VALOR PRIVACY POLICY

LAST UPDATED SEPTEMBER 2024

This privacy policy for Quark Games, LLC ("Company," "we," "us," or "our") describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at valor@quarkgames.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy policy, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Quark Games, LLC and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us at valor@quarkgames.com. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  12. DO WE MAKE UPDATES TO THIS NOTICE?
  13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

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9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EAA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In certain regions (like the EAA, UK, and Canada), you have specific rights under applicable data protection laws. These may include the rights (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. Under certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EAA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .

Withdrawing your consent: If we rely on your consent to process your personal information—whether express or implied depending on applicable law—you have the right to withdraw that consent at any time. You can withdraw it by contacting us using the contact details provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.

However, please note that this will not affect the lawfulness of processing before its withdrawal nor will it affect processing conducted under lawful grounds other than consent when applicable law allows.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing communications at any time by clicking on the unsubscribe link in our emails or by contacting us using details provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from our marketing lists. However, we may still communicate with you—for example, sending service-related messages necessary for account administration or responding to service requests.

Account Information

If you would like to review or change how information is handled in your account or terminate it altogether, you can:

Upon receiving a request for account termination, we will deactivate or delete your account along with its associated information from our active databases. However, we may retain some information in our files for fraud prevention purposes, troubleshooting issues, assisting investigations, enforcing legal terms and/or complying with legal requirements.

Cookies and similar technologies: Most web browsers are set up to accept cookies by default. If preferred, you can usually adjust browser settings to remove cookies or reject them entirely. Please note that doing so could impact certain features or services of our app. To opt out of interest-based advertising by advertisers on our services visit http://aboutads.info/choices/.

If you have questions about privacy rights related inquiries feel free to email us at valor+privacy@quarkgames.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers along with some mobile operating systems include a Do-Not-Track (“DNT”) feature allowing users signal their preference against having data about online activities monitored & collected. Currently no uniform technology standard exists for recognizing & implementing DNT signals; therefore we do not respond currently respond DNT browser signals nor other mechanisms communicating choices against being tracked online.

If standards arise regarding online tracking which require compliance moving forward we'll inform users through revised versions of this notice.

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? %p %em %strong In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1793.83, also known as the “Shine the Light'' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.). %p %strong CCPA Privacy Notice %p The California Code of Regulations defines a “resident” as: %ol %li %p Every individual who is in the State of California for other than a temporary or transitory purpose and %li %p Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose %p All other individuals are defined as “non-residents.” %p If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information. %p What categories of personal information do we collect? %p We have collected the following categories of personal information in the past twelve (12) months: %table.table %tbody %tr %td Category %td Examples %td Collected %tr %td %ol %li %p Identifiers %td %p Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name %td %p YES %tr %td %ol{start: "2"} %li %p Personal information categories listed in the California Customer Record statute %td %p Name, contact information, education, employment, employment history, and financial information %td %p YES %tr %td %ol{start: "3"} %li %p Protected classification characteristics under California or federal law %td %p Gender and date of birth %td %p YES %tr %td %ol{start: "4"} %li %p Commercial information %td %p Transaction information, purchase history, financial details, and payment information %td %p YES %tr %td %ol{start: "5"} %li %p Biometric information %td %p Fingerprints and voiceprints %td %p NO %tr %td %ol{start: "6"} %li %p Internet or other similar network activity %td %p Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements %td %p YES %tr %td %ol{start: "7"} %li %p Geolocation data %td %p Device location %td %p YES %tr %td %ol{start: "8"} %li %p Audio, electronic, visual, thermal, olfactory, or similar information %td %p Images and audio, video or call recordings created in connection with our business activities %td %p NO %tr %td %ol{start: "9"} %li %p Professional or employment-related information %td %p Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us %td %p NO %tr %td %ol{start: "10"} %li %p Educational Information %td %p Student records and directory information %td %p NO %tr %td %ol{start: "11"} %li %p Inferences drawn from other personal information %td %p Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics %td %p YES %p We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: %ul %li %p Receiving help through our customer support channels; %li %p Participation in customer surveys or contests; and %li %p Facilitation in the delivery of our Services and to respond to your inquiries %p %strong How do we use and share your personal information? %p Quark Games, LLC collects and shares your personal information through: %ul %li %p Targeting cookies/Marketing cookies %li %p Social Media cookies %p More information about our data collection and sharing practices can be found in this privacy notice. %p You may contact us by email at info@valor-game.com, or by referring to the contact details at the bottom of this document. %p If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf. %p %strong Will your information be shared with anyone else? %p We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf. %p We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information. %p Quark Games, LLC has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Quark Games, LLC has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: %ul %li %p Category A: Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name. %li %p Category B: Personal Information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information. %li %p Category C: Characteristics of protected classifications under California or federal law, such as gender or date of birth. %li %p Category D: Commercial information, such as transaction information, purchase history, financial details, and payment confirmation. %li %p Category F: Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements. %li %p Category G: Geolocation data, such as device location. %p The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”. %p %strong Your rights with respect to your personal data %p Right to request deletion of the data – Request to delete %p You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. %p %u Right to be informed – Request to know %p Depending on the circumstances, you have a right to know: %ul %li %p Whether we collect and use your personal information; %li %p The categories of personal information that we collect; %li %p The purposes for which the collected personal information is used; %li %p Whether we sell your personal information to third parties; %li %p The categories of personal information that we sold or disclosed for a business purpose; %li %p The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and %li %p The business or commercial purpose for collection or selling personal information. %p In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request. %p %u Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights %p We will not discriminate against you if you exercise your privacy rights. %p %u Verification process %p Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as circumstances dictate. %p We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you. %p %u Other privacy rights %ul %li %p You may object to the processing of your personal information. %li %p You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information. %li %p You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA. %li %p You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. %p To exercise these rights, you can contact us by email at info@valor-game.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you. %h4 12. DO WE MAKE UPDATES TO THIS NOTICE? %p %em %strong In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws. %p We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. %h4 13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? %p If you have question or comments about this notice