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Privacy Policy

1. Purpose and Introduction

We, as Pure Oyun Yazılım ve Pazarlama Anonim Şirketi ("Pure Games", "we", or "us"), are a technology company that designs, develops, and markets mobile games. This Privacy Policy is incorporated by reference into the Pure Games Terms of Service. With this Privacy Policy, we intend to explain our online and offline information practices, the kinds of information we may collect, how we intend to use, process, store, protect, disclose, and share that information, and how you can opt out of a use or correct, change, or request the erasure of such information.

This Privacy Policy applies to websites, mobile applications, forums, blogs, community spaces, and any other online or offline services provided by Pure Games and any other online or offline offerings operated by or on behalf of Pure Games (collectively referred to as our "Services"). It also applies to our marketing, advertising, and promotional activities on all platforms and other services that we may provide to you from time to time. All individuals whose responsibilities include the Processing of Personal Information on behalf of Pure Games are expected to protect that data by adhering to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, Turkey, APAC, and other jurisdictions.

By downloading our mobile application, accessing and/or playing our games, interacting with our websites or other Services, or somehow communicating with Pure Games, Pure Games may collect information about you in accordance with the nature of the information and transaction within the current technical possibilities. You accept, acknowledge, and promise that your personal information and data might be used in a limited manner by Pure Games and/or through Pure Games to the extent that it is limited to the format and purposes set forth in this Privacy Policy. You give an explicit and informed consent to the processing of your Personal Information in accordance with this Privacy Policy. If you have any other concerns about providing data to us or it being used as described in this Privacy Policy, or if you do not agree to this Privacy Policy or Terms of Services, you should not install, access, or use our games or other Services.

Every type of information related to an identified or identifiable natural person constitutes personal data. Processing your personal data signifies all types of transactions performed on the data such as obtaining, recording, storing, preserving, altering, re-arranging, disclosing, transferring, acquiring, making accessible, alignment, and preventing access. Please note that Pure Games is not responsible for the actions of Platforms or Third Parties, the content of their sites, the use of information you provide to them, or any services they may offer. Pure Games reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

2. The Identity of the Data Controller

The data controller responsible for your personal data under applicable personal data protection legislations (including the Turkish Personal Data Protection Law No. 6698 - "KVKK", and the General Data Protection Regulation - "GDPR") is:

3. How We Collect Your Personal Data and Types of Information We Collect

We may collect personal data automatically whenever you download or use our Services to your device, whenever you send us your feedbacks or convey your information or support requests directly to Pure Games, from the Facebook, Apple App Store, Google Play App Store, Amazon App Store (referred to as "Platforms" or "Third Parties" together) platforms, and the business partners or other third-party companies who have obtained your consent or have another legal right to share such personal data with us (including advertising platforms and partners and data aggregators who have obtained it). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. Primary goals in collecting information are to provide and improve our Services, to administer your use of the Services, and to enable you to enjoy and easily navigate our Services. We endeavor to collect only that information that is relevant for the purposes of Processing.

3.1. Personal Data Collected from Platforms and Third-Parties

If you play any of our games or use any of the Services on connected third-party applications or connect the Services to any third-party applications or Social Networking Sites ("SNS") such as Facebook, Pure Games may receive certain information about you from the provider of the third-party application. The information received depends on the third-party application, your privacy settings and, if applicable, your friends' privacy settings on that third-party application.

3.2. Personal Data Collected Directly from You

When you use the Services or engage in certain activities, such as registering for an account, responding to surveys, requesting services or information, participating in questionnaires or contests, participating in forum discussions, or contacting us directly, we may ask you to provide some or all of the following types of information:

3.3. Automated Data Collection (Technical and Device Data)

When you use our Services via Platforms, Pure Games and the Service Providers acting on our behalf (such as Fabric Analytics, Google Analytics, or other web analysis tools) may store log files and use tracking technologies such as Cookies, web beacons, and/or tracking pixels. We may collect certain information automatically through your device, including:

3.4. Information Submitted Via Services

You agree that Pure Games is free to use the content of any communications you submit via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing and/or marketing the Services. Pure Games will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

3.5. Ad Networks

Pure Games may feature advertising within the Services. The advertisers may collect and use information about you such as performance and game contextual data like your games session activity; aggregated and/or de-identified information that is not intended to specifically identify a user; and technical information such as device identifier, Advertising ID, and IP address. Ad Networks may use this information to provide interest-based or targeted advertisements to you.

3.6. Social Media Widgets

The Services includes Social Media Features, such as the Facebook and Twitter button, and Widgets, such as the "Share" button or interactive mini-programs that run on the Services. These features may collect your IP address and which page you are visiting on the Services and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a Third Party or hosted directly on the Services. Your interactions with these features are governed by the privacy policy of the company providing it. To protect you from such a data transfer to the social media provider, we implemented technical protection measures ("2 click solution"). This allows you to agree to the data transfer to the corresponding social media provider on a case-by-case basis or permanently by activating the respective sharing button. You can withdraw a permanent agreement at any time.

4. Purposes for Processing of Your Personal Data

We collect, store, use, and process Personal Information for a variety of business purposes, including:

5. The Legal Grounds of Processing Your Personal Data

The legal grounds that Pure Games relies upon while processing your personal data under global legal frameworks (including KVKK and GDPR) are the following:

In data processing activities where your personal data is processed based on the explicit consent, you have the right to withdraw your consent at any time. Pure Games' statutory interest in processing your device and usage data is to provide better service to you, to make suggestions, to improve its services, to improve and update our Services, to facilitate the use of Services at the works related to your interest and preferences, within the framework of legal legislation.

Pure Games undertakes to keep your data and any confidential information strictly private and confidential, without prejudice to the contents hereof, to regard it as an obligation to keep confidentiality, to take all measures and act in due diligence to prevent all or any part of your information from entering into the public domain or be subject to unauthorized use, or to take measures to prevent the confidential information from disclosure to any third party. If, despite all necessary data security measures taken by Pure Games, the confidential information is damaged because of attacks on the system or captured by third parties, Pure Games shall have no responsibility with that respect. If you share your name, password, etc. used by you when creating the membership record with third parties, Pure Games shall not be responsible for any damages that may arise from the information shared with third parties.

6. The Transfer and Disclosure of Your Personal Data

In case a public institution is authorized to request personal data by the law, your personal data can be transferred to such authorized public institution in accordance with the applicable personal data protection legislations. Requests from judicial authorities will also be fulfilled in accordance with the applicable legislation.

Your personal data may be transferred to our business partners, affiliates, and service providers only if it is required to provide Services with you. We may share any information we receive with Service Providers (data processors) whom we entrust, including companies that provide:

Pure Games has executed appropriate contracts with the service providers that prohibit them from using or sharing personal data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. We require our affiliates and Business Partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them.

We may access, preserve, and disclose your personal data, other account information and content if we believe doing so is required or appropriate (e.g. required by Law and similar disclosures):

In addition, from time to time, server logs may be reviewed for security purposes (e.g., to detect unauthorized activity on the Services). In such cases, server log data containing IP addresses may be shared with law enforcement bodies, so they may identify users in connection with their investigation of the unauthorized activities. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

7. International Transfer

All personal data collected via or by Pure Games may be stored anywhere in the world, including, but not limited to, in Turkey, the United States, the European Union, in the cloud, on our servers and on the servers of our affiliates or the servers of our service providers. When we transfer your personal data internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in may be different from the privacy laws applicable to the place where you are resident.

By providing information to Pure Games, you consent to the storage of your personal data in these locations. If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Turkey and the United States and to processing of your data globally. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Turkey and the adjudication of any disputes arising in connection with Pure Games or the Site will be in accordance with the Terms of Services.

8. Marketing, Cookies and Targeted Advertising

We and our third-party partners may use personal data collected about you to send you marketing communications about our mobile applications and related Services based on your interests. This might include advertising within third party websites and apps, offering you customized promotions for our services in the game you play, or offering you in-game advertisements and special offers regarding our services and games.

8.1. Information Used for Marketing and Partners

We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as ad identifiers and other non-personal data collected from your device, the games you play and information about how you interact with our games and Services, country or region, and other information that we might acquire from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us. Our marketing partners may help us to serve ads to you by combining this information with data which they have collected about you elsewhere.

8.2. Cookies and Similar Technologies Used by Third Parties

Service providers acting on our behalf, may use cookies, pixel tags, web beacons, or similar technologies to automatically collect information through the Services. Cookies are small text files placed in users' computer browsers to store their preferences, allowing us to recognize you across devices. Cookies and tracking technologies relating to the website and games fall into the following categories:

9. Ad Identifiers, Software Development Kits and Similar Technologies

To provide our games, websites, and interest-based advertising, we use ad identifiers, software development kits (SDKs), and similar technologies. Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID (GAID) and/or Apple's ID for advertising (IDFA), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use Websites and applications, provide interest-based advertising, allow our Services to interact with a third-party social network or Platform, and enable us and third parties to provide you with more customized services (e.g., proper language setups).

10. Your Rights and Opt-Out Mechanisms

You have certain rights in connection with your personal data and how we handle it. You can exercise these rights at any time by opening an in-game support ticket or, alternatively, by contacting us via info@pure.gs.

10.1. Summary of Rights

10.2. Specific Opt-Out Instructions

Your verified claims, deletion requests, and questions will be answered as soon as possible and within thirty days at latest, in line with applicable laws.

11. Chat Functionality

Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after the relevant period of time which is determined by us, your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We are not responsible for privacy practices of the other users who will view and use the posted information.

12. Children's Privacy

Most of Pure Games Services and games are not intended for children under the age of 18 (or under 13 in the United States, or under 16 in specific European Union jurisdictions) and Pure Games does not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the designated ages or knowingly allow such persons to use Pure Games Services.

You must be over the legal age limits to play our games and use our Services. We do not collect personal data from anyone under age thresholds knowingly and willfully. However if the Services are used by such person in contradiction to this Privacy Policy, we may collect personal data from such person. If you are a parent or legal guardian of a child under the designated ages who uses our games, please contact us at info@pure.gs. We will delete your child's Personal Information if we are able to identify your child unless you provide us with your verifiable consent for your child to continue to use our games.

13. Legal Bases (for European Economic Area users)

If you are an individual in the European Economic Area (EEA), we collect and process personal data about you only where we have legal bases for doing so under applicable EU laws. The legal bases which we rely upon are the following:

14. Data Retention and Security

15. Changes to Our Privacy Policy and Practices

16. Contact Info of Data Controller

If you have any questions about the privacy practices or this Privacy Policy, please contact Pure Games' data protection officer by email at:

Pure Oyun Yazılım ve Pazarlama Anonim Şirketi
Email: info@pure.gs