Privacy Policy

Who we are

This is the marketing website for Valhallr — a forthcoming licensed gaming platform currently in development. The site is operated by Valhallr Ltd, a company to be incorporated under Maltese law, and a subsidiary of 9RE Ltd (trading as 9 Realms Entertainment) (headquartered in Cyprus). Valhallr Ltd operates under the regulatory oversight of the Malta Gaming Authority (MGA).

For any privacy questions, contact: privacy@valhallr.com

1. What this policy covers

This Privacy Policy applies to this marketing website (valhallr.com) only. It does not govern the Valhallr gaming platform or application — when Valhallr launches, a separate and more detailed Privacy Policy will apply to that service, reflecting the additional requirements that apply to licensed gaming operators.

At this stage, the Valhallr website is a pre-launch marketing and awareness site. We do not collect names, email addresses, or account information. The only data we collect is through analytics and cookies, as described in Section 2.

This policy applies to all visitors to valhallr.com, wherever in the world you are based. We keep it updated — if we make material changes we will update the version date at the top.

2. What data we collect

Because this is a marketing-only site with no signup or contact forms, we collect only technical and usage data through cookies and analytics tools. We do not collect your name, email address, or any other identifying information.

Analytics and usage data

When you visit valhallr.com, our analytics tools automatically collect certain technical information, including:

• Your IP address (used to determine approximate country/region — not stored at precise level)
• Browser type and version
• Device type and operating system
• Pages visited, time spent, and navigation paths
• Referring website (how you found us)

Why: To understand how people find and use the site so we can improve it. Legal basis: Legitimate interests (GDPR) — this helps us make the site better and understand our audience. Where consent is required (e.g. for non-essential analytics cookies), we obtain it through our cookie banner.

3. Cookies

We use cookies — small text files stored on your device — to help the site function and to understand how it is used. We use two types:

Essential cookies: Required for the site to function correctly (e.g. security, load balancing). These cannot be disabled. Consent required: No — necessary for the site to work.

Analytics cookies: Help us understand visitor behaviour — pages viewed, time on site, traffic sources. Used to improve the site. Consent required: Yes — you can opt out via our cookie banner or browser settings.

You can manage your cookie preferences at any time through your browser settings. Disabling essential cookies may affect site functionality.

We do not use advertising, targeting, or social media cookies on this marketing site.

4. Who we share data with

We use third-party analytics providers to process the usage data described above. These providers act as data processors on our behalf and are bound by appropriate data processing agreements.

We do not sell your data. We do not share your data with any third parties for their own marketing purposes.

We may disclose data if required to do so by law, a valid legal process, or by our regulator (the Malta Gaming Authority).

5. International data transfers

As Valhallr Ltd will be incorporated in Malta (an EU member state), your data is processed within the European Economic Area. Our analytics providers may process data in other countries — where they do, appropriate safeguards (such as Standard Contractual Clauses) are in place.

6. Your rights

Depending on where you are based, you have various rights in relation to the limited data we hold about you.

EU and EEA users (GDPR)

You have the right to access, correct, or erase data we hold about you; to object to or restrict processing based on legitimate interests; and to lodge a complaint with your national data protection authority. Contact the European Data Protection Board at edpb.europa.eu for a list of national authorities. As a Maltese entity, our lead supervisory authority is the Information and Data Protection Commissioner (IDPC) of Malta — idpc.org.mt.

UK users (UK GDPR)

You have the same rights as EU users under the UK GDPR. You may also complain to the Information Commissioner's Office (ICO) at ico.org.uk.

California users (CCPA / CPRA)

You have the right to know what personal information we collect, to request deletion, and to opt out of sale or sharing. We do not sell personal information. To exercise your rights, contact privacy@valhallr.com.

Australian users

We handle personal information in accordance with the Australian Privacy Principles. You may request access to or correction of any data we hold by contacting privacy@valhallr.com. You may escalate complaints to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

To exercise any rights, contact privacy@valhallr.com. We will respond within 30 days.

7. Data retention

Analytics data collected through this marketing site is retained for a maximum of [13] months on a rolling basis, after which it is automatically deleted or anonymised. We do not retain any personal data beyond what is necessary for the purposes described in this policy.

8. Changes to this policy

We may update this Privacy Policy from time to time. The version date at the top of the document will reflect when it was last updated.

When Valhallr launches as a licensed gaming platform, a new and separate Privacy Policy will apply. That policy will include additional disclosures required under the Malta Gaming Authority's player data and responsible gaming requirements.