GAMES UNİTED YAZILIM EĞİTİM SANAYİ TİCARET A.Ş

PRIVACY POLICY

   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.