Privacy Policy
Effective Date: January 23, 2025
This Privacy Policy explains how Valun Soft LLC (referred to as “Valun Soft”, “we”, “us”, or “our”) collects, uses, discloses, and safeguards personal data when individuals (“users”, “you”, or “your”) interact with our mobile games, applications, websites, and associated services (collectively, the “Services”).
1. Data Controller Contact Details
Valun Soft LLC
Address: 220114, Republic of Belarus, Pervomaysky district, Minsk, Nezavisimosti Avenue, 117A
Email: info@valunsoft.com
2. Scope and Applicability
This Privacy Policy applies to all processing of personal data collected through:
Mobile applications developed or published by Valun Soft
In-game activities
Customer support interactions
Websites, social media, or marketing tools used in connection with the Services
It applies to users located in the European Economic Area (EEA), the United Kingdom, and other jurisdictions with similar data protection laws.
3. Categories of Personal Data We Process
We may process the following categories of personal data, depending on your use of the Services:
3.1. Device and Technical Information
Device type and model
Operating system and version
Device identifiers (e.g., IDFA, GAID, device ID)
IP address and country of connection
Screen resolution, system language, app version, and time zone
3.2. Usage Information
Game progress and achievement logs
Level completions, scores, and player interactions
In-app purchases and subscriptions (transaction ID, product type, price, date, currency)
Clicks and interactions with in-game advertisements
3.3. Location Data
Country, region, and city (approximate, based on IP or device settings)
3.4. Customer Communication Data
Content of support requests and user feedback
Email addresses or other identifiers if voluntarily provided
We do not actively collect your name, physical address, email, phone number, or other directly identifying contact data unless you provide it directly (e.g., when contacting our support team).
4. Legal Bases for Processing (Article 6 GDPR)
We process your personal data on the following lawful grounds:
Performance of a Contract (Art. 6(1)(b) GDPR): to provide, operate, and maintain the
Services
Legitimate Interests (Art. 6(1)(f) GDPR): e.g., analytics, fraud prevention, service improvement, and security
Legal Obligation (Art. 6(1)(c) GDPR): to comply with regulatory or legal requirements
Consent (Art. 6(1)(a) GDPR): when legally required, such as for personalized advertising or optional analytics
5. Purposes of Data Processing
Your personal data is used for the following purposes:
To operate and maintain the functionality of the Services
To personalize content, in-game experience, and advertisements
To process and verify in-app purchases and subscriptions To monitor, diagnose, and resolve technical issues
To detect and prevent fraudulent or abusive behavior
To analyze gameplay trends and improve game design and user engagement
To provide customer service and respond to inquiries
To comply with applicable laws, regulations, and court orders
6. Retention of Personal Data
We retain your personal data as follows:
Active Users: For as long as your account is in use or the Services are accessed
Inactive Users: For a period of 24 months after the last recorded activity
Earlier Deletion: When data is no longer needed or upon your request
Legal Obligations: For longer periods where legally required
Once the retention period ends, your personal data will be securely deleted or irreversibly anonymized. After deletion, your data rights (e.g., access, correction, deletion, portability) can no longer be exercised.
7. Data Sharing with Third Parties
We may share your personal data with:
7.1. Service Providers and Processors
We use third-party partners (acting as data processors) for:
Analytics (e.g., Unity Analytics, Firebase, GameAnalytics)
Advertising (e.g., AdMob, Unity Ads, Facebook Ads, ironSource)
Cloud storage and backend infrastructure
Customer support tools
These processors are contractually bound to process your data only on our behalf and in compliance with GDPR.
7.2. Platform Providers
If you make in-app purchases, your payment data is processed directly by:
Google Play (Google LLC)
App Store (Apple Inc.)
We do not have access to your payment card details or billing address.
7.3. Legal and Regulatory Disclosure
We may disclose personal data if:
Required by law, regulation, or valid legal process
Necessary to protect rights, safety, or property of Valun Soft or third parties
Required in the context of a merger, acquisition, reorganization, or sale of assets
8. Children’s Data Protection
The Services are not intended for children under 16 years of age. We do not knowingly collect data from children under 13. If we become aware that such data has been collected, we will delete it promptly.
Parents or legal guardians can contact us to request removal of any inadvertently collected child data.
9. Your Data Subject Rights (Under GDPR)
As an individual in the EEA or UK, you have the following rights:
Right of Access – to know what data we hold about you
Right to Rectification – to correct inaccurate or incomplete data
Right to Erasure – to request deletion of your personal data
Right to Restriction – to limit how we process your data in certain cases
Right to Data Portability – to receive your data in a machine-readable format
Right to Object – to object to processing, including direct marketing
Right to Withdraw Consent – at any time, where processing is based on consent
Right to Lodge a Complaint – with a supervisory authority in your country (e.g., your national Data Protection Authority)
To exercise your rights, please contact us at: info@valunsoft.com
10. International Transfers of Data
If personal data is transferred outside the European Economic Area (EEA), such transfer is secured using appropriate safeguards, such as:
Standard Contractual Clauses (SCCs) approved by the European Commission
Adequacy decisions of the European Commission
Binding Corporate Rules (where applicable)
11. Data Security Measures
We implement technical and organizational measures to ensure an appropriate level of security, including:
Data encryption in transit and at rest
Access control and user authentication
Regular security audits and monitoring
Pseudonymization or anonymization where appropriate
12. Advertising and Tracking Technologies
We use third-party advertising networks to deliver personalized and non-personalized ads.
These partners may collect data using:
Advertising identifiers (IDFA/GAID)
Behavioral profiling
Device metadata
You can opt out of personalized ads using your device settings:
iOS: Settings > Privacy > Tracking > Disable “Allow Apps to Request to Track”
Android: Settings > Google > Ads > Enable “Opt out of Ads Personalization”
13. Use of Analytics
Analytics tools help us:
Understand user behavior
Optimize gameplay and balance features
Identify crash issues and performance problems
Make localization and design decisions
This processing is based on our legitimate interests to improve our Services.
14. External Links and Third-Party Services
Our Services may contain links to external websites or services not operated by Valun Soft. We are not responsible for the privacy practices or content of such third parties.
We recommend reviewing their privacy policies before interacting with them.
15. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we may notify you via in-app notice, email, or other channels.
Please review the policy periodically to stay informed. The date of the most recent revision will always appear at the top of this document.
16. Contact Us
If you have any questions or concerns about this Privacy Policy or how we handle your personal data, you can contact us at:
Valun Soft LLC
Address: 220114, Republic of Belarus, Pervomaysky district, Minsk, Nezavisimosti Avenue, 117A
Email: info@valunsoft.com