Privacy Policy

THE USE OF OUR SERVICES, GAMES, AND WEB SITES ARE SUBJECT TO AGREEMENT TO THE TERMS OF THIS PRIVACY POLICY. THIS PRIVACY POLICY ONLY ADDRESSES ACTIVITIES FROM OUR SERVERS. OTHER SITES (INCLUDING THOSE TO WHICH WE MAY LINK) AND OTHER SERVICE PROVIDERS MAY HAVE THEIR OWN POLICIES, WHICH WE DO NOT CONTROL, AND THUS ARE NOT ADDRESSED OR CONTROLLED BY THIS POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF OUR PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR SITES.

1. Commitment

The VALOFE Global., Ltd. and its subsidiaries and affiliates (collectively referred to as, "VALOFE", “we”, “our” and “us”) respect and is committed to the privacy of our online visitors and recognizes the importance of protecting all information that you may choose to share with us. To further this commitment, we have adopted this Online Privacy Policy ("Privacy Policy") to guide how we collect, store, and use the information you provide us. The term “Services” refers to the act of providing you with the opportunity to use the named games (“Games”), websites (“Sites”), VALOFE accounts ("Account"), and any of our other products and services (including support services, forums) related to the Games ("Ancillary Services").

If you have any complaints or opinions concerning personal information, please send your opinions or complaints to support@valofe.com. Questions or comments regarding this Privacy Policy can also be directed to our customer service department using the Email Inquiry form located on our website. While we cannot guarantee privacy perfection, we will address any issue to the best of our abilities as soon as possible.

2. Consent

This Privacy Policy describes how VALOFE Corporation (“VALOFE”, “us”, “our” or “we”) collects, uses, and shares information about you and applies to your use of our game application (the “Game”) and services and content related to the Game including services provided via the vfun.valofe.com website (the “Services”).
Should the Privacy Policy change, we intend to take every reasonable step to ensure that these changes are brought to your attention by posting all changes prominently on our web site for a reasonable period of time.

3. Personal Information

Personal Information means any information that may be used to identify an individual, including, but not limited to, a first and last name, a home or other physical address and an email address or other contact information, whether at work or at home. In general, you can visit our Web pages without telling us who you are or revealing any Personal Information about yourself.

We collect Personal Data and other information that you voluntarily provide. It is entirely your decision to provide the requested information. However, your use of certain Services is possible only if you provide required information, e.g. while creating an Account. If you use our websites and games, we may collect personal information from you (such as name, e-mail address, contact information and payment and billing information), but only if you voluntarily provide it to us. This information will be used by us to allow you to register to use the services, register for contests or giveaways, complete questionnaires, order products and services from us and submit forms or send other information to us. We do store your personally identifiable information in a secure format, and also use Secure Sockets Layer encrypted connections to transmit your payment-related personally identifiable information to further protect its privacy. As outlined below, we may also collect unique usage information, which does NOT include personally identifiable information, to assist us in understanding our customers' use patterns and for use in developing new products and services.

If you decide to provide us your personal information, we will only collect the personal information which is needed to fulfill your requests and our legitimate business objectives. If you refuse to release your personal information when requested, you will not be able to access certain areas of our services.

3.1 VALOFE Account users

REGISTRATION TO USE SERVICES

If you wish to register with our game, you will be asked to provide us with, but not limited to, an email address and birth date. You may be asked to choose a user or member name and password. Please do not use your real name or the real name of another person when selecting a user name. Please note that your user name will be available to the Internet's general public while you participate in some services, like chat rooms or message boards, so you should exercise discretion when using these services.

We are not responsible for protecting such information that you may disclose to third parties through our services (e.g. sending your telephone number to another user through the chat service). To the extent that you create a public profile that may be available to others on our sites and services, you are solely responsible for its content and accuracy at all times. To edit or change such information, follow the instructions on the web site.

ONLINE GAMES

When you play any of the games offered and/or served by VALOFE, or use any of the communication features on the Sites, your IP address (the Internet protocol address from which you access any of the above) may be stored in our records. When any game is updated or "patched," our patch routine may check your computer to see that you have the most recent version of game-specific files; when you communicate within any game or any other communication feature within the Game (e.g. live chat, instant message services and the like), even "privately" to another person, you do so with the understanding that those communications go through our servers, can be monitored by us, you have no expectation of privacy in any of those communications and, accordingly, you expressly consent to monitoring of communications that you send and receive.

ONLINE STORE

When you sign up to play our game or you make an online purchase from our Web site or online store, you need to provide a valid credit card number, expiration date and credit card security code, in addition to name, mailing and billing addresses, phone number and e-mail address. Please note that you must be over the age of 18 to place orders online). Issues related to customer service, billing questions, etc. may also require you to provide us with some personal information so that we may resolve the issue properly. All financial and personal information is transmitted by SSL protocol via VALOFES' secure server.

COOKIES AND RELATED TECHNOLOGY

We may use cookies on our websites. A "cookie" is a small bit of record-keeping information that sites often store on a user's computer. Cookies do not include people's names, email addresses, or other information that is personally identifiable; they are typically used to quickly identify a user's computer and to "remember" things about the user's visit. Usage of a cookie is in no way linked to any personally identifiable information while on our site. Once you close your browser, the cookie simply terminates and is not saved on your computer disk drive. For instance, by setting a cookie on our site, you would not have to log in a password more than once, thereby saving time while on our site. If you reject the cookie, you may still use our site. The only drawback to this is that you will be limited in some areas of our site, or may have to enter passwords or identifying information more than once. We also collect other information of a non-personal nature, such as IP addresses, browser types, domain names, software versions, and access times for our internal purposes.

Additionally, we may also collect other types of non-personal information (known as demographic information) such as your age or date of birth, gender, hobbies, occupation, platform preferences, and other game ownership and preferences. This demographic information may be associated with your personal information.

If you choose to provide us with your Personal Information on the Web, we may transfer that Information within.

Generally, the information that you disclose on our website is collected by VALOFE or by third parties such as co-sponsors or vendors for the promotion. VALOFES ' use of any such information will be governed by this policy. The names of third parties such as co-sponsors (other than vendors hired by VALOFE to conduct, administer, and execute a promotion on behalf of VALOFE will be disclosed to you when you are asked to sign up for the promotion.

VALOFE strives to comply with all applicable laws around the globe that are designed to protect your privacy. Although legal requirements may vary from country to country, VALOFE intends to adhere to the principles set forth in this Privacy Policy even if, in connection with the above, we transfer your Personal Information from your country to countries that may not require an "adequate" level of protection for your Personal Information. In other words, our goal is to provide protection for your Personal Information no matter where that Personal Information is collected, transferred, or retained.

3.2 Social Networking Service (“SNS”) Account

Device Information

To provide you with an access to any of VALOFE Mobile Games and for your use of our Services pursuant to our Terms of Service, we must at least collect and process from all of you your device information including MAC Address, IP Address and unique mobile device ID (collectively, “Device Information”). We collect and process your Device Information because we have a legitimate business interest in providing the Services to you that do not override your interests, rights and freedoms to protect information about you. We use your Device Information to discharge our contractual obligations to you as a User of our Services.

With your Device Information, we will:

- provide access to the VALOFE Mobile Games and any of our Services;
- create your game account and manage the account information;
- inform you of (a) existing products, new products, services, features, promotions, enhancements and updates regarding our Service and (b) updates to the Policy;
- fulfill your request and/or order for VALOFE Mobile Games and our obligations under the Policy;
- monitor the technical functioning of the Service; and
- trouble-shoot errors or issues with any of the Service.

Game Data

Our Service will also record game play information including, without limitation, your activities within the VALOFE Mobile Games, high scores or game session duration, for the continuation of your game play. Any time you access the Service, we also collect aggregate information, including, without limitation, internet protocol addresses, your device’s operating system, browser type and browser language. We use the game play information and aggregate information to provide adequate services within the Services, better tailor the Service to your interests, to provide you more efficient customer support, and to overall enhance the Services. We collect and process your game play information because we have a legitimate business interest in providing the Services to you that do not override your interests, rights and freedoms to protect information about you.

Usage Data through Automated Means

When you access and/or use any of our Services, we may also collect your usage statistics about your interactions with our Services. Such usage data is collected through the use of server log files and/or automated means. We and our marketing partners and analytics service providers use technologies may use “cookies” and other technologies such as pixel tags and web beacons, clear GIFs on certain our Services, Games, advertising and web pages to analyze your use of our Services, games, advertising and web pages, to customize, improve the same, to measure promotional effectiveness, and to promote trust and safety. We collect and process your usage data because we have a legitimate business interest in providing the Services to you that do not override your interests, rights and freedoms to protect information about you. You are always free to decline our cookies if your browser or device permits, although doing so may interfere with your use of some of our Services, Games, advertising and web pages. Please note that certain features of our Services, Games, advertising and web pages will not be available once cookies are declined.

SNS Information

When you use or access VALOFE Mobile Games using a third party SNS, such as Facebook, Apple Play Center or Google +, you allow us to access and/or collect certain information from your SNS profile/account as permitted by the terms of the SNS Platform and your privacy settings thereon. To provide SNS Account users the Service and necessary customer support, we, in addition to your Device Information, collect your unique SNS identifier and your SNS profile photo (collectively, the “SNS Information”). We collect and process your SNS Information because we have a legitimate business interest in providing the Services to you that do not override your interests, rights and freedoms to protect information about you. We use your SNS Information to discharge our contractual obligations to you as a User of our Services.

With your SNS Information, we will:

- provide access to the VALOFE Mobile Games and any of our Services;
- create your game account and manage the account information;
- inform you of (a) existing products, new products, services, features, promotions, enhancements and updates regarding our Service and (b) updates to the Policy;
- provide customer support and respond to User inquiries;
- fulfill your request and/or order for VALOFE Mobile Games and our obligations under the Policy; and
- enable User-to-User communication and interaction

If you do not wish your SNS to provide us your personal data, you may disconnect the SNS login in the setting within the Services or change the privacy setting on your SNS. Your deliberate disconnection of the SNS login may limit certain features of our Services.

Additional Information

Furthermore, upon your explicit consent, we may also collect and process below information to provide enhanced game services and promotional/marketing information regarding VALOFE Mobile Games via push notification and/or e-mail newsletters:

- for the purpose of marketing, your country, phone number, email address, and birthday;
- for the purpose of providing you with social networking services within the Services, your profile photo, country, gender, and contact list; and
- for the purpose of providing you with VALOFE optional services (i.e. find your ID/password or other information to identify user/account), your birthday and secondary email address.

3.3 Users without Any Account

Users can access any of VALOFE Mobile Games without a VALOFE or SNS Account. These guest users (“Guest Users”) can enjoy VALOFE Mobile Games but may have limited access to online communities or social network services, customer support and other exclusive services rendered to VALOFE or SNS Account users.

To provide you as a Guest User necessary access to VALOFE Mobile Games and for your use of VALOFE Mobile Games pursuant to the Terms of Service concluded between you and us, we collect and process below information.

Device Information

To provide you with an access to any of VALOFE Mobile Games and for your use of our Services pursuant to our Terms of Service, we must at least collect and process from all of you your device information including MAC Address, IP Address and unique mobile device ID (collectively, “Device Information”). We collect and process your Device Information because we have a legitimate business interest in providing the Services to you that do not override your interests, rights and freedoms to protect information about you. We use your Device Information to discharge our contractual obligations to you as a User of our Services.

With your Device Information, we will:

- provide access to the VALOFE Mobile Games and any of our Services;
- create your game account and manage the account information;
- inform you of (a) existing products, new products, services, features, promotions, enhancements and updates regarding our Service and (b) updates to the Policy;
- fulfill your request and/or order for VALOFE Mobile Games and our obligations under the Policy;
- monitor the technical functioning of the Service; and
- trouble-shoot errors or issues with any of the Service.

Game Data

Our Service will also record game play information including, without limitation, your activities within the VALOFE Mobile Games, high scores or game session duration, for the continuation of your game play. Any time you access the Service, we also collect aggregate information, including, without limitation, internet protocol addresses, your device’s operating system, browser type and browser language. We use the game play information and aggregate information to provide adequate services within the Services, better tailor the Service to your interests, to provide you more efficient customer support, and to overall enhance the Services. We collect and process your game play information because we have a legitimate business interest in providing the Services to you that do not override your interests, rights and freedoms to protect information about you.

Usage Data through Automated Means

When you access and/or use any of our Services, we may also collect your usage statistics about your interactions with our Services. Such usage data is collected through the use of server log files and/or automated means. We and our marketing partners and analytics service providers use technologies may use “cookies” and other technologies such as pixel tags and web beacons, clear GIFs on certain our Services, Games, advertising and web pages to analyze your use of our Services, games, advertising and web pages, to customize, improve the same, to measure promotional effectiveness, and to promote trust and safety. We collect and process your usage data because we have a legitimate business interest in providing the Services to you that do not override your interests, rights and freedoms to protect information about you. You are always free to decline our cookies if your browser or device permits, although doing so may interfere with your use of some of our Services, Games, advertising and web pages. Please note that certain features of our Services, Games, advertising and web pages will not be available once cookies are declined.

Additional Information

Furthermore, upon your explicit consent, we may also collect and process the Device Information to provide enhanced game services and promotional/marketing information regarding VALOFE Mobile Games, including sending you push notification.

4. Notice

Where VALOFE collects Personal Information on the web, we intend to post a purpose statement that explains why Personal Information will be collected and whether we plan to share such Personal Information outside of VALOFE or those working on our behalf. VALOFE does not intend to transfer Personal Information without your consent to third parties who are not bound to act on our behalf unless such transfer is legally required.

5. Your Rights and Choices

You may choose whether or not to provide Personal Information to VALOFE. The notice we intend to provide where we collect Personal Information on the Web should help you to make this choice. If you choose not to provide the Personal Information we request, you can still visit most of our web sites, but you may be unable to access certain options, offers, and services that involve our interaction with you.

5.1. RIGHT OF ACCESS

You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access to your Personal Data through the “Data Export” tool available in the Account Management tools. Once the archive with the Personal Data we retain is ready, you will be able to download in it from our resources. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request. We also will not be able to provide you with some Personal Data that you may post or provide using our Services regardless of our request not to provide the Personal Data in this particular field, website, etc.

5.2. RIGHT TO RECTIFICATION

You control which ID, email, country, social networks accounts, and trusted sites we associate with your Account. If they change, please modify the data in the Personal Account directly. Please inform us if any of the Personal Data we retain about you is inaccurate.

5.3. RIGHT TO ERASURE

You have the right to obtain deletion by us of Personal Data concerning you by deleting your Account via our “Account Deletion” tool available in the account management section in our homepage. In the event a user requests the deletion of personal information, it will be conducted under the supervision of the 'Data Protection Officer'. In case of possession of SNS Account, you have the right to obtain deletion via "Account Deletion" available in game.

As a result of deleting your Account, you will lose access to most Services, including the Account and Game-Related Information linked to the Account, subscriptions to VALOFE forums and the possibility to access other services you are using the Account for including but not limited to, all of your game related items, characters, and all remaining game credits on your account.

Important note: Any Virtual Goods you purchase from us are directly linked to the existence of your Account. If you decide to close your Account, you will lose any Virtual Goods accessible from that Account at the time of the termination and you will not be entitled to any refunds or compensation.

Grace period. We will allow you to restore your Account during a minimum grace period of 45 (forty-five) days from the moment you request deletion of your Account. This functionality allows you not to lose various Game-Related Information and other important information and options by mistake. During the suspension period, we will be able to finalize financial and other activities that you may have initiated before sending the Account deletion request.

Complicated Account deletion. In some cases, deletion of your Account, and therefore Personal Data deletion, is complicated. In some cases, considering the complexity and number of the requests, the period for Personal Data erasure may be extended.

Information we retain. Upon expiry of the suspension period we will delete all Personal Data about you, except for the data that are required for our compliance with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating in the Game. We will retain anonymous information after your Account has been closed. Information you have shared with others (e.g. through in-Games chats, updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.

5.4. RIGHT TO OBJECT

Where processing of your Personal Data is based on legitimate interests according to Article 21 of the GDPR, you can use your right to object at any time. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defense of legal claims.

6. Third party services, features, and devices

Our Services contain content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). In addition, our Services contain features that allow you interact with, connect to, or access our Services through certain Third Party Services and third party devices (“Third Party Features”). For example, you interact with a Third Party Service when you “like” or “share” content over social media through our Services or login to our Services through a Third Party Service. Remember that third parties may use Tracking Technologies to independently collect information about you and may solicit personal information from you. If you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature. Also, if you make information public through our Services or a Third Party Service that references our Services, such as by tweeting or updating your status along with a hashtag associated with VALOFE, that information may be used on or in connection with our Services.

Our Services also contain Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Services to help us analyze your use of the Services, compile statistic reports on the Services’ activity, and provide other services relating to Services activity and Internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Services and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Services (“Interest-based Advertising”).

The information collected and stored by third parties, whether through our Services, a Third Party Service, or a third party device, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the U.S., South Korea, or elsewhere. We are not responsible for and make no representations regarding third party policies and practices, and encourage you to familiarize yourself with and consult their privacy policies and terms of use.

7. Security

We and our employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

8. Children's Privacy

VALOFE is not structured to attract children. Our Terms of Agreements specify that accounts are available only to individuals who are 13 years of age or older. If you are under the age of 13, you may not create an account on the Sites, you may not sign up for any subscription service or buy anything through the online Store, and you are not eligible to enter any of our sweepstakes or promotions.

Except as may be required by law, VALOFE will not knowingly collect, maintain, or disclose any personal information from children under the age of 13. We take the privacy of children very seriously, and encourage parents to play an active role in their children's online experience at all times. For residents of the EEA, where processing of personal information is based on consent, VALOFE will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.

Parents and guardians should regularly oversee their children's use of email and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us please contact us at support@valofe.com

9. Use and Share of Personal Information

We will use your Personal Data for our legitimate interests according to Article 6 of the GDPR to notify you and provide you with information about features on our Sites, new product releases and service developments and to advertise our products and services in accordance with this Policy. Namely, once you have created an Account we may use your email address, nickname, IP address, mobile phone number, in order to send you emails, messages and targeted in-game and web offers about Games. Also, if you opt-in, we will send you emails, messages and targeted in-game and web offers about VALOFE offline events, co-projects of VALOFE and its partners, as well as about VALOFE games, not using VALOFE ID. You can opt-in while creating your Account or later through our account management, while you are also free to opt-out from various subscriptions through this tool. Please note that even if you unsubscribe from all our emails, messages, in-game and web-offers, we may still send you some notifications (we often refer to them as “transactional”), e.g. to confirm purchases or changes in your Account, give warranty or security information, information about changes to the Terms of Service and Privacy Policy. We will be able to stop all communications only after your Account is deleted.

We use your Personal Information to provide you with contents and services that are tailored specifically to the profile you provide. In connection with the delivery of our services, we may share the personal information with third-party partners or vendors who help deliver or administer the services, but they are only permitted to use the information in connection with the delivery or administration of our services. We use your information on an aggregated basis (not personally identifiable) to do such things as operate our site, enhance our site and sell and deliver messages. We may disclose aggregated information about our users but that information contains no Personal Information.

By using this content, you signify your agreement to our Privacy Policy. If you do not agree to this policy, please do not use or access any of our contents. We reserve the right to make changes in this policy at any time. Please check the policy each time you use our contents to ensure you are aware of any changes in our privacy practices. If you choose to opt-out of our new policy, please send us e-mail in order to obtain instructions on how to opt-out. Your continued use of our contents will signify that you have accepted the changes to our Privacy Policy.

Changes to privacy policy

VALOFE reserves the right to change, modify, add or remove portions of this Privacy Policy. When we decide to change, modify, add or remove portions of this Privacy Policy, we may notify you via postings on our Services. Please ensure that you keep up to date with any changes by visiting this page on a regular basis.

General

Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to us with regard to processing of your personal information.

For the avoidance of doubt, in the event that relevant personal information protection laws permit an organization such as us to collect, use or disclose your personal information without your consent, such permission granted by the laws shall continue to apply.

10. Governing Law

Except as expressly provided otherwise, this Agreement shall be governed by, and will be construed under laws of the Republic of Korea and international law without regard to choice of law principles.