Privacy Policy

Last Update: 8 April 2022

This Privacy Policy explains the procedures we GAME THEORY BİLİŞİM YAZILIM VE PAZARLAMA ANONİM ŞİRKETİ follow for the protection of personal data, which includes your rights as well as our obligations regarding the collection, use and transfer of various information, including your personal data. We GAME THEORY BİLİŞİM YAZILIM VE PAZARLAMA ANONİM ŞİRKETİ., a company under laws of Turkey, (“Game Theory” or “we”), a developer and publisher of games and mobile game applications that are made available via app stores including the Apple App Store and Google Play Store. This Privacy Policy applies to personal information that we collect through our games, mobile applications and other products (“Games”) (together “Services”). By using our Services, you agree to be bound by this Privacy Policy and consent to our processing of information as specified therein.

This Privacy Policy has been prepared in accordance with the provisions of applicable privacy and data protection laws, including the Law on Personal Data Protection No.6698 of Turkey ("KVK") and the General Data Protection Regulation ("GDPR"). For additional provisions specific to United States laws that may apply, see the section below entitled “United States – State Notices”.

The data controller of your personal data is GAME THEORY. Your personal data, which you provided/will provide to GAME THEORY and/or obtained by GAME THEORY through any external means, will be processed as "Data Controller",

In the context of the objective of processing your personal data and in connection with this purpose, in a limited and measured manner,

By maintaining the accuracy the most up-to-date version of the personal data as reported or notified to GAME THEORY may be recorded, stored, preserved, reorganized, and be transferred to the institutions authorized to request such personal data by law and shall be transferred, shared with and classified to third parties within the country or abroad under the conditions stipulated by KVKK and/or GDPR, that they may be processed in other ways listed under KVKK and/or GDPR and that they are subject to other procedures referred to in KVKK and/or GDPR.

Collection of the Personal Data

GAME THEORY collects your personal data automatically whenever you download our Games to your device or play the Games, whenever you send us your feedbacks or convey your information or support requests directly to GAME THEORY or interact with third party advertisements presented in our Games or interact with GAME THEORY advertisements presented in other platforms. In general, the information we collect about you relates to your device and helps us to identify your device. GAME THEORY also collects data from the Apple App Store and Google Play App Store (Referred to as “Platforms” together) platforms and the business partners. GAME THEORY might collect the your personal information (user name, name if provided, IP address, the date and time of access, the pages accessed while being on Game) and the activities taken place under GAME THEORY in order to provide better service to you, to make suggestions, to improve its services, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

We obtain, store and transfer some of your personal data from you in order to provide our services.

  • Information provided by you:

Name and surname, contact information (e-mail address, phone number), payment method (s) provided by you according to which package you will use.

You may share data that contains your personal data when you share your comments and views about our Games. The content of user comments is composed fully of data that you voluntarily provided. We process your shared personal data to solve the issues you encountered and to fulfil your request.

  • Information we collect automatically:

We collect information about the computer, network, network devices or other GAME THEORY compatible devices you may use to access our service (game consoles, smart televisions, mobile devices, set-top boxes and other broadcast devices).

  • Data that is collected by third parties:

If the personal data provided to GAME THEORY by you is requested by official institutions/organizations as necessitated by the law, the data may be transmitted to the relevant authorities and courts if requested by the courts.

Our business partners or service providers can use server log files, cookies, pixel labels, web beacons or other tracking tools in our Games. Our advertisement business partners and analytics service providers mentioned in the part 3 below, can collect data regarding your IP address your advertising identifier (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), cookie identifiers, advertisement ID, 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, web browser information, websites you visited, connections you have within the Games and your preferences about the visited websites by using the stated technologies. You may access to the privacy policies of these third parties from their official websites.

GAME THEORY stores your data for as long as it is necessary to provide our Games and deletes it when the purposes of the data processing cease to exist. Personal data is deleted in case the reasons which necessitate processing within the context of the stated purposes in this privacy notice cease to exist and after 2 years as of the registration date of the relevant record at the latest.

  • Information from partners:

The personal data which we shared with our third-party partners. These Partners might include (depending on what services you use): your TV or internet service provider, or other streaming media device providers who make our service available on their device; mobile phone carriers or other companies that provide services to you and collect payment for the GAME THEORY service for distribution to us or provide pre-paid promotions for the GAME THEORY service.

 

When you download and/or play the Games via Platforms, GAME THEORY collect certain personal data from you and/or your device. In this regard, GAME THEORY collect your advertising ID (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), device identifier, operating system, model, producer information, hardware type, operating system version, memory usage, country, time zone and preferred language information, internet protocol (IP) number, location information according to your IP address, operator and browser information, information about properties of mobile application through which a consumer interacts with the Games, data regarding your in-game interactions (the time you spent while playing our games, your in-game expenses, level information, the amount of time for watching advertisements, the advertisements watched) and time of installation and first opening of the application.


The aforementioned advertising IDs (IDFA and GAID) are unique identifiers for mobile devices that advertisers use for personalized advertising and consistent across all mobile applications and thus allow cross-app tracking. You may disable this option by activating “limit advertisement tracking” from the privacy settings of Apple devices. As for the Google Android devices, you may change your advertisement setting by activating the “disable advertisement personalizing” option. Advertising IDs, are non-permanent identifiers, which are uniquely associated with your device.

 

We would like to remind that you have an option to play the Games without watching advertisements by using our no-ads feature, which is subject to a fee. Your user name and score can be viewed by other users in our games that include a scoreboard feature. Payments for in-app purchases are being carried out by the Platforms. GAME THEORY, does not collect personal data such as your name, surname, credit card number and e-mail address that you share with the Platforms for the payment, and only payment information for the items your purchase is being shared with us in order to fulfil your order.

Children data

GAME THEORY never knowingly or willingly collect any personal data concerning children under 16 years of age.

Use of the Personal Data

Your personal data will be processed with the automatic or non-automatic means for the aims stated below stern with the applicable legislation, in cases where your express consent is obtained, in the case when it is expressly permitted by any law, the establishment of the contract or the directly related with the execution or performance of the contract, in case it is necessary for GAME THEORY to fulfil its legal obligations, in case it is necessary for the institution, usage, or protection of a right and when it is necessary for the legitimate interests of GAME THEORY, provided that the fundamental rights and freedoms of the data subject are not harmed.

The purposes of processing personal data may be updated in line with our obligations arising from company policies and legislation; in particular,

  • Carrying out the information security, financial and accounting processes,

  • Preventing, detecting and investigating potentially prohibited or illegal activities, including fraud, and enforcing our terms,

  • Conducting e-invoice transactions,

  • Ensuring adequate support within the scope of customer service lines to be provided by GAME THEORY,

  • Presenting, analyzing, managing, developing and personalizing service and promotional initiatives,

  • Identifying the people who will use the service,

  • Developing services and customizing/personalizing of content,

  • Conducting marketing analysis studies and advertising/campaign/promotion processes (these processes can be carried out by various methods such as e-mail, push notifications, text message, online messaging channels and matching descriptive communications),

  • Providing after-sales support services,

  • Conducting contract processes,

  • Following-up the requests and complaints,

  • Has been processed for managing member referrals, processing your membership registration, orders and payments.

Transfer of the Personal Data

The procedures and principles to be applied transferring personal data is regulated by the legislation in force, and the personal data and special categories of data of the related person can be transferred to third parties in the country and/or abroad. Your personal data is transferred abroad since the servers and data center is located abroad.

 

We transfer your personal data to third parties for the following purposes:

 

With the Revenue Administration to carry out the legal processes, business partners to carry out the financial and accounting processes, with third parties/companies to provide marketing, advertising, communication, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide bank account or balance information, to process credit card transactions or other payment methods, to provide customer service.

 

Your personal data may be transferred to our business partners and service providers located abroad for the purposes of improving our Games and providing our Games to you, providing personalized advertisements according to your interests, measuring GAME THEORY’s and third parties’ advertisement effectiveness and carrying out measurements and analysis regarding your use of our games. In case a public institution is authorized to request personal data by the law, your personal data can be transferred to such authorized public institution in accordance with the applicable personal data protection legislations. Requests from judicial authorities will also be fulfilled in accordance with the applicable legislation.

Your personal data may be transferred to our business partners and service providers stated below:

 

Analytics services. Your personal data may be transferred to our service providers and business partners for the purpose of conducting analytical reviews, analyses, reporting and research activities regarding the use of our Games.

Cloud computing services. Your personal data is stored in the servers of the Amazon Web Services.

Advertisement business partners. Your personal data may be transferred to our advertisement partners who enable the Games to be provided free or for low cost.

You may find the list of our service providers and business partners and their privacy policies below:

ironSource Mobile Ltd. - https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Adcolony - https://www.adcolony.com/privacy-policy/

Applovin - https://www.applovin.com/privacy/

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

Google - https://policies.google.com/privacy

Vungle - https://vungle.com/privacy/

Tapjoy - https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy

Inmobi - https://www.inmobi.com/privacy-policy/

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

Google - https://policies.google.com/privacy

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

Facebook Analytics (Facebook, Inc.) - https://www.facebook.com/about/privacy/

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

Photon Engine - https://dashboard.photonengine.com/en-US/account/privacyandcookiepolicy

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

Game Center - https://www.apple.com/legal/internet-services/itunes/gamecenter/

Your Rights

  • You can make the following requests regarding your personal data within the scope of applicable law;

 

Learn whether or not her/his personal data have been processed, request information as to processing if her/his data have been processed; learn the purpose of processing of the personal data and whether data are used in accordance with their purpose; know the third parties in the country or abroad to whom personal data have been transferred; request rectification in case personal data are processed incompletely or inaccurately and request notification under these rectifications to third parties whom personal data have been transferred; request deletion, destruction or anonymization of personal data within the framework when the objective purpose of processing data cease to exist and request notification under these rectifications to third parties whom personal data have been transferred; object to the occurrence of a result against the data owner by analyzing the processed personal data exclusively through automated systems, request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.

 

In data processing activities where your personal data is processed based on the explicit consent, you have the right to withdraw your consent at any time.


GAME THEORY’s statutory interest in processing your device and usage data is provide better service to you, to make suggestions, to improve its services, to improve and update our Games, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

GAME THEORY undertakes to keep the your data and any confidential information strictly private and confidential, without prejudice to the contents hereof, to regard it as an obligation to keep confidentiality, to take all measures and act in due diligence to prevent all or any part of your information from entering into the public domain or be subject to unauthorized use, or to take measures to prevent the confidential information from disclosure to any third party. If, despite all necessary data security measures taken by GAME THEORY, the confidential information is damaged as a result of attacks on the system or captured by third parties, GAME THEORY shall have no responsibility with that respect.

GAME THEORY shall not be responsible for damages caused by the use of information that you disclose in comments made or messages given by third parties in public areas. If you share your name, password, etc. used by you when creating the membership record with third parties, the GAME THEORY shall not be responsible for any damages that may arise from the information shared with third parties.

  • Your applications and requests regarding your personal data,

You can submit all your claims and questions with respect to such rights to info@gametheory.games

GAME THEORY will finalize your application requests free of charge within 30 (thirty) days at the latest according to the nature of the request. In case the request is rejected, the reason or reasons for the rejection will be notified written or electronically with its justification.

This Privacy Policy may be revised by GAME THEORY when deemed necessary. In case of revision, amendments will be notified to your behalf. The most up-to-date version of this Privacy Policy can be found at https://gametheory.games