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Digital Pals Teknoloji ve Danismanlik A.S. Mobile Games Privacy Policy

The purpose of this Privacy Policy to be valid between you and Digital Pals Teknoloji ve Danismanlik A.S. (hereinafter shall be referred to as “Digital Pals” or the “Data Controller”) to clarify and inform you on the collection, process and use and the grade, purpose and scope to the transfer of the data that you have provided to us for the purpose of your purchasing and/or using games/applications (hereinafter shall be referred to as the “Mobile Games”) created and/or made available to the services by Digital Pals.

Personal data refers to all kinds of information related to an identified or identifiable real person. All kinds of processes refer to all kinds of transactions performed on personal data such as obtaining these by fully or partially automated means or non-automated means provided that it is part of any data recording medium, recording, storing, retaining, modifying, re-arranging, disclosing, transmitting, retrieving, making available, classifying or prevention of use of the same.

When you download, use or play the Mobile Games and communicate with Digital Pals in any manner, you agree, declare and undertake that Digital Palls shall collect and process some of your personal data as per the nature of the transaction and limited to the purposes described in the Section 1 of this Privacy Policy.

1. The Purposes of Collecting and Processing Personal Data

When you download, play, comment on or rate the Mobile Games, request help/support, or interact with third-party advertisements served in the content of the Mobile Games, the information related to your device and that identifies your device is automatically collected by Digital Pals. The data that you provide with platforms such as Apple App Store and/or Google Play App Store and their business partners (hereinafter referred to as the “Platforms”) is also collected by Digital Pals.

The purpose of collecting such data within the scope of legal regulations is to develop and update the services of Digital Pals according to your preferences on the Mobile Games, to make suggestions in line with your preferences and to make improvements in order to facilitate the use of the Mobile Games.

  1. Data Collected During Playing/Using the Mobile Games
    In this context, Digital Pals collects; your advertising identity (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), device identifier, operating system, model, manufacturer information, hardware type, operating system version, memory usage, country, time zone and preferred language information, internet protocol (IP) number, location information based on your IP address, operator and browser information, information on the features of the mobile application with which a consumer interacts with the Mobile Games, Game interactions (the amount of time that you spend playing the Mobile Games , your in-game spending, your level information, the amount of time for viewed advertisements, the advertisements viewed) and the time of installation and first opening of the application.

    The above-mentioned advertising IDs (IDFA and GAID) are unique identifiers for mobile devices that advertisers use for personalized advertising and that are consistent across all mobile applications, and thus allowing cross-application tracking. You can disable this option by enabling the “limit advertisement tracking” option in the privacy settings of Apple devices. As for the Google Android devices, you can change your advertisement setting by enabling the “disable advertisement personalizing” option. Advertising IDs are non-permanent identifiers that are uniquely associated with your device. We would like to kindly remind you that you have the option to play the Mobile Games without viewing advertisements by using our advertisements free play feature, which is subject to a certain fee. Your username and score can be viewed by other users of Mobile Games that include a scoreboard feature.

    Payments for inapp purchase transactions are being carried out by the Platforms. These Platforms do not share any data such as your name-surname, e-mail address and payment method information with Digital Pals except for the payment information of products that you have purchased in order to fulfill your order.

  2. Personal Data Collected When You Contact with Digital Pals

    When you request information and/or technical support on the Mobile Games or contact us with regard to other requests, your contact information shall be processed to reach you in order to fulfill your requests.

    The data that you voluntarily provide while sharing your comments about the Mobile Games is processed for the purpose of serving you better and of solving the problems that you encounter.

  3. Data Collected by Third Parties

    If the personal data provided to Digital Pals is requested by official authorities and institutions or courts as required by the legislation, such data can be transmitted to the relevant authorities or to the courts if requested by the courts.

    Our business partners or service providers can use server log files, cookies, pixel tags, web beacons or other tracking tools in the Mobile Games. Our advertisement business partners and analytics service providers, who are listed and whose privacy policy links are given under Section 3 of this Privacy Policy, can collect data regarding your IP address, your advertisement identifier (IDFA for IOS devices and GAID for Android devices), your other device identifiers (IDFV for IOS devices), your cookie identifiers, advertisement identifier, your mobile device’s type, operating system, version, model, hardware type, other device identifiers that are automatically determined for your device when you connect to the internet, your web browser information, websites that you visit, your connections within the Mobile Games and your preferences regarding the websites visited by using the specified technologies.

  4. Children’s Personal Data

    Digital Pals does not knowingly or intentionally collect any personal data concerning the users under the age of 16.

2. Legal Grounds of Processing Your Personal Data

The legal grounds on which Digital Pals is based when processing your personal data are as follows:

  • In case of having your explicit consent and/or request,
  • In case where the disclosure of such information is required in accordance with applicable laws or regulations or an issued court order or administrative warrant,
  • In case where it is necessary for the conclusion and execution of an agreement,
  • In case where it is necessary for Digital Pals to fulfill its legal obligations as a data controller,
  • In case where it is necessary for the establishment, exercise and protection of any right,
  • In case where it is mandatory for the legitimate interests of Digital Pals, without prejudice to your fundamental rights and freedoms,

We kindly remind you that in cases where your personal data is processed by basing on your explicit consent, you have the right to withdraw your consent at any time.

Digital Pals undertakes to keep the personal data and information, which were provided by you or collected automated means, strictly private and confidential against third parties, other than the exceptions set forth under this document, and to take the necessary care and measures in order to prevent unauthorized use. Digital Pals shall not be liable for any damages arising out of the acquisition of information by third parties despite all measures, or the use of information provided by you in public areas.

Digital Pals shall not be responsible for any damages caused by you sharing the username and password you use when registering for Platforms or Mobile Games with third parties.

3. Transfer of Your Personal Data

Your personal data can be transferred to our foreign located business partners and service providers for the purpose of developing the Mobile Games and offering the same to you, providing personalized advertisements according to your interests, measuring the advertisement effectiveness of Digital Pals and third parties, and conducting the measurement and analyzes of your use of the Mobile Games. Furthermore, your personal data can be transmitted to an official authority or judicial authorities authorized to request such data.

The list of our service providers and business partners and their privacy policies are as follows:

Service Provider/Business Partner

Privacy Policy

Analytics Services

  • Adjust

https://www.adjust.com/terms/privacy-policy

  • Facebook

https://www.facebook.com/about/privacy

  • Google LLC (Firebase)

https://firebase.google.com/support/privacy

  • Game Analytics

https://gameanalytics.com/privacy

Reklam İş Ortakları (Reklam Ağları)

  • Facebook Inc. (FB Ads, FB Audience Network)

https://www.facebook.com/about/privacy

  • Google LLC (Google Ads)

https://policies.google.com/privacy

  • Unity Technologies (Unity Ads)

https://unity3d.com/legal/privacy-policy

  • Apple

https://www.apple.com/privacy/

  • Snapchat

https://www.snap.com/en-US/privacy/privacy-policy/

  • Tiktok

https://ads.tiktok.com/i18n/official/policy/privacy

4. Deletion of Your Personal Data

Digital Pals stores your personal data, the purposes and scope of which are set out above, as long as its necessary for the provision of Mobile Games and deletes it no later than two (2) years from the date of expiration when the purposes are terminated.

5. Your Rights Regarding the Protection of Your Personal Data

In accordance with the laws, your rights regarding your personal data are as follows:

  • to learn as to whether your personal data is processed,
  • to request information on processing activities, if processed,
  • to learn the purpose of personal data processing and as to whether such personal data is used in accordance with these purposes,
  • to know the third parties to whom your personal data is transferred at home or abroad,
  • to request the correction if your personal data has been processed incompletely or incorrectly,
  • to request the deletion or destruction of your personal data,
  • to request that your correction, deletion and destruction requests to be transmitted to the third parties to whom your personal data has been transferred,
  • to object to any consequence occurred against you by analyzing your processed data through automated systems,
  • to claim compensation in case you suffer any damage due to the unlawful processing of your personal data,
  • to request the restriction of data processing activities,
  • to request data portability,
  • to object to the occurrence of an adverse result by analyzing the processed data only through automated systems, and
  • to file a complaint with the relevant data protection authority and to claim compensation in case you suffer damage because your personal data has been processed in violation of the relevant legislation.

You may send all your requests and inquiries regarding these rights via the website of https://digitalpals.com/en/contact. Your requests shall be responded as soon as possible and within thirty days at the latest.