1. INTAN GAMING – Privacy Policy

    1 – GENERAL INFORMATION

    1.1 – Introduction to Privacy Policy

    (Intan Gaming is a trademark of Intan Gay. Paz. Ve Dan. Hiz. Tic. Ltd. Şti. Throughout this Privacy Policy, Intan Gay. Paz. Ve Dan. Hiz. Tic. Ltd. Şti. will be referred to as Intan Gaming.)

    This policy describes how and why Intan Gaming (hereinafter referred to as <we>, <our>, or <us>) and any of its third-party partners collect, process, store, and share your data we and/or our third-party partners obtain from Intan Gaming games/applications (hereinafter referred to as <our services>, <services>, <games>, or <applications>).

    This policy is between you and Intan Gaming. When you use our services, you agree, declare and represent to be bound by, and subject to, all terms and conditions of this policy, including processing of personal data.

    (Processing of Personal Data means any operation or set of operations that is performed upon personal data, such as reorganization, alignment, storage, blocking access thereto, retention, obtaining, retrieval, alteration, disclosure, making accessible, recording, and transfer.)

    Please do not use Intan Gaming services if you do not understand or accept this Privacy Policy (for users who are children, this criterion applies to their parents or legal guardians).

    1.2 – Importance of Privacy Policy

    As Intan Gaming, we care about privacy of our users, and endeavor to do everything we can to protect their privacy. We respect the privacy rights of our users, and recognize the importance of protecting the personal data we collect about our users. We explain in detail what personal data we collect from you, for what purposes we use them, and how do we share/communicate and store such information, with all relevant details included.

    If you do not want your data to be collected, stored and protected, used and shared in the ways specified in this Privacy Policy, you may not be able to benefit from our services.

    This policy applies to all our services that are played/playable and used/usable on our websites (www.ai-turkey.com), mobile devices, and other platforms.

     

    1.3 – Amendments and Updates of Privacy Policy

    We reserve the right to amend this policy if and when we deem necessary. Each of our users should occasionally check the terms and conditions of this policy through the Privacy Policy section in our services and on our web site. In fact, any update to this policy will be deemed to have been seen, agreed, declared and represented by all our users, and to have entered into force on the date of issue of that update. For this reason, we recommend all our users to periodically keep track of the updates in the Privacy Policy before using our services.

    This Privacy Policy covering Intan Gaming services was last updated on May 5th of 2022.

    2 – DATA COLLECTION

    2.1 – How Do We Collect Your Data?

    • When you make a purchase in our games, applications, or services,
    • When you sign up for our newsletters to receive information from Intan Gaming,
    • When you need to create an account to use our services,
    • When you sign up for participating in any testing processes of our games or applications for support purposes,
    • When you chat with other users of our services in our games, applications, or other platforms,
    • When you play our games, use our applications, and employ our services associated with our games and applications,
    • When you contact our customer service via e-mail, or reach our technical support team, through our games, applications, or any other platform under our services,
    • When you participate in a contest, challenge, sweepstake, or campaign held by Intan Gaming and/or through our service partners,
    • When you watch advertisements in our games, applications or services,
    • When you create a user/users-generated content,
    • When you share something in, or otherwise contribute to our accounts on social media platforms.

    2.2 – What Data Do We Collect?

    Data we collect are adequate, relevant and limited to what is necessary for the following purposes for which they are collected.

    2.2.1 – Data you provide to us:

    • Your year of birth / Your age,
    • Your contact information (your name, e-mail address, etc.),
    • Your profile information (your profile avatar, etc.),
    • Your username and password,
    • Data provided to customer services (chat records, etc.),
    • Other information (such as information requested to ascertain the ownership of an account you have lost access to)

     

    2.2.2 – Automatically collected data:

     

    • Your IP address and device identifiers (Device ID, MAC address, IMEI, IDFA for iOS devices, Google Advertising ID (GAID) for android devices, etc.),
    • Intan Gaming game/username ID,
    • Data related to your activities in our games and applications,
    • Data we collect using cookies and similar technologies (if you do not have any knowledge about such technologies, or if you want to learn more about how to reject such technologies, you can refer to “Cookies Policy”),
    • Data about your device (such as your device name and operating system, browser information including browser type and preferred language),
    • General or precise geolocation information (GPS),
    • Information about your interaction with other users,
    • Error logs you encounter while using our services.

     2.2.3 – Data we obtain through our service partners:

     

    • Information we retrieve when you decide to connect through a third-party social network (Game Center, Facebook, etc.),
    • Information we collect through our billing partners when you make an in-game purchase or subscribe to one of our services,
    • Information for advertising and analytics purposes.

    3 – USE OF DATA

    3.1 – How and Why Do We Use Your Data?

    Subject to your approval and consent, Intan Gaming collects and uses your data for specific purposes in accordance with the regulations described in this policy. Although these data are primarily used to provide you with a better gaming experience, they may also be used to maintain activities of our organization, and to improve your player and user experience, specifically for the purposes described below.

    To improve your gaming experience, including:

    • To track your use of our services to help us learn more about your gaming activities and understand your preferences and tendencies, so that we can personalize your experience, provide you with offers and notifications that are tailored to you, and otherwise enhance your gaming experience,
    • To protect all our users from any kind of cheating, crime, or fraud related to our services, and to ensure the safety of all our users during their experience (limited to our services),
    • To provide you with services appropriate for your age in accordance with the laws of your country of residence,
    • To identify and correct service and technical errors that may occur in our services,
    • To provide you with the opportunity to participate in our game and application tests, upon your request to participate in the testing processes of our games or applications,
    • To register your participation in events held by us and/or our business partners, such as sweepstakes, campaigns, contests etc., and to contact and inform you if and when you win a prize in such events,
    • To be able to comply with all regulatory and legal requirements, and answer any requests from data protection authorities and/or law enforcement agencies,
    • To facilitate your contributions in social media as to our services,
    • To be able to carry out service management, optimization, research, analysis, and improvement studies,
    • To obtain statistical data which will allow us to take steps to improve user experience, including the actions and steps specified in the previous paragraph (3.1.i),
    • To provide you with a tailored user experience in our games and applications, and to allow you to smoothly employ features you have subscribed to.

     To personalize our communication with you, including:

    • To send push notifications to users (for US, who are at least 13 years old, and for Europe, who are at least 16 years old) (this feature is available only if you choose to allow this feature),
    • For our games and applications that include a chat, post, message, and/or another relevant communication feature, to facilitate communication between you and our other users (by collecting personal data of both sender user and receiver user) when you wish to send a message to another user or a specific user group via chat, post, message, or another relevant in-game/in-application communication feature, (Except for communications you make by means of features included in our services, your e-mails, SMS messages, or your messages conveyed through other platforms will never be subject to any kind of data or information collection by us.)
    • To be able to display personalized offers and content for our users,
    • To be able to make choices based on and appropriate for your gender, age and profile while serving ads to you,
    • To serve and measure the effectiveness of advertising,
    • To contact you for events (sweepstakes, contests, campaigns, promotions, etc.) held by us or through our service partners,
    • To send you campaign or marketing-related content, provided that you have given your consent for such communication beforehand (you can contact us to withdraw your consent on this matter),
    • To be able to handle your subscription to, and opting-out of, our newsletters.

     

    4 – DATA RETENTION

    As Intan Gaming, we securely store, retain, and use your data for as long as you use our services and for as long as necessary to fulfill the purposes we have detailed and explained in the Privacy Policy (in accordance with the applicable laws in your country of residence). However, in order to comply with requests of law enforcement and regulatory agencies, and to resolve actual or possible disputes, a longer retention period could be required. In such case, the collected data are retained and used until the respective request is closed.

    Please contact us immediately if and when you think you have detected such a violation so that such situations can be resolved as soon as possible following their occurrence. If you do not know how to contact us, please see “How to Contact Us?” section for detailed information.

    5 – SHARING OF DATA 

    Sharing with third-parties:

    We use third-party services, that have limited access to your data, for improving, performing and developing our operations, as well as for specific purposes, such as marketing assistance, management, analytics, optimization, prize delivery, advertising, data analysis, and customer services.

    Such third-parties are authorized to use your information for these purposes only. However, this matter is not subject to this policy, rather to the privacy policy of the respective third-party. In other words, the sole responsibility in this regard lies with you and the respective third-party. But, strictly speaking, the third-parties’ right to use your data and information is limited to the specified purposes.

    When using our services, you can select social networking features such as “Like” or “Share”, if available, on third-party social networking sites (for example, Facebook, Twitter, etc.). In this case, certain personal and non-personal data may be collected by, or shared with such social networking sites.

    If you want to learn about information collection methods used by third-parties, you should review their respective policies (we recommend that you familiarize yourself with the policies of such platforms before engaging with our games or applications through those platforms).

    (For detailed information, you can review the Third-party Services section.)

    Sharing with authorities:

    In order to ensure the safety of our users (during the user experience), we take legal action or launch an investigation against any abuse or unauthorized use of our services, or any other activity we determine to be illegal. We may also disclose your data if required by any law or court order, if the data relates to actual or threatened harmful conduct. In addition, we reserve the right to notify law enforcement agencies of such situations or activities if and when we detect them.

    Sharing with the relevant parties in case of sale of the company:

    In the event that our company or any of our business lines (including the respective assets) is sold to another party in whole or in part, your data may also be transferred to the buyer.

    Before such transfer process takes place, if you wish, you can contact us to request your data to be deleted, to be removed, and/or not to be processed. In such case, we will immediately take the necessary actions in line with your request. However, note that such actions may result in a restriction on your access to our services. You can contact us for more detailed information about your questions or issues.

    6 – DATA TRANSFER

    From time to time, we may transfer your personal data to our affiliates (Intan Gaming joint ventures, sub-units, parent and daughter companies, subsidiaries and other legal entities) in line with our legitimate goals and international operations.

    The headquarters of Intan Gaming is in Turkey. We take measures to ensure that your personal data are processed in a secure and lawful manner under the protection of adequate and appropriate safeguards in the jurisdictions where they are processed.

    7 – DATA SECURITY AND CONFIDENTIALITY

    We strictly implement all necessary security measures to prevent any unauthorized access to personal data collected through Intan Gaming services, to ensure proper use of personal data, to maintain data security, and to protect all personal data.

    We take necessary measures to avoid problems such as loss, destruction, alteration, unauthorized disclosure, and misuse of personal data, and we hold third-parties responsible for taking precautions against such situations. However, we would like to remind you that none of the transmissions made via the Internet or any wireless network can be guaranteed to be 100 percent secure. Therefore, although we do our best to take every possible action to protect your data, we simply cannot give a 100 percent guarantee of the security of your data. Thus, we do not assume any responsibility for any unauthorized access to, or use of, your data that is under our control.

    When we use third-parties to assist us in processing your personal data, we take reasonable steps to ensure that they comply with this Privacy Policy or otherwise protect your personal data (including credit card information). We are very sensitive to privacy concerns of our users, and we act accordingly when taking precautions to prevent damages that may arise due to acts of third-parties during the processing of your data.

    If there is a breach of security involving your personal data, including credit card information, we will inform you immediately in accordance with the applicable local regulations relating to the notification of data breach, and take reasonable steps required to rectify such breach.

    If you believe your personal data are being improperly used by Intan Gaming (including games, applications, and all services thereof), you can contact us immediately. If you do not know how to contact us, please check out “How to Contact Us?” section below.

    8 – CHILDREN

    We encourage parents and legal guardians of children using our applications and games (including all our services) to inform and teach their children about data privacy and how personal data of individuals may be exploited on the Internet. Children should never disclose or share their names, addresses, or phone numbers, or any other personal information, without permission of their parents or legal guardians.

    We treat all users under the age of 13 as children unless stricter regulations apply in their country of residence. In European Union countries, users under the age of 16 are considered children unless another age limit is specified in the applicable data protection legislation of their country of residence.

    If we detect that any of our games or applications is directed at users under the minimum legal age in their respective country of residence, we can block such users from using our games and applications or from conveying/providing information and/or we may limit the level of information we collect from such users as described below in more detail.

    You should not submit any of your personal data to us if you have not yet reached the minimum legal age required in your country of residence. Our users who lack knowledge about this subject should absolutely consult their parents or legal guardians.

    We apply the following limitations regarding the collection of personal data from such users (if you are under the specified minimum legal age, please have your parent or legal guardian review the following items).

    Such users cannot display or share their real names or any other relevant information in games/applications. They cannot subscribe to our newsletters, and any other features where users could appear under their real names. They cannot access the leaderboard, social networks (Facebook, Game Center, etc.) and chat.

    For such users, we prevent any collection and use of their precise geolocation information, and we display to them contextual advertising only (excluding any personalized advertising).

    Children can be invited to participate in playtests we held, with their parents’ or guardians’ permission and/or physical presence being required depending on conditions and requirements of the country where the respective playtest is organized.

    Parents or legal guardians must exercise their privacy rights for their children. Please refer to “Your rights” section of this Privacy Policy for your questions. If you still have questions after reviewing the said section, please contact us. If you do not accept or understand the requirements of this policy, please do not use our games or applications. In such case, the responsibility lies entirely with the relevant legal guardian and parent.

     

    9 – YOUR RIGHTS

     

    When you provide us with your data, you are deemed to accept, represent and undertake that all data and information you provide us are true, correct and belong to you. If you think otherwise, please contact us and update your personal data and information accordingly.

    You can exercise your rights at any time and ask us for access to, or rectification or erasure of, your data and information. If you reside in Europe, you may request restrictions on the processing of your personal data in accordance with the local regulations of your country of residence. If you consider that your personal data is being processed in violation of your relevant rights, you may invoke your right to object such processing, or you may exercise your rights related to this issue (Data Portability).

    Please note that your data and information may be controlled by other third-parties (our data and service partners). You can contact us to obtain more details about the sharing of your personal data with third-parties, or to notify us that you wish to opt-out of such sharing.

    If you have previously consented to any direct marketing communication from us or subscribed to our newsletters, you can unsubscribe by clicking on a link available in each communication and newsletter we send you.

    If you wish to review our policy about use of cookies and/or other tracking technologies, to decline use of such technologies, or to get more detailed information on this subject, please see “Cookies Policy” section.

    Please note that functionalities of our games and applications can be affected by actions of users. Collecting and processing some of your information are mandatory for us to provide our services. Certain user actions may force us to cease providing our services (to the relevant user who performed such actions). For example, regarding information we have specified as mandatory, if you make a change therein, ask for the deletion thereof, request limitations to processing thereof, object to such processing, or withdraw your consent to our policy, the game/application may be reset.

    In the event that a user withdraws their consent for any matter specified in this Privacy Policy or requests the deletion of their collected data, we may cease processing and using data of the relevant user. In any case, however, we will continue to retain the said data to answer possible future requests of law enforcement agencies. In addition, we retain an archive comprising such personal data for a commercially reasonable time as a precaution against any disruption of our data integrity and the deletion of such data and information. We further reserve the right to retain an anonymous version of this archive.

    If you are the parent or legal guardian of a child who is under 13 years of age (or under another age specified in the applicable regulations) and think or suspect that your child has provided us with information in contrary to the terms set forth in this Privacy Policy, please contact us to have the provided information deleted from our system.

    In some cases, you may have to submit a document proving your identity. For example, to preserve the confidentiality of your information, we may need to identify you correctly. In such cases, please provide us with a copy of your official identification document to prove your identity. This copy will be safely destroyed within two months after your request is resolved and closed.

    We will answer you within one month unless your request entails further investigation. If your request entails further investigation, we will contact and inform you as soon as possible.

    10 – THIRD-PARTY SERVICES

    Our services may occasionally link to external sites that are beyond our control. This Privacy Policy applies only to information we collect through our own services. When you use links to external sites, you are deemed to agree to the relevant privacy policies of those sites/services. Such external sites/services may have different data policies (with respect to data collection, use, transfer, etc.). As we have no control over the privacy and confidentiality practices of such third-parties, we are not and cannot be held responsible for any consequences of those practices. Therefore, we recommend you review the privacy policies of all third-party services you use.

    Below are the links to the respective policies of some of our third-party service partners. By clicking on the links, you can review, and get detailed information about, the said policies of those services.

    Google Play Services

    https://policies.google.com/privacy

    ironSource Ltd.

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

    Unity Technologies (Unity Ads)

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

    Google Firebase

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

    Google Admob

    https://support.google.com/admob/answer/10502938?visit_id=637864302345494155-3291851832&rd=1

     

    11 – LEGAL DISCLAIMER

    Our services are functionally accessible. However, we do not represent or warrant that our services will be available at all times, or that use of our services will be uninterrupted at all times. We are not responsible for your ability to access our services, or matters beyond our control.

    Further, this Privacy Policy is subject to the laws of countries where our users reside in. Any dispute regarding our services shall be submitted to the competent courts of the country of residence of the relevant user.

    12 – ADDITIONAL INFORMATION

    For more information on mobile privacy settings, we encourage you to refer to resources such as the Network Advertising Initiative’s guide on mobile device opt-outs (LINK). However, please consider that we do not maintain those resources and cannot guarantee their accuracy.

    Advertising Identifiers are used for interest-based advertising and other advertising-related purposes as a means of establishing a pseudonymous identity which remains constant from one application or property to another. You can control the extent to which your Advertising Identifier is used in this manner. By using the privacy settings on your device, you can typically reset and/or limit the use of your Advertising Identifier. For example, you can choose to not “allow apps to request to track” on iOS devices or to “opt out of interest-based ads” on Android devices. These settings are specific to each device, which means that you should set them to your desired state on each of your devices individually. Our games may offer additional options to opt in to or out of advertising-related uses of your data. Where applicable, these options can be accessed from the game settings, and you may be prompted to select your preferences. It may take some time for your selection or any updated settings to take effect. Please note that resetting or limiting the use of your Advertising Identifier will not stop you from seeing ads, but the advertisement materials you see may be less relevant to you.

    13 – HOW TO CONTACT US?

    If you have any question, concern, reservation, or comment about our Privacy Policy, games and applications, please contact us. You can contact us through contact@ai-turkey.com e-mail address, or by using the contact form on our website (www.ai-turkey.com).