Version dated 04 august 2022.
] («Agreement»), and is its integral part, an addition thereto. If there is a conflict between the Agreement and the Policy, the provisions of this Policy shall apply. Capitalized terms in this Policy, which have not been assigned a different meaning by this Policy, shall be used in the meaning assigned thereto in the Agreement.
ENBERİ YAZILIM TEKNOLOJİ ANONİM ŞİRKETİ, a legal entity registered in the Republic of Türkiye (“Company” or “we”), seeks to protect the privacy of the Service Users, as well as persons who provide us with their data (“User” or “you”).
This Policy posted at http://enberisoftware.com/eula.html, describes why and how we collect and use your information, and asserts your rights. In this Policy “Personal Information” means information that enables us to identify or recognize you as a specific subject.
The Company is the person who processes Personal Data and is therefore responsible for ensuring that the systems and processes we use comply with the data protection laws of the Republic of Türkiye that apply to us (“applicable law”).
1. Collection of Data. We collect Personal Data from a variety of sources, either directly from data subjects or from Users, colleagues, agents and other public sources. We may collect the following categories of Personal Data about you:
- • Contact Details: e-mail address, name (nickname, login), data of accounts in Social Media, for example, Facebook, VKontakte, Google Plus, as well as data posted in such an account;
- • Data on Device and from Device: Internet protocol (IP) address, approximate geolocation, various device identifiers, device type, web browser data, OS data, cookies files, files uploaded by you to the Service, and data about use of the Service, data about device capacity;
- • User Content: your Content posted on the Service;
- • Messages: User messages (if the corresponding messaging functionality is available on the Service);
- • Game Data: data about use of the Service, data on interaction with Users;
- • Identifiers: various identifiers of the User, his or her device;
- • Purchases: data about User’s payments;
- • Advertising Data: information about the ads you viewed;
- • Diagnostic Data: logs of failures, start time, frequency of freeze or use of energy when using the Game, other technical data on the Game operation;
- • Compliance Data: government IDs, passports or other IDs, mailing addresses, data received as a result of legal expertise, and other data and documents requested or received from us in accordance with the Agreement – we collect the specified data only if we received the corresponding request or another message from state authorities or if we have such obligations, or if you contact us and provide the specified information.
2. Use of Personal Data. We may use your Personal Data for the following purposes and on the following legal grounds:
- • Providing the ability to use the Service – we use Personal Data to enable you to use the Service. To ensure the most efficient operation of the Service and improve its quality, we may also transfer information to third parties, such as Mobile Platforms, Social Media, analytics systems, advertising networks and other providers and suppliers, partners, experts, consultants and other Contractors (as this term is defined below). We also use contact information for authorization on the Service, which is mandatory to use the Service.
- • Management of the Service, business processes and administration of relations with you – we use contact information, financial data and other data, including to update the in-game accounts of Users and to manage relations with our Contractors and you.
- • Communication of Users – we use your messages to provide you with an opportunity to discuss the game process. The specified functionality is not intended for the transfer of confidential and other similar information.
- • Advertising display – we use contact information, date on the device and from the device, game data, identifiers, advertising, purchase data and other data to show you advertisements on the Service. Such advertising shall be provided to you by our providers.
- • Ensuring security of the Service, IT systems and processes – we use contact data, financial data, data of cookies files and devices, and also other data to monitor usage of the Service, to detect and prevent fraud and other crimes and illegal use of the Service.
- • Compliance with legal or regulatory requirements and requests – we use contact information, financial data, cookies and device data, and compliance data to perform various orders and requests (including to combat money laundering and fraud).
- • Resolving questions and answers to claims – we may use contact information, compliance data and other data to resolve your questions and respond to your claims and other messages to us.
Among other things, the legal basis for processing of Personal Data shall be the Agreement, the contracts of the Company with the Contractors, the orders of state authorities.
We may process, and you agree with this, the Personal Data by non-automated, automated or mixed methods: we may also make decisions regarding you, including solely on the basis of automated processing of Personal Data.
3. Exchange of Information. We may transfer your Personal Data to the following categories of persons:
- • Affiliates and partners – we may transfer your Personal Data to our affiliates and partners to enable you to use the Service, and also to organize our relations with you.
- • Service providers – we may transfer your Personal Data to partners, as well as to persons who may process it on our behalf and in accordance with our written instructions to support our activities, such as IT service providers, Mobile Platforms, Social Media, financial institutions, management of databases on relations with you and other cloud solutions, as well as third-party companies that provide us with analytics and statistics, and other third-party sites necessary for the normal operation of the Service (“Contractors”). We enter into agreements with such Contractors to ensure that your Personal Data is processed only in accordance with our instructions, as well as to ensure the security and confidentiality of your Personal Data by implementing appropriate technical and organizational measures for such processing.
- • Corporate buyers – we may transfer Personal Data to third parties in connection with transfer of business, such as reorganization, restructuring, merger, acquisition or transfer of assets of the Company, provided that the receiving party agrees to process your Personal Data in accordance with this Policy.
- • Mandatory disclosure and legal claims – we may transfer Personal Data to law enforcement and regulatory or government agencies that request such Personal Data in connection with any query, subpoena, court order, or other legal or regulatory process that we are required to comply with. We may also transfer Personal Data to establish or protect our legal rights, property rights or security, and the property rights or security of others, or for defense against legal claims.
Please note that the Policy covers only the Service. We are not responsible for the Personal Data policies, procedures or content of any other sites or services where we refer and which are beyond our control. We recommend to check the personal data policy and security of each site that you visit.
4. Parent Memo. We recommend to discuss with your children the safe and reliable use of their personal data online. We do not publish the content of harmful, humiliating or pornographic nature. However, we bear no liability, if your children or other persons whom you legally represent provide any personal data to us without your consent. If you became aware that a child provided personal data to us without your approval, including subsequent one, please contact us by firstname.lastname@example.org. If we become aware that a child provided personal data to us without parents’ consent, we take actions to delete such information.
6. Your Rights. You have all the rights that are provided to you by applicable laws. You also have the right to the following:
- • Access. ou may request a copy of your Personal Data processed by us. The copies will be sent to you electronically. If you need additional copies, we may request a reasonable organization fee from you.
- • Correction. You may request correction of any error in your Personal Data, for example, their incompleteness or inaccuracy;
- • Deletion. You may be entitled to request deletion of your Personal Data, if we do not have to store such data for compliance with legal obligations or to establish, exercise or protect against claims.
- • Revoking Consent. If you agreed to processing of Personal Data, you may revoke your consent at any time for free. Besides, in some cases for this purpose you will have to additionally go to certain web-addresses and follow the instructions specified therein.
Please note that some of these rights may be limited in those cases when we have the preferential right or legal obligation to continue processing of your Personal Data, and also if Personal Data may not be disclosed by applying trade or other secret provisions to such data.
If you want to enjoy any of these rights, please:
- • Write to us to email@example.com;
- • Provide sufficient identification data about yourself (e.g. name, email etc.);
- • Provide proof of your identity and address; and
- • Describe your request.
If this Policy specifies no rights or obligations of yours in respect to the Personal Data provided by the applicable law, it shall not mean that we refuse from them.
7. Data Security. We use technical and organizational security measures to protect your Personal Data. Such measures include, for example, limited access to Personal Data only to employees and authorized service providers, and only to the extent necessary to perform our duties, as well as other administrative, technical and physical measures.
Even though we take measures to protect our systems, Service, operations and information against unauthorized access, use, modification and disclosure, given the properties of the Internet as an open global communication system and other risk factors, we may not guarantee that any information during transmission or storage in our systems will be absolutely protected against adverse impact. Please note that e-mail or the functionality of sending messages within the Service shall not serve as absolutely secure methods of transferring information and shall not be recommended for use to send confidential information. By submitting information online, you assume all relevant risks of possible loss, leakage, disclosure of information and will not hold us liable for any breach of security, unless this is caused by our negligence or willful default. If you have reason to believe that your username or password has been compromised, please contact us.
8. Data Transfer. Your Personal Data may be transferred, including through our integrated computer networks, to one or more offices of the Company or to our affiliates or partners and Contractors, which may be located in different countries that may not be subject to data protection laws similar to those applying in the territory of the Republic of Türkiye. However, these individuals follow the same procedures with respect to your Personal Data, including this Policy.
9. Data Storage. We store your Personal Data only as long as is necessary to process such data as set out herein, or for a longer period of time in accordance with applicable legal, regulatory, accounting or reporting requirements.
10. Change Notice. We may amend this Policy, if our services and practices regarding personal data and privacy change, or in accordance with applicable legal or regulatory requirements. Where possible, we will notify you by email of any material changes. However, the date of the most recent update is posted at the top of the page, and we recommend that you review this Policy from time to time to be informed of how we use your Personal Data.
11. Contacts. If you have any questions, issues or suggestions regarding this Policy, please contact us by email firstname.lastname@example.org.