Raising Game Studio Oyun Yazılım ve Pazarlama A.Ş. Privacy Policy

Effective November 2022

Raising Game Studio is committed to developing the gaming industry by sharing know how, building a future-proof ecosystem and encouraging the production of massively scaling global titles. In pursuit of our mission, we collect, use, store, disclose and otherwise process (“process”) certain information from our players. Being transparent about the processing of players’ information and respecting their privacy is incredibly important to Raising Game Studio.

This Privacy Policy applies when your personal information is processed as part of our Services (described below). Please read it because it will tell you how we process your personal information when providing these Services to you. This Privacy Policy is not, however, a contract and does not create any legal rights or obligations.

If you have questions, comments, or concerns regarding our Privacy Policy or practices, please Contact Us

Raising Game Studio Oyun Yazılım ve Pazarlama A.Ş. ("Raising Game Studio") offers a variety of online and mobile games. Our Privacy Policy applies whenever your personal information is processed as part of our “Services”, which means our games, products, services, content, raisinggamestudio.com, and/or other domains or websites operated by Raising Game Studio. It describes how we process your personal information and your rights and choices concerning your personal information.

Raising Game Studio develops and publishes games for web and mobile devices and other platforms on which players can use our Services.. You can find a list of our group companies here. These are referred to as our “Group Companies”. “Raising Game Studio,” “we,” “our” or “us” in this Privacy Policy refers to those Group Companies that operate under this Privacy Policy.

For purposes of data protection laws, Raising Game Studio is the “data controller” of your personal information. We will refer to countries in the European Economic Area (EEA), Switzerland and the UK collectively as the “European Countries” in this Privacy Policy.
This Privacy Policy applies whenever your personal information is processed as part of our Services, which means our games, products, services, content, raisinggamestudio.com and/or other domains or websites operated by Raising Game Studio. It describes how we process your personal information when providing these Services to you, and your rights and choices concerning your personal information. The Privacy Policy’s sections are listed and hyperlinked in the Table of Contents above for easier navigation.
If you play Raising Game Studio’s games or use Raising Game Studio’s other Services, your information will be processed in the ways described in this Privacy Policy.

Purpose/activity

Type of data

Lawful basis for processing including basis of legitimate interest

To provide you with access to our Services

Name, game username or alias, age, email address, [approximate location], device details including IP address, details about the games and information related to any purchases you make in our Services.

It is necessary in order to perform a contract with you.

To provide you with the product(s) that you have purchased in app.

Name, device, game ID and information related to any purchases you make in our Services.

It is necessary in order to perform a contract with you.

To improve, optimise and personalise our Services and ourplayers' experiences,

Information about your device and its identifiers; your contact details; details about your usage of the app, time spend engaging and number of click interactions; current progress in an app; and data and time Services used.

It is necessary for our legitimate interests to keep our products and Services up to date and relevant; develop our business; and inform our marketing strategy). On the basis of consent.

To communicate with you about the Services you are using or we think you will like, including in-game updates, new Services and pre-registrations.

Name, contact details, address(es), order details (if relevant), details of your communications with us, and IP address.

It is necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy). On the basis of consent.

To provide customer services to you and manage our communications with players (and prospective players), including responding to enquiries about our Services.

Name, contact details, address(es), order details (if relevant), details of your communications with us, and IP address (for the web chat).

It is necessary in order to perform a contract with you. It is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

To communicate with players to provide technical support.

Name, contact details, information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information.

It is necessary in order to perform a contract with you.

For marketing, research, ad performance analytics, for providing a better quality of service and delivering contextual and behavioural advertising.

Information about your identity; contact details; advertising profile; marketing / communications preferences; and technical and usage information.

It is necessary for consent purposes.

To maintain our business operations, including any business transition, like a merger, acquisition by another company, or sale (or other transfer) of all or part of our assets.

Name, contact details, in app purchases made and your technical and usage information.

It is necessary for our legitimate interests to develop and grow as a business. It is necessary to fulfil our legal obligations.

For security purposes and to prevent fraud or potentially illegal activities.

Your personal details, your device id associated with your game play, technical and usage information about your device.

It is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

It is necessary to fulfil our legal obligations.

It is necessary in order to perform a contract with you.

To enforce our Terms of Service.

Name, game username or alias, age, email address, [approximate location], device details including IP address, details about the games and platforms you use and how and when you use them and information related to any purchases you make in our Services.

It is necessary in order to perform a contract with you.

It is necessary to fulfil our legal obligations.

To cooperate with public authorities and law enforcement where lawfully permitted or required.

Information about your identity, your profile, your contact details and communications as well as technical and usage information.

It is necessary to comply with our legal obligations.

It is necessary to protect vital interest (to combat harmful conduct and promote safety, integrity and security).

To administer our agreements with third parties.

Name, age, email address, approximate location, device details including IP address, details about the games and platforms you use and information related to any purchases you make in our Services.

It is necessary in order to perform a contract with you.

It is necessary to comply with our legal obligations.

It is necessary for our legitimate interests (for running our business and maintaining service levels).

To protect Raising Game Studio's rights, including compliance with applicable legal obligations and resolving any disputes we may have.

Information about your identity, your profile, your contact details and communications with Raising Game Studio and technical and usage information.

It is necessary for our legitimate interests (for running our business, network security, to prevent fraud).

It is necessary to comply with our legal obligations.

It is necessary to perform our legal obligation and to perform a contract with you.

We will process any personal information that you provide to us, for example your name and email address when you contact us or details about your device when you download our games.

• Information We Collect and How We Collect It?

Information About You That You Share With Us Directly

When you use our Services, you may give us personal information directly when you download our games to your device or play the games), and we will store that personal information on our systems and process it for the purposes described in this Privacy Policy.

Depending on the Service, the personal information we collect will be relevant to providing that Service and include some or all of the following:

• Your first and last name

• Your game username or alias

• Your age

• Your email address

• Your approximate location

• Details about the device(s) you use, including IP address

• Details about the games and platforms you use, and how and when you use them

• Information related to any purchases you make in our Services (see further details below)

• Personal information you provide when you ask for help from our customer support team, including the content of that communication with our team

Information You Generate Using Our Services

We’ll collect personal information about the ways you use and interact with our Services.

When you use our Services, we will collect personal information about the ways in which you use and interact with our Services, such as when and for how long you play our games, information about the device you access our Services through, which game features you interact with, your in-game expenses, what progress or levels you achieve, other gameplay activities in which you participate, and the amount of time you may watch advertisements, and which advertisements you watch. We will also create a Raising Game Studio player ID for you for each of the Raising Game Studio that you play.

Payment Information

We’ll collect limited information related to in-app purchases made via third-party platforms for the purpose of fulfilling your order.

When you play Raising Game Studio’s games or access any of our other Services on connected third-party applications or on apps via Apple or Google stores, any purchases you make will be processed by that third-party application or platform and subject to that third-party application or platform’s terms of service and privacy policy. For these purchases, Raising Game Studio does not receive your financial information, but may receive non-financial information related to your purchases, like your name and the items purchased, as necessary to enable us to fulfil your order. Location data is only collected to comply with government sanctions.

Cookies and Other Automated Information Collection

We’ll collect information about your device and how you use our Services, including through the use of cookies and similar technologies.

We use cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize you and/or your device(s) across different services (both Raising Game Studio Services and third party services), including for advertising purposes.

We, our service providers, and our business partners use these cookies and other similar technologies to process information, including:

• IP address;

• The type of computer or mobile device you are using;

• Platform type;

• Your operating system version (like Apple iOS or Android);

• Your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);

• Application performance and de-bugging information;

• Your browser type and language;

• Referring and exit pages, and URLs;

• The number of clicks on an app feature or web page;

• The amount of time spent on an app feature;

• Domain names;

• Landing pages;

• Pages viewed and the order of those pages;

• Your preferences regarding the visited websites; and/or

• What your current progress is in our Services and the date and time of activity.

If you play Raising Game Studio on a mobile device, in addition to the information we collect using cookies and similar technologies, we may also collect:

• The name you have associated with your device;

• Your country;

• Your telephone number (if you provide it);

• Your specific geolocation (with your permission); and/or

• Information about the Raising Game Studio and about other third-party applications with embedded Services you have on your device.

If you want to adjust your privacy preferences on your device, please visit the devices “settings” page.

Other Sources

We may collect information from other third-party sources.

We may collect or receive information about you from other sources, including third-party information providers, and/or Apple App Store and Google Play App Store platforms when you purchase, download and/or play our games via these platforms. We use this information along with information you provide us directly, for example, to help you connect or to serve you advertising more tailored to your interests.
 

• Why We Process Your Information and our Legal Grounds

We process your personal information for a number of reasons, including to provide and improve our Services; protect you and others; for advertising our, and our third party partners’, products and services related to your interests and preferences; for business continuity reasons; and to comply with legal rights and obligations.

The main reason we process your personal information is to provide you with Services and to improve your gaming experience, but there are other reasons as well. We process your information for the purposes below:

• Provide our Services;

• Improve, optimise and personalise our Services and our players’ experiences;

• Communicate with you about the Services you are using or we think you will like, including in-game updates, new Services and pre-registrations;

• Provide customer services to you and manage our communications with players (and prospective players), including responding to enquiries about our Services;

• Communication with players to provide technical support;

• Improve, optimise and personalise our Services and our players’ experiences;

• Communicate with you about the Services you are using or we think you will like, including in-game updates, new Services and pre-registrations;

• Provide customer services to you and manage our communications with players (and prospective players), including responding to enquiries about our Services;

• Marketing, research, analytics and delivering contextual and behavioural advertising;

• Maintain our business operations, including any business transition, like a merger, acquisition by another company, or sale (or other transfer) of all or part of our assets;

• For security purposes and to prevent fraud or potentially illegal activities, and to enforce our Terms of Service

• Cooperate with public authorities and law enforcement where lawfully permitted or required; and

• Protect Raising Game Studio`s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties.

Our legal grounds for collecting and using the information described above depends on what the information is, the context in which we collect it and applicable privacy laws. Those grounds are as follows:

• Establish and perform our contract with you (i.e., our Terms of Service);

• For our or our partners’ legitimate interests, where those interests are not overridden by your data protection interests of fundamental rights and freedoms;

• Consent (where applicable);

• Compliance with a legal obligation;

• To protect your vital interests or those of another person (for example, another player);

• While we typically do not collect sensitive or special category personal information, where we do this, it will be on the ground of consent or other applicable lawful basis.

If you have questions, need further information about the legal grounds for processing your personal information, or want to withdraw your consent please see the Contact Us section below.

• How We Share Information

We share your information with our Group Companies and certain other third parties when you use our Services.

We may share your personal information from our Services with others in the ways described below.

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Third-Party Advertising Including Behavioural Advertising and Analytics

We’ll share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services.

We’ll share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services. We do not directly share personal information that identifies you with third-party advertisers for their advertising purposes unless you give us your consent, where legally required.

Advertisements that are tailored for your interests may include banner ads on game boards or in Services, such as full-screen ads between moves or games or ads made available through an “offer wall” (in which advertisers offer virtual currency or other in-game items to players in exchange for watching an advertisement, signing up for an account, completing a survey or performing some other activity). Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Raising Game Studio.

To enable advertisers, advertising intermediaries, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:

• Performance data (like the number of clicks on an advertisement);

• Certain device information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);

• A unique identifier, such as your ID provided by your device manufacturer, for example, Apple's Identifier for Advertisers (IDFA) or Google Ad ID (GAID) or Raising Game Studio player ID; and/or other contextual data about your game play (like your level and session length).

In addition to serving you with relevant ads, the information collected may be used to:

• Measure how effective advertising campaigns are;

• Offer you targeted advertising in third party services for products and services that are more likely to appeal to you;

• Undertake web analytics to analyse traffic and other player activity; and/or

• Improve our Services.

Advertisers or advertising intermediaries may collect this information through the use of cookies and other similar tracking technologies.

Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Raising Game Studio or the social network through which you are playing Raising Game Studio.
Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies and privacy practices. If you have any questions about how these third-party services use your information, you should review their policies and contact them directly.

Safety, Security, and Compliance with Law

We’ll share your information if necessary for safety, security, or compliance with legal obligations.

Your information, and the contents of all of your online communications in our Services and between you and Raising Game Studio may be accessed and monitored as needed to provide our Service and may be disclosed:

• To satisfy any applicable legal obligations;

• When we have a good faith belief that we have to disclose personal information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);

• When we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;

• When we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or

• To protect the rights or property of Raising Game Studio or applicable third parties, including to enforce our Terms of Service.

Third-Party Service Providers

We’ll share your information with the third-party service providers and business partners that we work with to bring you our Services and who support us with our business.

We will share your information with: Third-parties who perform services on our behalf, like, analytics, analysis, hosting services, customer service, marketing and advertising, including, for example, Amazon Web Services and Adjust; and our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (including, for example, Apple, Google and Facebook). You can find a list of our third-party service providers and business partners below which Raising Game Studio regularly maintains.

• Service provider/Business Partner - Privacy Policy Link

• Applovin - Privacy Policy

• Ironsource - Privacy Policy

• Google Admob - Privacy Policy

• Facebook - Privacy Policy

• Unity - Privacy Policy

• Fyber - Privacy Policy

• Mintegral - Privacy Policy

• Vungle - Privacy Policy

• A4G - Privacy Policy

• Chartboost - Privacy Policy

• Makroo Adsyield - Privacy Policy

• Pangle Global - Privacy Policy

• Pangle China - Privacy Policy

• Adsparc - Privacy Policy

Sale or Merger

We may share your information with a third party in connection with a business transition, like a merger or acquisition.

Where we consider a business transition, like a merger, acquisition by another company, or sale of all or part of our assets (like selling a game), we may disclose or transfer your information, including personal information, to the purchaser.

• Your Rights

Depending on what privacy laws apply to you, you and/or your legal representative have certain legal rights in connection with your personal information.

Your privacy rights are explained below. These rights apply to information about you, and their scope and applicability can vary across different regions. For example, they could extend to your household or a legal entity or could be exercised by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times.

Subject to certain exemptions, you have the right to:

• Request a copy of your personal information (known as ‘accessing your data’).

• Delete your information. When you ask us to delete your personal information please remember that there may be lawful limitations on this right. For example, we will keep certain information relating to your purchases or customer service records where we need to, including for legal or accounting purposes. We’ll also keep information in order to exercise, protect, defend, or establish our rights or the rights of third parties.

• Correct or update your personal information where it is inaccurate.

• Opt-out of third-party behavioural advertising by following the instructions in [“Opting Out of Third-Party Behavioural Advertising” – insert link] below.

• Where applicable, withdraw your consent at any time directly in the Service or by Contact Us. Withdrawing your consent will not affect the lawfulness of the processing already undertaken before your withdrawal. Also, it will not affect processing of your personal information under other lawful grounds.

• Object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

• Ask that you are not subject to automated decision-making that has a legal effect or any other significant effect on you.

• Complain to a data protection authority. A list of privacy authorities is available here. In certain regions, you also have the right to request compensation if you suffer damage due to unlawful processing of your Personal Data.

For California residents, please also review our [California Notice – insert link] for additional rights
You and/or your legal representative can exercise these rights by submitting a request via the Contact Us channels below.

Managing Personal Information We Receive From Third-Party Applications / Platforms and From Your Mobile Device

To manage the information we receive from third-party applications or platforms and from your mobile device, use the tools and settings provided by those third-party applications and devices.

You can manage the information we receive from third-party applications or platforms and from your mobile device as follows:

• To manage the personal information we receive about you from a third-party application or platform where you play our games, like Apple and Google you can update your privacy settings through the third-party application or platforms “settings” menu. Please note that the platforms where our games are available may differ from time to time.

• For your mobile device, visit the “settings” page or web browser on your device to review the access permissions of each of our Services.

Once we receive your information from a third-party application or platform or from your mobile device, that information is processed by us in accordance with this Privacy Policy.

Opting Out of Third-Party Behavioural Advertising

You can opt out of third-party behavioural advertising in your device and by using other third-party opt-out tools.

If you do not want to receive personalised in-application advertisements from third parties on your mobile device, you may exercise that choice by visiting your mobile device’s “settings” menu and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”). Certain apps, such as the Digital Advertising Alliance’s “AppChoices” app can help you exercise your behavioural advertising choices and are available from some platform providers (such as Apple or Google).

All of the opt-out tools described in this section are provided by third parties, not by Raising Game Studio. Raising Game Studio does not control or operate these tools or the choices that advertisers and others provide through these tools.

You will still see third-party advertisements in Raising Game Studio Services after using these opt-out tools, but the advertising will not be tailored to your interests.

• U.S. Privacy Laws

If you are a California resident, please see our California Notice. If you are a Nevada resident, please see this section for information on your rights.

If you are a California resident, you may be able to exercise additional rights granted by California law in relation to your personal information that we process (subject to certain limitations). For more information, please review our [California Notice – insert link here].

If you are a Nevada resident you may be able to exercise additional rights to opt out of future sales of certain covered information that a website operator has collected or will collect about you. If you are a Nevada resident, you may exercise this right by submitting a request through the Contact channels below. Please include sufficient information for us to identify you, such as information about previous games you’ve played, or, if applicable, your account information including Raising Game Studio ID. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

• Our Policies Concerning Children

We seek to ensure that we do not collect information from children.

Our Services are not marketed to, or intended for, children. Children for the purposes of our Services are (a) under the age of 13 years old or, if older (b) between 13 and 18 years old but under the age at which they can give valid digital consent to processing of their personal information under applicable data privacy laws. Raising Game Studio strives to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our Services.

Children are not permitted to use these Services, and we do not knowingly collect any personal information from children. Though our Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as children in our age-gate on such Services, if we allow children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA or other privacy laws (where applicable), or obtain legally valid parental consent.

If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under COPPA or another applicable privacy law, we will take measures to promptly remove that information from our records.

• International Operations and Transfers

When you use our Services, your personal information may be processed in the United States and other countries.

As part of our international operations, we may transfer personal information to our Group Companies, business partners and service providers located internationally for our legitimate business purpose, including for the purposes listed in the [Why We Process Your Information and Our Legal Grounds – insert link] section above. We store personal information about you on servers located in the United States or where our Group Companies, business partners and service providers have their operations.

Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is processed may be different from the privacy laws applicable to the place where you are resident. When we transfer your personal information internationally we treat your personal information securely, lawfully, and in accordance with privacy obligations. For example, in European Countries, this may include transferring personal information to countries deemed safe by the European Commission, implementing the European Commission’s Standard Contractual Clauses or using another approved mechanism for transfers of personal information between our Group Companies, business partners and service providers (where applicable).

• How Long We Keep Your Information

We’ll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary to provide you with the Services or for our legal requirements.

We will retain personal information that is connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

• Security of Your Information

We work hard to protect your information but you also have a role to play.

We implement reasonable and appropriate security measures to help protect the security of your information both online and offline and to ensure that your data is treated securely and in accordance with this Privacy Policy. These measures vary based upon the sensitivity of your information.

While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk.

• Changes to Our Privacy Policy

We’ll let you know about any material changes to the Privacy Policy.

We may update our Privacy Policy from time to time. When we do, we will revise the “last updated” date at the top of the policy. If we make changes that we deem material, we will use reasonable efforts to notify (such as by placing a notice in game or on raisinggamestudio.com or by sending you a notice to the email address you have registered with us, if any). We encourage you to periodically check raisinggamestudio.com and this Privacy Policy for updates. If you would like a copy of earlier policies, please get in touch using the Contact Us information below.

• Contact Us

You can contact us with your questions, comments, or concerns.

If you have any questions, comments, or concerns regarding our Privacy Policy and/or privacy practices, please contact us via our Data Subject Application Form or by contacting the following below:

Country

Republic of Turkey

Etiler Mahallesi Çamlık Yolu Sk. Ortaklar Apt. No:2/6 Beşiktaş/İSTANBUL

For all other matters, please contact Raising Game Studio Oyun Yazılım ve Pazarlama A.Ş. through our Contact Page or by post to VEtiler Mahallesi Çamlık Yolu Sk. Ortaklar Apt. No:2/6 Beşiktaş/İSTANBUL