Introduction

This Privacy Policy was issued by GG Studio Yazılım A.Ş. (“Gulliver’s Games”, “GG”, “We”, “us”) and the purpose of this Privacy Policy is to provide information on the collection, processing and use of the data provided by you in connection with the use of the Games. (as defined below)

GG Studio Yazılım A.Ş. develops, publishes and operates social games (the “Games”) for mobile applications (each, an “App“) for the Games to be played across multiple devices.

We also operate the website www.gullivers.games, its subdomains and its related features (“Site”, and together with the Games and App, collectively – the “Services“).

Gulliver’s Games respects your privacy and is committed to making our practices regarding your data more transparent and fairer. This Privacy Policy describes how we collect, process, store, use and share your personal data, and it applies whenever you visit our Site, install our App and play our Games, interact with us or otherwise access or use any of our Services.

When you use the Games; or somehow communicates with Gulliver’s Games, Gulliver’s Games collects information about you in accordance with the nature of the information and transaction within the current technical possibilities. You accept, acknowledge and promise that your personal information and data might be used in limited manner by Gulliver’s Games and/or through Gulliver’s Games to the extent that it is limited to the format and purposes set forth in this Privacy Policy. Every type of information related to an identified or identifiable natural person constitutes personal data. Processing your personal data signifies all types of transactions performed on the data such as; obtaining, recording, storing, preserving, altering, re-arranging, disclosing, transferring, acquiring, making accessible, alignment and preventing access.

We strongly urge you to read this Privacy Policy and make sure that you fully understand and agree to it. If you do not agree to this Privacy Policy, please discontinue and avoid using our Services. You have the right to cease using our Services, pursuant to this Privacy Policy at any time.
The purposes of collecting and processing personal data

Gulliver’s Games collects your personal data automatically whenever you download our Games to your device or play the Games, whenever you send us your feedbacks or convey your information or support requests directly to Gulliver’s Games or interact with third party advertisements presented in our Games or interact with Gulliver’s Games advertisements presented in other platforms. In general, the information we collect about you relates to your device and helps us to identify your device. Gulliver’s Games also collects data from the Apple App Store and Google Play App Store (Referred to as “Platforms” together) platforms and the business partners.

Gulliver’s Games might collect your personal information (username, name if provided, IP address, the date and time of access, the pages accessed while being on Game) and the activities taken place under Gulliver’s Games in order to provide better service to you, to make suggestions, to improve its services, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

Personal data that is collected while you are playing GG’s Games:

Gulliver’s Games might collect your personal information and the activities taken place under Gulliver’s Games in order to provide better service to you, to make suggestions, to improve its services, to improve and update our Games, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

When you download and/or play the Games via Platforms, Gulliver’s Games collect certain personal data from you and/or your device. In this regard, Gulliver’s Games collect your advertising ID (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), device identifier, operating system, model, producer information, hardware type, operating system version, memory usage, country, time zone and preferred language information, internet protocol (IP) number, location information according to your IP address, operator and browser information, information about properties of mobile application through which a consumer interacts with the Games, data regarding your in-game interactions (the time you spent while playing our games, your in-game expenses, level information, the amount of time for watching advertisements, the advertisements watched) and time of installation and first opening of the application.

The aforementioned advertising IDs (IDFA and GAID) are unique identifiers for mobile devices that advertisers use for personalised advertising and consistent across all mobile applications and thus allow cross-app tracking. You may disable this option by activating “limit advertisement tracking” from the privacy settings of Apple devices. As for the Google Android devices, you may change your advertisement setting by activating the “disable advertisement personalising” option. Advertising IDs, are non-permanent identifiers, which are uniquely associated with your device.

We would like to remind that you have an option to play the Games without watching advertisements by using our no-ads feature, which is subject to a fee.

Your username and score can be viewed by other users in our games that include a scoreboard feature.

Payments for in-app purchases are being carried out by the Platforms. Gulliver’s Games, does not collect personal data such as your name, surname, credit card number and e-mail address that you share with the Platforms for the payment, and only payment information for the items your purchase is being shared with us in order to fulfil your order.

Personal data that is collected when you contact with Gulliver’s Games
When you contact with us: We may ask for contact information (e-mail) when you request information about our Games, request technical support or contact with us anyhow. Your contact information will be processed for the purposes of fulfilling your requests and communicating with you.

You may share data that contains your personal data when you share your comments and views about our Games. The content of user comments is composed fully of data that you voluntarily provided. We process your shared personal data to solve the issues you encountered and to fulfil your request.

Data that is collected by third parties
If the personal data provided to Gulliver’s Games by you is requested by official institutions/organisations as necessitated by the law, the data may be transmitted to the relevant authorities and courts if requested by the courts.

Our business partners or service providers can use server log files, cookies, pixel labels, web beacons or other tracking tools in our Games. Our advertisement business partners and analytics service providers mentioned in the part 3 below, can collect data regarding your IP address your advertising identifier (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), cookie identifiers, advertisement ID, your mobile device’s type, operating system, version, model, hardware type, other device identifiers that are automatically determined for your device when you connect to the internet, web browser information, websites you visited, connections you have within the Games and your preferences about the visited websites by using the stated technologies. You may access to the privacy policies of these third parties from  section 3.

While privacy laws may vary between jurisdictions, Gulliver’s Games has taken commercially reasonable steps to ensure that your personal data is treated by its affiliates, business partners and service providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction.  If Gulliver’s Games transfer Personal Data, it makes such transfers in accordance with applicable personal data protection legislation. You can contact us using the details in section 4 to find out more about these safeguards.

Gulliver’s Games will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When Gulliver’s Games have no ongoing legitimate business need to process your personal information, Gulliver’s Games will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then Gulliver’s Games will securely store your personal information and isolate it from any further processing until deletion is possible.

The legal grounds of processing your personal data

The legal grounds that Gulliver’s Games relies upon while processing your personal data are the following:

Explicit consent and/or your request

In cases where it is necessary to disclose such information in accordance with applicable laws or regulations or a court judgment or administrative order issued

Being necessary for the establishment and execution of an agreement

Being necessary for Gulliver’s Games to fulfil its legal obligations as a data controller

Being necessary for the establishment, exercise and protection of any right

Without prejudice to your fundamental rights and freedoms, being compulsory for GG’s statutory interests

GG’s statutory interest in processing your device and usage data is provide better service to you, to make suggestions, to improve its services, to improve and update our Games, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

Gulliver’s Games undertakes to keep your data and any confidential information strictly private and confidential, without prejudice to the contents hereof, to regard it as an obligation to keep confidentiality, to take all measures and act in due diligence to prevent all or any part of your information from entering into the public domain or be subject to unauthorised use, or to take measures to prevent the confidential information from disclosure to any third party. If, despite all necessary data security measures taken by Gulliver’s Games, the confidential information is damaged as a result of attacks on the system or captured by third parties, Gulliver’s Games shall have no responsibility with that respect.

Gulliver’s Games shall not be responsible for damages caused by the use of information that you disclose in comments made or messages given by third parties in public areas. If you share your name, password, etc. used by you when creating the membership record with third parties, the Gulliver’s Games shall not be responsible for any damages that may arise from the information shared with third parties.

The transfer of your personal data

Your personal data may be transferred to our business partners and service providers located abroad for the purposes of improving our Games and providing our Games to you, providing personalised advertisements according to your interests, measuring GG’s and third parties’ advertisement effectiveness and carrying out measurements and analysis regarding your use of our games. In case a public institution is authorised to request personal data by the law, your personal data can be transferred to such authorised public institution in accordance with the applicable personal data protection legislation. Requests from judicial authorities will also be fulfilled in accordance with the applicable legislation.

Your personal data may be transferred to our business partners and service providers stated below:

Advertisement business partners. Your personal data may be transferred to our advertisement partners who enable the Games to be provided free or for low cost.

Web and Mobile Analytics services. Your personal data may be transferred to our service providers and business partners for the purpose of conducting analytical reviews, analyses, reporting and research activities regarding the use of our Games.

Website Performance Monitoring services. Your personal data may be transferred to our service providers and business partners for the purpose of conducting monitoring services of GG’s website performance.

Mediation Partners Your personal data may be transferred to our service providers and business partners for the purpose of conducting mobile measures regarding the use of our Games.

Cloud computing services. Your personal data is stored in the servers of the Google.

You may find the list of our service providers and business partners and their privacy policies below:

Your Rights Regarding the Protection of Your Personal Data

According to the relevant legislation, you have the right to;

learn whether or not your personal data is being processed,
request information as to processing if it has been processed,
learn the purpose of personal data processing and whether the personal data is used appropriately in line such purposes,
know the third parties to which your personal data is transferred domestically or abroad,
to request correction if your personal data is incompletely or incorrectly processed,
to request deletion or destruction of your personal data,
to request the transmission of your correction,
deletion and destruction requests to third parties to whom your personal data has been transferred,
to object to any consequence occurred against you by analysing your processed data through automated systems request compensation in case you incur any damage due to the unlawful processing of personal data.
request restriction of data processing activities, request data portability,
object to the occurrence of an adverse consequence by analysing the processed data exclusively through automated systems,
and to lodge a complaint with the relevant data protection authority and have the right to claim damages in case of impairment because your personal data is processed in violation of the relevant legal legislation.

You can submit all your claims and questions with respect to such rights to [email protected] 

Please note that your request must:

Provide sufficient information to allow us to reasonably verify you are the person about whom we processed personal data or an authorised representative.

Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Therefore, when you make a request, please include your name, surname, signature (if your request is written), your identity number or passport number with nationality, residential and business address subject to the notification; electronic mail address, telephone, fax number subject, and subject of demand. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Your requests will be answered as soon as possible and  30 (thirty) days at latest. 

Revisions

Gulliver’s Games may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

GG Studio Yazılım Anonim Şirketi

Sanayi Mah. Kağıthane, İstanbul

MERSIS Number: 0395186706200001