Mobile Apps Privacy Policy for iOS

 

Last updated March 05, 2021

 

PERA GAMES OYUN YAZILIM TEKNOLOJİ VE PAZARLAMA ANONİM ŞİRKETİ (hereafter referred to as “Pera Games”) is dedicated to protecting the privacy of our users and handling any personal date we obtain from our users with care and respect. An overall principle is that we do not collect more information than is reasonably necessary to provide you with the best user experience.

Pera Games may use affiliates’ or reputable third parties’ services for the processing of personal data collected on or through our mobile games (“Games”). By using our Games, you are accepting the practices described in this privacy policy.

Our games are for all ages. If a game is for children or for a mixed audience we do not serve interest based advertising to users 12 or under in the US or 15 and under in the EU. We do not actively collect information from users 12 or under in the US.

 

1. About this Privacy Policy

1.1. This privacy policy (“Privacy Policy”) explains how information about you is collected, used, and disclosed by Pera Games when you play one of our Games. This Privacy Policy is applicable where Pera Games acts as a data controller with respect to your data. This is the case where we determine the purposes and means of the data processing in our Games.

1.2. The Privacy Policy applies in addition to our terms of use and other policies. In the case of a contradiction between the Terms of Use and this Privacy Policy, this Privacy Policy will prevail.

 

2. About us

2.1. PERA GAMES OYUN YAZILIM TEKNOLOJİ VE PAZARLAMA ANONİM ŞİRKETİ, LEVENT MAH. MORKARANFİL SOK. NO:6 BEŞİKTAŞ – BEŞİKTAŞ / İSTANBUL / TÜRKİYE is responsible (“the Data Controller”) for processing of your Personal Data.

If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your data subject rights, please email us at info@peragames.co. If you are a parent and would like to review or delete your child’s information please contact us at info@peragames.co

 

3. What information does Pera Games collect?

3.1. Pera Games collects certain information when you play our Games. We may also collect information from ad network providers and other third parties such as payment service providers.

When you play our Games, we collect (among others) the following information:

  • Your device identifier and IP address;
  • Demographic information (such as your country);
  • Information collected through various technologies;
  • Other information that we receive from you, e.g. your emails, chats, surveys, or other communications and information exchanged with us on our social media channels related to the Games;
  • How you play the Game (frequency, device, platform, level, etc.);
  • Transaction information of payments made;
  • Information you post on the Community of the Game;

 

4. How do we use your information?

4.1. When you play the Game, we use the information that we have about you:

  • To provide you with the Game and associated websites, and continuously improve their features;
  • To store your gaming history;
  • To provide help desk and support services;
  • To analyze the functioning of the Game and associated websites;
  • To enable in-app purchases;
  • To present interest-based advertisements and to send you promotional messages by email or other communications;
  • To prevent fraud and crime;
  • To meet legal and tax obligations.

 

4.2. Your email address may be used for the following purposes:

  • service emails (regarding updates, new design, new features, surveys, (new) games, etc.);
  • administrative purposes, such as notification of a violation of our terms of use;
  • delivering messages you have allowed us to forward (e.g. from other users in your social network).

 

4.3. Your personal data will only be stored for a period necessary for your use of the Game for the purposes as described in this Privacy Policy.

 

5. Which third parties have access to your data?

The Website works with the following third party service providers.

 

Third Party

Usage

Privacy Policy

Tenjin

Analytics

Link

ironSource

Analytics

Link

Google Admob

Advertising

Link

GameAnalytics

Analytics

Link

Google Analytics

Analytics

Link

Appsflyer

Analytics

Link

Facebook Ads

Advertising

Link

 

 

5.1. Ad network providers

Pera Games uses ad network providers, ad exchanges, and ad servers (“Advertising Partners”) to help present advertisements in our Games or run advertising campaigns on third party games and platforms. These Advertising Partners use certain technologies for presenting, better targeting, and measuring the effectiveness of their advertisements, using data gathered over time and across their networks of games to determine or predict the characteristics and preferences of their audiences (“Advertising Data”).

If you are under 16 years old then you will not see any advertising including contextual advertising and Advertising Partners will not collect any Advertising Data from you.

If you are above 16 years old and opt-in to data sharing than Advertising Partners process the Data which includes but not limited to; your device identifiers, any information regarding in-app events (such as how often you use the app, for how long you use the app, the events that occur within the app, in-app purchases, aggregated usage), your device’s IP address, mobile advertising ID (IDFA / AdID).

Pera Games processes such information in accordance with this Privacy Policy. Our Advertising Partners may act as a data processor or data controller with regards to the Advertising Data, depending on the scope of their services. The Advertising Partners are responsible for their compliance with the applicable data protection legislation. The use of the advertising technologies by such third parties as ad network providers is subject to their own privacy policies, not this Privacy Policy. The legal basis for the processing of the Advertising Data for targeted advertisements is consent. The legal basis for optimizing and tracking conversion rates of advertising campaigns that we run with others is legitimate interest.

5.2. Payment Service Providers

Pera Games may also use third-party payment service providers (“PSP”), offering payment transaction services to Pera Games in order to sell a product or service through our Games. The PSP acts as a data controller with regards to the personal data related to the transactions (“transaction data”) processed for the purpose of purchasing the product or service. The transaction data may include your personal details, your payment card details, and the transaction details. Whenever you buy something in our Games (e.g., a virtual game item), the information that you provide to the PSP is subject to their privacy policies, not ours. The legal basis for this processing is the performance of a contract. You explicitly consent that Pera Games may provide personal information collected from you to a PSP for the purpose of the offering of the payment-transaction service whenever you buy something in our Games and that such PSP may use such data for (statistical) analysis of payment transactions. After you have purchased a product or service, Pera Games and the PSP have a legal requirement to retain your information for a legally determined period of at least 7 years. Pera Games shall be allowed to notify a PSP regarding a user that engages in (or who a party believes has engaged in) any activity that is illegal, that violates any person’s rights, or that led to such a user’s suspension or termination of use of the Games. Pera Games shall be allowed to notify a PSP regarding a user who engages in (or who a party believes has engaged in) any activity that is illegal, that violates any person’s rights, or that resulted in such user’s suspension or termination of use of a Game.

5.3. Analytics Partners

Pera Games uses analytics partners in order to help get insights into the usage of the Games (“Usage Data”). These analytics partners process Usage Data, which may include, among others, your IP address, geographical location, operating system, time spent in the Games, and other information about how you use the Games. This data is used to analyze the use of the Games and to improve the Games and related services. Our analytics partners will act as a data processor in relation to Usage Data. The legal basis for the processing of the Usage Data is legitimate interest.

5.4. Customer Support Partners

Pera Games uses third party service providers in order to offer our users customer support services. We may share personal data such as the communication content, IP address, email address, and username (“Correspondence Data”) with these partners. The Correspondence Data may be processed by Pera Games and business partners for the purpose of communication with you, blocking users, changing email addresses, reactivating or blocking accounts, adding or removing in-game items, and other customer support services. The legal basis for the processing of the Correspondence Data is legitimate interest or consent depending on the service provided.

5.5. Partner networks

Pera Games may use partner network providers who assist us to distribute the Game in order to enable as many gamers as possible to play the Game.

5.6. Other

We may supply information to other parties if we are required to do so by law or by a ruling from a court of law.

 

6. Your rights

6.1. Your personal data may be stored by Pera Games and its business partners. In case the applicable data protection laws provide so, you have the right to access, rectify, and erase the personal data we hold about you and to restrict or object to our processing of your personal data. To the extent that the legal basis for the processing of your personal data is consent, you have the right to withdraw that consent at any time.

6.2. If you wish to exercise these rights, you can do so by sending a written request to PERA GAMES OYUN YAZILIM TEKNOLOJİ VE PAZARLAMA ANONİM ŞİRKETİ, LEVENT MAH. MORKARANFİL SOK. NO:6 BEŞİKTAŞ – BEŞİKTAŞ / İSTANBUL / TÜRKİYE, detailing your request, (to prevent misuse of requests for information), or sending an email containing your request to: info@peragames.co.

6.3. You can, at any time, opt-out of marketing communication messages you receive from us by clicking the opt-out link in these messages.

6.4. Pera Games does not knowingly process personal data from anyone under the age of 16 without parental consent. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent, we will promptly delete such data. Parents of users under the age of 16: if you wish to have access to your child’s personal data to view, correct, or delete the information that we have collected about your child, please send a written request to PERA GAMES OYUN YAZILIM TEKNOLOJİ VE PAZARLAMA ANONİM ŞİRKETİ, LEVENT MAH. MORKARANFİL SOK. NO:6 BEŞİKTAŞ – BEŞİKTAŞ / İSTANBUL / TÜRKİYE, detailing your request along with a copy of your passport (to prevent misuse of requests for information), or send an email with all such information to info@peragames.co. After verification, the copy of your passport will be shredded.

6.5 In the event you have any questions or concerns in relation to the processing of your personal data, you can send an email to our Data Protection Officer by email at info@peragames.co. If you are not satisfied with our responses and/or support to resolve your concerns, you have the right to lodge a complaint with a supervisory authority where any alleged infringement of data protection laws occurred.

 

7. Security

7.1. Pera Games has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect in relation to the Game.

7.2. Although we allow you to set privacy options that limit access to your personal data, please be aware that no security measures are perfect or impenetrable. We are not responsible for the circumvention of any privacy settings or security measures contained in the Games.

 

8. Miscellaneous

8.1. We reserve the right to amend our Privacy Policy. Amendments will be effective from the moment of publication, so please check regularly to be sure you are familiar with the latest version.

8.2 In the event of a transfer of (one of our) Games to a third party, we may transfer to such third party all personal information that we collected about you in accordance with this Privacy Policy. In such an event, users who have provided email addresses to us will be notified when information about those users is transferred and becomes subject to a different privacy policy.

8.3 This Privacy Policy shall be governed by the laws of Turkey and submitted to the exclusive jurisdiction of the courts in Turkey.

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