Please carefully review this Privacy Policy to understand our policies and practices regarding your personal data (as defined below). This Privacy Policy outlines how DEMIR OYUN YAZILIMLARI REKLAMCILIGI ANONIM SIRKETI and its affiliated companies (referred to collectively as "we," "us," or "our") collect, utilize, secure, or otherwise handle the personal data of users ("you" or "your") when you engage with our Services. This Privacy Policy pertains to our games, applications, websites, and other services collectively referred to as the "Services," "Products," or "games," "apps," "websites" for specific categories.

Data collection

While utilizing our Services, we may gather specific details that can identify you ("personal data"). The type of personal data we collect will vary depending on the circumstances and the Services you're using. Generally, the data we collect includes

(a) Information you provide to us:

• Authorization and/or Account Details: When you register for an account, we may request certain details such as your email address or Facebook ID or Google ID, based on the Services' settings.
• Content Details: This includes photos, images, videos, audio files, documents, and other data that you upload using the Services.
• Personal Information: Information that you may input or provide yourself when the app is designed for tracking your information.
• Other information you choose to provide: We may also gather additional information you voluntarily submit to us while using our Services. For instance, we collect your information when you contact us through the embedded contact feature in our Services or when you directly email us.

(b) Automatically collected data:

• Device Information: When you download and utilize our Services, we automatically gather information about your device, such as device identifiers (device ID, advertising ID, MAC address, IMEI), device type, operating system, screen resolution, application version, language and time zone settings, and IP address.
• Cookies and similar technologies: Our advertising networks and their affiliates might utilize cookies and similar technologies, like mobile "SDKs," to offer our Services and targeted advertisements. Further details on cookie usage can be found in our Cookie Policy at: [link to Cookie policy].
• Location Data: We may collect location-related information, including general location data (country, region, city), your mobile device's region, and the region associated with your SIM card. With your consent, we may also collect precise geo-location data (GPS).
• Usage Information: Data about your utilization of the Services, such as the date and time you accessed a service, the features you've utilized and how you've used them, your in-app purchase history, subscriptions, the advertisements you've clicked on, and data generated during your use of our Services.
• Other Information: On occasion, we may collect other information, such as precise geolocation (latitude and longitude), with your permission. If you decline permission, we will not collect it.

(c) Data obtained from our partners:

• Social Network Information: You may opt to link our Services with your social media account, like Google or Facebook. In such cases, we may receive specific details from the social network. The information we receive depends on the Services you're using and the social network's policies, which you can find on the social network's website.
• Analytics Service Provider Information: We may receive information about you from our analytics service providers, based on the data they collect through our Services in line with their own privacy policies.
• Advertising Partner Information: Periodically, we may also receive personal information about you from other third-party sources. For instance, if you clicked on an advertisement leading to one of our Services, we may receive information about the ad network and advertising campaign that originated the installation.

Reasons for data collection

We utilize the information we gather about you to provide our Services, enhance and monitor them, deliver targeted advertising or personalized content, and ensure the safety and fairness of our Services.

(a) Providing Our Services to You:

We process data to furnish you with the requested Services. Our legal basis for this is the performance of a contract with you, which occurs when you download our Products and agree to our End User License Agreement ("EULA").

For this purpose we process your data, in particular, to:

• Enable your use of our Services;
• Operate the Services;
• Verify and process payments;
• Deliver the products and services you request;
• Send you communications related to our Services.

(b) Improving and Monitoring Our Services:

We process data to provide a great Services to you. Our legal basis is legitimate interests to run our business and make high-quality Products.

For this purpose we process your data, in particular, to:

• Enhance and optimize our Services;
• Personalize your Services experience;
• Address your comments and questions and provide user support;
• Offer you promotions within the Services;
• Gain insights into user behavior and trends;
• Identify potential outages and technical issues.

(c) Providing Interest-Based Advertising or Targeted Content:

We process data to serve personalized advertisements and content. Our legal basis for this is our legitimate interests in operating our business and offering you the best content and advertising. For details on how to opt out of personalized advertisements, refer to the section "Your rights and options" below.

For this purpose we process your data, in particular, to:

• Display ads tailored to your interests;
• Provide personalized content and information, including online ads or other marketing materials;
• Send you marketing notifications and gather feedback on your user experience;
• Track the content you access through the Services and your online activities;
• Enhance, target, and refine our advertising and Services.

(d) Ensuring Service Safety:

We process data for safety reasons. Our legal basis for this processing is our legitimate interests in safeguarding our business and Services.

For this purpose we process your data, in particular, to:

• Prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities;
• Safeguard our trademarks and other intellectual property rights;
• Enforce our EULA;
• Take action against fraudulent or disruptive users.

WHO CAN SEE YOUR DATA

Apart from ourselves, your data may be accessible to others in the following circumstances:

(a) Other Players and Users:

Social features are integral to certain Products. When you use certain games and apps, other players and users may have access to your profile data, in-game activities, and messages you've posted, among other things.

(b) Other Companies and Public Authorities:

To combat fraud and illegal activities, we may share data with other companies, organizations, and public authorities in response to lawful requests. Your data may also be disclosed based on your consent, to comply with the law, or to safeguard our rights, property, or the safety of ourselves, our users, or others.

(c) Our Service Providers and Partners:

We engage third parties to assist us in operating and enhancing our Services. These third parties aid us in various tasks, such as hosting and maintenance, ongoing development, analytics, customer support, marketing, and advertising. Additionally, we may share information with advertising partners responsible for distributing advertisements within our Services.

For more details about our partners, please refer to: [link to List of partners].

WHERE YOUR DATA CAN BE TRANSFERRED

Our Services have a global reach, meaning your data may be transferred to any location worldwide. Please be aware that we may transfer information, including personal data, to a country and jurisdiction that does not have the same data protection laws as those in your jurisdiction. We endeavor to ensure that any recipient of personal data provides adequate protection for the received data. The safeguards employed by our partners may include adherence to the regulations and protocols established by the EU-US Privacy Shield, or through contractual provisions recognized by the European Commission as providing satisfactory protection for personal data. For data storage purposes, we rely on the services of hosting organizations. We take your privacy seriously and therefore encrypt your personal data before transmitting it to these hosting organizations for storage. It's important to note that we only collaborate with hosting organizations that have successfully passed our security and reliability assessments. We take measures to establish sufficient safeguards to protect your data.

HOW LONG WE STORE YOUR DATA

We typically retain your data for as long as your account is active or as necessary to fulfill the Services. However, the specific duration may vary depending on the nature of the processing we undertake and our legal obligations. For instance, we may need to retain certain personal data even after you've closed your account if it's reasonably necessary to comply with legal requirements or if we have a legitimate interest in doing so. Once we no longer require your information and there's no legal or regulatory obligation to retain it, we will either delete it from our systems or anonymize it to prevent identification.

WHAT RIGHTS YOU HAVE

You possess certain rights concerning your personal data. If you wish to exercise these rights, please reach out to us using the contact information provided in the "HOW TO CONTACT US" section below.

(a) Opting out of targeted advertising

(b) You can choose to opt-out of interest-based advertising within mobile applications by adjusting the privacy settings on your Android or iOS device.

For Apple devices:

1.    Navigate to Settings

2.     Select Privacy

3.     Choose Advertising, then activate "Limit Ad Tracking"

For Android devices:

1.     Open Settings

2.     Select Google

3.     Select Ads and enable "Opt out of Ads Personalization"

(b) Opting out of marketing emails and other direct marketing

You can opt-out of receiving promotional communications from us, such as marketing emails, by following the instructions provided in those communications.

(c) Accessing the personal data we have on file for you

Upon request, we will furnish you with a copy of your personal data in an electronic format.

(d) Your additional rights

You also hold the right to rectify inaccuracies in your data, request the deletion of your data, object to how we utilize or disclose your data, and limit how we utilize or disclose your data. You can always revoke your consent, such as by disabling GPS location sharing in your mobile device settings.

We will address all requests within a reasonable timeframe. If you have unresolved concerns, you may also contact your local data protection authority.

Data protection

To ensure a secure and safe user experience, we continuously develop and implement technical and organizational security measures to safeguard your data from unauthorized access, loss, misuse, or alteration.

AGE LIMITS

Recognizing the importance of providing additional privacy protections for children, our Services are designed for individuals aged 16 and over. We do not knowingly collect personal information from children under 16 years of age. If you need to request the deletion of personal data for any reason, please utilize the in-app support feature within our Services or contact us at the address provided below, and we will promptly take reasonable measures to delete such personal data from our records.

PRIVACY POLICY CHANGING

We retain the right to modify our practices and this Privacy Policy at any time. Each time you access our Services, the current version of the Privacy Policy applies, and by doing so, you agree that your personal data will be processed in accordance with the updated Privacy Policy. We encourage you to regularly review this page to stay informed about our current practices.

CONTACT US

For inquiries or requests, you can contact us and our data protection officer using the in-app support feature within our Services, the "Contact Us" form on our websites, or via email.