GNARLY PRIVACY POLICY
1.
INTRODUCTION
1.1
Gnarly Oyun Teknolojileri Anonim Şirketi
("we," "us," or "our") is a technology company
dedicated to developing and operating high-quality mobile games. This Privacy
Policy explains how and why we collect, store, use, and share your personal
information when you visit our website, play our mobile games, or use our
related services (collectively, the "Services").
1.2
By using our Services, you agree to the
collection and use of your personal information in accordance with this Privacy
Policy. If you do not agree, please do not install or use our Services.
1.3
If you are a resident of US, EEA, UK, and
Türkiye, specific rights and provisions regarding your data are detailed in
the respective sections of this policy.
1.4
Data Controller
1.4.1
For the purposes of data protection laws, the
controller of your personal data is:
(a)
Address: Hızır Çavuş Mescidi Sk. No: 40/A Balat,
34087 Fatih/İstanbul, Türkiye
1.5
This Privacy Policy does not apply to any other
data we collect, such as data we collect offline, from job applicants, or from
employees.
2.
INFORMATION WE COLLECT
2.1
Information You Provide Directly. We collect information that you voluntarily provide to us,
including:
2.1.1
Contact Information: If you contact us for support, participate in sweepstakes, or
request a refund, we may collect your name, email address, or phone number.
2.1.2
Player Profile:
Information you create for your game profile, such as your nickname or avatar.
2.1.3
User Content:
Messages you send to our support team, chat logs, or feedback you provide in
surveys.
2.2
Information We Collect Automatically. When you use our Services, we automatically collect certain data
to ensure our games function correctly and to improve your experience:
2.2.1
Device Information: Your device model, operating system (OS) version, language
settings, country settings, available storage, and battery level.
2.2.2
Identifiers: Your
IP address and unique mobile device identifiers, such as your Advertising ID
(IDFA for iOS, GAID for Android) and internal game account IDs.
2.2.3
Usage Data:
Details about your gameplay, including game progress, level achieved, access
frequency, scores, and interaction events (e.g., how you interact with the game
interface).
2.2.4
Purchase History:
Records of the virtual items or currency you purchase. Please note that we do
not collect or store your credit card or bank account details; these are
processed entirely by the App Store or Google Play.
2.2.5
Cookies: We use
cookies and similar technologies to store your preferred settings and analyse
user behaviour.
2.3
Information From Third Parties. We may receive information about you from third-party partners:
2.3.1
Social Networks:
If you choose to link your game account to a third-party platform (such as
Facebook, Google, or Apple), we may receive your profile information, profile
picture, and friend list, depending on your privacy settings on that platform.
2.3.2
Advertising Partners: We work with mobile measurement partners (such as Adjust) and ad
networks to understand the effectiveness of our advertising campaigns and to
detect fraud.
2.3.3
Platform Providers: We receive payment confirmation and subscription status from
platforms like the Apple App Store and Google Play to validate your purchases.
3.
PURPOSES AND LEGAL BASES FOR PROCESSING
3.1
We use your personal data for a variety of
business purposes. Depending on the data protection laws in your region (such
as the GDPR or Turkish KVKK), we process your data based on specific legal
grounds:
3.1.1
Performance of Contract: We process data necessary to perform the contract with you and
provide the Services you request. This includes:
(a)
creating and managing your account and allowing
you to play our games.
(b)
verifying and confirming your in-app purchases
and payments.
(c)
delivering the virtual items or services you
have purchased.
(d)
sending you service-related communications, such
as security alerts, confirmations, and technical notices
3.1.2
Legitimate Interest: We have a legitimate interest in collecting and processing
necessary data to improve our Services and your experience. This includes:
(a)
Player Support: Responding to your comments,
inquiries, and support tickets.
(b)
Analytics: Understanding how you use our Services
to fix bugs, improve stability, and optimize gameplay.
(c)
Social Features: Enabling you to communicate
with other players, participate in teams, or compete in leaderboards.
(d)
Customization: Updating your player profile and
remembering your preferred game settings
3.1.3
Safety: Ensuring
a level playing field is a top priority for us. We use data to:
(a)
detect and prevent fraud, such as refund abuse
or advertising click fraud.
(b)
moderate chat automatically or manually to
prevent toxic behaviour.
(c)
take action against cheating, hacking, or
unauthorized use of the Services.
3.1.4
Consent: We may
use your data to show you advertisements for our games or third-party products.
(a)
General Advertising: We may process data to
track the content you access and deliver ads based on our legitimate interest.
(b)
Targeted Advertising: With your consent (where
required by applicable law), we may use device identifiers (such as IDFA or
GAID) to serve behaviourally targeted advertising and to measure the
effectiveness of ad campaigns.
(c)
Opt-Out: You can manage your consent settings
for targeted ads within the game settings at any time.
4.
SHARING AND DISCLOSURE OF INFORMATION
4.1
We do not sell your personal information to
third parties for money. However, to provide our Services, we share your data
with the following categories of recipients:
4.1.1
Service Providers:
We share your information with third-party companies that perform services on
our behalf. We require these providers to access your data only to the extent
necessary to perform tasks for us (such as hosting, player support, and
analytics) and to comply with applicable laws. These include:
(a)
Hosting and IT Services: To store data and run
our game servers.
(b)
Customer Support Tools: To help us manage and
respond to your support tickets.
(c)
Analytics Providers: Companies that help us
understand how players interact with our games to improve them. For more
information about their privacy practices and opt-out possibilities, please
visit the links below.
(i)
Facebook、Inc. (Facebook Ads & analytics)
(ii)
Google LLC (Google Ads, analytics & AdMob)
(iii)
Adjust GmbH
4.1.2
Other Players and Users Social: features are a core part of our games. When you play, other users
may see your profile data, such as your nickname, avatar, game statistics
(e.g., level, score), and any messages you post in public chat or team forums
4.1.3
Advertising Partners: We work with third-party advertising networks and technology
providers ("AdTech Providers") to show you ads within our games.
(a)
We may share identifiers (such as IDFA or GAID),
your IP address, and technical device data with these partners so they can
serve ads relevant to your interests.
For more
information on how to opt-out of targeted advertising, please see Clause 6
(Your Rights and Options).
4.1.4
Legal and Safety Requirements: We may disclose your information if we believe in good faith that
it is necessary to:
(a)
Comply with a legal obligation, court order, or
request from law enforcement.
(b)
Detect and prevent fraud, such as payment abuse
or cheating.
(c)
Protect the rights, property, or safety of
Gnarly Oyun Teknolojileri Anonim Şirketi, our players, or the public.
4.1.5
Corporate Transactions: In the event that Gnarly Oyun Teknolojileri Anonim Şirketi
undergoes a business transition, such as a merger, acquisition, or sale of
assets, your personal information may be transferred to the successor
organization as part of that transaction.
5.
INTERNATIONAL DATA TRANSFERS
5.1
Global Operations. Our Service is global by nature, and your data can therefore be
transferred to and processed in countries other than the one in which you
reside. Since we are based in Turkey, your personal information will typically
be processed on our servers there, or on the servers of our third-party
providers.
5.2
Safeguards.
Because different countries may have different data protection laws than your
own country, we take steps to ensure adequate safeguards are in place to
protect your data.
6.
YOUR RIGHTS AND OPTIONS
6.1
You have specific rights regarding your personal
information. Depending on where you live (such as the EEA, UK, Turkey, or the
US), these rights may include the following:
6.1.1
Your Privacy Rights:
(a)
Right to Access: You have the right to request a
copy of the personal data we hold about you.
(b)
Right to Correction: If your data is inaccurate
or incomplete, you can request that we fix it.
(c)
Right to Deletion (Erasure): You can request
that we delete your account and personal data permanently. Please note that if
you delete your account, all game progress and virtual items will be lost and
cannot be restored.
(d)
Right to Restriction & Objection: You may
have the right to object to our processing of your data (for example, for
marketing purposes) or ask us to restrict how we use it.
(e)
Right to Portability: You can request a copy of
your data in a structured, commonly used format to transfer it to another
service.
(f)
Right to Withdraw Consent: If we are processing
your data based on your consent (such as for targeted advertising), you can
withdraw that consent at any time.
(g)
Right to Non-Discrimination: We will not
discriminate against you (e.g., by denying services or charging different
prices) for exercising any of your privacy rights.
6.1.2
How to Exercise Your Rights: To protect your privacy, we may need to verify your identity before
fulfilling your request.
(a)
In-Game Support: The fastest way to exercise
your rights (especially for Account Deletion or Access) is to contact us
through the "Support" or "Contact Us" section within the
game settings. This helps us automatically verify that you are the owner of the
account.
(b)
Email: You may also submit a request by emailing
us at info@gnarlyteam.com
6.1.3
Managing Marketing and Push Notifications
(a)
Push Notifications: We may send you game updates
and alerts. You can stop receiving these at any time by going to your mobile
device’s "Settings" > "Notifications" and turning off
alerts for our games.
(b)
Marketing Emails: If we send you promotional
emails, you can opt-out by clicking the "unsubscribe" link included
in those emails.
6.1.4
Opting Out of Targeted Advertising
(a)
On iOS (Apple): Go to Settings > Privacy >
Tracking and toggle off "Allow Apps to Request to Track," or go to
Settings > Privacy > Advertising and turn on "Limit Ad
Tracking."
(b)
On Android: Go to Settings > Google > Ads
and enable "Opt out of Ads Personalization" or "Delete
advertising ID”.
7.
CHILDREN’S PRIVACY
7.1
General Policy.
Protecting the privacy of young children is extremely important to us.
Generally, our Services are not directed to children under the age of 13 (or
under 16 in certain jurisdictions, such as the EEA and UK). We do not knowingly
collect personal data from children under these ages without parental consent,
except as permitted by law.
7.2
Age Gates and Young Players. For games that may appeal to a broad audience, we may implement an
age screen ("age gate") upon launch.
7.2.1
Restricted Experience: If a player indicates
they are under the applicable age (e.g., under 13 in the US or under 16 in
Europe), we will restrict the collection of their personal data to only what is
strictly necessary to support the internal operations of the game (such as
saving game progress locally).
7.2.2
No Targeted Ads: We will not serve behaviourally
targeted advertising or tracking tools (like IDFA/GAID) to users identified as
underage.
7.2.3
Social Features: Certain features, such as chat
or social network integration, may be disabled for users under the applicable
age limit.
7.3
Note to Parents and Guardians. If you are a parent or legal guardian and you believe your child
has provided us with personal information without your consent, please contact
us at info@gnarlyteam.com.
7.3.1
Your Rights: You have the right to review the
personal data collected from your child, request its modification, or ask for
it to be deleted.
7.3.2
Parental Controls: We encourage parents to
monitor their children's device usage. You can often restrict in-app purchases
and social features directly through the "Settings" of your child's
mobile device (Apple iOS or Android).
7.4
Deletion of Child Data. If we learn that we have inadvertently collected personal data from
a child under the age limit without valid parental consent or a legal
exception, we will take reasonable measures to promptly delete that information
from our records.
8.
DATA SECURITY AND RETENTION
8.1
Security Measures. We take the security of your personal information very seriously.
We implement administrative, technical, and physical safeguards to protect your
data from unauthorized access, loss, misuse, or alteration. These measures
include:
8.1.1
Encryption: We use industry-standard encryption
(such as TLS/SSL) to protect the communication between your device and our
servers and to secure our databases.
8.1.2
Access Control: Access to your personal data is
restricted to authorized employees and contractors who need it to perform their
job duties. We conduct regular security training for our staff to ensure they
understand the importance of protecting user privacy.
8.1.3
Network Security: We use firewalls and intrusion
detection systems to monitor our network and prevent unauthorized access or
hacking attempts.
8.2
No Guarantee.
While we strive to use commercially acceptable means to protect your personal
data, please remember that no method of transmission over the internet or
method of electronic storage is 100% secure. Therefore, we cannot guarantee its
absolute security.
8.3
Data Retention.
We retain your personal data only for as long as is necessary to fulfil the
purposes outlined in this Privacy Policy.
8.3.1
Active Accounts: We generally keep your data for
as long as your account is active or as needed to provide you with the
Services.
8.3.2
Legal & Business Needs: Even if you delete
your account, we may retain certain information if necessary to comply with our
legal obligations (such as tax and accounting laws), resolve disputes, enforce
our agreements, or detect and prevent fraud (e.g., retaining a
"banned" device ID to prevent a cheater from returning).
8.4
Disposal of Information. Once the retention period expires or the data is no longer needed,
we will delete or anonymize your personal data.
8.4.1
Digital Data: Electronic files are permanently
deleted or de-identified so that they can no longer be linked to you.
8.4.2
Physical Media: Any paper records containing
personal data (if applicable) are destroyed by shredding or incineration.
9.
CHANGES TO THIS PRIVACY POLICY
9.1
Updates. We may
update this Privacy Policy from time to time to reflect changes in our games,
technologies, legal requirements, or data processing practices. When we make
changes, we will update the "Last Updated" date at the top of this
policy.
9.2
Notice of Material Changes. If we make material changes that significantly affect your rights
or the way we handle your personal information, we will provide you with
prominent notice before the changes take effect. This may include:
9.2.1
A pop-up notice or banner within the Game;
9.2.2
An email sent to the address associated with
your account (if available); or
9.2.3
Other conspicuous means through the Services.
9.3
Continued Use.
Your continued use of the Services after the effective date of the updated
Privacy Policy constitutes your acceptance of the changes. If you do not agree
to the updated policy, you must stop using our Services and close your account.
10.
CONTACT US
10.1
If you have any questions about this Privacy
Policy, or if you would like to exercise your privacy rights (such as accessing
or deleting your data), please contact us.
10.1.1
Recommended Method: For the fastest response, we
recommend contacting us through the "Help" or "Support"
section inside the game settings. This allows us to quickly verify your account
ownership.
10.1.2
Data Controller: You may also contact us by
email or mail at: GNARLY OYUN TEKNOLOJİLERİ ANONİM ŞİRKETİ
(a)
Email: info@gnarlyteam.com
(b)
Address: Hızır Çavuş Mescidi Sk No: 40/A, Balat,
34087 Fatih/İstanbul, Türkiye