Privacy Policy
NPATH GAMES OYUN TEKNOLOJİLERİ ANONİM ŞİRKETİ
PRIVACY POLICY
UNDER THE PERSONAL DATA PROTECTION LAW No. 6698
1. INTRODUCTION
As NPATH GAMES OYUN TEKNOLOJİLERİ ANONİM ŞİRKETİ (“NPATH”), we take necessary measures for the protection and confidentiality of your personal data. This Privacy Policy has been prepared to inform you about which personal data will be processed, how your personal data is protected and your rights in accordance with the Personal Data Protection Law No. 6698 and relevant legislation.
Logging into the mobile game means that you have read and understood this Privacy Policy and accepted the Terms of Use.
2. Personal Data and Processing of the Personal Data
Personal data is any information that demonstrates the personal, professional and family characteristics of an individual, and that is capable of distinguishing that individual from other individuals and revealing their qualifications. A process that begins with the first collection of personal data by fully or partially automatic or non-automatic means, provided that it is part of any data recording system, and all subsequent processing is defined as data processing.
3. Data Controller
Data controller refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
4. For what purposes is personal data used?
• Information Security Processes
• Communication Activities
• Fulfillment of Legal Obligations Arising from Regulations
• Verification of the Appropriate Use of the Mobile Game
• Recording In-Game Progress, Statistics, and Transactions
• Detection of In-Game Deficiencies and Errors
• Facilitating Communication Among Players
• Conducting Storage and Archiving Activities
• Tracking Requests/Complaints
• Ensuring the Security of Data Controller Operations
• Providing Software Updates for the Development of the Mobile Game
• Providing Information to Authorized Individuals, Institutions, and Organizations
5. PROCEDURES FOR COLLECTION OF DATA BY US
In order to improve the player experience by planning and tracking the levels, we use cookies, the information you share directly with us through the social platforms you prefer when logging in to the game (Facebook / Instagram), the account name section provided at the game login and / or your communication with our customer support team.
5.1 COOKIES
As NPATH, we use cookies within the scope of accessing and playing the mobile game we offer to you. With this Cookie Policy, we convey to you the structures of the cookies we use, the purpose and legal grounds for processing them, along with your rights.
Cookies are small data files received when you visit our website via your computer or mobile device. Frequently used cookies are used to make the site more functional and user-friendly and to report the collected information when necessary.
Frequently used cookies are used for the purpose of providing, facilitating, and enhancing users’ mobile gaming experiences, improving the functionality and performance of the mobile game, enhancing the mobile game and its sections, and obtaining analyses based on anonymous user experiences for corporate promotional purposes, as well as taking legal security measures to ensure the security of data controller operations.
Many types of cookies serve different purposes. Cookies may be collected directly from the website or collected by third parties. The main purpose of such cookies is to increase the functionality of the mobile game and use them in analysis processes. You can manage cookies via your device.
Reasons of Using Cookies; NPATH collects and processes essential cookies to maintain the technical functionality of the mobile game. Other cookies are used to enhance the online experience depending on the player experience. Other details about cookies are listed below.
Mandatory Cookies; These types of cookies are mandatory for the functionality of the mobile game and are used to increase user experience and perform registration and operations for technical reasons.
Functional and Analytical Cookies; These types of cookies are used to detect the user’s mobile game and its usage during the game and the stage in which it remains in the game, to list and analyze its preferences. At NPATH, we use our game servers and internal analytics technologies to collect information about how you use your mobile device while playing the game and mobile game performance. In addition, your information such as IP address and device ID, game playing and usage statistics, and system interactions are among the information collected by us.
Your personal data collected through these cookies are processed within the scope of the legal grounds of “Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”.
6. DATA COLLECTED BY NPATH
6.1 Data Provided to NPATH by the Data Subject
• User Name
• Device ID
• Profile Photo or Avatar
• Location
• Age
• Gender
Among the information listed above; profile photo, location, gender and age are obtained in case of Facebook/Instagram login option.
7. HOW IS PROCESSED PERSONAL DATA USED?
As NPATH, we care about your privacy. Therefore, we use the personal data and other information we collect from you solely to operate our gaming service activities and improve your gaming experience, as listed below:
In order to provide support while playing the game;
• Respond to your questions and comments through our customer support services,
• To find solutions to any problems you encounter while playing the game,
To improve your user experience while playing our game and conducting our business operations;
• To save your in-game progress, statistics, and transactions.
• To determine your in-game status and prepare the same conditions when continuing the game.
• To connect and communicate with your friends.
• For software updates.
• To identify and resolve any errors encountered during your gameplay as quickly as possible.
8. TRANSFER OF DATA
For the purposes stated above, in accordance with Article 8 of the KVKK, NPATH may share personal data domestically with regulatory and supervisory institutions and institutions or organizations authorized to request the personal data of the data subject, such as courts and enforcement offices, and the persons authorized by them. NPATH will also be able to transfer the mobile game to the Apple App Store and Google Play within the framework of game download and application management.
9. YOUR RIGHTS AS THE DATA SUBJECT
In accordance with the privacy and data protection laws to which you or your legal representatives (for children) are subject, you have the following rights in relation to your personal data set out in this privacy policy;
• To learn whether her/his personal data are processed or not,
• To demand for information as to if her/his personal data have been processed,
• To learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,
• To know the third parties to whom his personal data are transferred in country or abroad,
• To request the rectification of the incomplete or inaccurate data, if any,
• To request the erasure or destruction of his/her personal data under the conditions referred to in Article 7,
• To request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) to third parties to whom his/her personal data have been transferred,
• To object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
• To claim compensation for the damage arising from the unlawful processing of his/her personal data.
10. MEASURES TAKEN REGARDING PERSONAL DATA
NPATH takes technical and administrative data protection and data privacy measures:
• To prevent unlawful processing,
• To prevent illegal access,
• To ensure that it is stored in accordance with the law
Below are some administrative and technical measures taken by NPATH:
• Conducting and ensuring necessary audits within NPATH.
• Providing training and information to NPATH employees regarding the lawful processing of personal data.
• Employing personnel with technical expertise.
• Periodically updating and renewing technical measures.
• Establishing data recording systems within NPATH in compliance with regulations and conducting periodic audits of these systems.
• Implementing security systems, including technological developments, to prevent unauthorized access to personal data.
Your personal data processed by NPATH may be processed by taking all necessary information security measures, provided that it is not used outside the purposes and scope specified in this Privacy Policy. The data will be stored for the legal retention period or as long as required by the purpose for which they are processed, and at the end of the period required for the purpose of processing, they will be anonymized and continue to be used by NPATH or will be destroyed in accordance with the relevant legislation. Action is taken in accordance with the provisions of the law and relevant legislation.
NPATH attaches utmost importance to collecting the personal data of the data subject, when necessary, accurately and up-to-date, for specific, clear and legitimate purposes in connection with the relevant purpose, in accordance with the legal order and the good faith. They are processed, limited and measured for the period stipulated in the relevant legislation or required for the purpose for which they are processed, and the necessary administrative and technical measures are taken for this purpose.
With the necessary precautions mentioned above, we show all the necessary sensitivity to protect your information both online and offline, these may vary depending on the sensitivity of your information.
We take administrative and technical measures to prevent personal data breach and unauthorized disclosure of personal data in accordance with our relevant procedures. If we detect that personal data breach or unauthorized disclosure of personal data, we create systems and infrastructures to notify the data subject and the Data Protection Board about this situation.
11. AGE PRINCIPLES AND CHILDREN’S PRIVACY
The personal data of underage players is very important to us. At NPATH, it is our policy that users under the age of 18 obtain parental consent before using our services. Without parental consent, children will not be able to use our services and therefore their data will not be processed. For European Union citizens, this age limit is set at 16. It is important that parents read this Privacy Policy when granting these consents, and contact us as necessary.
In Turkey, minors under the age of 18 and those under the age of 16 who are citizens of the European Union should not engage in any paid transactions without the permission of their parents or guardians.
12. THIRD PARTY LINKS
The mobile game may contain links to other websites and/or other games operated by third parties. In some cases, these links may direct you, in whole or in part, to platforms or games managed and/or owned by us. In such cases, such link referral platform or mobile game policies may differ from this policy. In any case, you should check the privacy policy of each website and mobile game you visit and/or are directed to before engaging in any activity in such internet products or mobile games.
13. STORAGE OF PERSONAL DATA
The retention periods of the personal data collected vary depending on the purpose of collection and how it will be used. We will never store your personal data for longer than legal periods. If you delete/deactivate the account(s) you use to benefit from our services, we will take all necessary measures to delete your other information, except for the data necessary to fulfill our legal obligations or to establish, protect and enforce our rights.
14. CHANGES MADE TO THE PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time, in any part, for any reason. When we make any alterations to this Privacy Policy, such changes can be tracked through the Platforms. After the alteration, please note that the revised Privacy Policy will come into force on the date of publication on the Platform, unless otherwise is stated. We recommend reviewing the policy frequently to be informed about these alterations.
15. LEGAL BASIS
As NPATH, we process your personal data in accordance with the Personal Data Protection Law No. 6698 and the European Union General Data Protection Regulation and other relevant legislation. You may send your questions, requests and suggestions regarding this Policy herein at https://npathgames.com/.
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