Privacy Policy

Valor Games Oyun Yazılım ve Pazarlama A.Ş. (“Valor Games”) develops and publishes game titles for mobile devices (each game title, “Title”).

We gather information through two primary methods:

Direct Collection: We acquire information directly through the use of our applications (“Titles”). In this process, we may collaborate with analytics partners who collect this information on our behalf.

Indirect Collection: Information is also gathered indirectly via our advertising and analytics partners.

The information we collect, as outlined in this privacy policy, serves the internal objectives of Valor Games. As a data controller under relevant data protection laws, we manage this information accordingly.

Scope

This privacy policy outlines Valor Games’ privacy practices in connection with the data it handles concerning its Titles.

These titles are accessible to users worldwide. Consequently, throughout this document, we strive to maintain a consistent approach and employ uniform language within the privacy policy. However, there are instances where we refer to specific regulations that mandate additional disclosures. For instance, whenever you encounter the label “The GDPR angle” within the policy, it signifies that the purpose of that section is to meet the transparency criteria of the General Data Protection Regulation (GDPR). Therefore, it exclusively pertains to personal data (as defined by the GDPR) associated with devices that we determine to be situated in the European Economic Area, United Kingdom, or Switzerland. Should you be a resident of California, Virginia, Connecticut, or Colorado, kindly refer to the “State Privacy Rights” section of this privacy policy for insights concerning privacy regulations in these states.

Information We Gather

Data collected via our Titles, as well as information provided by our advertising and analytics associates:

Identifiers:

Advertising ID – The Advertising ID refers to the Google Advertising ID (“GAID”) on Android devices or the ID For Advertising (“IDFA”) on iOS devices. It is a resettable persistent identifier generated by Android or iOS, facilitating the recognition of a device by online advertising entities across apps for advertising objectives. To find out more about limiting the utilization of the Advertising ID, refer to the “How to Control Information” section.
IP address of the device.
A distinctive ID created by our advertising associates to uniquely identify a device within a specific Title.
Device ID exclusive to our Titles.

General technical details about a device – Technical data like:

Device model and language, name, and version of the operating system.
Time zone setting of the device.
Available free memory on the device.
Title’s name and version.
Battery condition.
Mobile carrier’s name.
Type of internet connection on the device (e.g., Wi-Fi).
Activity associated with the Title: Transactions and in-app purchases made within the Title, progress or movement within the Title, and in-game events.

Information obtained from advertising and analytics associates:

Campaign details – Indication of whether an advertisement for a Title was viewed or clicked.
Total revenue received due to advertising shown on a specific device.

How We Employ the Gathered Information:

We primarily utilize the collected information to provide services to players engaging with our Titles. Furthermore, we apply this information for the subsequent objectives:

Enhancing and optimizing the Titles and the overall player experience.
Supplying players with information about our Titles, encompassing in-game updates, fresh Titles, and promotional offers.
Rendering technical assistance.
Ensuring the safety and welfare of our players.
Safeguarding Valor Games’ rights and assets in connection with the Titles.
Mitigating fraud or potential illicit activities.
Administering and delivering advertising, which includes analytics, gauging ad effectiveness, limiting ad frequency, generating aggregated reports, and establishing attribution.
Managing rewards, promotions, or events sponsored or supervised by us or our business affiliates.
Conducting marketing campaigns in collaboration with our advertising and marketing partners, including campaigns employing audience lists formed according to player interactions with the Titles.
Observing legal commitments, settling disputes with players, and enforcing agreements with third parties.
Engaging in research endeavors.

Within the framework of the GDPR, our processing of personal data is grounded in the subsequent legal foundations:

We engage in the processing of personal data to furnish services to players of our Titles, in alignment with our contractual obligations to them.
We undertake the processing of personal data with the intent of averting fraud or potential unlawful activities, safeguarding our rights and assets, delivering advertising (excluding personalized advertising), orchestrating marketing campaigns (excluding campaigns reliant on audience lists), refining and enhancing the Titles, dispensing information and promotional opportunities to players of our titles, overseeing rewards, and undertaking research. This is carried out based on our legitimate interests.
In scenarios where player consent has been acquired, either by us or our advertising partners, we, or they, might process personal data for the delivery of personalized advertising, the analysis of game usage, or the execution of marketing campaigns hinging on audience lists, including the creation of such audience lists.
Additionally, we may process your personal data to fulfill our obligations in compliance with relevant legal mandates.

Maximum Data Retention Duration:

We retain information for a duration that is reasonably essential to fulfill the intentions for which it was gathered, as elucidated in this privacy policy. This retention period typically extends up to one year from the point of its acquisition. However, certain situations may necessitate an extended retention period. For instance, if the information is indispensable for the establishment or exercise of our rights, or to counter legal claims, we may uphold the retention of such information for an extended period of time.

We engage in the sharing of information with the following entities:

Other advertising partners – This sharing serves the purpose of either receiving or delivering advertising campaigns from these advertising partners.

Corporate affiliates – We share information with our affiliated companies from whom we obtain various services, including IT, security, storage, and other internal operations.

Advertisers – Information is shared for the purpose of attribution.

Analytics partners – We share information with analytics partners to avail ourselves of their analytics services.

Service providers – We share your information with service providers for the purpose of obtaining services like fraud detection and prevention, analytics, reporting, and storage.

We may also divulge information if we hold a genuine belief that disclosing such information is reasonably required to:

Adhere to applicable laws, regulations, legal processes, or governmental requests.
Enforce our agreements and policies, including investigations into potential violations.
Detect, investigate, prevent, or take action against illicit activities, suspected fraud, or security concerns.
Assert or exercise our rights and counter legal claims.
Safeguard the rights, property, or safety of us, our users, yourself, or any third party.
Cooperate with law enforcement agencies or when necessary to uphold intellectual property or other legal rights.
During potential or actual transitions in control, such as mergers, acquisitions, or the purchase of a substantial portion of our assets.

Controlling Your Information:

Managing device data collection – Updated iOS and Android versions enable you to control the collection of the Advertising ID. Refer to the following instructions:

iOS devices (iOS 14+): Navigate to Settings > Privacy > Tracking > Allow Apps to Request to Track. Note that if you use multiple devices, you must opt-out individually on each device.

Android devices: Follow the instructions provided at: https://support.google.com/ads/answer/1660762 (under Mobile Controls). Note that if you use multiple devices, you must opt-out individually on each device.

Revoking consent – You maintain the right to withdraw consent, either within each of our Titles (impacting processing solely within that specific Title), or by following the aforementioned instructions on managing device data collection (influencing data processing across all our Titles on your device).

Data subject rights – Keep in mind that you have the right, as stipulated by GDPR, to request access to and rectification or erasure of your personal data we process as controllers. You can also request restriction or objection to the processing of your personal data, in line with GDPR provisions. To submit a request for exercising these rights, email your request to: info@valorgamestudio.com. Please note that we’ll process your request upon verifying your identity.

Lodge a complaint with supervisory authority – You possess the right to lodge a complaint with the relevant supervisory authority (e.g., in your country or residence) if Valor Games has not satisfactorily addressed your concerns.

Third-Party Services: Our services may link to other websites or mobile apps. Please note that we are not accountable for the privacy practices of such external websites or mobile apps, as they may maintain distinct privacy policies and terms of use unrelated to us. You acknowledge that we lack control over these websites and/or mobile apps, and thus, we bear no responsibility for any utilization of these platforms.

International Data Transfers: The information we collect from your device is stored on servers provided by our service providers, located in the United States. Consequently, if you reside outside of the United States, your information will be transferred to and stored in the United States.

Rights Under State Privacy Laws

Residents of California, Virginia, Connecticut, and Colorado possess specific rights in accordance with state privacy regulations concerning the personal data we gather. If you reside in any of these states, this portion of the privacy policy entails legally mandated disclosures and outlines potential rights accessible to you.

Categories of Data Sources – As outlined in the “About Us” section above, we procure personal data from the following categories of sources:

Directly via the Titles.
Collaboration with advertising partners.
Partnerships with analytics entities. Our Objectives for Processing Personal Data – The personal data we collect is employed and disclosed for our commercial and operational motives, elaborated further in the “How We Use the Information We Collect” and “How We Share Information” sections.

Recipients of Personal Data – Although we do not engage in the monetary sale of personal data, our actions fall within the scope of “sale” as defined by state privacy laws (including data sharing for targeted advertising aims). Such sharing of personal data for sale, subject to players’ preferences, encompasses the following third-party categories:

Advertising partners.
Analytics partners. Your Entitlements Regarding Personal Data – Residents of particular states possess privileges concerning personal data gathered by businesses like Valor Games. You might be able to exercise the subsequent rights regarding your personal data, while certain exceptions and restrictions apply:
Confirmation of whether we process personal data related to you.
Correction of inaccuracies in the personal data we have amassed.
Disclosure of the categories and specific fragments of personal data we gather, utilize, disclose, and sell about you. This encompasses the categories of sources, our objectives for collecting/selling data, the categories of personal data sold or disclosed, and the third-party categories to which data is disclosed.
Request for the deletion of your personal data retained by us.
Choice to opt out of personal data sale and sharing, encompassing targeted advertising purposes. Bear in mind that opting out of specific practices might impede our provision of certain services.
Immunity from discriminatory treatment for the exercise of aforementioned privacy rights.
Valor Games does not amass “sensitive” personal data, a category recognized by some states.

Enacting Your Rights – To act on your rights, kindly get in touch by sending an email to info@valorgamestudio.com.

Depending on your state, should you contest our unfulfilled request, you can file an appeal by emailing us with the subject line “Appeal” at info@valorgamestudio.com.

Validation Process and Necessary Details – Note that additional information might be requested to validate your identity or process your request, notwithstanding the need to create an account with us. At the very least, you’ll be asked to provide your email address and state of residence. Furthermore, device-specific data will be collected upon submitting a request to facilitate identity verification.

Authorized Agent – You can designate an authorized agent to initiate a request on your behalf, given that their identity is verified, and they possess written permission from you.

Alterations to This Privacy Policy: This Privacy Policy may undergo revisions periodically. The most current version will govern information processing and is accessible at valorgamestudio.com/privacy. Modifications to this policy will be posted on valorgamestudio.com/privacy.

Contact Us

Valor Games Oyun Yazılım ve Pazarlama Anonim Şirketi

info@valorgamestudio.com

Esentepe Mah. Büyükdere Cad. Levent 199 199/6 Şişli/İstanbul