Privacy Policy

Effective Date: 07.12.2023

Updated Date: 07.12.2023

1. PURPOSE

As Lugal Oyun Yazılım ve Pazarlama A.Ş., ("Lugal Games, "we", "us", "us" or "our"), we hereby set forth this "Privacy Policy" to inform you about our policies and procedures regarding the collection, use and sharing of Personal Data about users.

2. SCOPE

This Privacy Policy covers our games, websites, apps, blogs and forums, and other services available through the Apple App Store, Google Play App Store, Facebook and/or other gaming sites (collectively, the "Services"). Our games do not have a specific audience and therefore we take additional steps to limit access to certain features for our games based on the age of the user. For more information, please read the disclosures in the Children's Privacy Policy section below.

Our Privacy Policy may be updated from time to time. Please check our Privacy Policy page periodically for more information. We will notify you of any material changes by posting the new Privacy Policy at the primary access points to the Services, where required, or as required by applicable law.

If you do not want Lugal Games to collect, store, use or share your information in the ways described in this Privacy Policy, you may not use its services.

3. PERSONAL DATA

When using the Services, you may provide us with Personal Data directly or indirectly.

3.1. Directly Acquired Personal Data

When you register as a registered user of the Services, we may directly collect the following Personal Data from you: Your name, e-mail address, postcode and username, which are the Personal Data we collect directly.

We may also receive Personal Data from third parties if you register to use or access the Services through social networking sites (each a "Social Networking Service"), referred to as third parties.

In this case, we may receive, store or use Personal Data that you provide to such Social Networking Services and make available through your account privacy settings. In this context, we may choose to collect the following Personal Data:

- Your name,

- Your profile picture,

- Your friends list (Optional)

- Your IP address,

- Facebook, your other platform profiles and your e-mail address.

Data we receive when you use the Services:

We may also collect the following Personal Data through our website or from your device when you use the Services or access the Services from other (third party) websites:

Operating system, software version, certain information about your computer or mobile device, protocol (IP) address, user settings, MAC address, cookie identifiers, mobile operator, mobile advertising and other identifiers, language, details about your browser, location information (including location inferred based on your IP address), internet service provider, information about the pages you visit before, during and after using the Services, information about the links you click and other information about how you use the Services.

The information we collect may be associated with your account and the devices you use.

Purchase Data:

If you choose to purchase any virtual goods as part of your use of the Services, to the extent available, we or our third party service providers may collect the following types of Personal Data from you to facilitate your payment for such virtual goods:

Purchase history (this does NOT include payment method details or banking information collected and processed by a third party).

Purpose of Processing Personal Data

We process Personal Data for various business purposes, including:

Providing Requested Products, Services or Information, including managing user information and accounts; responding to inquiries, comments and other requests; providing access to certain areas, functions and features of our Services; responding to customer or technical support requests.

We also do so for Administrative Purposes, including measuring interest in and engagement with our Services; conducting research and development; improving or developing new products and Services; maintaining internal quality control; verifying an individual's identity/account; communicating with you about activities and policy changes on our Services; processing your financial information and other payment methods for purchased products or Services; process applications and transactions; preventing potentially prohibited or illegal activities.

Marketing our Products and Services

Communicating with You

Conducting Surveys

Letting You Use Our Interactive Features

Allowing You to Register for Sweepstakes or Competitions

Identifying and Combining Information

If at any time you decide that you no longer wish to receive such notifications from us, please follow the unsubscribe instructions provided in any of our email communications to you.

Other uses

We may use Personal Data for our legitimate interests, research (including marketing research), network and information security and fraud prevention purposes. In addition, Lugal Games may use Personal Data for other purposes that are made clear to you at the time you provide the Personal Data or with your consent.

Cookies, Analytics and Interest-Based Advertising

In addition to third parties providing content, advertising or other functionality on the Services, we may use cookies, pixel tags, local storage and other technologies ("Technologies") to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone or other devices that allow us to record certain pieces of information when you visit or interact with our Services.

Cookies are small text files placed on visitors' device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do so, the Services may not function properly.

A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users' interaction on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We can also add web beacons to emails to recognise whether messages have been opened, acted upon or forwarded.

We may share the advertising identifier associated with your mobile device or tablet (such as Apple IDFA and Google Advertising ID) with advertisers. An advertising identifier is an alphanumeric string that can be used to identify your device so that advertisers can serve you relevant ads. We only use the Apple IDFA as permitted by Apple. Likewise, we only use the Google Advertising ID as permitted by Google. An advertising identifier is assigned by default on your mobile device and ad tracking is enabled. You can limit or even reset the use of your advertising device ID using the privacy settings on your mobile device. In some cases, you may need to reset the operating system to reset the advertising device ID.

We may also use Google Analytics to collect information about visitor behaviour and visitor demographics on our Services.

For more information about Google Analytics, please visit;

visit www.google.com/policies/privacy/partners/.

Cookies and Interest-Based Advertising

You can stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as permitted by your browser or device. Please note that cookie-based opt-outs are not effective on mobile applications. To make individual choices for mobile apps on a mobile device, you can download DAA's AppChoices app from your device's app store. Additionally, you can use your device's platform controls in your settings to make choices on some devices (e.g. Android, iOS, and others). You can also email us at info@lugalgames.com; We will do our best to assist you with your request.

Opting Out of Email and Electronic Communications

If you receive an unsolicited email from us, you can use the unsubscribe link at the bottom of the email to opt out of receiving future emails. Please note that you will continue to receive emails regarding transactions regarding the product or Services you have requested. Regardless of your marketing preferences, we may also send you certain non-promotional communications about us and our Services (for example, communications regarding the Services or updates to this Privacy Policy). We will obtain your consent where required by applicable law before sending you our promotional emails. We may send you notifications through our mobile application. You can change the settings on your mobile device at any time. We may also collect geolocation information if you use our mobile applications. You can change the settings on your mobile device to stop this.

Third Party Websites/Apps and Software Development Kits

The Services may contain links to other websites/applications, and other websites/applications may reference or link to our Services. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of every website and application they interact with. We cannot endorse and are not responsible for the privacy practices or content of such other websites or applications. You visit these other websites or applications at your own risk.

We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties, including advertising partners, to collect your Personal Data to provide content more relevant to you. For more information about our use of APIs and SDKs, please contact us as indicated below.

Data Sharing and Disclosure

At LUGAL Games, we do not sell your Personal Data to third parties and have not sold your Personal Data in any period in the past. However, to provide a more relevant advertising experience, we may allow third-party advertising partners to set Technologies and other tracking tools on our Services that collect information about your activities and your device (e.g., your IP address, mobile identifiers, page).

We may also combine and share this and other information (such as demographic information and past purchase history) with our third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) to serve you targeted ads in our games or when you visit third-party websites or applications that use their networks. This practice is often referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your Personal Data with third-party advertising partners, you can follow the instructions in the “Cookies and Interest-Based Advertising” section above.

Service providers:

We may share the Personal Data we collect about you with our third-party service providers. The types of service providers to whom we entrust personal information include service providers for the provision of the Services, provision of information, products and other services you request, marketing and advertising, analytics, customer service activities and IT and related services.

Disclosures to Protect Us or Others:

We may access, preserve and disclose your Personal Data, other account information and content if we believe that such action is necessary or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; to enforce our policies or agreements; to collect amounts owed to us; when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with the investigation or prosecution of suspected or actual illegal activity; or if we believe in good faith that disclosure is necessary or advisable.

Social Networking Services:

We may share information from your LUGAL Games account profile (including your Personal Data) with the Social Networking Service you have linked to your LUGAL Games account to provide you with enhanced services. These third parties have access to your Personal Data only for this purpose (unless they have legitimately received your Personal Data independently of the LUGAL Games service) and are obliged not to disclose or use it for any other purpose.

Business Transfers:

LUGAL Games may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, acquisition, reorganization, acquisition or sale of assets, transition of service to another provider.

Individual Rights in Personal Data

As a user of LUGAL Games, you benefit from the rights implemented in this section in accordance with applicable law. If you would like to exercise any of your rights or receive further clarification about them, please contact us using the contact details at the bottom of this Privacy Policy. Please note that some of these rights may be pre-distributed by certain legal means so you and your private repositories may be up to date.

Right of access

You may not be able to consent to our encryption of your Personal Data and gain access to your Personal Data. If you have any questions regarding the transaction or you can learn more about Personal Data regarding the assistance we may use, you can always contact us if you wish and we will be sure to provide you with further information.

You may be free to request that we correct information we have stored incorrectly. You may also have the right to have incomplete personal information completed, including by making an additional declaration.

Right to erasure / Right to be forgotten

You cannot request us to permanently delete your Personal Data. You may make such a request, for example, if the Personal Data is no longer necessary in relation to the purpose for which the Personal Data was collected or otherwise processed.

Right to Object

You may have the right to object to our processing of your Personal Data. If we object to our processing activities, you may not be able to use all of our Services.

Right to lodge a complaint with a supervisory authority

If you are not satisfied with the way we process your Personal Data, you can always contact us to resolve the issue. However, you do not always have to file a complaint with a supervisory authority.

Right to Withdraw Consent

To the extent that our processing of your Personal Data is based on your consent, you may have the right to withdraw that consent at any time. Withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

Security

LUGAL Games is interested in protecting your personal Data and takes steps to ensure that your Personal Data is processed securely and in accordance with this Privacy Policy.

Unfortunately, the Internet cannot be guaranteed to be 100% secure and we cannot guarantee the cost of Personal Data displayed to us. To the maximum extent permitted by applicable law, we declare that we exclude liability for inadvertent disclosure.

Phishing

Identity theft and the practice now known as “phishing” are major concerns for our business. Protecting information that will help protect you from identity theft is the most important visibility. We never, and will not, request your credit card information, “account ID,” login password, or national identification numbers in an unsecured or unsolicited email or telephone communication.

Storage period

We will retain and protect your Personal Data for as long as you use our Services or as necessary to fulfill the purpose(s) of collection, resolve disputes, establish legal defenses, conduct audits, maintain legitimate business purposes, our agreements.

Personal Privacy Policy for Children

Generally, our Services do not collect free personal data from children. If we receive a box of Personal Data, we delete all Personal Data we have collected unless we have a legal obligation to preserve it. Additionally, to provide access to games that are not directed to children but still appeal to them, we take additional steps to limit access to these Services based on the development of their information. For these services, we will limit certain access when a user is tracked under 13 (or the applicable age zone in their region), such as social media plug-ins, chat features, and certain types of notification alerts.

Additionally, we limit the filling and sharing of Personal Data to only what is necessary to support internal parts of our Services. As a parent, if you have any concerns about the service, benefit from the information taught, or would like this information to be changed or deleted, you can contact us at info@lugalgames.com.

If you have any questions about this Privacy Policy or would like to make a request to exercise your rights detailed in this policy, please contact us at: info@lugalgames.com

policy, please contact us at info@lugalgames.com.

Thank you!