising; defining our marketing strategy; growing our business |
| To analyse and monitor use of the Service and its chat features; prevent fraud and other illegal activities; protect our property; take action against fraudulent or misbehaving players; enforce our Terms of Service. | (a) Legal obligation – keeping our Service and its chat features safe and fair; ensuring that any use of our Service is lawful and non-fraudulent (b) Legitimate interests – protecting and running our business; keeping our Service and its chat features safe and fair; managing security, network and information security; risk and fraud prevention; protecting the safety and well-being of players |
5. Data Sharing
We may share your personal data with the following categories of third parties:
- Business partners and third-party service providers who perform services on our behalf, such as mobile platforms and social networks, software providers, providers of technical support, player support, email and notification services, payment service providers, data analytics, marketing, advertising, data storage, website security services. These partners handle the data in compliance with data protection laws and only as instructed by VOLKA.
With some of these partners, we only share anonymous information, i.e., information which does not directly or indirectly disclose your identity. For example, we may share anonymous and aggregated information with our advertising partners (such as Compado and WeLoveX). Such information may include technical data, unique identifiers, game statistics and behaviour, advertisement performance data. We may also allow our advertisers to collect anonymous and aggregated information within the Service and they may then share that information with us. Our advertisers may collect this information through the use of cookies and other similar tracking technologies. This enables our advertisers to deliver targeted advertising in order to personalise your experience by showing you advertisements for products and services that are more likely to be of interest to you. Advertisers will also use this information to measure advertising effectiveness and improve their operations. You can opt out of targeted advertising by following the instructions in section 9 below. We may also share anonymous data with our consent management platforms, including OneTrust and Usercentrics. This data typically consists of records of user interactions with our Service. By using these platforms, we aim to enhance your privacy and ensure compliance with relevant data protection laws.
- Public authorities and other organisations. We will disclose your personal data if we are required to do so in order to comply with any laws or regulations, to respond to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes, to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violation of our Terms of Service.
- Other users of our Service. The Service may include chat features where you can post messages and communicate with other users. When posting information to any chat feature, please be aware that such information is made available to other users. Therefore, please avoid disclosing any of your personal data to other users through any chat feature.
We do not sell or rent your personal data to third parties.
6. International Data Transfers
We may transfer the personal data we collect to countries other than the country in which the data originally was collected. We store your personal data on servers located in the European Economic Area (“EEA”) and in the United States, and we may also process these data in other countries (including outside the EEA) where our business partners and service providers operate. We take steps to ensure that your data are transferred to third countries which have been recognised as providing an adequate level of protection, otherwise, that appropriate safeguards are in place, such as by the use of standard contractual clauses approved by the European Commission for transfers of data from inside the EEA to a country outside the EEA. If you would like to learn more about these safeguards, please write to our Data Protection Officer at privacy@volka.com. If you are not satisfied with the safeguards we implement and you do not want your personal data to be transferred in third countries, unfortunately, you should request us to erase your personal data and you should stop using our Service.
For more details about where we transfer your personal data, please see the information below.
- Google (https://support.google.com/policies/contact/general_privacy_form)
Personal data transferred: Name, email address, username, language, Game ID, game progress, levels, session length, in-game purchases, game preferences, interactions with other players, other in-game activities, IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks, and mouse-overs), referring/exit pages and URLs
Country: Germany, Ireland, United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Google
Purpose for which the recipient uses the personal data: Hosting, cloud storage, authentication, analytics, advertising, notification delivery
Recipient’s retention period: Until the purpose of processing personal data is achieved - Meta (https://www.facebook.com/help/contact/1650115808681298)
Personal data transferred: Name, email address, username, language, Game ID, game progress, levels, session length, in-game purchases, game preferences, interactions with other players, other in-game activities, IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks, and mouse-overs), referring/exit pages and URLs
Country: Ireland
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Meta
Purpose for which the recipient uses the personal data: Authentication, advertising
Recipient’s retention period: Until the purpose of processing personal data is achieved - Helpshift (privacy@helpshift.com)
Personal data transferred: Technical data, such as username, language, Game ID, game progress, levels, session length, IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, browser plugin versions, date and time of activity
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Helpshift
Purpose for which the recipient uses the personal data: Game user support
Recipient’s retention period: Until the purpose of processing personal data is achieved - Leaseweb (privacy@leaseweb.com)
Personal data transferred: Name, email address, username, password, profile photo (if provided), language, Game ID, game progress, levels, session length, in-game purchases, game preferences, interactions with other players, other in-game activities, IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks and mouse-overs), referring/exit pages and URLs
Country: Netherlands, United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Leaseweb
Purpose for which the recipient uses the personal data: Cloud storage
Recipient’s retention period: Until the purpose of processing personal data is achieved - Zendesk (privacy@zendesk.com)
Personal data transferred: Technical data, such as username, language, Game ID, game progress, levels, session length, IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, browser plugin versions, date and time of activity
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Zendesk
Purpose for which the recipient uses the personal data: Game user support
Recipient’s retention period: Until the purpose of processing personal data is achieved - Pushwoosh (privacy@pushwoosh.com)
Personal data transferred: Technical data, such as IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, language, browser plugin versions
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Pushwoosh
Purpose for which the recipient uses the personal data: User notification
Recipient’s retention period: Until the purpose of processing personal data is achieved - Mailgun Technologies (privacy@mailgun.com)
Personal data transferred: Name, email address, IP address
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Mailgun Technologies
Purpose for which the recipient uses the personal data: Email delivery
Recipient’s retention period: Until the purpose of processing personal data is achieved - Brevo (dpo@brevo.com)
Personal data transferred: Name, email address, IP address
Country: France
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Brevo
Purpose for which the recipient uses the personal data: User communication
Recipient’s retention period: Until the purpose of processing personal data is achieved - AppsFlyer (privacy@appsflyer.com)
Personal data transferred: In-game purchases, in-game activity, IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, language, browser plugin versions, data and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks, and mouse-overs), referring/exit pages and URLs
Country: Israel
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and AppsFlyer
Purpose for which the recipient uses the personal data: Analytics and ads management
Recipient’s retention period: Until the purpose of processing personal data is achieved - Amazon AWS (aws-EU-privacy@amazon.com)
Personal data transferred: IP address, device type, operating system, platform, device settings, device identifiers, browser type and version, language, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks, and mouse-overs), referring/exit pages and URLs
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Amazon AWS
Purpose for which the recipient uses the personal data: Analytics and ads management
Recipient’s retention period: Until the purpose of processing personal data is achieved - Unity (dpo@unity3d.com)
Personal data transferred: In-game activity, IP address, device type, operating system, platform, device settings, browser type and version, language, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks and mouse-overs), referring/exit pages and URLs
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Unity
Purpose for which the recipient uses the personal data: Advertising
Recipient’s retention period: Until the purpose of processing personal data is achieved - Moloco (privacy@moloco.com)
Personal data transferred: In-game activity, IP address, device type, operating system, platform, device settings, browser type and version, language, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks and mouse-overs) referring/exit pages and URLs
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Moloco
Purpose for which the recipient uses the personal data: Advertising
Recipient’s retention period: Until the purpose of processing personal data is achieved - Liftoff (DPO@liftoff.io)
Personal data transferred: In-game activity, IP address, device type, operating system, platform, device settings, browser type and version, language, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks and mouse-overs), referring/exit pages and URLs
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Liftoff
Purpose for which the recipient uses the personal data: Advertising
Recipient’s retention period: Until the purpose of processing personal data is achieved - Taboola (dpo@taboola.com)
Personal data transferred: In-game activity, IP address, device type, operating system, platform, device settings, browser type and version, language, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks and mouse-overs), referring/exit pages and URLs
Country: United Kingdom
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Taboola
Purpose for which the recipient uses the personal data: Advertising
Recipient’s retention period: Until the purpose of processing personal data is achieved - Microsoft (https://www.microsoft.com/en-us/concern/privacy)
Personal data transferred: In-game activity, IP address, device type, operating system, platform, device settings, browser type and version, language, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks and mouse-overs), referring/exit pages and URLs
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Microsoft
Purpose for which the recipient uses the personal data: Advertising
Recipient’s retention period: Until the purpose of processing personal data is achieved - Yahoo Japan (https://privacy.lycorp.co.jp/en/inquiry/)
Personal data transferred: In-game activity, IP address, device type, operating system, platform, device settings, browser type and version, language, browser plugin versions, date and time of activity, features used, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (such as scrolling, clicks and mouse-overs), referring/exit pages and URLs
Country: Japan
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Yahoo Japan
Purpose for which the recipient uses the personal data: Advertising
Recipient’s retention period: Until the purpose of processing personal data is achieved - Adyen (dpo@adyen.com)
Personal data transferred: Email address, in-game purchases, IP address (personal data is collected directly from Adyen)
Country: Netherlands
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Adyen
Purpose for which the recipient uses the personal data: Payment processing
Recipient’s retention period: Until the purpose of processing personal data is achieved - Xsolla (gdpr@xsolla.com)
Personal data transferred: Email address, in-game purchases, IP address (personal data is collected directly from Xsolla)
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and Xsolla
Purpose for which the recipient uses the personal data: Payment processing
Recipient’s retention period: Until the purpose of processing personal data is achieved - PayPal (https://www.paypal.com/us/smarthelp/contact-us/privacy)
Personal data transferred: Email address, in-game purchases, IP address (personal data is collected directly from PayPal)
Country: United States
Date and method of transfer: Personal data is transferred as part of a continuing electronic data transfer between VOLKA and PayPal
Purpose for which the recipient uses the personal data: Payment processing
Recipient’s retention period: Until the purpose of processing personal data is achieved
7. Data Retention
We will retain your personal data for as long as is necessary for the purposes set out in this Privacy Policy. We will delete your data if you request us to erase your personal data (see section 9 below).
Please note that, even after you have asked us to erase your data, we may retain some of your personal data where necessary to enable us to meet our legal obligations, to exercise or defend legal claims, or for other purposes as permissible by law. We also reserve the right to depersonalise your data (remove all direct or indirect references to your identity) and continue using it for our own legitimate interests, such as for research and statistical purposes.
Your personal data will be destroyed without delay once they become unnecessary for the purposes set out in this Privacy Policy. Your personal data is stored in electronic format. We destroy your personal data within our systems through technical means which make the personal data permanently unrecoverable.
Information you have disclosed to other users through the Service, including without limitation through any chat feature, may remain visible to other users after you have asked us to erase your data. Such information will show an anonymised account as its source. We do not control the information that other users copy out of our Service. Therefore, please avoid disclosing any of your personal data to other users through our Service.
8. Data Security
We have implemented reasonable and appropriate security measures to protect your personal data against loss, destruction, alteration, misuse, unauthorised access or disclosure. In addition, we take reasonable steps to ensure that third parties to whom we disclose or transfer any data will provide sufficient protection of your data.
Please be aware that, in spite of all precautions we take, no security system can prevent all potential security breaches. Therefore, we cannot guarantee the absolute security of your data. We urge you to take steps to keep your personal information, including your account information, secure and to be careful when you submit or transmit any data through the Service, including through any chat feature.
9. Your Rights and Options
Under the data protection laws, you have the following rights:
- Right of access to your personal data, which allows you to obtain a copy of the data we hold about you and other supplementary information about our privacy practices with respect to your personal data.
- Right to have inaccurate personal data rectified or incomplete personal data completed.
- Right to have your personal data erased in certain circumstances; for example, where there is no good reason for us to continue processing them, where you have withdrawn your consent, or you have objected to the processing of your personal data (see below). The erasure of your personal data leads to the permanent loss of access to your game account.
- Right to request restriction of processing of your personal data in certain circumstances; for example, while we are considering a rectification or objection request made by you.
- Right to data portability, which allows you to receive the personal data that you have provided to us, in a structured, commonly used and machine readable format, and also to request that your personal data be transmitted to another controller.
- Right to object to the processing of your personal data, on grounds relating to your particular situation and in certain circumstances such as where we are relying on our legitimate business interests as the legal ground for processing, or where personal data are processed for direct marketing purposes.
- Right to withdraw your consent at any time if we are processing your personal data with your consent.
- Right to lodge a complaint about the way we handle your personal data with your local data protection authority.
To exercise any of your rights specified above, please submit a request via our Support directly within the Game.
We will try to respond to any such request as soon as possible, but we will always do so within the time limit set by the applicable data protection law.
- Opt out of direct marketing. Where permitted by applicable laws, VOLKA may send you marketing emails. If you want to stop receiving promotional emails from VOLKA, click on the “unsubscribe” link at the bottom of any promotional email from VOLKA. Please be aware that you may still receive non-promotional emails from us, including those related to the Service, updates to our Terms of Service or Privacy Policy, and transactional information (for example, details about your purchases on the Service). If you want to stop receiving push notifications, which are messages an app or website sends you on your mobile device or web browser even when the app or site is not active, you can turn off push notifications by going to your mobile device or browser settings.
- Opt out of targeted advertising. You can opt out of interest-based advertising by adjusting your device or your browser settings:
- For iOS devices: go to Settings > Privacy > Apple Advertising and turn off “Personalized Ads”.
- For Android devices: go to Settings > Google services > Ads and enable “Opt out of Ads Personalisation”.
You can also reset the “Advertising Identifier” from your mobile device settings page, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier”. - For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies, and by visiting the following sites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.
- To opt out of targeted ads on Facebook, please visit this page.
Please note that, even if you use your right to opt out, you will still receive advertising, but the advertising you see may be less relevant to your interests.
10. Automated Decision-Making
In some instances, our use of your personal data may result in automated decision-making, including profiling. Automated decision-making is the process of making a decision concerning you by automated means (using software algorithms) without any human involvement. For example, we use automated decisions to provide direct or targeted advertising on our Service. You can exercise your right to object to such processing or opt out of direct or targeted advertising as described in section 9 above.
We do not carry out any decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects any user.
11. Children
Our Service is available only to individuals who are at least 16 years old. If you are under the age of 16, you must obtain permission from your parent or legal guardian before using our Service and submitting your personal data.
We do not knowingly collect personal data from children under 16, or process such information without parental consent. If we learn that we have inadvertently done so, we will try to take steps to promptly delete such data from our records. If you believe that we might have collected personal data from a child under the age of 16 without parental consent, please contact us.
12. Links to Third Parties
Our Service may contain links to third-party websites. If you click on a third-party link, you will be directed to that third-party’s site and will be subject to their own privacy policy. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services. You should always review the privacy policy of each site you visit.
13. Governing Language
This Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. In case of any inconsistency or discrepancy between a translated version of this Privacy Policy and the English version, the English version shall prevail.
14. Contact Us
If you have any questions regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer at privacy@volka.com. For general enquiries, you may contact our Support team.