PRIVACY POLICY

Last updated: 22 December 2020

Table of Contents

1. Introduction

2. Definitions

3. Data We Collect and How

4. How We Use Your Data

5. Data Sharing

6. International Data Transfers

7. Data Retention

8. Data Security

9. Your Rights and Options

10. Automated Decision-Making

11. Do Not Track

12. Children

13. Links to Third Parties

14. Contact Us

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 consent 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 resident, please review our California Notice.

The data controller: VOLKA ENTERTAINMENT LIMITED
Address: 3, Kleopatras, 3042 Limassol, Cyprus
Email: info@volkagames.com

Data Protection Officer
Address: 3, Kleopatras, 3042 Limassol, Cyprus
Email: privacy@volkagames.com

2. Definitions

For the purposes of this Policy:

  1. “personal data” means any information relating to an identified or identifiable natural person
  2. “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 
  3. “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
  4. “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 information that you provide to us directly when creating an account or communicating with us. When you use our Service, 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, phone number (if provided).
  • 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 on our official page, game reviews, and feedback you submit about our Service.

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 Cookie Notice.

Data we obtain from third-party sources

  • Data from third-party platforms if you choose to link them to our Service (Facebook, 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 name, profile picture or its URL, user identification number (Facebook ID number), email address, friends list, information about your use of the Game. 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 information. However, to create an account and play our Game, you will need to provide your personal information.

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.

PURPOSELEGAL BASIS
To create your game account and allow you to play our Game and use our Service.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)
(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; 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 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 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 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 services, data analytics, marketing, advertising, data storage, website security services. These partners handle the data 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 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.

  • 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.

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, those 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@volkagames.com.

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 delete your account or you request us to erase your personal data (see section 9 below).

Please note that, even after you have deleted your account or 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.

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 any data through the Service.

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).
  • 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 through our Support team.

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. If you want to stop receiving promotional emails from VOLKA, click on the “unsubscribe” link at the bottom of any promotional email from VOLKA. If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by going to your mobile device 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 > Advertising and turn on “Limit Ad Tracking”.
    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.

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. Do Not Track

We do not support Do Not Track (“DNT”) and therefore do not respond to DNT requests.

12. Children

Our Service is not intended for children under the age of 16. If you are between the ages of 16 and 18, or between 16 and the age of majority where you live, 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 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, or without parental consent, please contact us.

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.

14. How to contact us

If you have any questions regarding this Privacy Policy or our data protection practices, please contact our Data Protection Officer at privacy@volkagames.com. For general enquiries, you may contact our Support team.