Player Privacy
Policy of SKEB STUDİOS BİLİŞİM BİLGİSAYAR HİZMETLERİ ANONİM
ŞİRKETİ / WITH ITS REGISTERED SEAT IN ISTANBUL
Last
update: 11th of February
2025
Dear
User,
1.
Below you will find
information about your personal data
and how it is processed, stored and protected,
in connection with our games and
services. Please be advised that:
·
in order for you to
use our games
and other services (“Services”), we need to process
some of your personal data. For
the processing of your data for other
purposes, we will always ask
for your explicit consent in advance, which you can withdraw at any time.
·
our Trusted Partners, help us develop our Services. Therefore, we can provide limited data to
them.
2.
Below you will also
find the scope of rights that you are
entitled to.
Our Privacy
Policy has been prepared so that
it is clear and understandable to you. In order
for you to
use our games
or other services, you will
need to accept
our Privacy Policy in advance. If you have
any questions or need any
assistance, please contact us at the address skebstudio@gmail.com
FULL
CONTENT
I. ABOUT US
SKEB Studios
Bilişim Bilgisayar Hizmetleri Anonim Şirketi with its registered address at: Kazım Özalp Sokak, Nazar Apt. No:46 B Blok D:0
Şaşkınbakkal/Kadıköy/İstanbul, is joint controllers of personal data under the
Turkey law (hereinafter referred to as „SKEB STUDIOS”). To contact
us, you can write to us an email skebstudio@gmail.com or
via traditional mail: Kazım Özalp Sokak, Nazar Apt. No:46 B Blok D:0
Şaşkınbakkal/Kadıköy/İstanbul.
II. SCOPE OF THE PRIVACY POLICY
Privacy Policy governs the handling of your personal data
and any other
data that does not constitute them, and which we
obtain from you in connection with your use
of the Services. Personal data means any
information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification
number, location data, an
online identifier or to one or
more factors specific to the
physical, physiological, genetic, mental, economic, cultural or social identity
of that natural person.
We put your right of privacy
first and that’s why your
personal data is processed by us in accordance with applicable regulations.
III. CHILDREN’S PERSONAL DATA
We are aware of the
obligation imposed on us to especially protect
personal data obtained from children.
Therefore, we shall not collect data from children
under 16 years of age without a legal guardian’s prior consent. Each legal guardian may contact
us at skebstudio@gmail.com
IV. COLLECTED DATA AND METHODS
OF ACQUIRING PERSONAL DATA
when you use our
Services, we may process some of the following information
about you:
a.
Information provided by you when
using the Games (collected automatically)
o your mobile device’s unique device ID (Device ID) and device name;
o your user preferences;
o data
and analytics about your use
of our Services, such as: your overall progression
to a particular level, your virtual
currency or the completion of certain tasks during
your gameplay, making a purchase or viewing a video ad.
b.
Information that you provide voluntarily
and data you
provide to us when contacting us or reporting a problem with our Services:
o your avatar/profile picture;
o your username/nick;
o your email address;
o your name; other details, necessary to process your
inquiries.
c.
Information collected and used for
the purposes of serving advertisements:
o the make, model and operating system
of your device;
o properties of your device, such as screen size and orientation, audio volume and battery;
o the mobile network operator linked to your
device;
o the games played;
o the country, time zone and locale
settings on your device (i.e. country
and preferred language);
o network
connection type and speed;
o IP
Address;
o internet
browser used to access the games;
o the advertiser ID, which is an identifier unique to you
if you use
an Apple or Android device.
d.
Information collected for the purposes
of providing analytics:
o your device ID;
o your user ID (which
is generated by us and allocated to
you when you first play
our games);
o your device operating
system & version;
o your device make
and model;
o game play attempts,
progression and results;
o session game time start, end and duration;
o purchase transaction types and spend
you have made using virtual
items in the games;
o the country of your device;
o the time, date and install source
of your first download (e.g. from a clicked advertisement);
o advertisements viewed and clicked;
o identification of crashes and defects.
e.
Information about you collected from
our Trusted Partners:
When you access our
Services via a third party social media
provider such as Facebook, we may collect
and store personal and non-personal
information which is available on that third party social
media provider, such as your Facebook name, your profile picture or its URL, your
Facebook ID and other public data of your
friends, provided that you have
expressly agreed to the use
of Facebook within our
Services. We will also receive technical
data in order to ensure our
Services connect to the correct Facebook account.
In the event that
SKEB STUDIOS will organize events
or competitions for Users, we
can also process your correspondence address, phone number, social media ID, your photo and bank account number.
In
order to fully use our
Services, it is necessary to
process the data listed above.
If you do not agree to provide
us with the above information, you will only
be able to use our games
and other Services to a limited extent.
If you make payments
under the Services, we will not collect
or store any information about your payments.
These issues are regulated under
the operation of a given payment operator.
SKEB STUDIOS obtains only the information on making the relevant
payment from the operator. We
only collect information about transaction dates, currencies, values and products covered
by the transaction,
to guarantee you obtain the
purchased products.
V. THE CAUSE OF PROCESSING YOUR
PERSONAL DATA (LEGAL BASIS FOR PROCESSING)
The primary purpose of processing your data is to provide
you with our Services, which you use, that
is, to perform the agreement between
us and your consent to use
our Services. The other grounds for
processing are the requirements to fulfill the
legal obligations imposed
on us, fulfillment of the so-called “Legitimate interest” of . SKEB STUDIOS or for the
reasons indicated in other parts of the Privacy Policy
(„COLLECTED DATA”; „ DATA PROCESSING PURPOSES”).
As “Legitimate
interest”, . SKEB STUDIOS treats the legitimate
and rational purpose of data processing, in particular, protection of the security of processed data, marketing of . SKEB
STUDIOS’s Services, but most
importantly, to ensure that marketing activities addressed to you are
appropriate, and to conduct analyzes
that will help us to combat
any illicit practices.
If we invoke a Legitimate
interest purpose, we first analyze
and consider each potential impact of the processing
on you and your rights. In
other cases, data processing will always be preceded by your
consent, which you can withdraw at any time. Withdrawal of consent does not affect the validity
of the data processing prior to its withdrawal.
In situations where the transfer of your data outside the
European Economic Area occurs, we
will execute it in accordance with the rules, which
we described below (“Trusted Partners”).
VI. PROTECTIVE MEASURES USED BY
SKEB STUDIOS
Methods
of data storage. The data collected
by us will be stored on a secure servers in the United States and Canada,
which provide an adequate level of protection, in particular confirmed by ISO and EU-US Privacy Shield certificates or – only if
it is necessary – on the servers of our Trusted Partners indicated below. We have implemented
and will continue to implement
appropriate technical and organizational solutions to protect
your personal data against unauthorized
or unlawful processing, loss, destruction or damage. Our priority is to ensure that
your data will be processed as securely as possible and in accordance with our Privacy
Policy.
The
period of data storage Your data will be available to us as long as it is necessary to meet
the objectives set out in our Privacy
Policy, in particular, for the time of providing you with
the Services or providing you with
technical assistance. In the case
of processing based on your consent, in the event of its
withdrawal we will delete the
data without undue delay, no
longer than 30 days from the
receipt of your request.
In exceptional cases, longer storage periods may result
from applicable law, e.g. tax
regulations or other legal requirements imposed on us, and obligations.
At the
time when we no longer need
your personal data to provide
you with the Services, we will remove them
or they will be made anonymous.
VII. DATA PROCESSING PURPOSES
Your data may be used
by us for the following purposes:
o fulfillment of our contractual obligations, as part of the agreement
you have concluded with us
o marketing,
in particular to provide personalized and targeted marketing mails about the
Services which you already use or
which we think may interest
you. This purpose is optional and we will
first get your consent in the required cases;
o delivery of the Services ordered by you;
o communication with you as a User of our Services;
o enable participation in interactive elements of the Services, if that is your will;
o inform you about
changes in our Services;
o improvements to our Services;
o organizing competitions by SKEB STUDIOS, in particular for contact, mailing
and tax purposes;
o determining the conversion rate and other components of our services;
o tax, legal and settlement;
o billing, resulting from EU regulations regarding the protection
of personal data;
o targeting and personalization
of marketing communication, offers
and advertisements addressed to you.
In the case of personalization
or targeting described above, we can profile your personal data. By
doing so, we mean using
the information we have collected
to tailor the communication addressed to you
and to your
needs. However, we will not use
profiling, which results in making automated decisions, which would affect
your legal situation in any way, in particular,
we do not submit automated offers by analyzing your
behavior as part of the Services.
If you decide that
you do not want to receive personalized
offers, product recommendations or any advertising information, you can object at any time.
We may process certain
aggregated data that is not personal data that relates to
the behavior of users, in particular, sales data in individual regions and forward
them to our
Trusted Partners to provide and
improve our Services.
VIII. THIRD PARTIES AND
EXTERNAL SERVICES
The
Services may include links from or
to websites or services of third parties. Familiarize yourself with the privacy
policies of the above-mentioned third parties.
Some of the Services may be characterized by interaction with our Trusted Partners.
Therefore, we may share some
of your personal information with our Trusted Partner, which will be protected
based on their privacy policies. Due to the
optionality of such access, it will be preceded by your
explicit consent, which you can always
withdraw.
IX. TRUSTED PARTNERS
As part
of creating and providing the Services, we use the
help of our Trusted Partners, to whom we
can share your data. We guarantee
that we provide
them with the minimum information necessary to enforce
their cooperation. They may access your
data and process
it on our behalf as “Data Processors”, for the purposes and
by the entities
listed below:
a.
Trusted Partners who provide
us with tools for internal management
and data sharing;
o Usercentrics Consent Management
Platform-privacy policy: https://usercentrics.com/privacy-policy/
o Google Sign-in-privacy policy: https://support.google.com/accounts/answer/12921417?hl=en#:~:text=Sign%20in%20with%20Google%20doesn,to%20visit%20that%20third%20party.
b.
Trusted Partners who help
us in analyzing data by providing analytical
tools;
o AppsFlyer -
privacy policy: https://www.appsflyer.com/privacy-policy/
o AdMob - privacy policy: https://policies.google.com/privacy
c. our legal, tax, audit and billing team;
d.
social platforms for personalizing
and targeting marketing.
o Facebook
Audience Network - privacy policy: https://www.facebook.com/policy.php
o Facebook
SDK-privacy policy: https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
o Pangle - privacy policy: https://www.pangleglobal.com/privacy/enduser-en
o Snapchat - privacy policy: https://www.snap.com/en-US/privacy/privacy-policy
e.
Trusted Partners helping us to manage advertising
and services of Third Parties that may
be of the most interest to you
o Applovin -
privacy policy: https://www.applovin.com/privacy/
o Appodeal-privacy policy: https://appodeal.com/privacy-policy/
o Adcolony -
privacy policy: https://www.adcolony.com/privacy-policy/
o AdsYield-privacy policy: https://adsyield.com/privacy-policy/
o BidMachine-privacy policy: https://bidmachine.io/privacy-policy/
o BigoAds-privacy policy: https://www.adsbigo.com/privacy.html
o CSJ-privacy policy: https://www.csjplatform.com/en/privacy
o Digital Turbine-privacy policy: https://www.digitalturbine.com/privacy-policy/
o Devtodev-privacy policy: https://www.devtodev.com/policy
o Fyber - privacy policy: https://www.fyber.com/services-privacy-statement/
o Google
(Firebase)-privacy policy: https://firebase.google.com/support/privacy
o HyperMX-privacy policy: https://www.hyprmx.com/privacy-policy#:~:text=We%20do%20not%20sell%20personal,third%20parties%20for%20advertising%20purposes
o Inmobi - privacy policy: https://www.inmobi.com/privacy-policy/
o ironSource -
privacy policy: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
o Liftoff-privacy policy: https://liftoff.io/privacy-policy/
o myTarget SDK: https://target.my.com/help/partners/mob/androidsdkstart/en
o Mintegral -
privacy policy: https://www.mintegral.com/en/privacy/
o MoPub – privacy policy: https://www.mopub.com/en/legal/privacy
o Moloco - privacy policy: https://www.moloco.com/en/privacy-policy
o Ogury-privacy policy: https://ogury.com/privacy-policy/
o Odeeo-privacy policy: https://odeeo.io/privacy-policy
o Smaato-privacy policy: https://www.smaato.com/privacy/
o Snapchat-privacy policy: https://values.snap.com/pl-PL/privacy/privacy-policy
o Supersonic-privacy policy: https://supersonic.com/privacy-policy/
o Tapjoy - privacy policy: https://www.tapjoy.com/legal/advertisers/#privacy-policy
o TikTok-privacy policy: https://www.tiktok.com/legal/privacy-policy?lang=en
o Vungle - privacy policy: https://vungle.com/privacy/
o Unity Ads - privacy policy:
https://unity3d.com/legal/privacy-policy
o Chartboost -
privacy policy: https://answers.chartboost.com/en-us/articles/200780269
o Gadsme-privacy policy: https://www.gadsme.com/privacy-policy
o Zebedee-privacy policy: https://zebedee.io/privacy
In cases provided by law, we
may be required to disclose your
data to the
public authority, in particular to the
police or the prosecutor’s office.
Your personal data may
also be subject to processing, storage or transfer outside your country
of residence and outside of the European Economic Area (EEA). Due to the fact
that regulations concerning the protection of personal data in these countries
may not guarantee the same level
of protection as in your country or in the
EEA, each time we will base our
actions on standard EU clauses, allowing you to transfer your data and provide
the right level of protection.
X. PUSH NOTIFICATIONS
If you use our
Services via mobile devices,
after obtaining your prior consent,
we can send you push notifications
or local notifications to inform you about
updates.
XI. OTHER MATTERS
We would like to
inform you that SKEB STUDIOS is a regulated entity to which
an obligation can be imposed
to disclose your personal data,
on the basis of a request by the
authorized state authorities or in connection with other legal entities.
In the case of transformation
or merger of SKEB STUDIOS with another entity,
we will be able to transfer personal data to
the third party involved in the process, which
will protect personal data at least to the extent
as under this Privacy Policy.
XII. RIGHTS OF INDIVIDUALS
UNDER THE GENERAL DATA PROTECTION REGULATION
Remember
that you have the right
to object to the processing
of your personal data at any time. To use this
right, you can contact us in particular by sending a message
to skebstudio@gmail.com
In addition, you have
the right to:
·
access to your stored
personal data;
·
request removal of your personal data from
our database;
·
requesting rectification / correction of your data in justified
cases;
·
requests to limit the processing
of your data
·
transfer your data to another
entity;
·
file a complaint with the appropriate
data protection authority.
To use the above
rights, you can especially send a message to the
address: Kazım Özalp Sokak, Nazar Apt. No:46 B Blok
D:0 Şaşkınbakkal/Kadıköy/İstanbul
If you have any
questions or doubts about how we process and
protect your personal data or
want to exercise
your rights, do not hesitate to contact
us and we will do our best
to resolve any problems and
provide you with help. You
can direct messages to skebstudio@gmail.com.
If you are in a position
that we have
not responded in a manner appropriate to any notification regarding your personal data, this
circumstance can be reported
to your local
data protection authority.
XIII. PRIVACY NOTICE FOR
CALIFORNIA RESIDENTS
This part of the document
supplements the information contained in this Privacy Policy
for the purpose
of meeting legal requirements
imposed by California
Consumer Privacy Act (CCPA)
and applies to all users
who are consumers
residing in the state of California, United States
of America.
Information in the
scope below is in the relevant paragraphs
of the Privacy Policy:
·
categories of personal information collected about you in the last
12 months (see paragraph IV)
·
categories of sources from which
the personal information was collected (see paragraph IV)
·
purposes for collecting personal information (see paragraph VII)
·
categories of third parties with
whom we share
personal information (see paragraph IX)
·
categories of personal information we have disclosed
within the last 12 months (see paragraphs IV)
·
categories of personal information we have sold
within the last 12 months to our Trusted
Partners helping us to manage advertising
and services of Third Parties (see paragraph
IV c)
·
We have
disclosed and sold personal information
to third parties within the last 12 months
to our third-party
advertising networks (see paragraph IX f). We do not sell the personal information
of minors under 16 years of age without
affirmative authorisation.
·
the date on which this
Policy was last updated (at the top of this Privacy Policy)
You can designate an authorised agent to make
a request under the CCPA on your behalf. The authorized
agent must submit power of attorney that they have been authorized
by you to
act on your behalf and proof
of their own identity.
You have the right
to:
·
request access to your
personal information
You have the
right to request access to and receive
the following information about personal information we maintain about
you in the preceding 12 months.
(1) The categories of personal information we collected about
you.
(2) The categories of sources from which
the personal information is collected.
(3) The business or
commercial purpose for collecting personal information.
(4) The categories of third parties to
whom we sell
or with whom
we share your personal information.
(5) The specific pieces
of personal information we collected about
you (i.e. data portability rights).
(6) If we
sold or disclosed
your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the personal information
categories that each category of recipient obtained.
·
request deletion of your personal information
(we will
delete the information we have collected about you, except
for situations when that information
is necessary for us to: maintain the
functionality or security of our systems; comply with or exercise
rights provided by the law).
·
opt-out of the sell of your
personal information
(email us at skebstudio@gmail.com) or
click “Do not sell My Personal Information” link.
·
CCPA gives you a right to
direct a business that sells your
personal information to stop selling your personal information
and to refrain
from doing so in the future.
If you would
prefer that your personal information
is not shared with third parties (Advertising Trusted Partners), please, visit “Do Not sell My Personal Information”.
You also have the
right not to be discriminated against for exercising any of the rights
listed above.
If you have questions
or concerns about your privacy
or you want
to exercise your rights, please
contact us by email skebstudio@gmail.com or via traditional mail: Kazım Özalp Sokak, Nazar Apt. No:46 B Blok D:0
Şaşkınbakkal/Kadıköy/İstanbul. We may
verify your request by asking
for proof of identity such as your device ID and/or User ID.
XIV. RIGHT TO CHANGE THE
CONTENT OF PRIVACY POLICY
We reserve the right
to make changes
to our Privacy
Policy, if necessary, in particular for legal reasons or in connection with changes in the Services provided. In the event
of such a circumstance, you will be informed
and we will
publish the current Policy text with the
date of change on our website.
The changes we make
will be legally binding after 30 days of publication on the Internet. If you have any
questions, please contact us.
If you do not accept the changes introduced
to the Privacy
Policy, regardless of sending an e-mail to us, it will be incumbent upon us to ask
you to immediately
cease using our Services. We are asking for
your understanding and please bear
in mind that such resources are needed for
the proper functioning of our Services, and that each
User is subject to the same rules.
DO
NOT SELL MY PERSONAL DATA
"Opt
out" of interest-based
advertising does not mean that you
will stop seeing ads, it means that
you will you turn off
personalized ads, and the content
of the ads may be random and
less interesting.
1.
Change the privacy settings
of your Android or Apple
(iOS) device:
Apple (iOS) device:
a.
Open Settings
b.
Select Privacy
c.
Select Advertising and enable "Limit Ad Tracking"
Android device:
a.
Open Settings
b.
Select Google
c. Select Ads and enable
"Opt-out of Ads Personalization
2. If you have any
questions or would like to
submit an opt-out or “do not sell my personal data” request to us directly,
you can:
contact
us by email skebstudio@gmail.com
or via traditional
mail: Kazım Özalp Sokak, Nazar Apt. No:46 B Blok D:0
Şaşkınbakkal/Kadıköy/İstanbul. We may
verify your request by asking
for proof of identity such as your device ID and/or User ID.
Note that you may need to provide us additional identifying information before we can process your request. Once we receive and process your request, we will not sell your data unless you later allow us to do so.