A. DATA CONTROLLER:
GAMES UNITED
YAZILIM EĞİTİM SANAYİ TİCARET A.Ş
E-mail Address:
[email protected]
Address: ARNAVUTKÖY MAH.BEBEK
ARNAVUTKÖY CAD. İNCİ YALI NO: 28 İÇ KAPI:2BEŞİKTAŞ
This
privacy and data policy (“Privacy Policy”) applies
and has effect in respect of all games, relatedonline services
(including online network play connectivity and interactivity) and
other software andproducts made available by Games United. Together
the mobile app/Game(s) and the Website arereferred to as the “Online Services”.
As Games United, we are committed to protecting and
respecting your privacy. The Privacy Policyexplains the basis on which
personal information we collect from you will be processed by us or
onour behalf. Where we decide the purpose or means for which personal
data you supply through theseOnline Services is processed, we are the
“controller”.
The Online Services may contain hyperlinks to
services owned and operated by third parties. Thesethird-party
services may have their own privacy policies and we recommend that you
review them. Theywill govern the use of personal information that you
submit or which is collected by cookies and othertracking technologies
whilst using these services. We do not accept any responsibility or
liability for theprivacy practices of such third-party services and
your use of these is at your own risk.
Games United
reserves the right to modify this Privacy Policy and your continued
use of the Servicesshall mean your acceptance of the changes to this
Privacy Policy You should check this page fromtime to time to ensure
you are aware of any changes. Where appropriate we may notify you of
changesthrough the Games.
B. THE PURPOSE, SCOPE AND LEGAL BASIS OF PROCESSING
This Privacy Policy is incorporated by reference into the Games
United Terms of Service (the “Terms ofServices”). The terms “Games
United,” “we,” and “us” include GAMES UNITED YAZILIM EĞİTİMSANAYİ
TİCARET A.Ş. This Privacy Policy explains our online and offline
information practices, the kinds of information we may collect, how we
intend to use, store, protect, disclose and share thatinformation, and
how you can opt out of a use or correct or change such information.
This
Privacy Policy applies to Personal Information that is Processed by
Games United in the course ofour business, including on Games United
websites, mobile applications, forums, blogs, and other onlineor
offline offerings (together with any and all future online and offline
offerings operated by or on behalfof Games United. All individuals
whose responsibilities include the Processing of Personal
Informationon behalf of Games United are expected to protect that data
by adhering to this Privacy Policy.
This Privacy Policy is
intended to meet requirements globally, including those in North
America, Europe,Turkey, APAC, and other jurisdictions.
By
visiting, installing, using or otherwise accessing the Services, you
agree to this Privacy Policy andTerms of Services of Games United and
give an explicit and informed consent to the processing of
yourPersonal Information in accordance with this Privacy Policy.
Please do not install or use the Services ifyou do not agree to this
Privacy Policy or Terms of Services.
PLEASE NOTE THAT GAMES
UNITED IS NOT RESPONSIBLE FOR THE ACTIONS OF THIRDPARTIES, THE CONTENT
OF THEIR SITES, THE USE OF INFORMATION YOU PROVIDE TOTHEM OR ANY
SERVICES THEY MAY OFFER.
The types of Personal Information
we may collect (directly from you or from Third-party sources) andour
privacy practices depend on the nature of the relationship you have
with Games United and therequirements of applicable law. Some of the
ways that Games United may collect Personal Informationinclude:
-
you may provide Personal Information directly to Games United through
interacting with theServices, participate in Services feedback,
questionnaires, surveys, or contests or participating inforums
discussions, and requesting Services, or information; and
-
as you navigate the Services, certain passive information may also be
collected about your visit,including through Cookies and similar
technologies as described below.
Primary goals in
collecting information are to provide and improve our Services, to
administer your useof the Services and to enable you to enjoy and
easily navigate our Services. We endeavor to collect onlythat
information that is relevant for the purposes of Processing. Below are
the ways we collect PersonalInformation and how we use it.
Games
United collects Personal Information regarding its current,
prospective, and former clients,customers, users, visitors, and
guests. We use information to operate the Services, including:
●
To administer your account and provide the Online Services to you
●
To inform you about offers and events
● To
communicate with you by email, phone, social media or mobile device
about products orservices that we think may interest you
●
To improve the Services and develop new ones
●
To prevent, detect and fight fraud or other illegal or unauthorized
activities
● To ensure legal compliance and take
action against fraudulent or misbehaving players
●
To verify and confirm payments
● To update and
develop player profiles
● To develop and improve
the Online Services and player experience
● To
provide social features as part of the service
●
To customize your service experience
● To
respond to your comments and questions and provide player support
●
To enable you to communicate with other players
To process
your information as described in this Privacy Policy, we rely on the
following legal bases:
●
Legitimate interests: We may use your information
where we have legitimate interests to do so.For example, we analyze
our Users’ behavior to improve the Services, to prevent and detect
fraudand misuse, and to marketing processes to you.
●
Consent: With your consent, we can track your user
data to provide personalized content and ads.You can opt-out targeted
advertising or receive personalized notifications by changing the
Privacysettings on your device. By opting out of targeted advertising,
your Advertiser ID cannot beshared. You have the right to withdraw
consent at any time, without affecting the lawfulness ofprocessing
based on consent before its withdrawal.
●
Performance of a Contract
● Compliance with a
Legal Obligation
You may contact us at [email protected] for more information
regarding legitimate interests.
C. THE COLLECTION METHODS OF DATA
We use different methods to collect data from and about you including
through:
●
Direct interactions. You may give us your personal
data by filling in forms or providing otherinformation via our e-mail
address or Google documents.
●
Automated technologies or interactions. As you use
our Online Services, we may automaticallycollect Technical Data about
your equipment, browsing actions and patterns. We collect thispersonal
information by using cookies and other similar technologies. We may
also receiveTechnical Data about you if you visit other websites
employing our cookies. Please refer to theCookies section in this
policy for further details.
●
Third parties or publicly available sources. We may
receive personal data about you from thirdparties as set out below:
●
Technical Data from the following parties: We may
receive personal data about you Analyticsproviders (Microsoft Azure
PlayFab);
● Ad Networks: Games
United may feature advertising within the Services. The advertisers
maycollect and use information about you.
●
Information Submitted Via Services
●
Social Media Widgets and Our social Media Pages
D.
TRANSFERS OF PERSONEL DATA
● Group members,
personnel, suppliers or subcontractors: We keep your informationconfidential, but may disclose it to any
member of our group (which means our subsidiaries, ourultimate holding
company and its subsidiaries), our personnel, suppliers or
subcontractors insofaras it is reasonably necessary for the purposes
set out in this Privacy Policy. However, this is onthe basis that they
do not make independent use of the information, and have agreed to
safeguardit.
●
Merger or acquisition: If we are involved in a
merger, acquisition, or sale of all or a portion ofits assets, any
third party to which we sell or transfer our assets to will have the
right to continueto use the personal and other information that you
provide us in the manner set out in thisPrivacy Policy.
● Required by law: In addition, we may disclose your
personal data to the extent that we arerequired to do so by law (which
may include to government bodies and law enforcement agencies);in
connection with any legal proceedings or prospective legal
proceedings; and in order toestablish, exercise or defend our legal
rights (including providing information to others for thepurposes of
fraud prevention).
●
Enforcement: We may also disclose your personal data
to third parties in order to enforce orapply the Terms of Use of Games
United, to investigate potential breaches, or to protect the
rights,property or safety of Games United, our customers, or
others.
●
Service providers:
We may also disclose your personal data with service providers that
operateon our behalf to help support the Online Services in accordance
with our instructions (for example,cloud storage providers, payment
processors, or analyzing and advertising partners).We storage your
personal data at Cloud (Microsoft Azure PlayFab, Game Analytics,
GoogleFirebase).
●
International Transfer: All Personal Information
collected via or by Games United may bestored anywhere in the world,
including, but not limited to, in Turkey, the United States,
theEuropean Union, in the cloud, on our servers and on the servers of
our affiliates or the servers ofour Service Providers. When we
transfer your Personal Information internationally, we will
takereasonable steps to ensure that it is treated securely, lawfully
and in the manner, we describe here.Please note that laws vary from
jurisdiction to jurisdiction, so the privacy laws applicable to the
places where your information is transferred to or stored, used or
processed in may be differentfrom the privacy laws applicable to the
place where you are resident.By providing information to Games United,
you consent to the storage of your PersonalInformation in these
locations.If you are using our Services from the European Union or
other regions with laws governing datacollection and use, please note
that you are agreeing to the transfer of your information to Turkeyand
the United States and to Processing of your data globally.By choosing
to visit the Site, utilize the Services or otherwise provide
information to us, you agreethat any dispute over privacy or the terms
contained in this Privacy Policy will be governed by thelaws of
Switzerland and the adjudication of any disputes arising in connection
with Games Unitedor the Site will be in accordance with the Terms
Services
We take steps to ensure adequate safeguards are in
place to protect your personal data during datatransfers.
E. CHILDREN'S INFORMATION
Games United does not address anyone under the legal age of the
country and the age determined by theAppStore, Google Store, Amazon
App Store or on Facebook, Microsoft and any related services. We donot
knowingly collect personally identifiable information from those under
that age limit. If we determinethat you have provided personal
information to us, we will delete it from our servers immediately. If
youare a parent or guardian and you are aware that your child has
provided us with personal information,please contact us
[email protected] So that we will be able to do necessary
actions.
F. RETAINTION PERIOD
We will retain your personal data for the period necessary to
fulfill the purposes outlined in this PrivacyPolicy unless a longer
retention period is required or permitted by law. The criteria used to
determine ourretention periods include:
● The length of time we have an ongoing relationship with you and
provide services to you (forexample, for as long as you have an
account with us or keep using the Websites);
● Whether there is a legal obligation to which we are subject (for
example, certain laws require usto keep records of your transactions
for a certain period of time before we can delete them)
● Whether retention is advisable; and considering our legal position
(such as, for statutes oflimitations, litigation or regulatory
investigations).
G. RIGHTS OF DATA SUBJECTS
We would like to make sure you are fully aware of all of your data
protection rights. Every user is entitledto the following:
● The right to access: You have the right to request
copies of your personal data. We may chargeyou a small fee for this
service.
●
The right to rectification: You have the right to
request that we correct any information youbelieve is inaccurate. You
also have the right to request that we complete the information
youbelieve is incomplete.
●
The right to erasure: You have the right to request
that we erase your personal data, under certainconditions.
● The right to restrict processing: You have the
right to request that we restrict the processing ofyour personal data,
under certain conditions.
●
The right to object to processing: You have the right
to object to our processing of your personaldata, under certain
conditions.
●
The right to data portability:
You have the right to request that we transfer the data that we
havecollected to another organization, or directly to you, under
certain conditions.
● The right to make a complaint to a Supervisory
Authority
❖ If you are a California resident, as defined in Section 17014 of
Title 18 of the California Code ofRegulations, you have certain rights
in respect of the personal information we hold about you. Under
theCalifornia Consumer Privacy Act (“CCPA”), among other rights,
consumers have the rights:
● To
know whether their personal information is sold or disclosed and to
whom
● To say no to the sale of
personal information
● To equal
service and price, even if they exercise their privacy rights
I. HOW TO EXERCISE THESE RIGHTS
Any requests to exercise data subjects’ rights can be directed to the
data controller through the contactdetails provided in this document.
These requests will be addressed by the data controller as early
aspossible and always within thirty (30) days.