Privacy Policy

This privacy policy was last modified on 23 JANUARY 2024

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Introduction

Kumkuat Games develops and publishes social games for the mobile platforms and PC. Our Privacy Policy applies only to the collection, use and disclosure of personal information that you may decide to provide to us in your use of: (i) our applications for mobile platforms or devices and our web applications accessible on third party social networking services ("SNS") (collectively, our mobile and web applications are referred to herein as ("Kumkuat Games Applications"), (ii) our web domains and

subdomains (collectively, our "Sites"), and web forums or messaging boards in Kumkuat Games Applications and our Sites (collectively, our "Forums"). (iii) our online games and game services whether reached through a third-party service or directly

through our website or our downloadable games (collectively, our "Games"). These available options for users to interact with Kumkuat games are collectively known as our "Services". For the Privacy Policy, Kumkuat Oyun ve Bilişim Teknolojileri A.Ş , a

company registered in Turkey with its office located at Meşrutiyet Mah. Rumeli Plaza No:22 no:7 Şişli/İstanbul / Turkey

shall be referred to as: "Kumkuat Games", "we", "us", or "our".

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We reserve the right to update this Privacy Policy at any time. If we modify this Privacy Policy in a material way, a notice will be posted in our Services and on the sites along with the updated Privacy Policy. We will also update the "Last Updated Date" in the Privacy Policy. By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

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The following policy states the practices that may impact you as a registered user with full access to our Services or a non-registered user of our Services (each a "Kumkuat Games User"). For information regarding the collection and use of Personal

Information (defined below) from children under 13 years old, see Section 6 below, entitled "Our Policy Toward Children"

 

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Information we collect

In the course of using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your name, phone number, photo representation ("avatar"), email address and mailing address ("Personal Information"). We will collect, use, transfer and disclose Personal Information in accordance with our Privacy Policy. We also collect non-personal information, which is data in a form that does not permit direct association with you or any specific individual ("Non-Identifying Information"). Non-Identifying Information is aggregated and used to help improve our Services and Third Party Mobile Applications (defined below) by providing a better way to understand the Kumkuat games User experience with the level of interest in various portions of our Sites, specific Kumkuat games Applications or specific Third-Party Mobile Applications. We may collect, use, transfer and disclose Non-Identifying Information for any purpose; details provided in this Privacy Policy about what Non-Identifying Information we collect currently, and how we use,

transfer and disclose such Non-Identifying Information concern only how such information is collected and used today.

Either Personal Information or Non-Identifying Information may be used alone or in the aggregate with information collected from other Kumkuat games Users. Our primary objective in collecting any Personal Information or Non-Identifying

Information is to provide you with a superior and personally relevant user experience.

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Collecting Information

In connection with registration of Kumkuat games Users on our Services, we collect Personal Information that may include your email address, as well as information on mobile device type, mobile carrier, unique mobile device identifier ("Device ID"), Internet Protocol ("IP") address and geolocation, as applicable. We use your Device ID and IP Address to make it possible to authenticate and understand your use of our Services, or the Third Party Mobile Application that you may choose to access through our Services. We also use the IP address as a way to ensure that the Terms of Services are followed and to protect the security of our other users.

Related to this information collection, our Services may serve ads that contain links to other Third-Party Mobile and Web Applications, and we may utilize your Device ID to track clicks or other ad fulfillment metrics. Our use of your Device ID does not

enable us to identify you personally, and we do not store this information in connection with your Kumkuat games User account information. You may also be asked explicitly to provide Personal Information or Non-Identifying Information

anytime that you are in contact with Kumkuat games.

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Additional Collection of Information

Personal Information that you independently submit to an SNS (e.g., Facebook) may be collected and used by us in order to provide you with enhanced functionality. In these instances, you consent to Kumkuat games's access and use of your username, alias and any other Personal Information you have independently provided to and made accessible through the SNS. Such access will be in accordance with the privacy settings you have set in your SNS account, if any. Similarly, we may use Personal Information that you have provided to us to help you establish social connections with other Kumkuat games Users.

 

When you use any Kumkuat games game at an SNS such as Facebook or any other platform, where our games may also be referred to as "applications", you allow Kumkuat Games to access certain information from your profile for that site. The information

you allow Kumkuat games to access varies by game and SNS, and it is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings at the SNS where you play our games. For example,

Kumkuat games may access and store some or all of the following information, as allowed by you, the SNS and your preferences:
 

● Your first and last name

● your profile picture or its URL

● your user ID number, which is linked to publicly available information such as name and profile photo

● the user ID numbers and other public data for your friends

● the login e-mail you provided to that SNS when you registered

● your gender

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By playing a Kumkuat games game through an SNS, you are authorizing Kumkuat Games to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the SNS could provide to Kumkuat games through the SNS Application Programming Interface ("API"). If you choose to participate in a Promotion, We may request that you provide us with

Personal Information such as your email address or mailing address in order to administer your participation in the Promotion.

When you interact with the Service (whether or not on an SNS), or any Kumkuat Games-owned games, website including Webshop, We may collect and store information from you directly as described below.

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For mobile platforms like Google, Apple we collect only device ID, display name, token. This will be updated when we open commercial version. Once we update it we will make another annoucment.

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Payment Information

If you purchase a license to use in-game virtual currency or virtual items directly from Kumkuat games, we will collect the billing and financial information necessary to process your charges, which may include your postal and e-mail addresses. Kumkuat Games may also receive the billing and payment information that you provide when your purchase is processed by another party.

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Payment Processors:

For Mobile Games we use payment processors such as Google (if you run Android on your mobile device), Apple App Store payments (if you run IOS on your mobile device).These payment processors are responsible for the processing of your Information, and may use your Information for their own purposes in accordance with their privacy policies as below:

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○ Apple: https://www.apple.com/legal/privacy/

○ Google: https://policies.google.com/privacy

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Technical and Usage Information

When you access our websites or play our games, We collect (i) certain technical information about your mobile device or computer system, including MAC Address, IP Address and mobile device ID; and (ii) usage statistics about your interactions with

the Service. This information is typically collected through the use of server log files or web log files ("Log Files"), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical

information; and (iii) game play information that tracks and stores your interaction with our Games. Some of the cookies the Service places on your computer are linked to your user ID number(s). For more information on how We utilize cookies and other

tracking technologies please review the "Cookies and Automated Information Collection" portion of the section "How We Collect Information about You". In connection with use of our Services or Third-Party Mobile Applications, in addition to information on device type, mobile carrier, IP address, platform version, and geo-location, as applicable, we may also collect navigation, interaction and engagement information regarding Kumkuat games Users.

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How We Collect Information about You

When you play one of our games, Kumkuat games collects and stores certain information that you provide directly or through the SNS or other third party website that is offering our game(s). To provide a richer game play and social experience,

Kumkuat games also collects information about your play and interaction with other players and the Service. The bulk of this information is collected and stored through the use of Log Files, which are files on our web servers that record actions

taken on our games and websites. You may be able to take part in certain activities on our websites or games that give

you the opportunity to communicate or share information not just with Kumkuat Games, but also with other users of our Service. These include:

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● participating in player forums and message boards

● posting public comments to other users' profiles 

● sending private messages or invitations to other users, through Facebook

● chat with other users in game and global chat

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We may record and store archives of these communications on Kumkuat games' servers to protect the safety and well being of our users and Kumkuat games's rights and property in connection with the service. You acknowledge and consent to

the recording and storage of such communications for these purposes.

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Related Technologies

When you use our Services or Third-Party Mobile Applications, our servers automatically record information that your browser or the applicable Service or Third-Party Mobile Application sends ("Log Data"). This Log Data may include information such as your computer's or mobile device's IP address, browser type, language, Internet Service Provider (ISP), referring and exit pages, time spent, information searched for, time and date stamp, clickstream data and other statistics.

We use this information to monitor, analyze and understand trends, for technical administration of Services and Third-Party Mobile Applications, and to gather demographic information about our Kumkuat games User base as a whole. We,and Third Party Publishers may use this information for product and services improvements, and in marketing and advertising services.

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Disclosures Within Kumkuat games Services

As a user, you may create your own profile, connect with other Kumkuat games Users of Services, send messages and transmit information through various channels. Please remember that any communications you have via our Services, depending on,

for example, the functionality of any Kumkuat games Application or Third-Party Mobile Application connected to our Services, may reveal your screen name and the content of your communications, making this information publicly available to other

Kumkuat games Users. Kumkuat games is not responsible for the activities of other Kumkuat games Users or other third parties with whom you choose to provide your Personal Information or otherwise interact.

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How we use your Information

We may use your information that we collect in any of the following ways:

1. To create your game accounts and allow you to play our games

2. To enable Users to communicate with other Kumkuat games users

3. To prevent fraud, potential illegal activity and to enforce our Terms of Service

4. To provide technical support and respond to your inquiries

5. To deliver and target advertising to you

6. To identify other Users for you to connect with

7. To improve our Games and Services and create a better experience for Kumkuat

  Games Users

8. To notify you of new Game updates

9. To customize your User experience and solicit feedback to improve Kumkuat

  Games Services

10.To inform you about new products and Services

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How we share your Information

In addition to sharing aggregated Non-Identifying Information with Third Party Publishers, we may also share aggregated Non-Identifying Information with advertisers and ad networks ("Advertising Entities") with whom we have strategic

relationships. Unless you specifically opt in to share your Personal Information, the information that we share with these third parties will only be used in the form of Non-Identifying Information to support user trend analyses and demographic

profiling. Some Third Party Publishers and Advertising Entities also act as Service Providers (defined below) to us, so in those cases we will share your information as described below.

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With Preferred Partners

We may share your username, email address and Device ID (collectively, "Specific Shared Data") with certain of our Third Party Publishers and other business partners ("Preferred Partners") for those parties to assist us with providing you with the aspect

of the Services for which you provided such Specific Shared Data to us, and to use such Specific Shared Data to provide you with information and marketing materials about Third Party Mobile Applications and other products and services in order, for

example, to further enhance your use of our Services and to augment your gaming experience generally. In addition, in the event of a user inquiry concerning Third Party Publishers or Third Party Applications, we may send Specific Shared Data as well as

the inquiry to the Third Party Publisher to address the inquiry. We only share such information with Preferred Partners pursuant to an agreement by which the Preferred Partner is under obligations not to disclose or use it for any other purpose. You may contact us by any of the means provided in the "Contacting Us" section below to request not to have such information provided to Preferred Partners, understanding, however, that if such information is not shared with Preferred Partners it may affect your ability to use or access portions of the Services. Some Preferred Partners also act as Service Providers (defined below) to us, and in those cases we may also share Personal Information and Non-Identifying Information as described below.

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With our Service Providers

Disclosure of your Personal Information and Non-Identifying Information may also occur where we engage or employ service providers, vendors or other third party entities to facilitate provision of our Services (each a "Service Provider") (e.g., without limitation, improvement of our Services' features, user account authentication, promotion and marketing, administration, analytics, virtual currency transactions, crowd-sourcing, cloud storage and other related services), to provide the Services on

our behalf, or to assist us in analyzing how our Services are being used. Our Service Providers may have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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Under Special Circumstances

At times, we may disclose information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Kumkuat games or a third party, to protect the safety of the public or any person or to prevent or stop activity we may consider to be or to pose a risk of being, any illegal, unethical or legally actionable activity. Such disclosures shall only happen with a written request by the agency for the requested information.

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Under another special set of circumstances, for example, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, we may sell, transfer or otherwise share some or all of Kumkuat games assets, including

your Personal Information.

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Our Policy Toward Children

Our Services are not intended for children under the age of 13 ("children") and we do not knowingly collect any Personal Information from children. If we discover that we have inadvertently collected Personal Information from children, we will take all reasonable measures to erase such information from our systems and records as soon as possible.(Please be aware that Kumkuat games may create certain areas on its website and some Games that contain adult or mature content. You must be at least 16 or 18 years of age to access and view such areas or Games. If you are less than the required age for such areas or Games, please do not use them)

If you are a Child, we recommend that you obtain permission from your parents or legal guardian (“Parents”) to play our Games. You should also read this Policy with your Parents so they can help you understand anything you may not understand. If you are a Parent and are concerned about your Child’s use of our Games or have any questions, you can contact us using the details in section “Introduction”.

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How we protect your information

Kumkuat games takes your privacy very seriously and employs administrative, physical and electronic measures to safeguard your information from identity theft and unauthorized access. We do not and will not, at any time, request your credit card

information, login password or national identification numbers in a non-secure or unsolicited communication.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email

or conspicuous posting on the Sites in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and

restore the reasonable integrity of the data system.

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How long we keep your information for

Your Personal Information or Non-Identifying Information is kept for as long as you are registered or using our Services, and then for up to one year from the date you stop interacting with the games. When deleting Personal Information or Non-Identifying Information, we will take measures to make the Information irrecoverable or irreproducible, and electronic files which contain Information will be deleted permanently.

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How You Can Change Your Information

You may email us at developer@kumkuatgames.com to request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by

law or for legitimate business purposes. Specific Shared Data cannot be retrieved from Preferred Partners after its disclosure.

 

Where you share information with other users through the communication channels of our Services, you generally should not expect to have any ability to modify or remove such communications. Nor should you expect us to modify or delete your comments

upon your request. If you participate in a Promotion hosted by us (where you may or may not disclose the information requested), you have the option to opt out at any time from such participation and the receipt of any related communications. Please follow the

unsubscribe instructions provided in the relevant communication.

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