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PRIVACY POLICY

Spyke Yazılım Anonim Şirketi Privacy Policy

This Privacy Policy was executed by and between Spyke Yazılım Anonim Şirketi (“Spyke”) as the “Data Controller” and you. In this context, the purpose of this Privacy Policy is to provide information on the collection, processing and use of the data provided by you in connection with the use of Spyke’s Services as well as the grade, purpose and scope of transfer thereof.

 

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, websites, marketing and advertising activities and other services collectively as our “Services”.

 

When you use the Services; or somehow communicate with Spyke, Spyke collects 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. 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.

  1. The purposes of collecting and processing personal data

Spyke collects your personal data automatically whenever you download or use our Services to your device, whenever you send us your feedbacks or convey your information or support requests directly to Spyke or interact with third party advertisements presented in our Services or interact with Spyke advertisements presented in other platforms. In general, the information we collect about you relates to your device and helps us to identify your device. Spyke also collects data from the Apple App Store and Google Play App Store (Referred to as “Platforms” together) platforms and the business partners.

 

Personal data that is collected while you are using Services:

Spyke might collect the your personal information and the activities taken place under Spyke in order 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.

When you use Services via Platforms, Spyke collects certain personal data from you and/or your device. In this regard, Spyke collects our first and last name, your username, your gender, your age or birthday, your e-mail address, your advertising ID (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), device identifier, operating system, model, producer information, hardware type, operating system version, memory usage, country, time zone and preferred language information, internet protocol (IP) number, location information according to your IP address, operator and browser information, information about properties of mobile application through our Services, data regarding your in-game interactions (the time you spent while playing our games, your in-game expenses, level information, the amount of time for watching advertisements, the advertisements watched) and time of installation and first opening of the application and other information that helps us to identify you or helps us to provide or improve our services.

We may also let you create a player profile that other Zynga players can see. Your player profile may include information like your profile photo, your first and last name, your game username, your gender, your biographic details (like your age or age range), the approximate physical location information that you provide, links to your profiles on various social networks, details about the games you play; and/or

The aforementioned advertising IDs (IDFA and GAID) are unique identifiers for mobile devices that advertisers use for personalized advertising and consistent across all mobile applications and thus allow cross-app tracking. You may disable this option by activating “limit advertisement tracking” from the privacy settings of Apple devices. As for the Google Android devices, you may change your advertisement setting by activating the “disable advertisement personalizing” option. Advertising IDs, are non-permanent identifiers, which are uniquely associated with your device.

We would like to remind that you have an option to use the Services without watching advertisements by using our no-ads feature, which is subject to a fee.

Your user name and score can be viewed by other users in our games that include a scoreboard feature.

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, and only payment information for the items your purchase is being shared with us in order to fulfil your order.

  • Personal data that is collected when you contact with Spyke
  • When you contact with us: We may ask for contact information (e-mail) when you request information about our Services, request technical support or contact with us anyhow. Your contact information will be processed for the purposes of fulfilling your requests and communicating with you.
  • Comments: You may share data that contains your personal data when you share your comments and views about our Services. The content of user comments is composed fully of data that you voluntarily provided. We process your shared personal data to solve the issues you encountered and to fulfil your request

 

Data that is collected by third parties

If the personal data provided to Spyke by you is requested by official institutions/organizations as necessitated by the law, the data may be transmitted to the relevant authorities and courts if requested by the courts.

Our business partners or service providers can use server log files, cookies, pixel labels, web beacons or other tracking tools in our Services. Our advertisement business partners and analytics service providers mentioned in the part 3 above, can collect data regarding,your first and last name ,your profile picture or its URL, your user identification number (like your Facebook ID number), which may be linked to publicly-available information like your name and profile photo, your friends’ user ID numbers and other public data, your approximate physical location and that of the devices you use to access our Services, your gender, your birthday, age, and/or age range, information about your activities on or through the connected third-party application, other publicly-available information on the third-party application, your IP address,  your advertising identifier (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), cookie identifiers, advertisement ID, your mobile device’s type, operating system, version, model, hardware type, other device identifiers that are automatically determined for your device when you connect to the internet, web browser information, websites you visited, connections you have within the Services and your preferences about the visited websites by using the stated technologies. You may access to the privacy policies of these third parties from section 3.

 

 Cookies

Spyke collects information about your devices by using cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize you and/or your device(s) on, off, and across different Services and devices. You have always option to opt out from such use and control it where needed.

We, our service providers, and our business partners use these cookies and other similar technologies to collect and analyze certain kinds of technical information, including; Protocol (IP) address, cookie identifiers, mobile advertising identifiers, mobile device’s identifiers like User Identifier For Advertising , Advertising ID, Game Center ID, the type of computer or mobile device you are using, your device’s operating system, version, model, hardware type and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, hardware type, operating system, internet service provider, pages that you visit before and after using the Services, the date and time of you visit, the amount of time that you spend on each page, information about the links you click and pages you view within the Services and other actions taken through use of the Services such as preferences; information Spyke collect via cookies and widgets that allows Spyke to collect data, such as your device’s model, operating system and screen size, IP, game center IP, preferences and other information about how you use the Services, domain names, performance and game contextual data like your games session activity, aggregated and/or de-identified information that is not intended to specifically identify a user, details about how you use and interact with the Services (for example, information about how and when you use Services or visit the websites(s), information that you provides Spyke when you fill in forms, and/or questions or complete surveys when using any of the Services, when you creates an account with Spyke or your  interactions with Spyke on the social media channels;

Spyke stores your data for as long as it is necessary to provide our Services and deletes it when the purposes of the data processing cease to exist. Personal data is deleted in case the reasons which necessitate processing within the context of the stated purposes in this privacy notice cease to exist and upon consummation of the legal ground for processing of the relevant record at the latest.

  1. The legal grounds of processing your personal data

The legal grounds that Spyke relies upon while processing your personal data are the following:

  • Explicit consent and/or your request
  • In cases where it is necessary to disclose such information in accordance with applicable laws or regulations or a court judgment or administrative order issued
  • Being necessary for the establishment and execution of an agreement
  • Being necessary for Spyke to fulfil its legal obligations as a data controller
  • Being necessary for the establishment, exercise, and protection of any right
  • Without prejudice to your fundamental rights and freedoms, being compulsory for Spyke’s statutory interests

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 the 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 as a result 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.

  1. The transfer of your personal data

Your personal data may be transferred to our business partners and service providers located abroad for the purposes of improving our Services and providing our Services to you, providing personalized advertisements according to your interests, measuring Spyke’s and third parties’ advertisement effectiveness and carrying out measurements and analysis regarding your use of our games. 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 stated below:

Analytics services. Your personal data may be transferred to our service providers and business partners for the purpose of conducting analytical reviews, analyses, reporting and research activities regarding the use of our Services.

Cloud computing services. Your personal data is stored in the servers of the Amazon Web Services and Google.

Advertisement business partners. Your personal data may be transferred to our advertisement partners who enable the Services to be provided free or for low cost.

You may find the list of our service providers and business partners and their privacy policies below:

Service Provider/Business Partner

We may share the information we receive from you with our Service Providers. The types of Service Providers (processors) to whom we entrust personal date include Service Providers for: (i) provision of IT and related services; (ii) provision of information and services that you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. Spyke may also share information with platform partners for SDK Advertising and S2K Tag Advertising with AdColony, Inc., Admob, Inc., AppLovin Limited, Chartboost, Inc., Pubnative GmbH, Inmobi Pte. Ltd., ironSource Mobile Ltd.  Mopub Inc. Tapjoy, Inc. Unity Ads Vungle, Inc., Facebook Analytics for Apps (Facebook, Inc.), Google Analytics for Firebase (Google Inc.), Google Analytics (Google Inc.)  Adjust GmbH. In order to provide safety to personal date, Spyke takes reasonable precautions information (as required by applicable data protection laws) while sharing such information with Service Providers.

  1. Your Rights Regarding the Protection of Your Personal Data

According to the relevant legislation, you have the right to;

  • learn whether or not your personal data is being processed,
  • request information as to processing if it has been processed,
  • learn the purpose of personal data processing and whether the personal data is used appropriately in line such purposes,
  • know the third parties to which your personal data is transferred domestically or abroad,
  • request correction if your personal data is incompletely or incorrectly processed,
  • request deletion or destruction of your personal data,
  • request the transmission of your correction, deletion, and destruction requests to third parties to whom your personal data has been transferred,
  • object to any consequence occurred against you by analyzing your processed data through automated systems
  • request compensation in case you incur any damage due to the unlawful processing of personal data.,
  • request restriction of data processing activities,
  • request data portability,
  • object to the occurrence of an adverse consequence by analyzing the processed data exclusively through automated systems, and
  • lodge a complaint with the relevant data protection authority and to claim damages in case of impairment because your personal data is processed in violation of the relevant legal legislation.

You can submit all your claims 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.

Spyke Games Oyun Yazılım ve Pazarlama A.Ş.

Mersis No: 0781087417300001

 

Privacy Notice for California Residents

Last modified: Dec 2020

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA“). Strictly for the purpose of this part of the Privacy Policy, the term “Personal Data” shall be as defined in the CCPA.

Processing Personal Data

We may have collected and disclosed for a business purpose the following categories of Personal Data: 

Category of Personal Data Collected

  1. Identifiers

Personal data collected: Name, username, email address, social media identifier, IP address, username, advertising ID, device and operating system information.

  1. Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

Personal data collected: Name, image

  1. Commercial Information

Personal data collected: Transaction information, purchase history. This does not include any payment information, which is collected directly by the mobile app distribution platform.

  1. Internet or Other Electronic Network Activity Information

Personal data collected: Interaction with our App

  1.   Geolocation Data

Personal data collected: Country, State, City

Categories of service providers to whom Personal Data was disclosed

  •         Advertising networks
  •         Social media services
  •         Data analytics vendors
  •         Quality assurance vendors
  •         Cloud storage Providers
  •         Service providers
  •         App distribution platforms

Business Purpose for Collection

  •     Operate our business and game
  •     Product development/improvement
  •     Customer service
  •     Detecting/Protecting against security event
  •     Internal analytics and reporting
  •     Internal research
  •     Game mechanics or functionality
  •     Facilitate players’ social interaction
  •     Maintaining and enhancing service, debugging
  •     Advertising and direct marketing
  •     Detecting/protecting against security events, preventing fraud and abuse of our policies
  •     User acquisition
  •     Compliance purposes and meeting legal/regulatory requirements

Sources of Personal Data

  • Directly from users
  • Directly or indirectly by cookies or other tracking technologies
  • Social networks
  • Advertising networks
  • Data Analytics Providers

Your Rights

In accordance with the CCPA, you have the right to request: (i) that we disclose what Personal Data we collect, use or disclose, (ii) the deletion of your Personal Data as collected or maintained by us; (iii) to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA – in accordance with the CCPA, using the methods we made available herein.

You can designate an authorized agent to make a request under the CCPA on your behalf, in accordance with the CCPA, using the methods we made available herein.

Selling Personal Data

We do not “sell” Personal Data about our players as most people would typically understand that term. However, we do allow certain third-party advertising partners to collect information about consumers through our games for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting. In order to serve you personalized ads, we share your resettable identifiers provided by your mobile device’s operating system with our selected partners. Typical advertising IDs are AID (Android) and IDFA (Apple). These mobile advertising IDs allows developers and marketers to track activity for advertising purposes and are used to enhance the personalization of ads. You may reset these identifiers from within your mobile device or limit ad tracking for your mobile device as mentioned in the Privacy Policy. Please see our Advertising Uses section above for more information.