Privacy Policy

This Privacy Policy ("Policy") explains how we, Games Valley ("we," "us," or "our"), collect, use, disclose, and protect information, including Personal Data (meaning any information that identifies or could reasonably identify a specific individual (“Personal Data” or “Personal Information”)), in connection with your (“User”, “you”, or “your”) download, access, or use of our mobile application, together with any related content, features, and services (collectively, the “App”).
This Policy is incorporated into, and forms an integral part of, our Terms of Service and/or any other applicable terms of use (“Terms”) that govern your use of the App. Any capitalized terms used in this Policy but not defined herein have the meanings given to them in the Terms. To the extent permitted by applicable law, if there is any conflict between this Policy and the Terms, the Terms will prevail.

Where applicable law distinguishes between privacy roles (for example, a "Controller" under the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) or a "Business" under certain U.S. state privacy laws), we act as the party that determines the purposes and means of the processing described in this Policy.
This Policy applies worldwide to any individual who downloads, accesses, or otherwise uses the App. Certain jurisdictions, including the European Economic Area and U.S. states such as California, provide additional privacy rights and require additional disclosures. Where applicable, those supplemental notices are set out in the relevant sections below.

1. METHODS OF PROCESSING
We process Users' Personal Data in a proper manner and apply appropriate security measures intended to prevent unauthorized access, disclosure, alteration, or unlawful destruction of Personal Data. Processing is carried out using computers and/or other IT-enabled tools, in line with organizational procedures and methods that are strictly related to the purposes described in this Policy. In addition to us, Personal Data may, in certain circumstances, be accessible to authorized personnel involved in the operation of the App (including administration, sales, marketing, legal, and system administration) and to external service providers (such as third-party technical service providers, mail carriers, hosting providers, IT companies, and communications agencies) that may be appointed, where necessary, as our processors/service providers. You can request an updated list of these parties by contacting us as described in the "Contact Us" section below.

2. DATA COLLECTION AND PROCESSING
Online Identifiers and Device ID: When you install, access, or use our App, we collect certain identifiers, including your Internet Protocol (“IP”) address, device ID, and Google Advertising ID (GAID) (collectively, “Online Identifiers”). We use these Online Identifiers to: (1) operate the App and provide its features and functionality; and (2) collect telemetry data (as described below) and carry out analytics, marketing, and measurement activities, including serving personalized advertisements. When we process Online Identifiers for operational, functional, and security purposes, we do so based on our legitimate interests. When we process Online Identifiers for marketing, personalized advertising, or tracking, we do so based on your consent, as provided via the App's built-in permissions and/or your device settings. You can withdraw your consent at any time through the App settings or your device settings (for example, by opting out of the advertising ID or tracking).
Telemetry and Usage Data: We also collect information regarding how you use and interact with the App, including access times, date logs, activity logs, the features and content you view or use, conversions, and your interactions with advertisements, social media-related information, and, where applicable, your purchase and transaction history. We process this data to: (1) operate, maintain, improve, and secure the App, including troubleshooting, diagnosing, and correcting errors; (2) conduct internal analytics to improve the App and customize the user interface for you; and (3) use information about the ads you interact with to help advertisers assess campaign performance and to provide applicable reports. We process this data where necessary to perform our contract with you (including enabling the installation, operation, and functionality of the App) and to improve the App and your user experience. Processing for other operational and security purposes is carried out based on our legitimate interests. Where we process this data for analytics and advertising, we do so on the basis of your consent provided through the onboarding permissions.
Installed Application Information: We will collect, process, and transmit information about the applications installed on your device, including a list of those applications ("Installed Application Information"). We obtain this Installed Application Information via the Inventory Permission (as described below). We use it to support and enhance the performance of our launcher, including by redesigning your home screens. We may also use this information to tailor the App's performance to your device's particular features and functions, and for internal business purposes such as improving the App, gaining insight into user preferences, and providing personalized and customized services. We process this data on the basis of your consent.
Contact Information: If you contact us for customer support or other inquiries, we may ask you to provide certain contact details, such as your full name, email address, and any other information you choose to share. We use this information to provide the support you request and to respond to your inquiry. We may also process and keep records of our communications with you to improve our customer service. Additionally, we may retain this correspondence where we reasonably deem it necessary to protect our legitimate interests, for example, to address possible disputes or legal claims, or to provide further assistance where applicable. We process this information based on our legitimate interests. Where you contact us for customer support, we process this information as necessary to provide that support as part of our contractual obligations to you.

3. HOW WE USE THE DATA
We use the Personal Information collected about you and/or information about your device to operate the App, manage our business, enhance our services and user experience, strengthen security, and conduct analytics and research. We also use your information to promote our services and the App within the App and in other publishers' applications, and to display third-party advertisements to you. Furthermore, we may use your information for advertising-related tracking and fraud prevention, to comply with our legal obligations, and for our legitimate interests (e.g., to assess potential employment relationships with you).
Your Personal Information is utilized for the following purposes:
* We use your information to develop, provide, operate, and improve our App and other products, services, content, and offerings; to personalize our services; and to display third-party advertisements within our App. For additional details, please refer to the Advertising section of this Policy.
* We use your information to advertise our App by showing ads for it in other publishers' apps, and to display third-party advertisements within our App. For additional details, please see the Advertising section of this Policy.
* We use your information to cross-promote our App and services, for example, by marketing one of our App to you while you are using another of our App.
* We use your information to evaluate and understand the effectiveness of our advertising campaigns, and to detect and help prevent fraud and other invalid activity related to advertising (including clicks, impressions, and installs), as well as for related business intelligence purposes (such as tracking potential issues or emerging trends analyses for research and business intelligence purposes, such as tracking potential issues or emerging trends relating to our App and services and testing new App features and content.
* We use your information to identify and analyze trends in App usage, to compile demographic insights regarding our user base, and to determine where the App was downloaded from. We may also prepare reports and analyses for research and business intelligence purposes, such as tracking potential issues or emerging trends relating to our App and services, and testing new App features and content.
* We use your information to help maintain and enhance the safety and security of our App, products, and services.
* We use your information to provide customer support and to respond to your questions and requests.
* We use your information where required under applicable law, for example, using your country or region to satisfy tax reporting obligations.

4. LEGAL BASIS FOR COLLECTION AND USE OF PERSONAL DATA
We process your Personal Data only where permitted by applicable law and where an appropriate legal basis applies. The legal basis we rely on varies depending on the context and the particular purpose for which we collect and use your Personal Data, and may include:
Legal Basis
What does it mean?
Types of Data
Legitimate Interests
In certain jurisdictions, we may process your Personal Data based on our legitimate interests, for example, to operate, maintain, and improve our App.

(i) Telemetry and Usage Data
(ii) Online Identifiers
(iii) Contact Information
Contract Necessity
We collect and process certain Personal Data where it is necessary to perform our contract with you and to provide the App and related features and functionality.

(i) Telemetry and Usage Data
(ii) Online Identifiers
Legal Obligation
We may process your Personal Data where it is required to comply with our legal obligations.

Depending on the circumstances, any category of Personal Data may be used for legal purposes, including meeting legal and regulatory duties, enforcing our policies, complying with internal standards, and defending or responding to actual or potential claims.
Consent
We collect certain Personal Data only where you have given your informed consent. You may withdraw your consent at any time; however, doing so will not affect the lawfulness of any processing performed prior to your withdrawal.

(i) Installed Application Information - before enabling the relevant permissions, you can decide whether to provide your informed consent.
(ii) SDK Data - you can disable Personalized Ads and modify your preferences at any time via your device settings. Disabling Personalized Ads will not remove all ads from the App, but it will mean that the ads you see are not tailored to your preferences.

5. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
We may share your Personal Data with the categories of third parties listed below:
* With third-party service providers that perform services for us (for example, data processing, hosting, customer support, analytics, and marketing). By contract, these service providers are required to protect the confidentiality and security of your Personal Data and to use it solely for the specific purposes for which we share it with them.
* To our business partners (for example, co-branding, joint venture, and marketing partners). These partners are required by contract to safeguard the confidentiality and security of your Personal Data and to use it only for the purposes for which we share it with them.
* With our affiliates (entities we control or that are under common control with us). Our affiliates are required by contract to protect the confidentiality and security of your Personal Data and to use it solely for the purposes for which we disclose it to them.
* With third-party advertisers, including advertising networks and data brokers. These third parties are required by contract to protect the confidentiality and security of your Personal Data and to use it only for the purposes for which we disclose it to them.
* To government authorities or law enforcement where we are legally required to do so, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of our business, our customers, or others.
* In the event of a merger, acquisition, or sale of all or a portion of our business, we may share your Personal Data with a buyer, seller, or other successor in connection with a merger, acquisition, reorganization, or sale of all or part of a business. Any such recipient will be required by contract to protect the confidentiality and security of your Personal Data and to use it only for the purposes for which we have disclosed it to them.
* In the event of a bankruptcy or insolvency, we may share your Personal Data with our creditors or other parties involved in any bankruptcy or insolvency proceeding. Any such recipients will be required by contract to protect the confidentiality and security of your Personal Data and to use it only for the purposes for which we have disclosed it to them.
We will take reasonable measures to help ensure that your Personal Data is processed securely and in accordance with this Policy.

6. INTERNATIONAL PERSONAL DATA TRANSFERS
If we need to transfer your Personal Data outside your jurisdiction, we will take appropriate steps to ensure your Personal Data is afforded an adequate level of protection, as required under applicable law.
In addition, where Personal Data collected within the European Economic Area ("EEA") is transferred outside the EEA to a country that has not received an adequacy decision from the European Commission, we will take the necessary measures to ensure appropriate safeguards are in place for such transfers, in line with the standard contractual clauses approved by the European Union. Accordingly, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections pre-approved by EEA (known as standard contractual clauses), or we will rely on adequacy decisions adopted by the European Commission. Certain assurances may also take the form of well-recognized certification schemes.
To request more information about these safeguards, contact us at linksdot.games.valley@gmail.com.

7. AUTOMATIC DATA COLLECTION AND ADVERTISING
We work with advertisers and third-party advertising networks, which require information about your interactions with ads in the App. This helps us keep the App available to you at no additional cost. Advertisers and ad networks may use certain information collected via the App, including, without limitation, your device's unique identifier and your mobile telephone number. To protect your anonymity, we use encryption technology so that these third parties cannot personally identify you. These third parties may also receive anonymized information about other apps you have downloaded to your device, the mobile websites you visit, and non-precise location information (for example, your ZIP code) in order to analyze and deliver anonymous targeted advertising in the App and elsewhere. We may also share encrypted versions of information you provide so that our partners can combine it with other available information about you for analytics or advertising-related purposes

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8. RIGHTS
We recognize that privacy concerns and preferences vary among individuals. Our aim is to explain, in a transparent manner, what information we collect so you can make informed and meaningful decisions about how that information is used. We enable you to exercise certain choices, rights, and controls in relation to your information. Depending on your relationship with us, your jurisdiction, and the applicable data protection laws, you may have the right to request that certain rights be exercised or that certain limitations apply.
Subject to applicable law, you may have the following rights in relation to your Personal Data:
* Opt out of advertising and/or marketing materials. You may opt out of receiving advertising and/or marketing communications by following the opt-out instructions included in those communications, or by using the relevant options available in your device settings.
* Access and correct the Personal Data we hold about you. You have the right to request access to the Personal Data we maintain about you and to request that it be corrected if it is inaccurate or incomplete.
* Right to data portability. At any time, and using the methods described below, you may request a copy of the Personal Data we currently maintain that is associated with you. If you make such a request, we will provide the information in an electronic format within thirty (30) days.
* Other rights - deletion, objection, and withdrawal. You also have the right to request deletion of your Personal Data, to object to our use or sharing of your Personal Data, and to ask that we restrict how we use or share your Personal Data. You may withdraw your consent at any time. If you have data protection questions or want to submit a request regarding your Personal Data, we encourage you to contact us first so we can respond as quickly as possible. We will respond to all requests within a reasonable timeframe.
* Right to lodge a complaint with a supervisory authority. You also have the right to submit a complaint to the relevant supervisory authority in your country of residence.
California Residents
We seek to respond to a verifiable consumer request within forty-five (45) days after receiving it. If more time is required (up to ninety (90) days), we will notify you in writing, provide the reason for the delay, and state the length of the extension. We will send our written response by mail.
Any disclosures we provide will cover only the twelve (12)-month period immediately preceding our receipt of the verifiable consumer request. Where applicable, our response will also explain the reasons we cannot comply with a request. For data portability requests, we will choose a format that provides your Personal Data in a readily usable form and that enables you to transmit the information from one entity to another without undue hindrance.
* Right to opt out. Under the CCPA, California residents may request that a business stop selling or sharing their Personal Information (as those terms are defined under the CCPA), where applicable.
* Right to be informed. You have the right to be informed about the categories of Personal Data we collect and the purposes for which we collect it. This information is set out in this Policy, which we update at least once every twelve (12) months.
* Right to disclosure. You may request that we disclose what Personal Data we have collected about you during the preceding twelve (12) months. This Policy also explains the categories of Personal Data we collect and intend to collect, the sources of such data, and the ways we use it.
* Right of access (copy of Personal Information). You may request, free of charge, a copy of your Personal Information in a readily usable and readable format up to twice per year. When responding to an access request, we will provide the following information:
- The categories of Personal Data we collect about you.
- The categories of sources from which we collect Personal Data.
- The purposes for collecting your Personal Data.
- The categories of third parties with whom we share your Personal Data.
- The specific pieces of Personal Data we have collected about you.
* Right to deletion. You may request that we delete Personal Data we have collected about you during the preceding twelve (12) months. We acknowledge your right to deletion; however, we may be required or permitted to retain certain Personal Data for specific purposes, such as providing the App to you, detecting or addressing security or functionality issues, complying with legal obligations, conducting research in the public interest, protecting free speech, or carrying out internal actions that you may reasonably expect. If none of these exceptions applies, we will delete your Personal Data upon request.
* Right to equal service and price. California residents are protected from discrimination for exercising their rights under the CCPA. We will not discriminate against you for exercising any of your CCPA rights.

9. ADDITIONAL NOTICE FOR U.S. RESIDENTS
Depending on your state of residence, you may be entitled to additional disclosures and/or privacy rights under applicable U.S. state privacy laws. If you believe you may be entitled to additional disclosures or rights under applicable law, please contact us at linksdot.games.valley@gmail.com, and we will provide you with the relevant information and instructions on how to exercise such rights, as required by applicable law.

10. HOW TO EXERCISE MY RIGHTS
If you wish to exercise any of the rights described above, you may contact us at any time by email at linksdot.games.valley@gmail.com.
Mandatory verification: We must verify your identity before we can process your request. Since the App does not allow you to create an account and you do not provide information to us directly (we collect information only automatically), we may rely on limited verification methods. Generally, we will verify your identity by matching the information in our systems with the information we are able to process when you submit your request. In some cases, we may decline to act on a request, mainly where we cannot verify your identity, for example, if you have disabled cookies, changed the device used to access the App, or have already asked us to delete your Personal Data.

11. AGE
We provide Users with a variety of applications, besides this App. Some applications are intended primarily for children under the age of 16, while others are designed for Users of all ages. As a general rule, we do not process children's Personal Data on the basis of consent. If we do so and become aware that we have collected Personal Data from a child under 16, we will either delete the Personal Data or promptly seek parental consent for its collection, as required by applicable law.

12. RETENTION
We will keep your Personal Data only for as long as needed to provide the App and to fulfill the purposes described above, unless applicable laws (including accounting requirements) require a longer retention period, or unless it is necessary to establish, exercise, or defend legal claims.

13. UPDATES
From time to time, we may revise this Policy to reflect material changes to the way we process Personal Data. Before any material changes become effective, we will, where applicable, provide notice by email (if you have provided your email address), within our App, or by displaying a pop-up notice on our website.

14. CONTACT US
If you have any questions, concerns, or requests about this Policy or our privacy practices, please contact us at linksdot.games.valley@gmail.com.