BIGGER OYUN YAZILIM VE PAZARLAMA A.S.

PRIVACY AND COOKIE POLICY

Last updated: 31 January 2021

We are committed to respecting your privacy and protecting your personal data. This privacy and cookie policy (“ Policy ”) sets out how we use data relating to you and applies to all use of your personal data by Bigger Oyun Yazilim ve Pazarlama A.S., a company registered in Turkey under tax number 1680978598 and with registered office Esentepe Mah. Büyükdere Cad. Apa Giz Plaza No:191 Sisli/Istanbul (“ we ”, “ us ” or “ our ”).

This Policy sets out the basis on which personal data will be processed by us. This Policy applies to personal data we may collect from you, or that you provide to us, through or in connection with our games for which we make this policy available (each a “ Game ”). This Policy also applies for our websites where we make this Policy available (each a " Website "). Our Games and Websites are together the “ Services ”. Please read the Policy carefully to understand our views and practices regarding your personal data.

If there are certain games or sites for which the data processing activity differs from what is set out in this policy, we would then need to consider further and either update the policy or provide a separate policy for the game/website which differs from the others.

We will only collect and process information about you in accordance with this Policy and we will only use information collected about you in accordance with applicable data protection laws including without limitation the Data Protection Act 2018 and the UK GDPR (as defined in the Data Protection Act 2018) and Turkish Law on Protection of Personal Data numbered 6698. Where we decide the purpose or means for the processing of the personal data that you provide when using our Services, we are the “data controller”.

You have the right to object to the processing of your personal data, including where your personal data is being processed for direct marketing purposes. Further information on this right, and your other rights, is set out below.

If you have any concerns over privacy, or this Policy, contact us at info@biggergames.com .

  1. HOW WE COLLECT AND USE YOUR PERSONAL DATA
  1. The table below explains what data we collect, how we use it, and which recipients it might be shared with.

Your data

How we use it

Third Party Recipients

Game support / enquiry information ( information we receive when you get in touch with us for support through the Game or by email ):

  • Name;
  • Contact details (address, phone number, email); and
  • Other personal data you choose to send to us.

We process this information in accordance with the terms of our contract with you (where we need this information to provide our services to you such as under our Terms of Use or End User Licence Agreement) and in pursuit of our legitimate interests in responding to your enquiry and also in order to improve our services (such as where you notify us of a problem or a Game issue).

N/A.

Website support / enquiry information ( information we receive when you get in touch with us via our Website ):

  • Name;
  • Contact details (address, phone number, email); and
  • Other personal data you may send to us.

In line with the legitimate interest we have in promoting our business, we will process your enquiries to provide you with information about the services we offer.

This might include replying to your enquiry. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our services.

You are under no obligation to provide us with any details, but if you don’t provide all relevant information, we may not be able to help.

N/A.

Game analytics and usage information (collected automatically when you play the Game, or which may be available to us from Game platforms / stores):

  • IP address;
  • Location (country and city);
  • Country of install and language;
  • IDFA and/or AAID (advertising-related identifying data);
  • Unique device ID, hardware manufacturer and model;
  • Operating system and version;
  • Relevant Game and version; and
  • ‘Events’ related to Game usage, such as progress, achievement of a milestone and the occurrence of other particular events during your Game usage (such as Game installation/uninstallation, play session durations and choices/selections for different parts of the Game, interactions with Game content and timestamps),

(“ Game Technical & Usage Data ”).

We may collect this data so that we can understand usage of our Game, analyse and improve our Game and develop new services or new parts thereof. In some cases it may also help us to identify problems (e.g. bugs or problems preventing in-Game progression).

In many cases the data would be aggregated and/or anonymised so that it would not identify you.

To the extent this data includes your personal data, we rely upon your prior consent for us to process it for our analytics and research and development purposes. You can withdraw your consent at any time by contacting us.

Third parties who provide us with services, such as for analytics, advertising or attribution, may receive this information. Please see our Cookie Policy, below, for the list of our partners.

In-Game advertising related data ( processed when you are using the Game, to allow us and our vendors to serve advertising) :

We may process your Game Technical & Usage Data for this purpose.

General display advertising

In order to support us being able to make our Game available on a free-to-play basis, our Game includes advertising. Game Technical & Usage Data may be processed in order to ensure the correct serving of the advertising to you (such as to ensure it displays correctly on your device).

To the extent the advertising served to you is not customised to your perceived interests, we rely upon our legitimate interests for the data processing involved – being our interests in promoting the success of our business by being able to generate revenues to support the Game's availability.

Interests-based advertising

In some cases the advertising content may be tailored to your perceived interests by our advertising services vendors. This is in order that advertising can be served to you which may be more interesting to you.

To the extent the advertising served to you through the Game by our advertising vendors is tailored to your perceived interests, we rely upon your express prior consent. You can withdraw your consent at any time upon notice to us or by (if we may make these available) utilising in-Game privacy settings.

Please see our Cookie Policy, below, for the list of our partners who process information in this way to serve advertising through our Games.

Competition and promotion related entry data ( where you may enter a competition / prize promotion with us (such as over email or over social media) ):

  • your entry contact information (e.g. social media username or email);
  • information submitted as part of your entry; and
  • information submitted so we can process your entry (such as your address, if we need to send you a prize).

We may from time to time operate prize promotions and competitions (without any obligation to do so). If we do, your personal data processed in connection with that activity would be processed on the basis of performance of a contract (being the competition / prize promotion terms of entry).

N/A

The following may be processed to fulfil orders for in-Game content and purchases (where made available):

  • Your order information;
  • Your mobile device’s unique device ID;
  • Your user/account ID (where applicable);
  • Your email address; and
  • Your name.

If you make purchases through the Game, your order and information may be processed so that you can access these features within the Game and for us to fulfil your order.

For the above purposes, we rely upon the legal basis of performance of a contract, being our Terms of Use or End User Licence Agreement with you.

First-party application stores, such as the Apple App Store or Google Play Store.

For the purposes of our advertising attribution activities, we may process the following personal data:

Game Technical & Usage Data.

We may process information about you so that we can understand which of our partners, or our marketing campaigns or adverts, directed you to us (such as to install our Game).

Attribution information enables us to promote the success of our company by better understanding the comparative successes of our marketing and our partners’ efforts, so that we can be more efficient with our marketing and our arrangements with partners.

We process this information on the basis of our legitimate interests, being our interests to promote the success of our company.

Please see our Cookie Policy, below, for the list of our partners who process information in this way.

Device-level consents and push notifications.

Most smartphone and tablet devices compatible with the Games provide in-device privacy control mechanisms such as that the device may require your prior consent (to your device provider) in order for the Application to access certain device data and to provide you with certain Game functionality.

You can control your device-level consents by selecting your preferred option in the ‘pop-up’ option your device presents to you at the relevant time. Also, you may be able to edit your preferences later in the 'settings' options available from your device provider.

Your editable consent preferences may include, for example, whether you would like the Game to send you 'push notifications' on your device or not.

N/A

Information received from social media partners, such as Facebook.

In some cases, where we make the functionality available, you may be able to connect your social media account to your Game user account with us. If you choose to do this, the social media platform will share certain of your information with us, such as your email address and other information relating to your social media profile.

The social media platform, such as Facebook, will not share this information with us unless you consent first. You can also edit your consent preferences in your social media profile (such as in your Facebook profile settings) anytime afterwards.

N/A

  1. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
  1. You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:
  • for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
  • to restrict, stop processing, or to delete your personal data;
  • for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
  • to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/ .

Whereas, if you are located in Turkey and our data processing operations are subject to Turkish Law on Protection of Personal Data numbered 6698, you will have the following rights in relation to your personal data:

  • Learn whether personal data  relating to you are being processed;
  • Request further information if personal data relating to you have been processed;
  • Learn the purpose for the processing of personal data and whether they are being processed in compliance with such purpose;
  • Learn the third-party recipients to whom your personal data are disclosed to,
  • Request correction of the personal data which is incomplete or inaccurate and request such corrections to be notified to third parties to whom your personal data have previously transferred;
  • Request deletion or destruction of personal data in the event that the data is no longer necessary in relation to the purpose for which the personal data was collected, despite being processed in line with the laws and request such process to be notified to third parties to whom your personal data have previously transferred;
  • If and where applicable, object to negative consequences that have arisen as a result of analysis of your personal data by us through solely automatic means;
  • Claim compensation in relation to any damages you have suffered as a result of our improper handling of your personal data.         
  1. To make a request in relation to any of the aforementioned rights, please send your request to info@biggergames.com .
  2. You may request deletion of your personal data by sending an e-mail to info@biggergames.com . Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.
  3. For data processing activities for which we rely upon your consent, you can withdraw your consent at any time by using the tools provided (if applicable, such as in-Game or through your device settings) or otherwise by contacting us at info@biggergames.com .
  1. DISCLOSURE OF YOUR PERSONAL DATA
  1. We will share your personal data with third parties only in the ways that are described in this Policy.
  2. Group, suppliers, subcontractors, service providers.  We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.
  3. Government authorities.  In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
  4. Potential acquirers or investors . If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the website of any changes in ownership or use of your personal data, as well as any choices you may have.
  5. Enforcement.  We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.
  6. Stores.  We may also disclose your personal data, to the extent necessary, to game / application stores or platforms (such as the Apple App Store and Google Play Store) if that is required, for example, for fulfilment of an order you make (e.g. if needed to fulfil a mobile game DLC order) or in order to investigate or prevent fraud. Such platforms and stores may also process your information in order to provide you with cross-device access to your current position in the Game and your in-Game progression, for example.
  7. We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.
  1. DATA RETENTION
  1. We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy.
  2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
  1. SECURITY
  1. We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Services taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Service visitors and customers.
  2. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
  1. INTERNATIONAL DATA TRANSFERS
  1. Where necessary, there are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission, such as the European Commission’s standard contractual clauses, or other appropriate measures.
  2. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at info@biggergames.com .
  1. CHILDREN

We do not use the Services to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at: info@biggergames.com . We will delete such information within a reasonable time.

  1. GENERAL
  1. If you follow a link from the Service to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites.
  2. We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email.
  3. All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours or otherwise within a reasonable time.

CONTACT US

E-mail: info@biggergames.com  


COOKIE POLICY

Cookies (and equivalent technologies in the context of mobile devices) are small text files that are placed on your device by websites that you visit and mobile applications you use. They are widely used in order to make websites and applications work, or work more efficiently, as well as to provide information to the owners of the sites and apps.

The below explains the main cookies we use in our Games and why:

Cookie/SDK/API

Purpose/ Third Party Access

Facebook

This technology enables us to collect analytics about how our Game is used. The analytics collected is shared with Facebook.

This technology also assists us in our marketing activities, by allowing us to: (i) provide you with advertising more tailored to your interests when marketing to you through Facebook or third parties (this may include re-targeting advertising and/or Facebook advertising services); (ii) so that we can serve in-Game advertising to you; and (iii) understand which of our advertisements were successful, by way of attribution, enabling us to make our marketing more efficient.

You can find out more about Facebook’s privacy practices here .

MoPub

(a Twitter company)

This technology enables MoPub collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient (such as by allowing us to understand when an advert results in you installing our Game), as well as enabling us  to serve, and customise based on your perceived interests, advertising in our Games.

MoPub (a Twitter company) receives your data in order to do this. You can find out more about MoPub’s privacy practices here .

AppLovin

This technology enables AppLovin to: collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient (such as by allowing us to understand when an advert results in you installing our Game); and serve advertising in our Games, which may be customised based on your perceived interests.

The data is shared with AppLovin. You can find out more about AppLovin’s privacy practices here .

ironSource

This technology enables ironSource to: collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient (such as by allowing us to understand when an advert results in you installing our Game); and serve, and customise based on your perceived interests, advertising in our Games.

ironSource receives your data in order to do this. You can find out more about ironSource’s privacy practices here .

Tenjin

This technology enables Tenjin to collect analytics data from your device and to provide us with analytics dashboard information for our use. Tenjin receives your data in order to do this. You can find out more about Tenjin’s privacy practices here .

Adjust

This technology enables Adjust to collect analytics data from your device and to provide us with analytics dashboard information for our use. Adjust receives your data in order to do this. You can find out more about Adjust’s privacy practices here .

Inmobi

This technology enables Inmobi to serve, and customise based on your perceived interests, advertising in our Games. Inmobi receives your data in order to do this. You can find out more about Inmobi’s privacy practices here .

Vungle

This technology enables Vungle to: collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient; and to serve, and customise based on your perceived interests, advertising in our Games.

Vungle receives your data in order to do this. You can find out more about Vungle’s privacy practices here .

Chartboost

This technology enables Chartboost to: collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient (such as by allowing us to understand when an advert results in you installing our Game); and to serve, and customise based on your perceived interests, advertising in our Games. Chartboost receives your data in order to do this.

You can find out more about Chartboost’s privacy practices here .

AdColony

This technology enables AdColony to: collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient (such as by allowing us to understand when an advert results in you installing our Game); and serve, and customise based on your perceived interests, advertising in our Games. AdColony receives your data in order to do this. You can find out more about AdColony’s privacy practices here .

Fyber

This technology enables Fyber to serve, and customise based on your perceived interests, advertising in our Games. Fyber receives your data in order to do this. You can find out more about Fyber’s privacy practices here .

Pangle

This technology enables Pangle to serve, and customise based on your perceived interests, advertising in our Games. Pangle receives your data in order to do this. You can find out more about Pangle’s privacy practices here .

Smaato

This technology enables Smaato to serve, and customise based on your perceived interests, advertising in our Games. Smaato receives your data in order to do this. You can find out more about Smaato’s privacy practices here .

Tapjoy

This technology enables Tapjoy to: collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient (such as by allowing us to understand when an advert results in you installing our Game); and to serve, and customise based on your perceived interests, advertising in our Games. Tapjoy receives your data in order to do this. You can find out more about Tapjoy’s privacy practices here .

Unity Ads

This technology is used in order to (A) enable us to serve advertising in our Game, from Unity Ads; and (B) for Unity to collect and provide us with information that assists us with our advertising activities on third party platforms, enabling our marketing to you on third party platforms to be more efficient (such as by allowing us to understand when an advert results in you installing our Game). The data is shared with Unity, so that Unity can provide us with these services. You can find out more information about Unity Ads’ (Unity Technologies’) privacy practices here .

Google Firebase

This technology is used to collect analytics information about how players use our Game. We use the information to compile reports and to help us improve our Game. The data is shared with Google, for Google to provide us with these services. Google’s privacy information is available here . You can also read Google’s overview of privacy and safeguarding data here .

Google Admob

This technology is used to serve, and customise based on your perceived interests, advertising in our Games. Google’s privacy information is available here. You can also read Google’s overview of privacy and safeguarding data here.

Google Ads

This technology is used to serve, and customise based on your perceived interests, advertising in our Games. Google’s privacy information is available here. You can also read Google’s overview of privacy and safeguarding data here.

COOKIE DURATIONS

As the above devices are contained within the Games (as may vary between each of our Games), the duration for which they are on your device will be the same as the duration for which the Game is installed on your device.

HOW DO I CHANGE MY COOKIE SETTINGS

For some of our Services, we may provide you with in-Service preference tools which you can use to edit your cookie preferences in-Game. Most web browsers and mobile devices allow some control of most cookies and similar devices through the browser and mobile device settings. To find out more about cookies, including how to see what cookies have been set, visit  www.aboutcookies.org . Your mobile or tablet device provider may also provide you with additional cookie and browser control options, which may be available to you in your device settings – please consult your device settings for such device-specific controls (if applicable).