Privacy

1. INTRODUCTION

• Imaginite Studios Studios Teknoloji Anonim Sirketi (imaginite Studios, We or Us) develop and publish interactive social games for web and mobile platforms. This Privacy Policy ("Policy") outlines the methods by which imaginite Studios collects, stores, uses, discloses, or otherwise processes the personal information of our users ("users" or "you") in the context of their engagement with our products and services. These include our website accessible at https://www.imaginitesoft.com/ and any mobile game, application or other service provided under the imaginite Studios brand that references or links to this Policy (individually a "Service" and collectively, "Services").
• Furthermore, this Policy details the rights and options available to you regarding your information as you use our Services. If you have any questions about this policy or our overall privacy and data protection practices, please feel free to reach out to the imaginite Studios Data Protection Officer, as detailed in the contact section of this policy.

2. THE DATA WE COLLECT

• imaginite Studios does not collect any data that directly identifies you. We gather mobile identifiers and other technical details (with your consent, when necessary) to recognize your device.
• When you use our apps and services, we employ cookies and similar technologies to gather data about; (1) the apps you utilize, (2) your IP address, (3) your Mobile Advertising ID (Apple IDFA or Google AAID—technical identifiers created by mobile operating systems for advertising purposes, which you can control, reset, or erase at any time through your device settings) and device identifier (e.g., IDFV for iOS devices and Android ID for Android devices) (4) details about your device and connection (user agent, connection type, timestamp, system language, device model, screen resolution and settings, battery level, available storage space, time zone, operating system) (5) Data related to your activities within our applications, particularly how and when you interact with our applications and the advertising displayed within them (e.g., number of ads viewed, clicks on ads)
• In relation to certain Services, we will generate and assign an identifier to your device, connected to an account number. Under certain circumstances, we may also collect the name associated with your device, device type, telephone number, and country. Additionally, you may choose to provide further information such as your username, character name, or email address. We may also deduce your approximate geographic location from your IP address.
• We offer the possibility to create a user profile that can be viewed by other users of imaginite Studios. When setting up your Account, you might provide details such as your name, username, email address, password, and other information to help verify your identity when you access your account. This can be done through in-game dialog boxes, which you have the option to bypass.
• In some of imaginite Studios’s apps we may collect and securely store your email address in a hashed format within our database, solely for account recovery and customer support purposes. Your email will not be shared with any third party without your consent. With your consent, we may also use your email address to keep you updated about app and game updates and promotions.
• Whenever you make a purchase through the applications we collect non-financial transaction details. These details include the type of item purchased, its price, and the date of the transaction.
• We generally do not request or solicit sensitive or special categories of information. The definition of sensitive or special categories of information can vary by jurisdiction, but it may include data such as health, genetic or biometric details, or precise location information.

3. HOW WE USE YOUR PERSONAL DATA

• We use the information collected through our applications for the following purposes when you utilize our services:
• We use Personal Data for the following purposes:
• Service Delivery:
• To create and manage your service accounts, enabling access to our games and services.
• To authenticate your identity and provide access to additional features.
• To operate and improve our services, enhancing your user experience based on your preferences and interactions.
• To provide customer support and technical assistance.
• To communicate with you regarding service-related information, such as confirmations, maintenance notices, and administrative messages.
• To manage and deliver in-game communications and promotions, such as updates, new features, and special events.
• To enable interactions among players and suggest potential connections within the game.
• To prevent and address fraud, unauthorized or illegal activities, and ensure compliance with our terms of use.
• Marketing and Advertising:
• To deliver targeted advertising and promotional materials based on your in-game activities and preferences.
• To communicate with you about promotions, contests, and upcoming events through various channels including email and push notifications.
• Research and Development:
• To analyze game usage and player interactions for continuous improvement of our services.
• To aggregate data for statistical analysis to enhance game features and user experience.
• To conduct surveys and research to understand player preferences and improve our offerings.
• Compliance and Protection:
• To comply with legal obligations, respond to lawful requests, and protect the rights and safety of our users and our services.
• To enforce our terms and conditions and protect our services from fraudulent or illegal activities.
• Consent and Control:
• We process your Personal Data based on your consent in scenarios where you opt-in for marketing communications or when accepting cookies on our sites.
• You have the right to withdraw your consent at any time by contacting us as detailed in our privacy policy.
• Legitimate Interests:
• We process your Personal Data based on legitimate interests to maintain and enhance our services, serve effective advertisements, and improve customer interactions.
• Security Measures:
• We implement robust security measures to protect your data from unauthorized access, alteration, and potential threats.
  
• The chart in the “Sharing of Your Information” Section above summarizes the categories of personal information we collect, the sources of personal information collection, the business purposes for our collection, and the categories of third parties with whom we “disclose,” “sell,” or “share” personal information. The chart describes our practices, both current and during the last 12 months.
  
  
  
  

• Push Notifications
• Our Service might send you push notifications to provide updates about games, high scores, and other relevant service announcements, as well as marketing messages. You have the option to stop receiving these communications at any time by using the "unsubscribe" link or by disabling them in your device's settings.
  
  

4.HOW WE SHARE YOUR PERSONAL DATA

• Your information may be disclosed to our professional advisors such as lawyers, auditors, bankers, and insurers, when it's necessary for the services they offer to us. Additionally, in situations like mergers, acquisitions, reorganizations, bankruptcies, or similar events, we may transfer or share your information with entities that assume our business responsibilities.
• Internet Based Advertising
• Our services may feature advertisements, and with your consent where required, we allow third-party advertising networks and social media companies to collect information about your interaction with our services. This data collection is mainly conducted through cookies and similar tracking technologies. The information collected typically includes:
• Technical details about your device (make, model, operating system, screen properties, audio settings, battery life, etc.).
• Connection specifics (carrier, connection type and speed, IP address).
• User demographics (country, time zone, language settings, gender).
• Behavioral data (interaction with services, browsing history, advertisement clicks).
• Location data (city and/or country-level).
• Identifiers (browser user-agent, advertising IDs such as IDFA for iOS and GAID for Android).
• The collected information is used to:
• Deliver personalized advertising content based on your past interactions and preferences.
• Assess the effectiveness of advertisements.
• Conduct analytics and market research to optimize and improve the advertising experience.
• Provide reports and insights regarding advertising performance.
• You have various options to control and restrict how your personal information is used for interest-based advertising:
• Device-Level Settings:
• You can adjust your mobile device's settings to limit ad tracking by disabling features that allow apps to request tracking or by utilizing other privacy-related settings.
  
• Ad Interaction:
• Some ads may provide a direct option to opt-out of interest-based advertising through an icon displayed on the ad itself.
• Online Tools and Preferences:
• Manage specific ad preferences through tools like Google's Ads Preferences Manager available at Google Ads Preferences Manager.
• Broader opt-out resources are also available through the Network Advertising Initiative and Your Online Choices websites.
• Effectiveness and Limitations:
• Opting out does not prevent the display of ads; instead, it makes the ads you see less targeted to your interests.
• Opt-outs need to be applied on each browser or device you use, as they are not automatically synchronized across different platforms.
• If you reset your browser or use a new device, you may need to opt-out again.
• Third-Party Control and Responsibility:
• Note that these opt-out tools are managed by third parties, and we do not control or guarantee their effectiveness or compliance.

Third parties may still use cookies for purposes other than interest-based advertising, such as analytics and fraud prevention.



5.YOUR RIGHTS

• Depending on your residency, consumer privacy laws may grant you additional rights concerning your personal information. These rights may include:
• Right to Access and Data Portability:
• You can request access to the personal information we've collected about you, up to twice per year. This includes information categories, collection sources, the purpose for processing, and disclosure details. You may also ask for your personal data in a commonly used, machine-readable format, although certain information may be exempt from disclosure under applicable laws.
• Right to Deletion:
• You have the right to request the deletion of your personal data, with some exceptions. For instance, we may retain information necessary for service provision, legal compliance, fraud prevention, or other lawful internal uses.
• Right to Correction: 
•  If your personal information is inaccurate or incomplete, you can request a correction.
• Right to Restrict Processing:
• Under specific conditions, such as disputed data accuracy or unlawful data use, you can request restrictions on processing your data.
• Right to Object:
• You may object to our processing of your data for direct marketing, research, or other specific legal grounds.
• Right to Opt-out of Automated Decisions and Profiling:
• Certain jurisdictions give you the right to opt-out of automated decision-making and profiling that significantly affects you. We do not engage in such profiling.
• Right to Opt-out of Targeted Advertising:
• You may opt out of data processing for targeted advertising. Our privacy policy explains how to disable targeted advertising by adjusting your settings or through specific requests.
• Right to Nondiscrimination:
• We will not discriminate against you for exercising your privacy rights. This includes not altering the price, quality, or level of services unless legally allowed incentives are applied.
• Exercising Your Rights
• Contact us at privacy@imaginitesoft.com to exercise your rights. Verification of identity is required, and you may appoint an authorized agent to act on your behalf. We aim to respond within one month but may extend this period or decline requests under certain conditions, which will be explicitly explained.
• Responses to Requests:
• If you have an account, we'll respond within it; otherwise, we'll respond by mail or electronically, depending on your preference.
• Authorized Agents:
• Rights can be exercised by you or an authorized representative, whom we may require additional verification to recognize, unless a valid power of attorney is provided.

6.YOUR CHOICES REGARDING DATA COLLECTION, USE, AND DISCLOSURE

• We offer various options to manage the collection and use of your personal information, which may vary by the specific services you utilize.
• Managing Tracking Technologies:
• You can configure your browser to block or alert you about browser cookies and other tracking technologies. Note that disabling cookies may affect the functionality of certain parts of our Services.
• Opting Out of Targeted Advertising:
• To prevent your information from being used for targeted advertising, you can take the following actions:
• Mobile Applications:
• Enable privacy settings on your mobile devices:
• For Android, activate “Opt out of interest-based ads.”
• For iOS, use the “Limit Ad Tracking” feature and reset your advertising identifier.
• Industry Programs:
• Opt out of targeted advertising through industry groups like the Network Advertising Initiative (NAI) and Digital Advertising Alliance (DAA) by visiting their opt-out pages. This will stop targeted ads but not all advertising.
• Tools for Google Services:
• Google provides tools such as the Google Analytics opt-out browser add-on, which allows you to block the use of data by Google Analytics.
• Additional Rights:

Residents in certain states or countries may have further rights regarding personal information. Please refer to the “Your Rights” section.



7.LEGAL BASIS FOR PROCESSING DATA

For EEA and UK Citizen

If you reside in the European Economic Area (EEA), UK, or a country with similar privacy regulations, we process your personal information based on one or more of the following legal grounds, aligned with the purposes described below:

• Consent: We process your personal information when you have explicitly agreed to this processing.
• Contractual Necessity: We process your personal information when it's necessary to:
• Deliver our Services and any other features you may request or enable;
• Handle your purchases and payment instructions;
• Fulfill and enforce our agreements with you, including our Terms of Service.
• Legal Obligations: We process your personal information when it is necessary to comply with legal requirements, such as responding to a court order or subpoena.
• Vital Interests: We process your personal information when necessary to protect the essential interests of a user or another person, which includes:
• Preventing and addressing fraud, abuse, or illegal activities that could harm you or others.
• Legitimate Interests: We process your personal information when it is necessary for our legitimate interests or those of a third party, provided these interests are not overridden by your rights and freedoms. This includes:
• Providing customer service and technical support;
• Delivering targeted advertisements based on your preferences;
• Detecting and resolving any security or technical issues.

For GDPR

• imaginite Studios commits to respecting the confidentiality of your personal data and ensuring you can exercise your rights. Under this Privacy Policy, and by law if you are within the EU, you have the right to:
• Request access to your personal data. The right to access, update or delete the information we have about you. Where possible, you can directly access, update or request deletion of your personal data within your account settings. If unable to do so yourself, please contact us for assistance. This also allows you to receive a copy of the personal data we hold about you.
• Request correction of your personal data that we hold. You have the right to have any incomplete or inaccurate information we maintain about you corrected.
• Object to processing of your personal data. This right applies where we rely on a legitimate interest as the legal basis for processing and there is something about your particular situation that makes you want to object to our processing of your personal data on this ground.
• Request erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no reasonable need for us to continue processing it.
• Request transfer of your personal data. We will provide your personal data to you or a third-party of your choosing in a structured, commonly-used, machine-readable format. Note this right only applies to automated data which you initially consented for us to use or where we used it to perform a contract with you.
• Withdraw your consent. If we obtained your consent to use your personal data, you have the right to withdraw that consent. If withdrawn, we may not be able to provide access to certain specific service functionalities.

For Residents in Republic of Turkiye

Under Article 11 of the Law, as data subjects, you have the following rights against imaginite Studios, acting as the data controller:

• To learn whether your personal data has been processed,
• To request information if your personal data has been processed,
• To learn the purpose of processing your personal data and whether they are used for intended purposes,
• To know the third parties to whom your personal data is transferred within Turkey or abroad,
• To request the deletion, destruction, or anonymization of your personal data in case the reasons necessitating their processing cease to exist, and to request that the process be notified to the third parties to whom the personal data has been transferred,
• To object to an outcome that is to your detriment by means of analysis of the processed data exclusively through automated systems,
• To claim compensation for damages caused by the unlawful processing of your personal data.
• You can submit your requests related to your rights mentioned above by filling out the "Personal Data Owner Application Form" and sending it to privacy@imaginitesoft.com with the required information for your identification, either signed with a secure electronic signature or by sending a wet-signed copy of this form in person, through a notary, or by registered mail to Şehit Muhtar, Tarlabaşı Blv No: 150 K:5, D:49, 34435 Beyoğlu/İstanbul, In case a third party submits the request on behalf of the personal data owner, you must also submit a power of attorney issued through a notary on behalf of the person making the request.
• imaginite Studios declares and undertakes to finalize your application within a maximum of thirty days free of charge by providing a written response as provided by the Law, depending on the nature of your request. However, if the transaction requires an additional cost, imaginite Studios reserves the right to charge a fee as determined by the Board.
• If your application is rejected under Article 14 of the Law, if you find the response insufficient, or if you do not receive a timely response, you have the right to file a complaint with the Board within thirty days from the date you learn of the response and in any event within sixty days from the date of the application.
• For Residents of California, Virginia, Connecticut, Utah, and Colorado
• All sources of personal data collected are outlined in the "Information We May Collect and How We Collect It" section above and retained according to the "Data Retention" section above. The reasons for our collection of this information are described in the "How We Use Information" section above. Over the past 12 months, we have disclosed (or enabled you to disclose) the following categories of personal information to third parties for business or commercial purposes:

8.HOW WE STORE YOUR PERSONAL DATA

imaginite Studios will keep your Personal Data only for as long as it's needed for the purposes outlined in this Privacy Policy. We'll retain and use your Personal Data as required to meet our legal obligations (such as retaining your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Additionally, imaginite Studios will retain Usage Data for internal analysis purposes. Usage Data is typically kept for a shorter duration, unless it's used to enhance security or improve our Service's functionality, or if legal requirements mandate its retention for longer periods. imaginite Studios will keep your Personal Data only for as long as it's needed for the purposes outlined in this Privacy Policy. We'll retain and use your Personal Data as required to meet our legal obligations (such as retaining your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Additionally, imaginite Studios will retain Usage Data for internal analysis purposes. Usage Data is typically kept for a shorter duration, unless it's used to enhance security or improve our Service's functionality, or if legal requirements mandate its retention for longer periods.

9.WHERE WE STORE YOUR DATA

Your personal information may be stored and processed outside of your country or jurisdiction. This may involve personnel from our affiliates and third-party service providers

who operate outside of your country or jurisdiction. We take reasonable steps to ensure that these third parties implement commercially reasonable security measures to protect your information. However, it's important to note that data protection laws in other countries may not offer the same level of comprehensive protection as those in your country of residence. By using our Services, you consent to the transfer of your personal information to recipients in other countries, including networks like Google Cloud, AWS, and Microsoft Azure, and to the storage and processing of your information on servers located in other countries, for the smooth use and provision of game services.

10.CHILDREN’S PRIVACY

We have safeguards in place to prevent the collection of personal information from minors under the age of 18 through our Games We also do not knowingly share such data with our service providers. Third-party service providers have their own terms and policies, and we advise parents and legal guardians to supervise their children's online activities and teach them not to share information without permission.

We do not sell personal information of individuals we know are under 18 years old without affirmative consent. Those who opt-in to such sales can opt-out at any time. To do so, you can contact us to submit a request.

If you suspect that a child under 13 (or 16) has provided us with personal information, please contact us with sufficient details so we can promptly delete that information.

11. CONTACT

Here is the contact information for our Data Protection Officer:

Email: privacy@imaginitesoft.com Address: Şehit Muhtar, Tarlabaşı Blv No: 150 K:5, D:49, 34435 Beyoğlu/İstanbul/Turkiye