FUNMOTH Oyun Teknolojileri A.S.

PRIVACY POLICY

Version 2

A. DATA CONTROLLER:

Address: Yesilce Mah, Yunus Emre Cad, No:8, K:5, Kagithane/Istanbul

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by Funmoth Games. Together the mobile app/Game(s) and the Website are referred to as the “Online Services”.

As Funmoth Games, we are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “controller”.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in 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 through the Games.

B. THE PURPOSE AND LEGAL BASIS OF PROCESSING

We use information to operate the Services, including:

To administer your account and provide the Online Services to you
To inform you about offers and events
To communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
To improve the Services and develop new ones
To prevent, detect and fight fraud or other illegal or unauthorized activities
To ensure legal compliance and take action against fraudulent or misbehaving players
To verify and confirm payments
To update and develop player profiles
To develop and improve the Online Services and player experience
To provide social features as part of the service
To customize your service experience
To respond to your comments and questions and provide player support
To enable you to communicate with other players

To process your information as described in this Privacy Policy, we rely on the following legal bases:

Legitimate interests: We may use your information where we have legitimate interests to do For example, we analyze our Users’ behavior to improve the Services, to prevent and detect fraud and misuse, and to marketing processes to you.
Consent: With your consent, we can track your user data to provide personalized content and You can opt-out targeted advertising or receive personalized notifications by changing the Privacy settings on your device. By opting out of targeted advertising, your Advertiser ID cannot be shared. You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

● Performance of a Contract

Compliance with a Legal Obligation

You may contact us at privacy@funmoth.com for more information regarding legitimate interests.

C. THE COLLECTION METHODS OF DATA

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your personal data by filling in forms or providing other information via our e-mail address or Google documents.
Automated technologies or As you use our Online Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to the Cookies section in this policy for further details.
Third parties or publicly available We may receive personal data about you from

third parties as set out below:

Technical Data from the following parties: We may receive personal data about you Analytics providers (Google Analytics);

D. Our social media pages

TRANSFERS OF PERSONEL DATA

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets to will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy
Required by law: 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 in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Enforcement: We may also disclose your personal data to third parties in order to enforce or apply the Terms of Use of Funmoth Games, to investigate potential breaches, or to protect the rights, property or safety of Funmoth Games, our customers, or others.
Service providers: We may also disclose your personal data with service providers that operate on our behalf to help support the Online Services in accordance with our instructions (for example, cloud storage providers, payment processors, or analysing and advertising partners). We storage your personal data at Cloud (Microsoft Azure).

We take steps to ensure adequate safeguards are in place to protect your personal data during data transfers.

E. CHILDREN’S INFORMATION

Funmoth Games do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 years of age. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

F. TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use
Web Beacons. Certain sections of our Online Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Funmoth Games, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

● Necessary / Essential Cookies

Type: Session Cookies Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for

cannot be provided, and we only use these Cookies to provide You with those services.

Functionality Cookies Type: Persistent Cookies Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Online Services such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Online Services.

G. RETAINTION PERIOD

We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Websites);
Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
Whether retention is advisable; and considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).

H. RIGHTS OF DATA SUBJECTS

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access: You have the right to request copies of your personal We may charge you a small fee for this service.

The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

The right to erasure: You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

● The right to make a complaint to a Supervisory Authority

If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of

Regulations, you have certain rights in respect of the personal information we hold about you. Under the California Consumer Privacy Act (“CCPA”), among other rights, consumers have the rights:

To know whether their personal information is sold or disclosed and to whom
To say no to the sale of personal information
To equal service and price, even if they exercise their privacy rights

İ. HOW TO EXERCISE THESE RIGHTS

Any requests to exercise data subjects’ rights can be directed to the data controller through the contact details provided in this document. These requests will be addressed by the data controller as early as possible and always within thirty (30) days.