Last updated: 28 August 2024
Table of Contents
2. Collection and Use of Personal Information
3. Disclosing Personal Information
4. Selling and Sharing Personal Information
7. Commitment to Compliance with US Privacy Laws
1. Introduction
This United States Privacy Notice (“Notice”) supplements the information contained in the Privacy Policy of VOLKA ENTERTAINMENT LIMITED (“VOLKA”, “we”, “us”, or “our”) and applies solely to individual residents of the States of California, Virginia, Colorado, Connecticut, Utah, Oregon, and Texas in the United States (“consumers” or “you”).
This Notice describes how we collect, use, and disclose personal information about you when you use our Service which comprises VOLKA’s game (the “Game”), website, and related services. We adopt this Notice to comply with the following laws (“US privacy laws”):
- California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and as supplemented by any adopted regulations.
- Virginia Consumer Data Protection Act (“VCDPA”).
- Colorado Privacy Act (“CPA”), as supplemented by any adopted rules.
- Connecticut Data Privacy Act (“CTDPA”).
- Utah Consumer Privacy Act (“UCPA”).
- Oregon Consumer Privacy Act (”OCPA”).
- Texas Data Privacy and Security Act (”TDPSA”).
All the terms in this Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the US privacy laws. The terms “personal data” and “personal information” are used interchangeably in this Notice.
We may update this Notice from time to time, in which case we will notify you. If you do not agree to the then-current version of this Notice, you must stop using our Service.
2. Collection and Use of Personal Information
We collect the following categories of personal data about consumers, which are also the categories of personal information we have collected over the previous 12 months:
- Identifiers: name, username, email address, Game ID, account password, IP address, device identifiers, online identifiers.
- Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): name.
- Commercial information: in-game purchases.
- Internet or other network activity information: date and time of activity on our Service, features used, in-game activities, content viewed or engaged with, pages viewed and the order of those pages, amount of time spent on a page, page interaction information (scrolling, clicks, and mouse-overs), referring/exit pages and URLs.
- Geolocation data: IP address.
- Inferences drawn from any of the above categories of personal information: information reflecting in-game behaviour and preferences.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you. We collect personal information that you provide to us when you create an account or communicate with us.
- Indirectly from you when you use our Service. We collect information by automated means, including through the use of cookies and similar technologies, about how you use and interact with our Service.
- Third parties. We obtain information from third-party platforms if you choose to link them to our Service (Facebook, Google, app stores).
We may use the personal information we collect for the following business or commercial purposes:
- To create your game account and allow you to play our Game and use our Service.
- To respond to your questions, comments, requests, complaints, and provide player support.
- To send you email alerts, updates, and other notices concerning our Service.
- For monitoring, troubleshooting, testing, system maintenance, technical support.
- For product development/improvement.
- To personalise and enhance player experience.
- To improve our Service.
- To deliver and target advertising.
- To prevent fraud and other illegal activities, protect our property, take action against fraudulent or misbehaving players, and enforce our Terms of Service.
3. Disclosing Personal Information
We may disclose your personal information to third parties for business purposes as identified in section 2 of this Notice. We may disclose your personal information to the following categories of third parties:
- Business partners and third-party service providers: Mobile platforms and social networks, software providers, providers of technical support, player support, email services, data analytics, marketing, advertising, data storage, website security services.
- 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 disclose the following categories of personal data about consumers. These are also the categories of personal information we have disclosed in the previous 12 months:
- Identifiers.
- Personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
- Commercial information.
- Internet or other network activity information.
- Geolocation data.
- Inferences drawn from any of the above categories of personal information
4. Selling and Sharing Personal Information
VOLKA does not sell any personal information to third parties for monetary consideration. However, we may use and share the following categories of personal data with our advertising partners for the purpose of targeted advertising. The following are the categories of personal information we have shared with our advertising partners for the purpose of targeted advertising in the previous 12 months:
- Identifiers.
- Commercial information.
- Internet or other network activity information.
- Geolocation data.
- Inferences drawn from any of the above categories of personal information.
You may opt out of the sharing of your personal data for the purpose of targeted advertising through the “Do Not Sell My Personal Information” link on our website. Please note that we comply with Global Privacy Control signals (“GPC signals”), through which you can opt out of targeted advertising. Further information on how you can opt out through the GPC signals can be found here. Please also note that we support Do Not Track (“DNT”) requests.
5. Data Retention
We will retain your personal information as long as is necessary for the purposes set out in this Notice. We will delete your information upon your request (see section 6 below).
Please note that, even after you have asked us to delete your information, we may retain some of personal information where necessary to enable us to meet our legal obligations, to exercise or defend legal claims, or for other purposes as permissible by law.
6. Your Rights
The US privacy laws provide consumers with specific rights regarding their personal information. This section describes your rights and explains how to exercise those rights.
Right to Know and Access
You have the right to confirm whether or not we are processing your personal data and to access such personal data.
If you are a California resident, you have the right to request that we disclose to you the following information about our collection and use of your personal information:
- The categories of personal information we have collected about you.
- The specific pieces of information we have collected about you.
- The categories of sources from which the personal information was collected.
- If we have sold, shared, or disclosed your personal information for a business purpose, the categories of personal information we have sold, shared, or disclosed about you, and for each category of personal information identified, the categories of third parties to whom the personal information was sold, shared, or disclosed.
- The business or commercial purpose for collecting, sharing, or, if applicable, selling that personal information.
If you are an Oregon resident, you have right to confirm the categories of personal data processed.
Right to Correct
You have the right to request that we correct any inaccurate personal information we hold about you.
Right to Delete
You have the right to request that we delete any personal information we have collected about you, subject to certain exceptions.
Right to Data Portability
You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance.
Right to Opt Out of Targeted Advertising / Sharing of Personal Information
You have the right to direct us not to share personal information about you with third parties for the purpose of targeted advertising.
You may opt out of targeted advertising by following the methods described in section 4 of this Notice.
Right to Opt Out of the Sale of Personal Information
You have the right to direct us not to sell personal information about you to third parties.
As described in section 4 of this Notice, VOLKA does not sell your personal information for monetary consideration but shares your personal data with third parties for the purpose of targeted advertising. To the extent that this practice is considered a “sale” under the US privacy laws, you may opt out of such processing by following the methods described in section 4 of this Notice.
Right to 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. 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).
Right to Opt Out of Profiling
You have the right to opt out of the processing of the personal data for the purpose of profiling in furtherance of automated decisions that produce legal or similarly significant effects concerning the consumer. Please note that VOLKA does not carry out profiling in furtherance of automated decisions that produce legal or similarly significant effects as defined by US privacy laws.
Right to Limit Use and Disclosure of Sensitive Personal Information
If you are a California resident, you have the right to direct us to limit the use of any sensitive personal information we hold about you to that use which is necessary to perform our Service and is reasonably expected by an average consumer who uses our Service. Please note that VOLKA does not collect any sensitive personal information as defined by the CCPA.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your rights. Specifically, we will not:
- Deny you our Service.
- Charge you different prices or rates for our Service, including through the use of discounts or other benefits or imposing penalties.
- Provide you a different level or quality of our Service.
- Suggest that you may receive a different price or rate for our Service, or a different level or quality of our Service.
How to Exercise Your Rights
To exercise the rights described above, please submit a request by one of the following methods:
- Via our Support directly within the Game.
- By sending an email to privacy@volka.com.
When submitting a request, please specify the US state where you reside.
Only you or a person authorised to act on your behalf may make a consumer request related to your personal information. We will need to verify your identity before processing your request. In order to verify your identity, we will either require the submission of the request via our Support directly within the Game or the provision of sufficient information related to your game account. If you designate an authorised agent to make a request on your behalf, we will require the authorised agent to provide proof that they have been authorised by you.
If you are a Virginia, Colorado, Connecticut, Oregon, or Texas resident, you also have the right to appeal in case we refuse to take action on your request by contacting us via one of the methods mentioned above. In such a case, we will examine and process your appeal in accordance with the applicable US privacy law.
Response Timing
We will endeavour to respond to a verifiable consumer request within the time limits set by the applicable US privacy law. We will deliver our written response to your email address.
7. Commitment to Compliance with US Privacy Laws
We are committed to comply with all applicable US privacy laws, including those that will come into effect in the future. This includes US privacy laws in Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, and Maryland. Please rest assured that once these US privacy laws become effective, we are fully committed to respecting and adhering to the applicable legal requirements.
8. Contact Us
If you have any questions regarding this Notice, please contact our Data Protection Officer at privacy@volka.com. For general enquiries, you may contact our Support.