Privacy Policy

We, as Spyke Yazılım Anonim Şirketi (“Spyke”), are a technology company that designs and develops mobile games. With this Privacy Policy, we intend to explain our online and offline information practices, the kinds of information we may collect, how we intend to use, process, store, protect, disclose, and share that information, and how you can opt out of a use or correct or change such information.

This Privacy Policy applies to websites, mobile applications, forums, and every kind of blogs of Spyke and any other online or offline services provided by Spyke. It also applies to our marketing and advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our games and websites and other services collectively as our “Services”.

By downloading our mobile application, accessing and/or playing our games, or interacting with our websites or other Services; or somehow communicating with Spyke, Spyke may collect information about you in accordance with the nature of the information and transaction within the current technical possibilities. You accept, acknowledge, and promise that your personal information and data might be used in limited manner by Spyke and/or through Spyke to the extent that it is limited to the format and purposes set forth in this Privacy Policy. If you have any other concerns about providing data to us or it being used as described in this Privacy Policy, you should not use our games or other Services.

Every type of information related to an identified or identifiable natural person constitutes personal data. Processing your personal data signifies all types of transactions performed on the data such as obtaining, recording, storing, preserving, altering, re-arranging, disclosing, transferring, acquiring, making accessible, alignment and preventing access.

Please note that Spyke is not responsible for the actions of Platforms (defined below), the content of their sites, the use of information you provide to them or any services they may offer.

Spyke reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

The data controller is Spyke Yazılım Anonim Şirketi, registered with the İstanbul Trade Registry with number 269335-5 whose residing at Esentepe Mah. Büyükdere Cad. Astoria Blok No: 127 İç Kapı No: 59 Şişli, İstanbul, Turkey.

We may collect personal data automatically whenever you download or use or Services to your device, whenever you send us your feedbacks or convey your information or support requests directly to Spyke,  from the Facebook, Apple App Store and Google Play App Store (Referred to as “Platforms” together) platforms and the business partners or other third-party companies who have obtained your consent or have another legal right to share such personal with us (including advertising platforms and partners and data aggregators who have obtained). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use your personal data as described in this Privacy Policy.

By downloading, accessing and/or playing our games or using our other Services, you consent to the collection of your personal data by Spyke. When you use Services via Platforms, Spyke may collect certain personal data from you and/or your device. Most of this data comes directly from you or your device, such as your unique device ID (persistent/non-persistent), your device operating system, version, model, CPU, amount of RAM and disk space, hardware type, Identifier For Advertising (IDFA for IOS devices and GAID for Android devices), advertising ID, the version of your operating system ("OS"), your device name, game center ID, and your location based on your Internet Protocol ("IP"). We use this data to provide our games and Services to you, to provide better service to you, to make suggestions, to improve its services, to improve and update our Services, to facilitate the use of Services at the works related to your interest and preferences, including for the purposes of optimization, customizing and in-game offers and verifying purchases, within the framework of legal legislation. We may also use it for the other purposes set out in this Privacy Policy.

Payments for in-app purchases are being carried out by the Platforms. Spyke 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. Spyke does not have access to your credit card or bank account data. However, Platforms may share non-financial payment information for the items your purchase is being shared with us to fulfil your order.

If you choose not to create a Spyke profile by connecting your Facebook account, the personal data that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including:

We use your personal data to enable us to provide our websites, advertising, and other Services to you and to optimize all of them so that we can make them the best they can be for you and all our players. This will include use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players.

We use your personal data, including contact information (e-mail) that you provide directly to us in communications, to provide you with technical support through our customer service channels when you need it or contact with us anyhow. Your contact information will be processed for the purposes of fulfilling your requests, communicating with you, as part of customer service or to send you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.

From time to time, you may share your comments about our games and provide certain information that may include personal data. All personal data collected from your participation in such reviews is provided by you voluntarily. We may use such personal data to solve issues you encountered, to fulfil your requests, to improve our products, websites and/or Services and in any manner consistent with the policies provided herein.

We use analytics tools, which may include third party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes.

From time to time we may run promotions or competitions during which we may collect certain personal data from you, such as your name, address, post code, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal data that you provide in relation to that competition for the purposes of running the competition.

Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after the relevant period of time which is determined by us, your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason.

We may use personal data that we hold to prevent cheating, crime, or fraud. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention, such as the police.

Legal Uses
We may use your data as required or permitted by any applicable law.

When you visit our website https://www.spykegames.com/ (“Website”), we collect and process below-mentioned personal data about you: Any information provided to us when filling out the job application form on our Website, or when you upload a CV and provide additional links.

3.2. Personal Data Collected from Third Parties
As mentioned above, most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising, or other Services. However, when you allow third party companies to access to your personal data (e.g., downloading our mobile applications through Platforms), we also collect information from such Platforms.

Connection of Facebook Account
Spyke may collect your first and last name if you are connected to the Services via Facebook. When you log in to your Spyke profile using your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games online, your basic Facebook account information will automatically be associated with your Spyke profile. Exactly what information we receive is Facebook ID, profile picture and your name. If you do this, you will be able to use your account to log in on multiple devices and synchronize progress across those devices. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other functionality we make available in our games and other Services, such as inviting friends to play.

We will also collect the email account associated with your Facebook account and the name and avatar of those of your Facebook friends that are already playing our games. You can choose not to allow us to access your email address in the Facebook dialog box the first time at which you associate your Facebook account with your Spyke profile.

Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our game. If you do not wish your Facebook friends to be able to see you and your progression in our game, you can prevent this by disconnecting from Facebook from our game and updating your app permissions from within your Facebook settings.

We would recommend that you read Facebook’s Privacy Policy (https://www.facebook.com/privacy/explanation) and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.

Installation of our Mobile Applications via App Store and Google Store
When you install or purchase items related to our mobile apps (such as those you can purchase/download via Platforms), Spyke does not have access to your credit card or bank account data. However, Platforms stated above may share non-financial payment information with us related to your purchases, like the items purchased to fulfill your order. The personal data received from the Platforms will depend on privacy settings on relevant Platform applications.

4. Purposes for Processing of Your Personal Data
We collect and use your personal data for the following purposes:

5. The Legal Grounds of Processing Your Personal Data
The legal grounds that Spyke relies upon while processing your personal data are the following:

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.

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

Spyke undertakes to keep 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 Spyke, the confidential information is damaged because of attacks on the system or captured by third parties, Spyke shall have no responsibility with that respect.

Spyke shall not be responsible for damages caused by the use of information that you disclose in comments 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 Spyke shall not be responsible for any damages that may arise from the information shared with third parties.

6. The Transfer of Your Personal Data
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 only if it is required to provide Services with you. The types of Service Providers (data processors) to whom we entrust include companies that provides:

(i) provision IT and related services;
(ii) provision of information and services you have requested;
(iii) customer service activities;
(iv) analytics and search engine activities that assist us in the improvement and optimization of the Services; and
(v) any supporting activities in connection with our Services. Spyke has executed appropriate contracts with the service providers that prohibit them from using or sharing personal data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

We may access, preserve, and disclose your personal data, other account information and content if we believe doing so is required or appropriate (e.g. required by Law and similar disclosures):

(i) to comply with law enforcement or national security requests and legal process, such as a court order or subpoena;
(ii) to respond to your requests;
(iii) to protect yours, ours or others’ rights, property or safety;
(iv) to enforce Spyke Games’ policies or contracts;
(v) to collect amounts owed to Spyke Games;
(vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or
(vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes (e.g., to detect unauthorized activity on the Services). In such cases, server log data containing IP addresses may be shared with law enforcement bodies, so they may identify users in connection with their investigation of the unauthorized activities.

7. International Transfer
All personal data collected via or by Spyke may be stored anywhere in the world, including, but not limited to, in Turkey, the United States, the European Union, in the cloud, on our servers and on the servers of our affiliates or the servers of our service providers. When we transfer your personal data internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in may be different from the privacy laws applicable to the place where you are resident.

By providing information to Spyke, you consent to the storage of your personal data in these locations.

If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Turkey and the United States and to processing of your data globally.

By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Turkey.

We and our third-party partners may use personal data collected about you to send you marketing communications about our mobile applications and related Services based on your interests. For example, we may serve ads within our Services or place ads on third party websites and apps.

We may use the information that we hold about you to promote Spyke’s Services in several ways. This might include:

We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as:

When we market our games in media published by other companies, we use various third-party marketing partners to assist us on our behalf, and we may share data which we have collected about you with such third parties for these purposes.

Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for Spyke’s games or Services, they will serve you with a Spyke ad while you are using other websites and services.

If you would prefer that your personal data is not processed to receive interest-based ads, you can submit an opt-out request by contacting us via [email protected]. You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising and you may see advertising for Spyke products, but that advertising will not be targeted using your personal data.

This Privacy Policy does not apply to the collection of your data by our marketing partners. We recommend that you review our partners’ privacy policies for more information.

Service providers acting on our behalf, may use cookies or similar technologies to automatically collect information through the Services. Cookies are small text files placed in users’ computer browsers to store their preferences. Cookies belonging to such service providers may be set on your device when using our website or Services. Cookies relating to the website will be used by service providers for the purposes set forth below:

Opting Out of Cookie Tracking: You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash Cookies operate differently than browser cookies, and cookie management tools available in a web browser may not remove flash cookies.

Please be advised that if you disable cookies, you may lose some of the features and functionality of our Services because the cookies are necessary to track and enhance your activities.

9. Ad identifiers, Software Development Kits and Similar Technologies
To provide our games, websites and interest-based advertising, we use ad identifiers, software development kits and similar technologies. This section describes our use of these technologies.

Ad identifiers and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third-party advertising partners to:

Work of Ad Identifiers and Similar Technologies
Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising, which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use Websites and applications.

You have certain rights in connection with your personal data and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.

Those rights include:

There are other ways in which you can control the personal data that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone.

We may occasionally send you push notifications through our mobile applications with game updates, high scores and other notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device.

If you believe we have misused your data or violated any data protection regulations, you may file a complaint with a Data Protection Authority, for example, the Authority of your place of residence.

You can submit all your claims, deletion requests and questions with respect to such rights to [email protected].  Your requests will be answered as soon as possible and within thirty days at latest.

There are other ways in which you can control the personal data that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone.

Most of Spyke Services and games are not intended for children under the age of 18 and Spyke does not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use Spyke Services.

You must be over 18 years old to play our games and use our Services. We do not collect personal data from anyone under 18 years old person knowingly and willfully. However if the Services are used by such person in contradiction to this Privacy Policy, we may collect personal data from such person. If you believe that we might have any information from or about a child under 18 years old, please contact us.

12.Legal Bases (for European Economic Area users)
If you are an individual in the European Economic Area (EEA), we collect and process personal data about you only where we have legal bases for doing so under applicable EU laws. The legal bases which we rely upon are the following:

In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our game we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our games and stop using our Services.

Spyke retains the personal information collected as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

The personal data that you provide to Spyke is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such data such as firewalls and data encryption. However, no server, computer or communications network or system or data transmission over the internet can be guaranteed to be 100% secure. As a result, while Spyke strives to protect your personal data, Spyke cannot ensure or warrant the security of any personal data you transmit to Spyke or through the Services.

By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security privacy, and administrative issues related to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you.

Revision to the Privacy Policy
We may revise this Privacy Policy at our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy
If there are any material changes to this Privacy Policy, Spyke will notify you by email or as otherwise required by applicable law. We will post adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information
Additionally, before we use personal information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. When consent of the individual for the processing of personal information is otherwise required by law or contract, Spyke will endeavor to comply with the law or contract.

16. Contact Info of Data Controller
If you have any questions about the privacy practices or this Privacy Policy, please contact Spyke’s data protection officer by email at [email protected].