JOINCO GAMES PRIVACY POLICY

This Privacy Policy explains who we are, how we process your personal information, and how you can exercise your privacy rights. Joinco Games Bilişim Ve Prodüksiyon Hizmetleri Sanayi Ticaret Anonim Şirketi ("Joinco Games" or "we," "us," "our"), established under the laws of the Republic of Turkiye, is a developer and publisher of mobile game applications and games, registered at Ege Teknopark Teknoloji Geliştirme Bölgesi, Ege Üniversitesi Kampüsü, İnci Binası, No:172/67 -1, İnci Binası Co-Work Ar-Ge Alanı, 35100 Bornova/İzmir.

This Privacy Policy aims to explain how and why we collect, store, share, and use your personal data in compliance with the laws of the countries in which we operate. In this Privacy Policy, the term "personal data" refers to any data or information that identifies, relates to, or can reasonably be directly or indirectly associated with a specific individual or household. Additionally, any other data or information that falls under the definitions of "personal data," "personal information," or "information used to identify an individual" is also included within this scope.

This Privacy Policy applies to the personal information we collect through our games, websites, mobile applications, forums, blogs, and other offline services, as well as our products on all platforms ("Games"), and our marketing and advertising activities, along with any other services we may provide to you from time to time (collectively referred to as "Services").

By using our Services, you agree to be bound by this Privacy Policy and consent to the processing of your information in the manner described herein. Joinco Games is the data controller of the personal data we retain in connection with your use of the Services. This means that we determine how your personal data will be used and are responsible for this process. Under this Privacy Policy, your personal data will be processed when you download our mobile applications, access our games, play our games, or interact with our Services, for the purpose of providing the Services. If you are hesitant to provide your personal data to us or have concerns about how it is used as described in this Privacy Policy, you may contact us and exercise your rights as outlined under the section titled "Ways to Control Your Data".

You can find the methods of data collection, detailed explanations of the collected data, and the purposes for which the data is collected in the sections titled Data We Collect and Purposes for the Processing of Your Data. For information about all your personal data rights and how to exercise these rights, please refer to the Ways to Control Your Data and Your Rights and Options sections.

If you reside in California, Virginia, Turkiye, Europe, the United Kingdom, or Switzerland, please consult the Local Data Regulations section for information on your local rights and data guidelines.

THE DATA WE COLLECT

The categories of personal data we collect vary depending on the Services you use and the requirements of applicable laws. We obtain your personal data directly from you or from third-party companies that have the right to transfer your personal data to us, either by obtaining your consent or based on another legal basis (such as promotional platforms that have received your consent or our business partners involved in promotional activities).

Most of the information we collect about you comes directly from you when you play our Games or interact with third-party advertisements in our Games or with our advertisements in other publishers' Games. Generally, the information we collect about you relates to the type of device you use, information that helps us identify your device, how you play our Games, and any information you voluntarily provide when you contact us. We may also collect information from app store platforms, partners, and other third parties, such as details about your interests and in-app purchases (with the condition that we never receive your Payment or Credit Card information).

The information we may collect about you through the Services generally falls into the following categories:

2.1 The Data You Provide Us Directly

At Joinco Games, most of the data we collect comes directly from you while you use our games or products. These instances include downloading our mobile game, creating an account in our games, filling out a form on our website, interacting with our forums, blogs, and customer support, or engaging in similar activities. It also includes contacting us via email, SMS, or phone, and reporting issues. The categories of personal data we collect may vary depending on the Services you use and the requirements of applicable laws.

The data we collect directly from you may include the following items, depending on the information you voluntarily provide while using our Services:

Services: Messages and content you send while using the Services (e.g., chat content, reviews, and feedback), as well as data provided in surveys, promotions, sweepstakes, contests, and other events.
Contact Information: Your country or region, username, player name/tag and password, phone number, e-mail address, home address etc.
Support: Customer support tickets, their content and contact information.
User Generated Content: Any files, documents, videos, images, data or information that you choose to upload or send during your communications with us or customer support.
Profile and Game Information: Screen name, avatar or profile picture, in-game scores, achievements, purchases, competition, tournament or event participations, involvement in teams, and similar information.
Surveys: Feedback and reviews you provide related to our Services, as well as information given in surveys, promotions, sweepstakes, contests, and other events.
Inferences: Information reflecting predictions about your interests and preferences, as well as data generated when you use the Services.
Parental Information: Information such as a parent’s email address and PIN code, created only if you enable parental control settings in the Services.

2.2 Data We Collect Automatically

Joinco Games may automatically collect data from you and your device when you use our Services. The data we collect is used to ensure the operation of our Services, optimize performance, and improve the user experience. We may automatically collect the following data from you and your device:

Analytic Data: Details about how and when you use our games, advertisements, and other Services, including how you interact with them; information about the device you use to access our Services; details on profile visits; and error logs and diagnostic information regarding the performance of our Services on your device (such as battery life, loading times, latency, frame rate, or other technical diagnostic information).
Inferences: Information reflecting predictions about your interests and preferences, as well as data generated when you use the Services.
Device Data: Your IP address, mobile device identifiers (such as your device or advertising ID), device name, operating system, browser type and language, internet service provider, and telephone operator are examples of data collected about your device. Additionally, approximate location data (as derived from your IP address) may also be collected.
Commercial Information: Information related to products and services purchased, obtained, or considered, as well as other purchasing or consumption histories and tendencies.
In-Game Activity and Progress: This includes in-game scores, achievements, purchases, participation in in-game events and competitions, membership in teams within the Services, and interactions with other players. It also encompasses in-game progress, levels, games played, session duration, preferred settings, in-game ads viewed, in-game references, or general gaming preferences, and how you were directed to our Services.
Data Collected Through Cookies and Similar Technologies: To provide services on our website, cookies or small data files stored on individuals' computers, as well as other related technologies such as web beacons, pixels, embedded scripts, location tracking technologies, and log technologies, may be used. These technologies will collectively be referred to as "cookies." For more detailed information, please refer to the Cookies section.

2.3 Data Collected from Third Parties

In addition to the aforementioned cases, there are instances where you grant access to your personal data to third-party companies such as advertising networks, data analytics providers, and similar entities (e.g., when you download our mobile applications through the App Store or Google Play, or when you link your Facebook account to our mobile applications). In such cases, we also collect information from these third parties.

2.3.1 Data Acquired from Third Party Sources and Ad Optimization

From time to time, to better deliver our services and optimize your user experience, we may also obtain personal information about you from other third-party sources. For example, when you are directed to our services via an advertisement (such as clicking on an advertisement for one of our Games featured in another publisher's game), we may obtain certain data related to this redirection process. This data may include information such as which advertising network facilitated the redirection, the identity of the advertising campaign used, the platform where the advertisement was displayed, and the device from which the click was made. Such data is used to measure the effectiveness of advertising campaigns, understand user behavior, and develop future advertising strategies. Additionally, this information is processed to help us deliver more relevant and engaging advertisements to you. For example, with your consent, data sharing with our advertising partners is conducted to optimize ad content and prevent you from seeing the same ad multiple times. Your device identifiers are shared with selected partners to improve the mentioned advertisements and personalization processes.

2.3.2 Service Providers

Regarding items offered in connection with our applications (e.g., content that can be downloaded or purchased through the App Store or Google Play Store), Joinco Games does not have direct access to your credit card or bank account information in cases of downloading or purchasing such items. These financial transactions are entirely conducted by third-party payment service providers, and Joinco Games does not have access to this information. However, these third-party payment service providers may share certain non-financial information related to your purchase transactions with us. In this context, the personal data obtained from third parties is subject to the privacy policies and permissions you have set on the relevant service providers, and these third parties are required to act in compliance with their own data protection obligations.

Certain sections of our services allow you to log in through third-party social networks or authentication services such as Google or Facebook. This feature operates by having these third-party services verify your identity and share some of your personal data with us as part of the verification process. For example, when you log in with your Google or Facebook account, you may permit the sharing of information such as your name, email address, user ID associated with the third-party service, profile picture, and names and avatars of Facebook friends who have previously played our game.

This data can be used to provide you with faster and easier access to our services, personalize your gaming experience, offer social features, and facilitate interactions with your friends. You can control and limit which information is shared according to the privacy policies of these third-party networks and the privacy settings you have configured on these networks.

When integrating your Facebook account with our services, you have the opportunity to review and control which information you grant access to through the Facebook dialog box. For instance, you may choose not to share your email address with us during this integration. Such options provide opportunities to maintain your privacy and control the extent to which your personal data is shared according to your preferences. We strongly recommend reviewing these settings before using our services and adjusting them to ensure maximum protection of your privacy.

2.3.4 Facebook Integration and Privacy Options

At Joinco Games, logging into our games with your Facebook account does not give us the right to post anything on your profile without your permission. Additionally, we want to emphasize that we do not collect any data about friends who do not play our games. If you do not want your Facebook friends to see your in-game progress, you can disconnect the game's Facebook integration or revoke this permission via Facebook at any time. If you choose not to link your Facebook account to our games, the personal data we collect during your gameplay will be associated with a randomly generated identifier rather than directly identifying information about you. However, we will continue to collect device-specific identifiers and other related information as mentioned above.

We strongly advise our users to carefully review Facebook's Privacy Policy and ensure that they are fully informed about the data sharing practices outlined in this policy. To understand how Facebook processes user data and with which third parties this data is shared, we recommend regularly reviewing your privacy settings. This will enable you to make informed decisions about protecting your personal data and maintain control over how and when your data is shared.

When you interact with us through various social media networks as part of our services—such as clicking the "Like" button on Facebook, following us, or sharing our content on social networks like Google, Facebook, X (formerly Twitter), or Instagram—we may collect information about these interactions. In such cases, the relevant social media platforms may share this information with us according to the privacy settings and permissions you have set.

For instance, when you follow us or share our content through a social media platform, we may obtain information such as your name, profile picture, social media ID, connections, and other interactions you perform on these platforms. Additionally, we may record information related to your consent to share data with third parties from these social media networks. This information can be used to enhance our interaction with you, personalize your experience, and provide content that is more relevant to you.

2.3.7 Processing of Personal Data Obtained from Third Parties and Partnerships

Our company may collect personal data about individuals from public sources, third-party data providers, partnerships, brand agreements, and similar collaborations, as well as through company mergers or acquisitions, which we otherwise would not obtain directly. The collected information is used to effectively manage the features and functionality of our services, ensure their continuity, and provide you with the most suitable service. All data obtained during these processes is processed and protected in accordance with relevant legal regulations.

Partners, in addition to managing the advertising network and alignment platforms, may organize or participate in advertising inventory offer meetings. Partners may also use device identifiers for fraud detection based on legitimate interests.

PURPOSES FOR PROCESSING OF YOUR PERSONAL DATA

We collect and process your personal data for the following purposes:

3.1. Enhancing the performance of our Services

We use your information to provide, develop, and improve our Games and other services. This enables us to personalize your in-game profile, offer social elements of the games (such as team play and competitions), and provide in-game events, offers, and promotions. Additionally, we use this information to enhance the performance of our Games and other products, resolve technical issues, understand and analyze user trends, personalize our services, and optimize your user experience through internal research and analysis. We also manage rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or organized by us or our partners as part of these processes. Measuring interest in our services and user satisfaction, managing our daily operations, and ensuring internal quality control are also important aspects of these processes.

3.2. Surveys

Our organization may conduct surveys at certain intervals to better understand your experiences and opinions about our services and those of our partners. Participation in these surveys is entirely voluntary. However, your responses are crucial for improving the quality of the services we offer, ensuring customer satisfaction, and enhancing our relationships with our partners. Data obtained from surveys will be used solely for the relevant analysis and evaluation processes and will not be shared with any third parties outside of these processes. Your participation in the survey will be evaluated to provide you with better service, and your information will be protected under our Privacy Policy.

3.3. Ads

We use your information to display advertisements for our Games in other publishers' applications and to show third-party advertisements within our Games. For more information on this, please refer to the Advertising section of this Privacy Policy.

3.4. Cross-Promotion

We use your information for cross-promotion, which means promoting one of our Games while you are playing another one of our Games.

3.5. Advertising Tracking and Fraud Prevention

We use your information to monitor the performance of our advertising campaigns and to detect and prevent fraud in these campaigns. The personal data you provide may be used in various advertising activities to enhance the effectiveness of the Games and Services we offer as Joinco Games. This includes processing your data for displaying advertisements in other publishers' applications and showing third-party ads within our Games. For detailed information about our advertising activities, please review the Advertising section of this Privacy Policy.

Additionally, we may conduct cross-promotion activities to promote new Games developed by Joinco Games in the future. In this process, your data may be used to promote one of our Games while you are playing another one of our Games. Furthermore, your data is processed to monitor, evaluate, and detect and prevent potential fraud in our advertising campaigns. All these processes will be conducted in compliance with applicable legal regulations and the protective measures specified in our Privacy Policy.

3.6. Analysis

Our company may process your personal data to understand and analyze trends related to the use of our services and Games. This includes activities such as collecting demographic information about our user base and gathering data on where and how the Games are downloaded and used. Additionally, we may generate reports and conduct analyses to monitor potential issues or trends related to our Games and services, test new game features and content, conduct research and development, or create business intelligence. Only the necessary data will be processed during these activities, with privacy and security of the data being a primary concern.

3.7. Security/Fraud Prevention

For security purposes, we use your information to enhance the safety, security, and integrity of our Games, products, and services. This includes ensuring the security of our assets and technological resources, preventing potentially prohibited or illegal activities, and protecting our players from threats such as cheating or fraud. We use this data to comply with legal obligations, prevent fraud, ensure adherence to terms of use, and, when necessary, defend, enforce, and recognize our rights under the Terms of Service.

3.8. Customer Support

To provide customer support, we use your information to verify your identity and your right to use our products or services, as well as to respond to your requests. This process includes communicating with you to provide service-related information such as confirmations, technical notices, updates, security alerts, and administrative messages. Additionally, it involves addressing comments and requests made through our customer support services and providing support through our customer service channels when needed.

3.9. Legal Obligations

Our company may use and process your personal data in accordance with relevant legal regulations and obligations. This use and processing are limited to situations required by law. For example, your personal data may be processed and shared with relevant authorities to fulfill legal obligations such as tax reporting for your country or region, notifications to government agencies, and regulatory requests. During this process, only the data that is necessary and required by law will be processed and shared, without exceeding the legal framework.

We may process your personal data to provide access to certain sections, functionalities, and features of our services. This is necessary for the use of specific services, such as social features and multiplayer competitions. Additionally, we may process your data to enable communication between users within the mobile application. Such data processing activities are essential for delivering our services and providing the best experience to our users and will be carried out solely for the purpose of fulfilling the related functions.

Furthermore, your data may be processed to monitor user chats using either automated or manual methods, detect players exhibiting fraudulent or inappropriate behavior within the game, and implement necessary measures such as warnings, account restrictions, or closures against players involved in such actions.

3.11. Parental Control

We use your data to enable parental control settings on user accounts and to verify that these settings are correctly configured and approved by the user. This verification process is also used to keep a record of the confirmation.

3.12. In-Game Purchases

In-app purchases can be made within our Games. Payment transactions for in-app purchases are not processed directly by us, and we do not have access to your credit card information. These transactions are conducted through the respective app store, using your App Store or Google Play account. All subsequent transactions and processes are under the control of Apple or Google stores and are subject to their specific terms and conditions. Therefore, please carefully review the privacy policies and terms of service of the Apple and Google stores.

You can always request a refund through the relevant link below:
iOS: https://support.apple.com/en-us/HT204084

Google Play: https://support.google.com/googleplay/answer/7205930

To cancel your subscription, please visit the relevant link below and follow the instructions:

iOS: https://support.apple.com/en-us/HT202039

Google Play: https://support.google.com/googleplay/answer/7018481?hl=en&co=GENIE.Platform%3DAndroid

WHO CAN SEE YOUR DATA

We may share, transfer, disclose, grant access to, provide, and make your personal data available to third parties as specified below. We share your personal data with our third-party service providers for the purposes outlined in this Privacy Policy, including the provision of services, compliance with legal obligations, and the protection and defense of our rights and property.

4.1. Other Users

Social features are a central component of the gaming experience in Joinco Games' titles. When you play through or connect to a social network (such as Facebook), your social network friends who are also playing Joinco Games can view descriptions of your in-game activities, your name, and your player profile (which may include personal data described in the "Data You Provide to Us Directly to Us and Data We Collect Automatically" section above). Additionally, when you join online gaming sessions or purchase goods or services through our Services, certain information such as your username or ID, display name, profile picture or avatar, in-game scores, and achievements may be automatically published within the game, on social network platforms, or on customized gaming websites. If you participate in tournaments or online gaming events, these details may need to be publicly shared. Leaderboards and multiplayer match records, which are key elements of our Services, may be made accessible to both you and other users. Furthermore, other players in Joinco Games, regardless of whether they are your social network friends, will be able to view your player profile. Your gaming activity and related statistics may also become visible on our Services or third-party websites, and such dissemination may be necessary for the provision of our Services.

4.2. Contest, Sweepstakes, and Survey Providers

Your personal data may be shared with third-party service providers who assist us in conducting contests, sweepstakes, or surveys, and in processing responses. These service providers will only process the data necessary for carrying out these activities, strictly for the specified purpose, and in compliance with applicable data protection laws. The transfer of data to these third-party service providers will be limited to what is necessary for the performance of the service, and the confidentiality and security requirements of this transfer will be carefully maintained.

4.3. Business Partners

To enhance services and connect you with products and services that may interest you, we establish exclusive marketing relationships with advertisers and other companies. In this context, when you connect a third-party tool to our Services, we may share the data we collect, including demographic information (e.g., approximate location of your IP address), fraud prevention data (e.g., abuse of refunds in games or click fraud in ads), data from the platforms where the games are run, or verification data from payment service providers, as well as data for advertising and analytics purposes (e.g., surveys) with our relevant marketing partners. These disclosures are made in accordance with your privacy settings and to ensure that content that may be of interest to you is delivered effectively.

4.4. Service Providers:

We may share your personal data with our service providers (data processors). These service providers offer technical support and similar services, provide the information and services requested by you, deliver customer support services, conduct analytics and search engine activities, and contribute to the development and improvement of the Services. Additionally, they provide any necessary technical support related to our Services. In accordance with applicable legal requirements, Joinco Games has entered into agreements with these service providers that include obligations ensuring your personal data is not used or shared for purposes other than the provision of the relevant service.

4.5. Our Analytics Providers

To deliver and enhance our services, as well as to conduct analysis and research, we use third-party analytics providers such as Unity and Firebase The device data we send to these providers is encoded. These providers may assign random identifiers to this data and cannot trace it back to you personally. We may aggregate the data for comparison purposes.

4.6. Our Cloud Service Providers

We store the information we collect from you on servers provided by third-party cloud service providers such as iCloud and Google Cloud Platform.

4.7. Tracking and Fraud Prevention Providers

To ensure the security and integrity of our Services, we may share your personal data with third-party monitoring and fraud prevention providers. These providers help us detect, prevent, and respond to fraudulent activities, unauthorized access, and other security threats. They use advanced analytics and real-time monitoring tools to safeguard your data and ensure the safe use of our Services. Such data processing is necessary to protect both our users and our platform from potential harm.

In compliance with applicable data protection laws, Joinco Games has established contractual agreements with these providers. These agreements restrict the use of your personal data solely for the purpose of fraud detection and prevention, and they include obligations to prevent the sharing of this data for any other purposes. We continually monitor and assess these providers to ensure their compliance with our security standards and applicable legal requirements.

4.8. Other Third-Party Service Providers

We use Unity Software to develop our games. For more information about Unity’s data processing practices, please refer to Unity’s privacy policy at: https://unity3d.com/legal/privacy-policy.

In the future, we may enter into agreements with additional partners or replace existing ones to perform any services related to our games. Such changes will be updated from time to time or immediately when there are significant changes to our data processing practices.

Joinco Games may share your information, including as required or requested by law enforcement or other public authorities, to protect the security of our Services, servers, network systems, databases, users, and business. This includes sharing information related to investigations into fraud, intellectual property violations, interference with our rights, property, or users, or other illegal activities that could expose you or us to legal liability.

We reserve the right to access, retain, and share your personal data, account information, and content with relevant third parties in situations involving legal requirements, legal processes, court orders, subpoenas, or national security requests. Such situations may include compliance with laws, legal processes, and public authority requests, as well as protecting your rights, property, or security.

Additionally, we reserve the right to share your information to enforce Joinco Games' policies and agreements, collect debts, investigate or prosecute suspected or actual illegal activities, and address national security, law enforcement, or other public interest matters as deemed necessary.. Furthermore, we may disclose information if we reasonably determine it is necessary to enforce our terms or protect our operations, users, or user experience. Joinco Games may also disclose information if we believe in good faith that such disclosure is necessary or reasonable for reasons not outlined above.

4.10. Advertising Networks and Partners

In some of our games, we use analytics providers to measure performance, optimize advertising campaigns, display ads, conduct analysis, and prevent fraud. These providers may use APIs and SDKs within our games to collect and analyze data related to users and devices. This data may include impressions, clicks, installations, or other performance indicators of advertising campaigns and post-install in-app activities. These providers may assign random identifiers to this data and cannot trace it back to you personally.

We collaborate with third-party advertising networks and partners to deliver advertisements and personalized content on our Services, other websites, services, and devices. These third parties may collect information directly from your browser or device through cookies or other data collection technologies when you visit our Services. This information is used for purposes such as delivering promotional services, reporting, attribution, analysis, market research, and providing and enhancing personalized advertising.

For more information, please refer to the section on Online Advertising and Data Third Party Data Collection.

Joinco Games utilizes third-party advertising services, such as advertising networks, data exchanges, traffic management service providers, social networks, and marketing analytics providers, to support our services. These third-party providers use cookies and similar tracking technologies (for detailed information, see the "Cookies and Similar Technologies" section above) to collect information about your devices and usage of our services. This information enables Joinco Games or our third-party providers to identify you or your device, deliver targeted advertisements to you or your device, and measure the effectiveness of those ads. This information may include categories such as identifiers/contact information, internet/electronic activity, device and usage data, and profile inferences.

To continue offering our games for free or at a low cost, Joinco Games contracts with certain third-party advertising networks. These advertising networks may use third-party tracking providers to monitor the performance of advertising campaigns. Our advertising partners are allowed to use their own third-party tracking providers to track ad impressions, clicks, installations, or other indicators of advertising campaign performance.

Joinco Games and our third-party providers collect or share this information when you use our services, click on a site or advertisement, or launch one of our games or other mobile applications. The collected information:

Allows for accurate and necessary payment processing for advertisements provided on behalf of Joinco Games (e.g., ads prompting you to purchase or download one of our games) and ensures Joinco Games receives payment when you view an ad in our services;
Helps prevent you from seeing the same ads repeatedly;
Assists in selecting and displaying targeted ads or other content that may be of particular interest to you on your device (e.g., on a visited site, social network service, or mobile application you use);
Aids in measuring and analyzing the effectiveness of our ads, the popularity of content, and traffic on our services;
Helps us improve the quality of our services and user experience.

Joinco Games incorporates various functions into its services, such as social media interaction tools, application programming interfaces (APIs), or software development kits (SDKs) provided by our partners. Relevant partners may access and process the data collected through our services according to their own privacy policies. We recommend reviewing these privacy policies carefully to understand their data processing practices.

These partners may have access to various data related to your interactions with our services and devices (e.g., IP address, mobile identifiers, pages visited, location, visit times). Additionally, we may share the data we collect about you with third-party advertising partners. These advertising partners may use this data (and similar data collected from other services) to deliver targeted ads when you visit third-party services within their networks. These advertising partners will operate in accordance with their own privacy policies. This practice is generally referred to as "interest-based advertising" or "online behavioral advertising."

If you prefer not to have your personal data shared with third-party advertising partners, please follow the instructions in the "Your Rights and Choices" section below to manage your preferences.

In certain situations, we may share personal data with specific third parties or publicly, based on an individual's explicit consent or written instructions. This consent or instruction must be clear, specific, informed, and based on voluntary agreement. For example, with an individual's explicit consent or instructions, we may publicly share their opinions, comments, or other personal content on our Sites or in any publication related to our services. Such sharing will be conducted solely within the framework of the individual's consent and in compliance with applicable legal regulations.

4.13. Use of Personal Data in the Event of Asset Sales, Change of Control, and Corporate Restructuring

In the event of a sale of Joinco Games’ assets, merger, acquisition, corporate restructuring, bankruptcy, or change in ownership structure, or during the preparation for such events, third parties involved in these transactions or acquiring Joinco Games' assets will have the right to continue using the personal data and other information you have provided to us in accordance with the terms and conditions outlined in this Privacy Policy. Such situations will be subject to our legal obligations and relevant regulations regarding data transfer and processing by third parties.

ADVERTISING AND THIRD PARTY DATA COLLECTION

This text provides information about the advertising processes that help finance our Services and enable us to offer our Games for free. In some of our Games, we may display both our own advertisements and those from third parties. Additionally, we may advertise our Games on third-party properties outside of our Services (e.g., on websites or applications). This section offers detailed information on how we may use your data for advertising purposes and how you can control the use of this data.

5.1. General Information:

We use advertising to fund our services and offer our games for free. To continue offering our games at no cost, we need to share the information we collect from you with third-party advertising partners. However, to protect your privacy, we only retain personal information temporarily. The information we gather helps us improve our websites and games, as well as make our games available to a wide audience for free.

If you are a user located in the European Economic Area (EEA), please note the following:

(a) When you use our games, we rely on our legitimate interests to display ads to you. The legal basis for showing ads to users in the EEA is grounded in legitimate interests under Article 6, Section 1, Subsection (f) of the GDPR, in compliance with European data protection requirements. Additionally, the data processing agreements we have with external advertising technology providers are structured according to Article 28 of the GDPR. We ensure that our external service providers commit to a high level of data protection by establishing data protection agreements.

(b) For personalized ads, we always seek your consent before sharing any information with our advertising partners. You provide this consent by clicking the appropriate button when the game is loaded. We only allow our advertising partners to show you personalized ads if you click the "ACCEPT" button in the relevant pop-up and consent to the sharing of your personal information for personalized advertising purposes. Our advertising partners use various technologies that process your personal information in different ways, so it is important that you review the data processing practices of these advertising partners before agreeing to personalized ads when the game loads. You can find the list of our current advertising partners and links to their privacy policies here. The legal basis for showing personalized ads to users in the EEA is your consent, as specified in Article 6, Section 1, Subsection (a) of the GDPR, in compliance with European data protection requirements. The data processing agreements with external advertising technology providers are also in line with Article 28 of the GDPR. We aim to improve our games and deliver more relevant ads to players. You have the right to withdraw your consent at any time. If you withdraw or do not provide your consent, you may continue to see the same number of ads on your mobile device; however, these ads may be less relevant to you since they will not be based on your interests, behaviors, or demographic information. Our advertising partners may continue to show you ads based on the content of the application you are using.

5.2. In-Game Advertising:

To display in-game advertisements, we may share your advertising ID and IP address with advertisers (or ad networks). This enables them to deliver relevant ads to you within our games and across third-party properties. You can manage and limit the use of your advertising ID through your device settings. While we do not have control over specific ads shown in our games (as these are managed by ad networks), we implement blacklist measures to block certain categories of ads.

The Advertising ID is an alphanumeric string provided by your mobile device's operating system, known as the Identifier for Advertisers ("IDFA") on iOS devices and the Google Advertising Identifier ("GAID") on Android devices. Advertising IDs are used by ad networks for various purposes (you can access our advertising partners' privacy notices here), including limiting the frequency at which you see the same ad, ensuring that ads are shown to real users rather than automated bots, and delivering ads that are relevant to you based on your interaction with the Advertising ID.

Other brands purchase ad placements through an ad network or ad exchange platform to promote their products within our games. The ad network or ad exchange platform acts as an intermediary between other game companies and us. To charge the advertiser, the ad network tracks ad clicks and potentially the installation of other developers' applications. Ad impressions, clicks, and installs are measured using the Advertising ID, and the games you play are monitored to market similar types of games to you. Advertisers typically use the IP address to determine your general geographic location at the country, state, and sometimes city level.

5.3. Displaying Our Game Ads on Third-Party Services

We also promote our games by displaying ads in other applications, targeting audiences that are likely to be interested in our games (determined through the use of Advertising IDs).

Advertising IDs are used by ad networks for various purposes (you can access our advertising partners' privacy notices here), including:

Measuring Ad Effectiveness: Analyzing the total impressions, clicks, and installs that our ads achieve when shown in other publishers' games.
Re-engaging Lapsed Players: Informing players who haven't engaged with the game for a while about new content. We provide a list of these users, represented by Advertising IDs, to an ad network. The ad network then shows ads to these users about the new content in the game.
Avoiding Ads for Active Players: Ensuring that players who are already actively playing the game are not shown ads. We send a list of active players, represented by Advertising IDs, to an ad network, which then excludes these players from ad targeting.
Marketing Games to Potential Players: Promoting our games to potential new players.

These practices help us effectively reach and engage with both new and existing players through targeted advertising.

5.4 Processing of Personal Data and Third-Party Advertising Services

We collaborate with third-party advertising companies to deliver personalized ads and promotions based on your browsing history and interests. As part of this collaboration, we allow third-party online advertising networks, social media companies, and other service providers to collect information about your use of our services over time. This information is used to display ads to you. These ads may be shown both within Joinco Games Services and on other websites, services, and devices.

In the context of advertising activities, our partners may combine data collected from other sources about you with the personal data processed by us to help personalize advertising campaigns. These partners collect this data through their own services or via third-party websites and services, analyzing it to predict what types of ads might interest you. Consequently, if our partners determine that an ad from Joinco Games may appeal to you, they may display Joinco Games ads to you while you are using other websites and services.

For the provision of our services and the collection of data from your device, we use advertising identifiers and similar technologies. These technologies enable us and our third-party advertising partners to:

Recognize you and your device;
Deliver ads tailored to your interests;
Facilitate interaction between our services and third-party social media networks or platforms, with your consent;
Provide personalized services to you and third parties (e.g., delivering services in the correct language).

The data used to deliver ads tailored to your interests is typically collected through tracking technologies such as cookies, web beacons, embedded codes, and location-tracking technologies. This data may include device identifiers, clickstream data, browser type, timestamps of visits to websites, advertising identifiers (AdID), precise location data, and similar information. To recognize you across different devices, we may use a common account identifier (e.g., an encrypted email address or user ID) in collaboration with our third-party advertising partners.

Our third-party partners and our company may process your data to deliver more relevant online ads, as well as for purposes such as reporting, attribution, analysis, and market research. Additionally, we may show you and other users on social media platforms personalized ads through services provided by these platforms. To deliver such personalized ads, we may share an encrypted version of your email address or other personal data with platform providers.

Our website uses strictly necessary cookies, functional cookies, analytics and performance cookies, as well as advertising and targeting cookies. For more information on these cookies, please refer to our Cookies section.

INTERNATIONAL DATA TRANSFER

The personal data collected or stored by Joinco Games under this Privacy Policy may be stored and processed in various countries worldwide, including but not limited to the Republic of Turkiye, the United States of America, and European Union member states. When Joinco Games transfers your personal data internationally, we will take all necessary technical and administrative measures in accordance with applicable local laws to ensure the security of your data.

Please note that privacy laws can vary from region to region. Therefore, the privacy laws governing where your personal data is stored, used, or processed may differ from those in your place of residence and may not provide the same level of protection. However, when it is necessary to transfer your personal data outside of Europe, we act within the framework of appropriate safeguards such as adequacy decisions and standard contractual clauses.

In this context, Joinco Games is committed to ensuring the protection of your personal data by taking the necessary measures in compliance with the legal requirements of the relevant countries to maintain an adequate level of security. For any international data transfers, Joinco Games will only transfer your personal data in accordance with applicable legal regulations and with a commitment to maintaining the confidentiality of your personal data.

Joinco Games may transfer the personal data we collect or process to countries outside the European Union. When we carry out such international data transfers, we rely on adequacy decisions, standard contractual clauses, or similar legal mechanisms to ensure appropriate safeguards as required by the General Data Protection Regulation (GDPR) and other relevant data protection laws.

We may transfer personal data related to you outside of Europe. When we do so, we rely on the appropriate and recognized safeguards under applicable laws, such as adequacy decisions and standard contractual clauses.

If you use our Services from the European Union or any other region governed by data collection and usage laws, please be aware that by providing your personal data to us, you consent to the processing of your data in the jurisdictions mentioned above.

By choosing to use our Services or providing us with personal data in any way, you acknowledge and agree that any legal disputes arising from international data transfers or processing activities will be governed by the laws of the Republic of Turkiye as outlined in this Privacy Policy. Furthermore, you agree that any disputes related to our Services will be resolved in accordance with the provisions specified in the Joinco Games Terms of Service and will be subject to the exclusive jurisdiction of the courts of the Republic of Turkiye.

WAYS TO CONTROL YOUR DATA

7.1. Deleting or Resetting Your Data:

There are various ways to control and manage your personal data. For example, you can stop the collection of your personal data by deleting our games from your mobile device. Additionally, you have the option to reset the advertising ID on your mobile device, which allows you to reconfigure or reset the data used for advertising targeting purposes.

These actions provide an effective method to stop or limit the processing of certain personal data. However, please note that such actions may affect how you use and experience our Services. Deleting our Services or resetting your advertising ID does not necessarily mean that your data has been completely deleted or that processing has ceased; these actions may only limit certain data collection processes.

7.2. Limiting Access to Your Device Information

To restrict or block access to your device information by our Services, you can make the necessary adjustments through the "Settings" app on your device. For example, you can revoke or limit our Services' access to your network devices, location data, or other applications.

By removing these permissions, you can stop our Services from accessing certain features or functions. However, please be aware that such access restrictions may affect the full functionality of our Services and could limit the use of certain features.

7.3. Reviewing, Correcting, or Deleting Your Information

If you have any questions about reviewing, correcting, or deleting your personal data, please contact us using one of the communication methods provided at the end of this Privacy Policy.

We will make reasonable efforts to take the necessary steps to correct or delete your personal data in accordance with your requests. However, in some cases, it may not be possible to modify or completely delete certain data due to legal or commercial requirements. In such cases, we will inform you and offer possible alternative solutions.

7.4. Push Notifications

We may send you push notifications related to updates about our game, high score alerts, and other topics that might interest you. If you prefer not to receive such notifications, you can update your notification preferences or disable notifications at any time through the settings menu on your mobile device. Changing your notification preferences may stop notifications entirely or limit the receipt of certain types of notifications.

7.5. Online Advertising

If you do not wish to have your personal data processed for interest-based advertising, you can opt-out by sending an email to [email protected]. If you choose to stop receiving interest-based or personalized ads, please be aware that you will still see ads, but they will not be customized based on your personal data. In this case, you may receive general ads related to Joinco Games products and Services, but these ads will not be targeted according to your interests.

7.6. Opting Out of Interest-Based Ads on Your Device

To prevent interest-based ads from being shown to you, you can disable the use of your device's advertising identifier or reset it by changing your device settings. The specific settings may vary depending on your device model and operating system, but you can typically find these options under the "Privacy" or "Ads" section of your device settings.

Disabling or resetting your advertising identifier may limit the delivery of interest-based ads to you, but you will continue to receive general ads. If you need detailed instructions on how to perform these actions, you can refer to your device's user manual or contact us for assistance.

7.7. Opting Out of Facebook Ads

To update your preferences for ads served through the Facebook platform, you can log in to your Facebook account and adjust your ad preferences from the "Settings" section. Additionally, you have the option to disconnect our games from your Facebook account or other social media accounts.

By following these steps, you can manage the ads shown to you through Facebook and end connections with your social media accounts. If you need further information on how to perform these actions, please refer to Facebook's user guide or contact us for assistance.

7.8. Cookies

For detailed information on how to manage or disable cookies, please refer to the Cookies section of this Privacy Policy. This section provides step-by-step instructions on how to control your cookie settings and information on the measures you can take to limit the use of cookies.

YOUR RIGHTS AND OPTIONS

As a user of our Services, you have certain legal rights regarding your personal data and how it is processed by us. These rights include, under certain conditions, the ability to request the correction, deletion, or restriction of the processing of your personal data. However, please be aware that exercising some of these rights (e.g., requesting the deletion of your personal data) may impact our ability to provide you with our products and services fully or interact with you effectively.

To exercise these rights or to make any requests related to the processing of your personal data, you can contact us at [email protected]. Requests received will be processed as quickly as possible in accordance with applicable legal regulations, and you will be informed of the results.

Additionally, as a resident of the European Union, you may have specific rights under the EU General Data Protection Regulation (GDPR). If you reside in Virginia, you may have rights under the Virginia Consumer Data Protection Act (VCDPA), and if you reside in Brazil, you may have rights under the Lei Geral de Proteção de Dados Pessoais (LGPD). Users residing in other countries may also have similar rights under local data protection regulations.

Please do not hesitate to contact us to exercise your rights or to make requests regarding the processing of your personal data under applicable laws. We will take the necessary steps to provide detailed information about the relevant legal rights and how to exercise them.

8.1. Access to Personal Data

You have the right to access your personal data processed by Joinco Games. By exercising this right, you can request information about which personal data is being processed and how it is used. If necessary, you can also request a copy of this data. To exercise your right to access your personal data, please contact us.

8.2. Rectification or Deletion of Personal Data

If you believe that your personal data is incorrect or incomplete, you have the right to request Joinco Games to correct or complete this data. Additionally, under certain legal conditions, you may request the deletion of your personal data from Joinco Games.

To exercise these rights or to submit requests for the rectification or deletion of your personal data, please contact us. Following our assessment, your request will be processed as quickly as possible, and the necessary actions will be taken.

8.3. Deactivating Your Account

If you wish to completely deactivate your account, you can remove the connection between our mobile games and your Facebook account and uninstall our games from your device. Please note that when your account is deactivated, your in-game progress and any unused virtual currency will be irretrievably lost.

Deactivating your account may result in the deletion of all your game data, which will be irrecoverable. We recommend that you consider this carefully before proceeding with this action.

8.4. Limiting the Processing of Your Personal Data

Under certain conditions, you have the right to request that Joinco Games limit the processing of your personal data. You may use this right to request that your personal data be processed only for specific purposes or that the processing of your data be completely halted. Please be aware that such requests will be evaluated and processed in accordance with applicable legal requirements.

8.5. Objection to the Processing of Personal Data

Under certain conditions, you have the right to object to the processing of your personal data by Joinco Games. You can use this right to oppose the processing of your personal data for specific purposes and request that such processing activities be halted. Your objection will be evaluated in accordance with applicable legal regulations and will be processed if deemed appropriate.

8.6. Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format. Under certain conditions, you can use this right to transfer your data to another service provider. This right allows you to request the direct transfer of your personal data from one company to another or to receive the data for your own use. To exercise your right to data portability or to obtain more information about this right, please contact us.

8.7. Right to Opt-Out

8.7.1. Specialized Advertising

If you do not wish for your personal data to be processed for the purpose of delivering personalized advertisements, you have the right to object to this processing.

By exercising this right, you can stop the delivery of targeted advertisements based on your interests and prevent your personal data from being processed for this purpose. To submit this request or to obtain more information, please contact us.

8.7.2. Specific Types of Profiling

You have the right to stop the processing of your personal data for certain profiling activities.
By exercising this right, you can object to specific types of profiling and request that these activities not be applied to you. To exercise your opt-out rights, please contact us using one of the communication methods specified in the "Contact Us" section of this Privacy Policy. Additionally, you can refer to the "Ways to Control Your Data" section for more information on how to manage your data.

The exercise of your rights regarding personal data processing is protected under the right not to be subject to discrimination or adverse treatment. However, please note that if the requested actions, such as data deletion, impede our ability to carry out personal data processing activities, we may not be able to fully provide our products and services, or the quality of the services may decline, or our interactions with you may be limited. This situation arises solely from the technical and legal requirements related to the inability to process personal data in response to the request and is not a result of any discriminatory practices.

8.8. Right to Appeal Regarding the Use of Rights

If we make a negative decision regarding your rights claims, we will provide you with a written explanation of the reasons for this decision. You have the right to appeal this decision in accordance with the procedures and timeframes set out by national and international regulations. During the appeal process, your requests will be reassessed, and necessary actions will be taken based on the final decision of the appeal authority. Measures will be taken to ensure that there are no disruptions in our personal data processing activities and that your rights are protected during the appeal process.

In certain cases, explicit consent is required for the processing of your personal data. You have the right to withdraw your consent at any time. Please note that withdrawing your consent does not affect the legality of any data processing activities carried out before the withdrawal. If you withdraw your consent, the relevant personal data processing activities will be stopped, and you will be informed about this. However, you should be aware that withdrawing your consent may lead to limitations in the provision of some of our services.

8.10. Identity and Residency Verification Requirement

Under certain conditions, verification of your identity and residency in California may be required to process your requests. During the identity verification process, we will generally request sufficient and accurate data that matches the information we hold in our systems, such as your email address, phone number, and/or the date of your most recent transaction within our Services. Additional personal data may also be requested from you as needed. Successful and complete verification of your identity is necessary to process your requests.

In certain situations, including if we are unable to verify your identity or access the relevant information in our systems, we may reject your request to exercise the aforementioned rights. If we are unable to fulfill all or part of your request, a detailed explanation of the reasons will be provided to you in writing. This process is implemented to ensure that your requests are evaluated and that decisions are transparently justified.

LOCAL DATA REGULATIONS

9.1 Rights of Residents in the United Kingdom/EEA

As a user residing within the European Economic Area (EEA), you have certain rights concerning the processing of your personal data. These rights are governed by relevant data protection legislation such as the General Data Protection Regulation (GDPR) and the UK Data Protection Act, and may be subject to certain exceptions and limitations. These rights include:

9.1.1. Right to Information

You have the right to be informed about whether your personal data is being processed. If your personal data is being processed, you have the right to request information about the processing activities.

9.1.2. Access to Processing Activities

If your personal data is being processed, you have the right to obtain details about these processing activities. You can request detailed information about the purposes of the processing, the scope, the methods used, and how your personal data is being handled.

9.1.3. Knowledge and Control of Processing Purposes

You have the right to learn the purposes for which your personal data is being processed and to verify whether your data is being processed in accordance with those specified purposes.

9.1.4. Information on Transfers to Third Parties

You have the right to know which third parties your personal data is being transferred to, whether domestically or internationally. This allows you to understand who your personal data is shared with and for what purposes it is being used.

9.1.5. Request for Correction

In the event that your personal data is processed incompletely or inaccurately, you have the right to request correction of the data. You can request that incorrect data be corrected and incomplete information be completed.

9.1.6. Request for Deletion or Erasure

You have the right to request the deletion or erasure of your personal data. You can request the deletion of your data if it is no longer necessary for the purposes for which it was processed, or if you believe it should no longer be processed.

9.1.7. Request to Notify Third Parties

You have the right to request that your requests for correction, deletion, or erasure of personal data be communicated to third parties to whom your personal data has been transferred. This is important to ensure that your personal data remains accurate and up-to-date.

9.1.8. Objection to Automated Processing Results

You have the right to object to results that are detrimental to you, which arise from the analysis of your personal data by automated systems. You have the right to assess whether such analyses are legally compliant.

9.1.9. Request for Compensation

You have the right to seek compensation for damages suffered due to the unlawful processing of your personal data. This ensures that your grievance is addressed in the event of a violation of your data protection rights.

9.1.10. Request for Restriction of Processing Activities

You have the right to request the restriction of the processing activities concerning your personal data. This ensures that your data is processed only for specific purposes and is protected from other processing operations.

9.1.11. Right to Data Portability

You have the right to request the portability of your personal data. This allows you to easily transfer your data to another data controller.

9.1.12. Objection to Automated Decisions

You have the right to object to decisions that are made solely through automated processing, including profiling, that have legal or similarly significant effects on you. This allows you to exercise your rights regarding the impact of automated processes on you.

9.1.13. Right to Lodge a Complaint and Seek Compensation

If your personal data is processed in violation of applicable legal regulations, you have the right to lodge a complaint with the relevant supervisory authority and to seek compensation if you suffer harm. This provides you with the means to take necessary steps to ensure the protection of your personal data.

9.1.14 If you reside in Switzerland:

You can submit data protection-related complaints to the Swiss Federal Data Protection and Information Commissioner (FDPIC). Further information and contact details can be found at this link.

9.2. Rights of Turkish Citizens

As a user residing in Turkiye, you have certain rights regarding the processing of your personal data under the Personal Data Protection Law (Law No. 6698). These rights may be subject to certain exceptions and limitations according to relevant legislative provisions. The rights you have under the applicable legislation are as follows:

9.2.1. Right to Apply to the Data Controller

9.2.1.1. Right to Learn Whether Your Personal Data is Processed

Pursuant to Article 11 of the Personal Data Protection Law No. 6698, you have the right to request information from the data controller regarding whether your personal data is being processed.

9.2.1.2. Right to Request Information About the Processing of Your Personal Data

If your personal data is being processed, you have the right to request information from the data controller about the processing activity. This includes details on the purposes for which your personal data is processed, the legal basis for processing, the method of data collection, the retention period, and all other relevant details.

9.2.1.3. Right to Learn the Purpose of Processing Your Personal Data and Whether It is Used Appropriately

You have the right to request information from the data controller about the purposes for which your personal data is processed and whether it is used in accordance with those purposes.

9.2.1.4. Right to Know the Third Parties to Whom Your Personal Data is Transferred

You have the right to request information about third parties to whom your personal data is transferred, whether domestically or internationally. This includes the right to obtain details about the identity of the individuals or organizations receiving your data and the locations to which the data is transferred.

9.2.2. Right to Correction, Deletion, and Restriction

9.2.2.1. Right to Request Correction of Your Personal Data

Pursuant to Article 11 of the Personal Data Protection Law No. 6698, you have the right to request the correction of personal data that is processed incompletely or inaccurately. In this regard, if you believe that your processed personal data is incorrect or incomplete, you can request the correction of this data and the necessary changes to be made in writing or by other methods specified in the Law.

9.2.2.2. Right to Request Deletion or Anonymization of Personal Data

You have the right to request the deletion or anonymization of your personal data from the data controller if the legal conditions for processing your personal data cease to exist, the purpose of data processing ends, or in other cases stipulated by the legislation. This right is particularly applicable when the processing period ends according to the purpose for which the data was collected or when the deletion or erasure of personal data is required under Article 7 of the Law.

9.2.2.3. Right to Request Restriction of Processing

If you dispute the accuracy of your personal data, you have the right to request the restriction of its processing until its accuracy is confirmed. In this context, you can request the data controller to limit the processing of your personal data to storage only and halt other processing activities until the necessary review regarding the accuracy of your data is completed.

9.2.2.4. Right to Receive and Transfer Your Personal Data

Pursuant to Article 11 of the Personal Data Protection Law No. 6698, you have the right to receive your personal data in a structured, commonly used, and machine-readable format. Additionally, you have the right to transfer this data directly to another data controller, to the extent technically feasible by the data controller. This right can be exercised when your personal data is processed based on your explicit consent or for the performance of a contract.

9.2.3. Right to Objection

9.2.3.1. Right to Object to Direct Marketing

You have the right to object at any time to the processing of your personal data for direct marketing purposes. The data controller is obliged to immediately cease processing your personal data for direct marketing purposes upon receiving such a request.

9.2.3.2. Right to Object Based on Personal Circumstances

Depending on the legal grounds for processing your personal data, you have the right to object to the data controller by presenting legitimate reasons related to your personal situation. In such cases, the data controller must evaluate your objection and, if the legitimate reasons are confirmed, must cease processing your personal data.

9.2.4. Right to Object to Automated Decisions

You have the right to object to decisions that are made solely through automated systems, which produce results that are detrimental to you. The data controller is obliged to review your objection and, if necessary, take steps to reconsider the decision or provide human intervention in relation to the decision.

9.2.5. Right to Lodge a Complaint

9.2.5.1. Right to Complain to the Personal Data Protection Authority

If you believe that the data controller has acted in violation of Law No. 6698 during the processing of your personal data, you have the right to lodge a complaint with the Personal Data Protection Authority. This right can be exercised in any situation where you believe the data controller has failed to fulfill its obligations.

Under the European Union General Data Protection Regulation (GDPR), if you believe that the data controller has acted in violation of the GDPR during the processing of your personal data, you have the right to lodge a complaint with the relevant supervisory authority. This complaint right may be directed to supervisory authorities in EU member states where your data is processed.

If you have any questions or concerns regarding your rights related to your personal data, please contact us via our privacy email address: [email protected].

Upon receiving a verifiable consumer request, we will make efforts to provide a written response within 30 days. Our written response will be sent to you by mail.

If you wish to delete or erase your personal data, please make this request by using the "Delete Data" button available in the game settings.

9.3. Rights for Residents of California

Joinco Games provides users residing in California with the right to request information, free of charge and once per calendar year, regarding whether their personal information has been shared with third parties for direct marketing purposes.

This right is granted under Section 1798.83 of the California Civil Code and requires users to contact Joinco Games to exercise this right. In response to such a request, users may receive a report including a list of third parties with whom their personal information has been shared and the types of personal information shared with those parties. Joinco Games does not share users' personal information with third parties for their own marketing purposes.

In certain situations, Joinco Games may require verification of your identity and residency in California. This verification process typically involves successfully verifying your account or providing sufficient information that matches the data we hold about you in our systems. This may include, but is not limited to, requesting additional personal data such as your email address, phone number, and/or the date of your most recent purchase of our Services.

During the identity verification process, we reserve the right to deny your request to exercise the aforementioned rights if the necessary information is not provided or if information about you cannot be identified in our systems. Additionally, if we are unable to fully or partially fulfill your request, we will provide you with reasons for our inability to comply.

Joinco Games conducts this verification process to ensure that the requested information is accurate and complete and to prevent misuse of our users' rights. If the verification process is not completed, Joinco Games is not obligated to fulfill the relevant request. We are committed to responding to a verifiable consumer request within 30 days. If we need additional time (up to 90 days), we will provide a written explanation and the extension period. Our written response will be sent to you by mail.

Our explanations will cover only the 12-month period from the date the verifiable consumer request is received. Our response will also explain any situations where we did not comply with the request. For data portability requests, we will provide your personal data in a usable format that facilitates transferring it from one entity to another.

9.3.1. Opt-Out Right

Under the CCPA, every California resident has the right to request that any business stop selling their personal information to third parties.

9.3.2. Right to Notification

You have the right to learn about the categories of personal data we collect and the purposes for which we collect it. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once a year.

9.3.3. Right to Disclosure

You may request a disclosure of the personal data we have collected in the past 12 months. Our Privacy Policy is a relevant document where you can find information about what personal data we collect about you, the sources of that data, and how we use it.

Additionally, you have the right to receive a free copy of your personal information in an easily accessible and readable format (right of access). You can make this request up to twice a year, free of charge.

Under the right of access, when providing information, we will give you the following details:

The categories of personal data we have collected about you,
The categories of sources from which the personal data was collected,
The purpose for which we collected your personal data,
The categories of third parties with whom we have shared your personal data,
The specific personal data we have collected about you.

9.3.4. Right to Deletion

You may request the deletion of personal data we have collected in the past 12 months.

We fully acknowledge your right to deletion; however, there may be instances where we are required to retain your personal data for a certain period. For example, to provide you with services, address security or functionality issues, comply with legal obligations, conduct public interest research, protect freedom of expression, or fulfill any other internal purpose you might reasonably expect. If such obligations do not apply, we can delete your personal information upon request.

9.3.5. Right to Equal Services and Prices

California residents are protected against discrimination for exercising their CCPA rights.

We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you access to the application,
Charge different prices or fees for the application, provide discounts, or offer other benefits or penalties,
Provide a different level or quality of the application,
Propose a different price or fee for services or suggest a different level or quality of the application.

How Can I Exercise My Rights?

If you reside in California, please remember that you have certain rights regarding your data under the California Consumer Privacy Act (CCPA) of 2018. Requests related to these rights should be made in writing or through a specific method and must be submitted to the communication channels designated by Joinco Games.

You can send your requests and inquiries regarding your rights to the email address: [email protected].

We will respond to your requests as soon as possible and within thirty days at the latest.

COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small data files that may contain an anonymous unique identifier. These files are sent to your browser from a website and stored on your device’s hard drive.

We utilize cookies to gather information. You have the option to configure your browser to reject all cookies or notify you when a cookie is being sent. However, please note that declining cookies might limit your access to certain features of our Service.

Most web browsers provide settings that allow you to manage your cookie preferences.

Learn how to manage cookies on common browsers:

Google Chrome (here)
Microsoft Edge (here)
Mozilla Firefox (here)
Opera (here)
Apple Safari (here)
HOW WE PROTECT YOUR DATA

The personal data you provide to Joinco Games is protected through physical and electronic security measures. These data are secured using industry-standard technical and administrative protocols such as firewalls and data encryption. We take appropriate protective measures to help ensure the security, integrity, and confidentiality of the information we collect about you.

To provide a safe and secure gaming experience and to maintain the privacy and integrity of your personal data, we continually develop and implement administrative, technical, and physical security measures designed to prevent unauthorized access, disclosure, alteration, loss, misuse, or destruction of your data. These special measures vary depending on the sensitivity of the data and may include encryption, pseudonymization of personal data where possible, physical and technological controls that limit access to services or systems containing personal data, and other similar precautions.

However, it is not possible to guarantee the absolute security of any data transmission system or data storage system. Therefore, although Joinco Games takes all necessary technical and administrative measures and exercises utmost care to protect your personal data, we cannot guarantee the absolute security of the information you provide to us or share through our Services.

By using our Services or providing us with your personal data, you consent to Joinco Games communicating with you electronically regarding security, privacy, and administrative matters. In the event of a security breach, we reserve the right to notify you of this situation either through notifications on our Services or by sending a message to your registered email address.

RETENTION

We will retain your information for the period necessary to provide you with our Services, fulfill our legal obligations, and/or enforce, defend, or establish our rights. We will keep your personal data as long as your account is active or as necessary to provide the Services. For example, we may periodically anonymize inactive game accounts and review and anonymize unnecessary data regularly. If you wish to delete your account or request that we no longer use your personal data to provide you with the Services, please contact us as outlined in the "Manage Your Account, Communications, and Data" section.

If your account is inactive, we will retain your account for a reasonable period during which we expect you to reconnect with our Services. After this period, we will delete your personal information, including your email address and login credentials, and you may no longer have access to your account.

If you wish to retrieve your personal data, we may continue to retain it for legitimate purposes such as fulfilling our legal obligations, resolving disputes, and enforcing our agreements. We may keep some of your personal information for a reasonable period to resolve disputes, enforce our terms and policies, manage our Services, and comply with technical and legal requirements and/or restrictions related to the security, integrity, and operation of our Services. After this period, we will take measures to either delete or archive your personal information.

CHILDREN’S RIGHTS

Our Services are intended for a general audience, and we do not knowingly collect data from individuals under the age of 16. If you suspect that data from your child has been collected, please contact us via the email address provided in the "CONTACT" section.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to make updates to this Privacy Policy from time to time. Any changes to the Privacy Policy will be posted on this page, and the date at the top of the Privacy Policy will be updated accordingly. If significant changes are made to this Privacy Policy, depending on the scope of the changes, we will notify you through your registered email address, highlight the updates on our Services, or use other appropriate communication channels. Changes will be effective as of the date they are published on this page, unless otherwise stated. To the extent permitted by applicable law, your continued use of our Services constitutes acceptance of the changes. We recommend that you periodically review this Privacy Policy to stay informed of any updates.

CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us via the email addresses listed below:

For emails related to the Privacy Policy: Email: [email protected]

For feedback related to the Privacy Policy: Email: [email protected]

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