(Last Updated: May 2024)
Introduction
Who are we?
ÇELİK ÇOMAK GAMES OYUN YAZILIM VE TEKNOLOJİ ANONİM ŞİRKETİ (“Çelik Çomak” or “we“, “us“, “our”) is a technology company that designs and develops mobile games. With this Privacy Policy, we aim to explain how and why we gather, store, share and use your personal data in a manner consistent with the laws of the countries where we do business.
Where we decide the means or purpose of processing your personal data, we are the “controller.”
What’s this notice about?
This notice explains how we process personal data, as a controller, relating to:
- Visitors (“Website Users”) to our website: http://celikcomakgames.com (“Website”)
- Users (“Mobile App Users”) of our mobile games (“Apps”), which are accessible via certain online stores such as Google Play Store and Apple App Store.
Together the Website Users and Mobile App Users shall be the “Users” (and “you” and “your” shall refer to any User).
We update this notice from time to time, so Users should check back in on a regular basis.
Please note that other websites or services mentioned on the Website or our Apps are not operated by us, and you should refer to the privacy notices on those websites to understand how they process personal data.
Personal Data and How We Use It
- Our Purpose
We collect and use your personal data for the following purposes:
- To provide our Apps, ensure purchases are activated, and provide player support,
- To operate, improve, and optimize Apps,
- To manage day-to-day operations of the organization,
- To optimize Apps for users and devices, and deliver customized in-game events, offers, and promotions,
- To verify identity and entitlement to products or services,
- To help maintain safety, security, and integrity of property, services, technology assets, and business,
- To personalize services, understand users and preferences, enhance user experience and enjoyment, and improve user experience,
- To provide access to certain areas, functionalities, and features of services,
- To communicate regarding Apps-related information, including confirmations, technical notices, updates, security alerts, support, and administrative messages,
- To prevent potentially prohibited or illegal activities, including cheating or fraud, and to protect players,
- To ensure internal quality control,
- To comply with contractual and legal obligations and requirements,
- To provide support through customer service channels when requested,
- To conduct internal research and analytics
- As otherwise expressly set out in this Privacy Policy or as required or permitted by law.
- Categories of Personal Data
We collect and process following data categories:
- Advertising
We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we will have about you, such as:
- ad identifiers and other non-personal information collected from your device;
- the games you play and information about how you interact with our games and Services; your age, country or region, and gender; and
- Mobile App Users’ IDFA (identifier for advertisers) and/or AAID (advertising-related identifying data) and
- other information that we might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
Our Apps will include advertising for third party products and services.
We and our advertising partners collect and use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our Apps.
We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our Apps that might be of interest to you. This includes information such as:
- ad identifiers and other information collected from your device.
- the games you play and information about how you interact with our games and Services; your age, country and region, and gender; and
- other demographic and interests based information that we might acquire from our third party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us.
- Analytics
We process each Mobile App User’s device’s operating system, resolution settings, language settings, time zone settings and IP address; as well as the version of the App downloaded to each Mobile App User’s device.
- Gameplay
We process certain information such as users’ in-app purchase history, subscription data, player progress, IP-based location, Apple ID, Facebook ID and Facebook name.
- Cookies Analytics and Similar Technologies
We use ad identifiers, cookies and similar technologies. Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple’s ID for advertising (the ‘IDFA’), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.
- Legal Bases
We collect and process personal data about you only where we have legal bases for doing so under applicable laws. The legal bases which we rely upon are the following:
- Contractual Necessity. This covers data used by us in order to provide you with services that you have requested – and that we have agreed – to provide to you, such as our Apps, customer services, chat functionality and third-party social network connectivity;
- Legal Obligation. This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;
- Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our services, such as marketing, advertising, analytics, research and optimization of our Apps; and
- Consent. This is used as a legal basis in the following contexts: the collection of data stored on your device by our advertising partners and us, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and can withdraw your consent by uninstalling our Apps.
Storage, Transfers and Disclosure
- Security
We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession; and take steps to ensure only those at Çelik Çomak with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. The security of your personal data is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. If you have reason to believe that your personal information is no longer secure, please immediately contact us as set forth below in the “Contact Us” section.
- Transfers and Third Parties
Our Apps may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective Privacy Policies.
We may disclose your personal data:
- Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
- With suppliers and subcontractors, as necessary for the purposes set out in this notice.
- With other members of our corporate group and our international network of partners.
If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.
- International Transfer
Our operation is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
- Storage
We retain your data for as long as your account is active or as needed to provide you with the Services.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
International Users
- USA Residents
California Residents: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes.
- European Residents
European Residents: You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner’s Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).
Your Rights
Users have the following rights, although these rights may be limited in some circumstances:
- Access to personal data: You have the right to access your personal data that we use.
- Correction or deletion of personal data: You have the right to ask us to correct or complete your personal data if it is wrong or incomplete. You may also have the right to ask us to delete your personal data when certain conditions apply.
- Restriction on processing personal data: You may have the right to ask us to restrict the use of your personal data when certain conditions apply.
- Object to processing of personal data: You may have the right to object to the use of your personal data by us when certain conditions apply.
- Portability of personal data: You may have the right to receive your personal data in a structured and commonly used format so you can use this data with another company when certain conditions apply.
- Right to appeal. If we decline to take action on a request exercising one of your rights set forth above, you may have the right to appeal our decision.
- Right to Withdraw Consent. There are certain circumstances where we require your consent to process your personal data. In these instances, and if you have provided consent, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.
Contact Us
If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: publish@celikcomakgames.com
ÇELİK ÇOMAK GAMES OYUN YAZILIM VE TEKNOLOJİ ANONİM ŞİRKETİ, a company registered in Republic of Turkey whose registered office is at MERKEZ MAH. AYAZMA CAD. PAPIRUS PLAZA NO: 37/161 KAĞITHANE ISTANBUL 34406
All rights reserved.