Privacy Policy

Effective Date: March 15, 2024

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US

This Privacy Policy applies to all of our games, websites and related services, collectively referred to here as our Services. Your continued use of the Services after the effective date will be subject to the new Privacy Policy. Your use of our Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Privacy Policy. If you are a resident of the United States, please see Additional Information for the US Residents for additional disclosures.

Please read the following to learn more about how we use your personal data.

For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), Voila Games (referred to as “Voila”, “we”, “us”, or “our”) will be the data controller responsible for any personal data we process.

If you have any questions or concerns about this Privacy Policy, including those related to the exercise any of your rights, please contact us through the game’s Help & Support so we can reply to you more quickly.

Data Controller: Voila
Email: support@voila-games.com
Address: Parou, 4 Office 302, Strovolos, 2062, Nicosia, Cyprus

2. WHAT PERSONAL DATA DO WE COLLECT AND WHY?

We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting your personal data.

In each of the sections listed below, we describe how we obtain your personal data and how we treat it.

2.1 INDIVIDUAL CUSTOMERS

We collect personal data from current, prospective, and former consumers ("users") of our Services.

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

•  directly from you (via the game, website, or online forms);
• from third parties, service providers assisting in delivering services to you (including analytics providers, OS providers, ISPs), or from your social media accounts used for registration (e.g., Facebook*, Google, Game Circle, Weibo).

B - TYPES OF PERSONAL DATA COLLECTED AND PROCESSED

We may collect the following categories of personal data:

• Contact information (e.g., name, username, or email provided during registration or social login);
• Build version data, account info, game progress, in-game events, and unique identifiers (e.g., Playfab login ID);
• IP address and unique mobile device identifiers (e.g., device ID, advertising ID, MAC address);
• Device data (manufacturer, OS, CPU, RAM, browser type, language, time);
• Geolocation data (country or city level);
• Data from third-party services linked to our Services (e.g., Facebook*, Google);
• Purchase history (order ID, amount spent, currency, date, time, vouchers used);
• Data to fight fraud (e.g., fraudulent refund attempts or ad click manipulation);
• Platform data (e.g., payment verification);
• Data for advertising and analytics purposes;
• Your email and communications within our Services (e.g., support requests via Helpshift);
• Any other data you choose to provide.

C - PURPOSES AND LEGAL BASES FOR PROCESSING PERSONAL DATA

We may use your personal data to:

• Provide Services (e.g., access to games, online purchases);
• Manage and support your account, personalize your experience;
• Learn how our products/services are used or could be improved;
• Ensure security (e.g., prevent unauthorized access, safeguard systems);
• Provide marketing/advertising (e.g., promotional emails or messages).

Legal bases:

• Contract fulfillment;
• Legitimate interest:

• Account management;
• Administrative reporting;
• Legal claims;
• Market understanding;
• Risk management and fraud prevention;
• Product and service promotion.

If you object to the use of your personal data for these purposes, including direct marketing, contact us at the email listed in Section 1.

When using your email for marketing, we seek prior consent if required by law.

We do not knowingly collect personal data or send direct/targeted marketing to individuals under 16 years old. If you are under 16, do not provide any personal data. If we learn we collected data from a child under 16, we will delete it promptly. Please contact us if you believe we have such data.

D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will process your personal data only as long as necessary for the purposes collected, unless we are legally required or justified to retain it longer (e.g., legal claims).

2.2. REPRESENTATIVES OF CURRENT OR PROSPECTIVE CORPORATE CLIENTS, PARTNERS, AND SUPPLIERS

We may collect personal data of employees, executives, or other representatives of Voila Games' corporate clients, partners, and suppliers.

A - SOURCES OF DATA

We may collect data from:

• You directly;
• Your employer (if they are our client, partner, or supplier);
• Networking events (organized/sponsored/attended by us);
• Public sources (e.g., company websites or LinkedIn).

B - TYPES OF DATA COLLECTED

We may collect:

• Name;
• Business address;
• Business email;
• Business phone number;
• Job title.

C - PURPOSES AND LEGAL BASES FOR PROCESSING

We may use this data to:

• Deliver or receive products/services;
• Establish or manage relationships;
• Understand usage of our products/services;
• Ensure security;
• Promote products/services via email or digital communication.

Legal bases: Legitimate interests, such as:

• Fulfilling contractual/legal obligations;
• Administrative reporting;
• Market understanding;
• Security, fraud prevention;
• Product and service promotion.

If you object to our use of this data, including direct marketing, contact us via in-game support or the email in Section 1.

D – HOW LONG DO WE KEEP YOUR PERSONAL DATA?

 We will retain your data as long as necessary for business purposes, unless a longer period is required or justified (e.g., legal claims).

3. WHO DO WE SHARE YOUR PERSONAL DATA WITH

Our partners and service providers We may disclose data to organizations providing services under contracts requiring them to maintain confidentiality and comply with GDPR and applicable data protection laws.

We may share with:

• Technical support providers;
• software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
• Professional advisors (e.g., lawyers, auditors);
• Product/service review providers;
• our advertising and promotional agencies and consultants and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you. A list of our partners is available through this link; and/or
• Service providers assisting with service delivery;
• Law enforcement and government agencies.

We may disclose data for legal reasons such as investigation, prevention, or enforcement actions related to fraud, IP rights, safety threats, or legal compliance.

4. TRANSFER OF PERSONAL DATA OUTSIDE THE EU/EEA

We may share your data with affiliates and partners inside and outside the EU/EEA. Where no adequacy decision exists, we rely on safeguards under GDPR Art. 46+, including EU-approved Standard Contractual Clauses (SCCs), additional protections (e.g., risk assessments, encryption).

External providers must contractually agree to GDPR-level protection and process data only under our instructions.

We may also disclose data to advisors, authorities (e.g., tax or law enforcement), prosecutors, or courts. These entities are independently responsible for GDPR compliance.

For a copy of the applicable SCCs or further info, contact us at the email in Section 1.

5. YOUR RIGHTS UNDER THE GDPR

You have the right to:

• Be informed about data processing;
• Access your personal data;
• Request correction or deletion;
• Restrict or object to processing.

We do not engage in automated decision-making or profiling.

You may withdraw consent at any time for data processing (e.g., for marketing). Withdrawal does not affect prior lawful use.

You may object where processing is based on legitimate interests (see above).

If you would like to exercise any of your above rights, contact us via the email in Section 1.