HOME VALLEY PRIVACY POLICY

We at Ingames (Ingames, we, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

The purpose of this privacy notice (Privacy Notice) is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, Personal Data) when you play our games that are part of our gaming platform. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

This Privacy Notice applies whenever you play Home Valley, use our services within the Home Valley app or visit our website https://www.homevalleygame.com/ (“Service Website), all of which together we refer to as Services.

In this Privacy Notice, we will give you general information about how we process your Personal Data. We will furthermore give you more detailed information on the specific processes within our Services.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the specific information below.

Who is responsible for the processing of your Personal Data?

Ingames, Céspedes 3249 Loft 303, CABA, Argentina is responsible (the data controller) for the processing of your Personal Data in Home Valley.

What types of Personal Data do we process and how do we collect it?

When you use our Services, we may collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

The information we collect depends on which of our Services you use and how you use them. We may process the following types of your Personal Data:

Personal Data provided by you

When you use our Services, you may provide or be asked to give us certain information, including:

Personal Data we receive or generate from your use of our Services

When you use our Services, we may also process device-related information and information about how you interact with our Services, including:

Personal Data we collect from third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations. Your Personal Data may be provided by the following third parties:

To learn more about which data is processed when you use our Services, please see the section with service specific information below.

For what purpose do we process your Personal Data?

Depending on which Service you are using and which privacy settings you have selected, we may process your Personal Data for the following purposes:

Provision and improvement of our Services

Personalization of your game experience

Marketing and analytics

Prevention of fraud and illegal activity

Compliance with our legal or regulatory obligations

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data within our Services.

Do we engage in profiling activities?

We may use tracking mechanisms to track your Personal Data for profiling purposes. This helps us to find new users for our Services, based on the information we have about you, and to target users who were already interested in our Services on the website(s) or in apps of our business partners. You have the right to object to this type of processing. You can also go to your in-game settings to review and amend your privacy choices related to this type of processing at any time.

On which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:

Please see for additional information the section with service specific information below.

With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorised to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments and technical support involved in the gaming process and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfil the purposes mentioned above, we may disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

Please see the section with service specific information below for more information about the third parties we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared with by clicking here.

Where will my Personal Data be processed?

In general, your Personal Data is stored on servers within the European Union (EU)/the European Economic Area (EEA). However, your Personal Data may also be shared outside the EU/EEA. We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data. Where the recipient is a U.S. based company certified under the EU-U.S. Privacy Shield, the data transfer may also be based on the EU-U.S. Privacy Shield.

How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations. Afterwards, we will delete or anonymize your Personal Data. Please see below for service specific information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

Right to object

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such case we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example the Autoriteit Persoonsgegevens in the Netherlands.

How often do we update this Privacy Notice?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example because you did not create an account, we will inform you with a banner on our Service Website.

This Privacy Notice was last updated on:

Version

Last updated

0.0.501

2021-07-12

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Hosting and content delivery:

Home Valley is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Creation/administration of your account:

In order to play Home Valley, you have to create an account. We store your account data (your log-in credentials, your account ID, your avatar and avatar name) to allow you to log in on different devices and to enable socializing and communication with the other players, based on the performance of a contract. Furthermore, we will store your avatar’s in-game progress, your virtual assets (rooms, clothes, furniture), and your friends list in your account in order to make the multiplayer/online game work.

If you choose to link your e.g. Facebook, Google, Apple or Huawei account, we will send the information that you wish to log-in in Home Valley with your credentials to the third-party platform (e.g. Facebook, Google, Apple or Huawei) and will receive an authentication token from them. This information will be stored for your account’s lifetime to ensure that your Home Valley account is connected with the third-party platform and that you can log-in with your credentials.

Your account data will be collected and stored for as long as your account exists, based on the performance of a contract. You can delete your Home Valley account at any time, for example by submitting a deletion request to our support team using the “Delete Account” feature within the game, using the contact feature on our Service Website or by contacting our Data Protection Officer.

Third-party advertising within our game:

In Home Valley, we show advertising from different advertising companies. These advertisements can be personalized or non-personal content related ads. In order to show you personalized ads and only if you have provided your consent, we will use an Ads SDK from Google LLC (Google) inside our game which enables Google and third-party advertising companies to collect your Personal Data. The collected data includes your device information, like IP address and device identifiers, your location data, your in-game activity (such as purchase events and your game play sessions), information regarding the delivery of ads and your interaction with them.

You can adjust your privacy preferences at any time in your game settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific.

For some of the ads shown in Home Valley, you can earn virtual currency if you watch the ad (“rewarded ad”). In order to credit the virtual currency to your account, we process the following Personal Data: your device type, device language and country.

This process is based on our and third-party advertising companies’ legitimate interests, to encourage you to watch the ad and spend money for the product shown in the ad.

Data Management Platform:

Based on your consent you provided for “Profiling”, we create user segments and use these user segments for new user acquisition purposes. The user segments are created based on your in-game behaviour (such as your in-game purchases, the level you reached within the game) and by determining the spending behaviour for each segment. For this purpose, your Personal Data, including your in-game behaviour, your country, game language, purchase segmentation, the highest price point ever spent in Home Valley, and the advertisement ID are collected and sent to a data management service provider.

In-game offers:

We also process your personal data in order to inform you via push notifications about our in-game offers. Different in-game items will be offered to different user segments. For this purpose, we process the following information: your avatar level, highest bought IAP in last 30 days, your total revenue in the last 30 days, your country, game language setting, information about in-game items you already own, whether you have bought a specific offer before the current offer, whether you have bought a specific IAP, the account age, avatar gender, coin balance, and diamond balance. This information is collected for the purpose of analyzing whether specific in-game offers are particularly relevant for certain user segments and stored for the period of three years. In this context, we only look at data in an aggregated form without reference to you. Based on your information, you may fall into a specific user segment and thereby receive in-game offers that are more relevant to you.

This process is based on our legitimate interests. You can turn off the push notifications in your phone’s settings at any time.

New user acquisition, remarketing and campaign tracking:

Analytics:

We use internal and external analytics services to understand which features and ads you like in Home Valley and how you use or interact with them. The analytics data helps us to improve the game for you, to develop new items, to find crashes and issues in the game, and help third-party advertising companies to measure and improve the effectiveness of their campaigns placed in Home Valley. For this purpose, we process/enable third-party advertising companies to process the following Personal Data: your advertisement device ID (IDFA & GAID), your in-game behaviour (including in-game purchases), in-game user segments, your location data (country and city), your language, the campaign ID, your avatar and account ID, your internal device ID and your IP Address. We store the (personalized) analytics data for three years.

We process this information based on our legitimate interests.

Customer service:

If you contact us for customer support, an external customer service company will process your email address and/or your name (optional), and the content of your request. In order to provide you with support, this information will be processed together with your device information (model, OS, game language, carrier), the user ID, user segment, and the last steps taken within the game. The request history is stored for your account’s lifetime to enable handling of newer requests based on your previous request and to improve our services.

We process this data on the basis of the performance of a contract as far as the information is required to answer your request. The continued storage of your request history is based on our legitimate interest, in order to improve our services.

Payments:

If you make in-app purchases, you will be redirected to an external payment provider for the transaction of your payment. For this purpose, if you use Google pay, the product ID, a purchase token, and the application name will be sent to Google. If you use Apple pay, a purchase receipt will be sent to Apple. If you use Huawei, the shop name (“Ingames”), product ID, and request ID will be shared with Huawei.

The transactions will be processed by the third-party payment provider. While we do not collect and do not receive any financial data (such as your bank account data), we collect or may receive from third-party payment providers the following information related to your transaction: the purchased amount and item, the currency, your country, your IP address, device information (user agent), time stamp, url visited, payment/transaction id, and the status of your payment. We store this information for at least 7 years or your account’s lifetime in the event that your account continues to exist after the expiration of 7 years.

We process your Personal Data in connection with your payments on the basis of the performance of a contract in order to facilitate your in-game purchase.

Chats:

If you use the chat feature within our game, your message will be processed, together with your user ID and your avatar, the timestamp, recipients of your message or room ID (if you post your message in a public chat room). Your messages in public chat rooms will be stored for six months whereas your private chat messages will be stored for 60 days (read messages) or for one year (unread messages). This process is based on the performance of a contract.

The content of your messages will also be processed by an external content moderation service in order to detect and filter offensive language or violations of our terms and conditions and to set automatic sanctions (temporary muting) to offenders. This process is based on our legitimate interests.

Please be aware that when you use the chat function, the information you disclose may be read, copied, collected or used by other users. Never share information or personal data that is harmful for yourself or others.

Logging of all in-game activities:

In order to help you with any issues you might have with our game, to understand how our software works, and to investigate fraud and illegal behaviour in our game, we collect and store all the steps you take within Home Valley, together with the following information: your account ID, your IP address, device information (user agent or mobile device information), IDFA (mobile advertising ID) in our logs which will be deleted after 60 days.

This process is based on our legitimate interests.