Privacy Policy

Last Updated: September 1, 2018

Please read this Policy carefully before using this Website

Table of Contents

  1. Introduction
  2. Definitions
  3. Information we collect and how
  4. How we use information we collect and our legal basis for processing it
  5. How we share your information
  6. Where and how long we store your personal data
  7. How we protect your personal data
  8. Your rights concerning your personal data
  9. Age Limits
  10. Links to third parties
  11. Changes to our Privacy Policy
  12. How to contact us

Introduction

Protecting your data and privacy is very important to VOLKA ENTERTAINMENT LIMITED (“VOLKA”, “us” or “we”).

This Policy (together with our Terms and Conditions of Service and any other documents referred to in it) sets out the basis on which any personal data we collect from you or that you provide to us, will be processed by us in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). Please read the following carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, as well as the rights you have concerning your personal data. By visiting our website (“Website”) or playing one of our games (“Games”) you are accepting and consenting to the practices described in this Policy. Unless context otherwise requires, a reference to the Games shall be deemed to also refer to the Website. 

For the purposes of the relevant data protection legislation, the data controller is VOLKA ENTERTAINMENT LIMITED, a Cyprus company (company number HE 355146) having its registered office at 15, Spyrou Kyprianou Street, Matrix Tower II, 1st Floor, Mesa Geitonia Area, 4001 Limassol, Cyprus.

Definitions

For the purposes of this Policy:

  1. “personal data” means any information relating to an identified or identifiable natural person (“data subject”);
  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, organization, 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.

Information we collect and how

We may collect and process the following data about you:

  • Information you give us

    Summary: You may give us information about you by filling in forms when using the Games or by corresponding with us by phone, e-mail or otherwise. This includes (but is not limited to) information you provide when you register to use the Games, subscribe to our Service, or when you report a problem with our Games.

    The information you give us may include:

    • your first and last name;
    • your username and password;
    • your gender;
    • your age or birthday;
    • your e-mail address;
    • your phone number;
    • your Internet Protocol (IP) address;
    • your profile photo;
    • any other information you have made available on your Facebook profile.

  • Information we collect about you

    Summary: With regard to each of your visits to our Games we may automatically collect information about how you interact with and navigate our Service, as well as the device and software you use to do so.

    We collect the following information:

    • technical information, including the IP address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Games (including date and time); what you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
    • information we collect via cookies. For more information, please refer to our Cookies Policy here.

  • Information we receive from other sources

    Summary: We may receive information about you if you use any of the other services we provide. We are also working closely with third parties (including, for example, Facebook, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

    Information we collect from other sources include:

    • information we receive if you access our Games through third-party applications or connect a third-party tool with our Service (such as Facebook);
    • information for advertising and marketing purposes;
    • information for analytics purposes, so that we can provide you a better service;
    • information from third-party companies who have obtained your consent or have another legal right to share such information with us (including publishing partners, platforms, advertising platforms and partners and data aggregators). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use this information as described in this Privacy Policy and subject to any limitations in the privacy policy of the company that collected the information from you.

How we use information we collect and our legal basis for processing it

Summary: We use your information under several legal bases, including to perform our contract with you, to comply with our legal obligations, to pursue our legitimate business interests, or otherwise, with your consent.

Processing is necessary for the performance of our contract with you. We use your information to carry out our obligations arising from any contract entered into between you and us, such as to create your game accounts and allow you to play our Games, to ensure that content from our Games is presented in the most effective manner for you and for your computer or mobile device, to notify you of changes to our Service, to provide you with the information, products and services that you request from us or information about goods and services we feel may interest you.

Processing is necessary for compliance with legal obligations we are subject to. We may use your data when processing is necessary for us to comply with a legal obligation, such as to keep our Service and its social features safe and fair, to protect VOLKA’s rights and property in connection with our Service, to prevent fraud or potentially illegal activities and ensure acceptable use, otherwise, take action against fraudulent or misbehaving players.

Processing is necessary for the purposes of our legitimate business interests. We may use your data when processing is necessary for us to pursue our legitimate interests and provided that these are not overridden by your interests or rights, such as for the purposes of data analysis, testing, research and surveying, as well as for the purposes of marketing and promotion of our products.

Processing is based on your consent. We may from time to time ask your consent to collect other information from you or your device. For instance, we may invite you to allow us to access your contacts to enable us to invite them to play our Games with you. If we do so, we will tell you what information we would like to collect, why we need it and what we will use it for. Provided that you have given us your specific and express consent to the use of your personal data, then the lawfulness of such processing might be based on that consent. You have the right to withdraw consent at any time.

How we share your information

Summary: We may share your personal information with third parties when you use our services under the circumstances described in this section.

We may share your information with selected third parties including:

  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
  • analytics and search engine providers that assist us in the improvement and optimization of our Games.

We may disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if VOLKA or substantially all of its assets is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation we are subject to, or in order to enforce or apply the Terms and Conditions of Service and any other documents referred to on it; or to protect the rights, property, or safety of VOLKA, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Where and how long we store your personal data

Summary: All information you provide to us is stored on our secure servers, based both in the European Economic Area (“EEA”) and in the United States of America. We will keep your information for as long as your account is active or we consider necessary for the purposes described in this Privacy Policy.

The data we collect from you may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Our processors include app markets, social networks, and payment service providers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

We restrict access of your personal information to those employees of VOLKA who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and privacy of customer information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information from any unauthorized access.

We will retain your personal data only for as long as it is necessary to provide you with our services or to complete the purposes set out in this Privacy Policy. However, please note that even after you have closed your account or have stopped using our services, we may continue to store your personal data if this is deemed necessary for us to fulfil our legal obligations.

Your personal data will be deleted when they no longer serve one of the abovementioned purposes but in any event, your personal data will be deleted after six (6) months of inactivity in your use of our services. Once we have deleted your information, you will not be able to exercise any right related to your personal data.

How we protect your personal data

Summary: We make all efforts to protect your personal information and maintain an appropriate level of security, while acknowledging the risks the Internet presents.

We take reasonable and appropriate technical and organizational security measures to ensure that your personal data is protected against accidental or unlawful loss, destruction, alteration, misuse, unauthorized access or disclosure. In addition, we request that our suppliers who process personal information on our behalf, take a range of security measures designed to help protect your personal information. However, unfortunately, no server, communications network, or data transmission over the Internet is 100% secure. Therefore, although we will do our best to protect your personal data, we cannot guarantee the absolute security of your information. As such, you should always take care when sharing your information online.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Games, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Your rights concerning your personal data

Summary: Under the relevant data protection legislation, you have a number of rights in relation to the data we hold about you, which you can exercise by contacting us at the email address provided below.

These rights include:

  • Right of access to your personal data. You have the right to know what information we hold about you, how and why we use your information, to whom we disclose your information, and request a copy of the information we hold about you. If you wish to exercise this right, please contact us at the email address provided below and let us know what information in particular you would like to receive, by filling in a form we will provide you with. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within one (1) month of receipt of your request and verification of your identity.
  • Right to rectification of your personal data. We try to keep the information we hold about you accurate and up to date. Should you realise that any of the information we hold about you is out of date, incorrect or incomplete, please let us know by contacting us at the email address provided below and filling in a form we will provide you with, and we will correct it as soon as we can.
  • Right to erasure of your personal data. In certain circumstances, you have the right to ask us to delete the data we hold about you where there is no good reason for us to continue processing it. Should you wish to ask for any information about you to be deleted, please contact us at the email address provided below. We will ask you to fill in a form which we will provide you with, and we will delete your personal information without undue delay and within one (1) month of receipt of your written request. Please note that in order for us to process your request, you must delete our Games from your mobile devices and terminate your account with us and clear our cookies from any device where you have played our Games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as record-keeping purposes, protecting or enforcing legal rights, as well as other purposes as permissible by applicable law. We may also retain your information in an anonymised form.
  • Right to restriction of processing of your personal data. Where certain conditions apply, you may have the right to request restriction of the processing of your personal data. For more information and to exercise this right, please contact us at the email address provided below. A form to fill in will be provided to you in this regard.
  • Right to object to the processing of your personal data for specific reasons. Should you wish to exercise this right, please contact us at the email address provided below and we will ask you to fill in a form in this regard. Following your request, we shall no longer process your personal data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms.
    You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise your right at any time by contacting us at the email address provided below.
  • Right to opt-out of direct marketing. If you have elected to receive direct marketing communications from us, you can change your mind at any time by following the opt out link in any marketing communication that is sent to you. If you have elected to receive more than one type of marketing communications from us, you may need to opt out of all of them individually. It may take a few days for us to update our records before any opt out is effective.
  • Right to data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so that you can transfer it to another data controller. You may also have the right to have your personal data transmitted directly from us to another controller. Should you wish to exercise this right, please contact us at the email address provided below and we will provide you with a form to fill in in this regard.
  • Right to withdraw your consent. In the event you gave us your consent to the processing of your personal data for specific purposes, you may withdraw this 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. You can exercise your right at any time by contacting us at the email address provided below.
  • Right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We do not carry out any decision-making based solely on automated processing, including profiling unless we have your consent, or we need to do so to perform a contract with you.

Age Limits

Summary: Our services are intended for use only by those over a certain age. Please refer to our Terms and Conditions of Service.

We do not knowingly collect personal information from children under 13 years of age. If you believe that we might have any data from or about a child under the relevant age and in order to request the deletion of personal data, for any reason, please contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.

Our Games may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you either by e-mail or by pop-up notification when opening the Games. Please check back frequently to see any updates or changes to our Privacy Policy.

How to contact us

Should you have any questions regarding this Privacy Policy or would like to use your personal data protection rights described above, please contact us at privacy@volkagames.com