PRIVACY POLICY FOR APPS AND WEBSITE

(Last update September 5, 2022)

ABOUT US AND THIS PRIVACY POLICY

Your privacy is very important for us and we will always use your personal information only for the purposes as described in this Privacy Policy. As used in this Privacy Policy, Play Valley", "we", "us" or "our", "ours" refers to Play Valley Limited and all of its subsidiaries.

This Privacy Policy covers how we collect, use, disclose, transfer and store information received about users and/or information received about users' computing devices through their use of the Apps or use of the website https://playvalley.io and any other websites and/or URL which may replace it or which may be added to the list of websites published by us and linking to this Privacy Policy (the "Website/s").

We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us, use the Applications or visit our Website. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services, content, and advertising.

INFORMATION WE COLLECT FROM YOU

Most of the information that we collect about you comes directly from you when you play our Apps or visit our Website. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our apps and may include information that you submit to us when you voluntarily contact us or which you allow us to access when you connect to your social network accounts through our Apps. We may also collect information from app store platforms and partners and other third parties such as information about in-app purchases (if we never receive your payment or credit card information).

1. Technical Information

We collect technical information about your device that is necessary for you to use our App and additional technical data that enables us to maintain and analyze the functioning of the App, and to personalize the content of the App. Such information includes amongst others the type of device(s) you are using to play our Apps, persistent identifiers, such as IP address, device identifiers, ad identifiers, unique user ID specific for our Apps, and the country or region that you are playing in.

Persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address) are identifiers that do not identify you personally but may uniquely identify your device. Such online identifiers provided by end user devices, applications, tools and protocols may be considered as personal information according to applicable data protection legislation. Please check the rights you have under applicable data protection legislation in Section "Your Rights".

We automatically collect certain information about your computing device, including:

IP address; Country or region;
IDFAs, IDFVs, Advertising IDs;
Language; Locale (specific location where a given language is spoken);
Time zone, session start/stop time,
Network status (Wi-Fi, etc.), browser plug-in types and versions;
User agent string (UA), platform, SDK version, timestamp;
All Play Valley Apps installed;
Technical device information (e.g. device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, Android ID, Android Serial No);
Push notifications token (in order for us to be able to determine whether you are subscribed to push notifications);
Player identifier string (we collect player identifier string only upon your sign into Google Play Games Services or Apple's Game Center).

In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps.

2. Application Usage Information

When you use our Apps, we collect additional information from you about how you play our Apps by using persistent identifiers that permit identification of your device. We collect information about how you play our Apps. Such information is used for delivering and improving our service, and analytics purposes.

We collect information, including log information, that lets us know:

How you play our Apps (how often you play the app, for how long you use the app, the events that occur within the app, in-app progress, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc.);
Whether you use chat feature, and if you do, the content of messages sent using our chat system, provided that this is only used for operating the service;
If you connect to Third Party Social Network, information we collect from you when you connect to such Third Party Social Network as described in "Third Party Social Networks" Section.

3. Classical Personal Information

We do not collect classical personal information through our Apps or Website (such as your name, address, email or phone number) and you can use our Apps or Website without providing us with your classical personal information. We will receive your classical personal information (such as your name, address, email or phone number) only when you contact us directly and will use such information only to respond to your inquiry.

We may ask you to submit and we may process other non-personally identifiable information that may be personal to you such as your age range, year of birth and gender.

For some of our Apps we may collect information about the nickname you choose or the information about the name you give to your virtual pet and your rating of the Application (if any). Please do not use your real name.

HOW WE USE YOUR INFORMATION

1. In General

We use the information we collect about you/your device to deliver services, our Apps and Website to you and to operate our business. We use it also for improving our services and Apps, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. We use your information also for complying with our legal obligations.

We use your information for the following purposes:

Delivering and improving our services: We use your information for developing, delivering and improving our Apps and other products, services, and content, tailoring our products and services, providing App updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Apps, and administering the Apps.
Analytics and research: We use your information for understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the App was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new game features and content.
Security: We use your information for enhancing the safety and security of our Apps, products and services.
Customer Support: We use your information for providing customer support to you and to respond to your inquiries.
Our legal obligations: We use your information when we are required to do so by law, for example we use your country or region for tax reporting purposes.

2. Game Notifications

We have two types of notifications in our Apps - local and push notifications. Local notifications are contextual and sent from the device, whereas push notifications are sent from the server. Push notifications are never sent to users who are under the age of digital consent. We use such notifications to remind you about your activities within the App. You will receive such notifications only if you are subscribed to such notifications in the App. You can always unsubscribe from push notifications, please use the instructions provided below.

For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive notifications. Please note that if you accept, some mobile phones will allow you to disable notifications later by using the settings on your mobile phone. To manage notifications on your mobile phone please follow these instructions: Open your Settings menu and tap "Notifications"; Find the App; Tap on the icon of App; Manage the "Notifications" option by sliding it OFF or ON.
For Android and Windows: After an App is downloaded, you will automatically receive notifications. You can manage notifications on your mobile phone by entering the "info screen" on the homepage of the App and choosing the "Settings" option. Here, notifications can be disabled by unchecking the "Notification" option within the App.

When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.

3. Survey

We are conducting surveys to improve our services and you may freely decide whether you would like to help us or not. We will always ask for your consent before conducting a survey.

From time to time, we may conduct an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. Participating in a survey is completely voluntary. We will use the information to make our services more appealing to users. Collected information shall be anonymized and aggregated. We might collect the following information: age and gender of the user of an app, whether another person uses the app, the age and gender of the people regularly using the app, assessment of popularity of the main character, which of the characters are known to the user, which app is most commonly used, the gender of users playing the app, different ways of using the app, an assessment of the features of an app, the time period of using the app, which apps the user has, what would make the app more appealing, and other information needed for the purposes of internal analysis, marketing and brand development.

We may use third party providers for the in-app surveys and they may place their tags within an App to collect non-personally identifiable data from the device ("Tag Data") solely for the purposes of conducting the survey, such as to collect cross device information in order to enable the deduplication of audiences across devices. These providers may use the data collected from the survey and Tag Data on anonymized and aggregated basis together with the data from other partners ("Unified Data") to publish syndicated reports on internet behavior and trends. If you wish to opt out from conducting an in-app survey, do not click on the survey button or deny answering the survey questions.

4. In-App Purchases

Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.

Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store. Please review privacy policy and terms of service of your app store.

We cannot provide all services necessary for the successful operation of the Apps or Website by ourselves. We must therefore share collected information with third parties, including analytics providers, cloud service providers, and other third party service providers that develop and support the Apps or Website (collectively referred to as "Partners"). We share information that can be used to personally identify your device (e.g. persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of developing and delivering our services, and conducting analysis and research. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

Our analytics providers: We use third party analytics for the purposes of delivering our services, conducting analysis and research.
Our cloud service providers: We store information we collect from you on servers provided by our third party cloud service providers;
Other third party service providers: For some Apps we use Unity Software to develop such Apps. For the data processing by Unity please see Unity's privacy policy available at https://unity3d.com/legal/privacy-policy. For some Apps we partner with third party developer studios to develop such Apps. Such third party developer studios do not have access to your personal information, they can only access aggregated data that they cannot trace back to you.

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

Some of our Apps enable you to connect to third party social networks, to share the content you created within the Apps on such third party social networks or to participate in leader boards or multiplayer apps. If you connect to third party social network, such as Google Play Games Service or Apple Game Center, you will be able to use your account to log in on multiple devices and to synchronize progress across those devices. If you connect to third party social network, such as Facebook, you may be able to interact, compete and connect with your friends (please see more in "Special Privacy Features In Some Of Our Apps"). Some of our Apps enable you also to share the content you created within the App on third party social network, such as Facebook, YouTube, Twitter or Vkontakte. When you log in to your social network account or by using the App to share content on social network, we will receive some of information you have on such social network account (please see more below).

Some of our Apps use third parties' services such as Google Play Games Service, Apple Game Center, Facebook, YouTube, Twitter or Vkontakte ("Third Party Social Network/s"). Such Apps enable you log in to your Third Party Social Network account to connect to our App by using the "Log in with" or "Connect to" feature in our App. Please note, Third Party Social Networks are governed by their own privacy policies, terms and end user agreements and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites.

The information you allow us to access varies by App, and it is affected by the privacy settings you and your friends establish on those Third Party Social Networks. You can control and find out more about these settings at the Third Party Social Network in question. When you use the "Log in with" or "Connect to" feature we may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your public profile, such as your name, surname, profile picture, age range, gender, and other public information; (ii) email address, login ID and/or player identifier string (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the "Log in with" or "Connect to" process. We may share your name, profile picture and your game data (such as moves, App progress and scores) with respect to the applicable App, with your friends who have also used the "Log in with" or "Connect to" feature in connection with such App or with your contacts in applicable Third Party Social Media Network account.

The App may further ask you to allow us to post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the App on your device so that the App will be able to communicate with Third Party Social Network directly; Voice recordings from Apps are also only being collected and stored within the Apps solely upon your request.

If you use Third Party Social Networks to participate in game related activities, such as in leaderboards and multi-player games, you share your information with other players and Third Party Social Networks (for example scores, rankings and achievements).

SPECIAL PRIVACY FEATURES IN SOME OF OUR APPS

Some of our Apps offer you the option to talk to the virtual character of such Apps, but you will always be asked to give us the permission to access the microphone in advance. Such Apps do not have a function to record audio, please learn more below. Some of our Apps offer special features that enable you to interact and connect with your friends, compete with your friends and to chat with your friends. Such features collect additional information from you and share such information also with others. Learn more about such features below and please do not use these additional features if you are not comfortable with all the additional information that is collected when you use such features.

Some of our Apps offer you the option to talk to the virtual character of such Apps. All of our Apps that offer such feature will always ask you in advance for your permission to access the microphone on your device. If you decide to give us permission, the virtual character will be able to repeat what you say to him. Please note that our Apps do not have a function to record audio, so what you say to the virtual character is not stored on our servers, it is only used by the App to repeat to you in real time. If you decide not to give us the permission to access the microphone on your device, the virtual character will not be able to repeat after you.

Some of our Apps offer you to compete and interact with your Facebook friends, but you need to login with your Facebook account. By doing so, the App will receive your public profile and the list of friends. If you do not want to share the list of friends with the App, you can uncheck the box next to the permission for sharing the list of friends in the notice that appears during the "Log in with Facebook". If you choose to login with Your Facebook account, the App will show Your public profile to your Facebook friends.

Some of our Apps can be played in a single or a multiplayer mode. In a multiplayer mode you can play matches with random players or your Facebook friends. Such Apps will ask you to choose your name. Please do not choose your real name. You can always change your name by going to "Settings" and selecting "Change Name". The name you enter and your rank will be publicly displayed when playing with random players in a multiplayer mode. To play matches with Your Facebook friends, you need to login with your Facebook account. By doing so, the App will receive your public profile and the list of friends. If you do not want to share the list of friends with the App, you can uncheck the box next to the list. However, you cannot play matches with your Facebook friends without giving the App the permission to share your public profile. If you choose to login with Your Facebook account, the application will show Your public profile when playing with your Facebook friends or random players.

Some of our Apps have in-app chat, so you may communicate with your friends who also play the same App as you. Users of our chat service can send messages to other players. Your messages are used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after 1 month your in-app chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.

THIRD PARTY TERMS AND CONDITIONS

Our Apps or Website may contain links to third party websites, products, or services. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We cannot control the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party's privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of third parties with which you interact.

CHILDREN'S PRIVACY

We consider ourselves to be family oriented, however we have decided to voluntarily implement higher child protection standards even though our products and services are not directed to, and we do not knowingly collect personal information from children under the age of digital consent according to applicable data protection legislation, with the sole exception of persistent identifiers as described below. If we learn that we have collected personal information other than persistent identifier of a child under the age of digital consent according to applicable data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at [email protected].

YOUR RIGHTS

According to applicable data protection legislation, you may have certain rights in connection with your personal information and how we handle it, i.e. you may have a right to obtain information about whether we hold personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to [email protected].

Your rights include:

Right to object. You have the right to object to the processing of your personal information that is processed on the grounds of legitimate interests (see Legal Bases below). You are always free to opt out from the future collection of your personal information by us and our Partners by uninstalling all the Apps from each of your computing devices.
Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right, please contact us by letting us know that you wish to exercise your right of access and what information in particular you would like to receive. 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 explain to 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 1 month of receipt of your request and verification of your identity.
Right to correct personal information. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us via [email protected] and we will correct it as soon as we can.
Data deletion. You have a right to request deletion of the personal information that we hold about you. Should you wish to do that, please contact us via [email protected]. We reserve the right to ask to provide us additional information to verify your identity before we can start processing your request. Once we receive all information we need in order to be able to identify you, we will delete your personal information you requested us to delete as soon as possible, but we will always do so within 1 month of receipt of your request and verification of your identity. Please note that we may still retain some or all of that information, for example for complying with our legal obligations and protecting or enforcing legal rights. We may also retain your information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players' devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a Wi-Fi network.
Data portability. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another data controller. Should you wish to do that, please contact us via [email protected].
Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal information.
Right to file a complaint. You have the right to file a complaint against us. To do so, contact the supervisory authority in your country of residence.

California's "Shine the Light" law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties' and affiliates' own direct marketing purposes. Under the law, we will provide California customers certain information upon request ("Right to access").

If you are a California resident and wish to obtain information about our compliance with this law, please contact us via [email protected]. We may request information from you to verify your identity. Please note that Play Valley is not required to respond to requests made by means other than through the provided email address.

GENERAL

Your privacy and security of your information is important to us and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under the applicable data protection laws that apply to users. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners as for the purposes described above in "How We Share Your Information" Section.

Please check https://playvalley.io/privacy/en regularly for changes to our Privacy Policy.

LEGAL BASES

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under applicable data protection legislation.

The legal bases that we rely upon under EEA, UK, and Brazil data protection legislation are the following:

Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested - and that we have agreed - to provide to you, that is to deliver and improve our services, to provide customer support, and to deliver special features in our Apps (such as in-app chat feature, multiplayer feature, leaderboards and other third party social network features), to deliver content of the in-app purchase you make.
Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Apps free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, and push-notifications.
Consent. When we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before conducting any surveys.
Legal Obligation. This covers information that is processed by us to comply with a legal obligation, for instance is to maintain records for tax purposes.

The legal bases that we rely upon under Brazil data protection legislation are the following:

Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested - and that we have agreed - to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Apps (such as in-app chat feature, multiplayer feature, leaderboards and other third party social network features), to deliver content of the in-app purchase you make.
Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Apps free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, and push-notifications.
Consent. When we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before conducting any surveys.
Legal or Regulatory Obligation. This covers information that is processed by us to comply with a legal or regulatory obligation, for instance is to maintain records for tax purposes.

SECURITY

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

INTERNATIONAL TRANSFER

We operate globally, so we need to transfer your personal information to our affiliated entities and/or to other third party service providers across borders and from your country to other countries around the world. Please note that not all these countries have the same data protection laws as your own country, but we will always take appropriate steps to safeguard the privacy of your personal information.

For EEA and UK residents, we will transfer your personal information only when the transfer is based on one of the following safeguards:

To a country with adequate data protection. We will transfer your personal information outside Europe to a country that ensures an adequate level of protection in accordance with Europe data protection legislation.
Based on standard contractual clauses. We will transfer your personal information to our Partner outside EEA, if we have entered into standard contractual clauses with such Partner, that are adopted by Commission of European Union in accordance with Europe data protection legislation and are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals (you can obtain a copy of the clauses by contacting us via [email protected]).
Based on an approved certification mechanism. We will transfer your personal information to our Partner outside Europe if our Partner is certified by an approved certification mechanism pursuant to Europe data protection legislation. For instance, to our partner that is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (you can view the entities certified under Privacy Shield at www.privacyshield.gov).

RETENTION

We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than five (5) years after your interaction with all our Apps has ceased.

When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data, we will delete your data as described above in "Your Rights" Section.

CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at https://playvalley.io/privacy/en.

CONTACT US

If you have questions or concerns about Play Valley's Privacy Policy, please contact us through one of the following ways:

for privacy questions and exercising your rights via our privacy email: [email protected];
for general information please feel free to contact us via our customer support email: [email protected].

For information collected under this Privacy Policy, the data controller is Play Valley Limited, a company registered at Christaki Kranou 20, 1st Floor, 4041 Limassol, Cyprus.

PLAY VALLEY LIMITED PRIVACY POLICY FOR APPS, v1.0, updated September 5, 2022