Updated on 03.06.2023
FuGaWo (“FuGaWo”, “our”) are committed to protecting and respecting your privacy.
This privacy policy sets out the types of personal data we collect and use when you use one of our games and how we may use that data.
1. Introduction
This Policy covers our collection, processing and use of personal data when you use any of our games.
When you supply any personal data to FuGaWo, FuGaWo has legal obligations towards you in the way FuGaWo uses that data.
It is important that you read this Policy together with any other privacy notice or fair processing notices that FuGaWo may provide on the games at or around the time that FuGaWo collects or process personal data about you (for example, fair processing notices that FuGaWo may display to you at the time that you first download and begin using a game, or that may be displayed where you are given the opportunity to sign up to receive email updates from FuGaWo) so that you are fully aware of how and why FuGaWo is using that data.
By using our games, you are agreeing to the practices set out in this Policy to the extent permitted by data protection legislation s. If, for any reason, you do not agree to the terms of this Policy, please stop using the games.
FuGaWo reserves the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the relevant games know. However, it is your responsibility to check this Policy before each use of the games for ease of reference the top of this Policy indicates the date on which it was updated.
Please note that our games are not directed at children under the age of 13 and FuGaWo does not knowingly collect personal data about children. If you believe FuGaWo has collected personal data about your child, you may contact us at info@fugawo.com and request that FuGaWo ceases processing data about your child.
2. What is Personal Data and What does FuGaWo Collect?
What is Personal Data?
Where this Policy refers to “personal data” it is referring to data about you from which you could be identified such as your name, your date of birth, your contact details and even your IP address.
By law all organizations in the Turkey are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organizations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the Your Rights section of this Policy.
The data FuGaWo collects from you when you use the games
Voluntary Provision of Data
When you voluntarily supply your personal data to FuGaWo, for example where you; use the games to upload or send personal data (by filling out a form on our website, entering your details into a profile page on one of our games, contacting our customer support team, subscribing to one of our publications or newsletters, or similar activities in which you volunteer data about yourself); contact with FuGaWo by post, telephone, email or SMS; report a problem with a game; FuGaWo may collect, store and use the personal data that you disclose to FuGaWo.
The personal data that FuGaWo collect from you may include your title, name, age, address, email address but will depend on precisely what details you volunteer to FuGaWo as you interact with the games.
Automated Collection of Data
We may also collect personal data about you when you visit a game (in particular the FuGaWo website) through the use of technologies such as cookies. The following are examples of data that FuGaWo may collect:
– Information about your device, browser or operating system (including unique identifiers which identify that device, such as your “Identifier for Advertising” or “IDFA”);
– Your IP address and information about the network you are using to access our game;
– Information about links that you click in games and pages you view on our games
– Length of visits to certain pages on the games;
– Data about how you play our games such as your scores, progress and global ranking;
– Data about purchases you make make via our games (e.g. in-app transactions) including details of the purchases you have made and the value of those transactions;
– Details about other users with whom you have connected via our games (e.g. your Friend lists) and any communications you send/receive to such people;
– Subjects you viewed or searched for;
– Page response times;
– Records of download errors and/or broken links;
– Page interaction information (such as details of your scrolling, clicks, and mouse-overs);
– Methods used to browse away from the page;
– The full Uniform Resource Locators (URL) clickstream to, through and from our games (including date and time).
FuGaWo uses the data described above for several different reasons. Firstly, FuGaWo uses it to ensure that the games work properly and that you are able to receive the full benefit of them. Second, FuGaWo uses the data to monitor online traffic and audience participation across the games. The relevant data is processed due to the fact that it is mandatory for the legitimate interests of FuGaWo, provided that this processing shall not violate the fundamental rights and freedoms of the users.
FuGaWo also uses the data described above to provide a range of services to you these include answering your support queries, giving you access to in-game functions such as records of high scores, enabling you to purchase items in-game, and letting you connect with and communicate with your friends across our games.
Our games may include various functionality which lets you connect to social media (such as Facebook) if you choose to use this functionality then FuGaWo will collect various data from you in order to enable those connections and to enable FuGaWo to keep accurate records of the connections that you have made.
Third Party Resources
Our games contain various features that serve advertisements to you. In order to make those advertisements as relevant as possible FuGaWo uses third party advertising networks, which collect and use details about you and your interests in order to target relevant advertisements to you (rather than showing all game users the same material).
Where FuGaWo uses these services FuGaWo will give you the opportunity to disable the collection and transmission of information about you to those networks. Any such refusal will not cause you to cease seeing adverts, but it will decrease the relevancy of the adverts which are shown to you.
For details of the advertising partners that FuGaWo uses, please see the section below which names our providers.
3. How and Why does FuGaWo Use/Share Your Personal Data?
Sharing Your Personal Data
Depending on how and why you provide FuGaWo with your personal data FuGaWo may share it in the following ways:
– FuGaWo may share your Personal Data with our Turkish company, which deals with customer support requests where they arise;
– FuGaWo may share your Personal Data with selected third parties who FuGaWo sub-contract to provide various services and/or aspects of the game’s functionality, such as where third party plugins provide functionality such as message boards or image hosting services (see Service Providers below);
– FuGaWo may share your Personal Data with analytic s and search engine providers that assist FuGaWo in the improvement and optimization of the games as described above.
FuGaWo will not share your personal data with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which FuGaWo is undertaking with a third party (e.g. a competition where a third party is providing the prize) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your personal data may be used, which you will be notified of at the relevant time.
FuGaWo may also disclose your personal data to third parties in the following events:
– If FuGaWo is acquired by a third party, in which case personal data held by FuGaWo about our customers will be one of the transferred assets;
– If FuGaWo is under a duty to disclose or share your personal data in order to comply with any legal obligation, or if FuGaWo is asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder;
– In order to enforce or apply our games s terms of use or terms and conditions; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Service Providers
Our service providers provide FuGaWo with a variety of administrative, statistical, and technical services. FuGaWo will only provide service providers with the minimum amount of personal data they need to fulfil the services that FuGaWo request, and FuGaWo stipulate that they protect this data and do not use it for any other purpose. The following is a list of our major service providers:
– Azure Playfab (Microsoft Corp.)
– AppsFlyer (AppsFlyer Ltd.)
– AdMost (AdMost Mediation Ltd.)
– AdMob (AdMob Google Inc.)
– AdColony (Jirbo, Inc.)
– AppLovin (AppLovin Corporation)
– Facebook Audience Network (Facebook, Inc.)
– Unity Ads (Unity Technologies ApS)
– Vungle (Vungle, Inc.)
– SupersonicAds (SupersonicAds Ltd.)
– Facebook Analytics for Apps (Facebook, Inc.)
– Facebook Authentication (Facebook, Inc.)
– Google Analytics for Firebase (Google Inc.)
– Google Analytics (Google Inc.)
Links to Third Party Sites
Where FuGaWo provides links to third party websites that are not affiliated with FuGaWo (for example. where you click or tap on adverts in a game) such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those games.
4. How Long does FuGaWo Keep Your Personal Data?
FuGaWo will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.
Where you sign up to receive email marketing from FuGaWo, FuGaWo will retain your email address on file should you ever “opt-out” of receiving emails from FuGaWo. FuGaWo will retain your email address in this way in order to ensure that FuGaWo continues to honour and respect that opt-out request.
In some circumstances you can ask FuGaWo to delete your data: see “Your Rights” below for further information.
5. Security
FuGaWo takes the protection of your personal data very seriously. FuGaWo uses encryption (SSL) to protect your personal data when appropriate, and all the data provided to FuGaWo is stored on secure servers once FuGaWo receive it.
FuGaWo may store your personal data on secure servers either on our premises or in secure third party data centers.
Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for FuGaWo or for one of our suppliers and may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services.
In particular, if you engage with FuGaWo for support services (e.g. if you report a problem with one of the games) it is highly likely that your complaint will be dealt with by our support team in Turkey.
FuGaWo may process, store or transfer your personal data in Turkey or abroad, in accordance with the the Law on Protection of Personal Data No. 6698 and the relevant legislation within the limits set forth in the Policy. Where we transfer your data to a service provider that is outside of Turkey we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. If you would like more information about how the mechanism via which your personal data is transferred, please contact info@fugawo.com.
If FuGaWo ever give you (or where you have chosen) a password which enables you to access certain parts of this game, you are responsible for keeping this password confidential. FuGaWo ask you not to share a password with anyone.
6. Your Rights
As a data subject you have a number of rights in relation to your personal data in particular your requests under Article 11 of the Law on Protection of Personal Data No. 6698 regarding the rights of data subject. Below, FuGaWo has described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that FuGaWo hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that FuGaWo hold about you in order to enable you to check that it is correct and to ensure that FuGaWo is processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from FuGaWo that do not relate to your personal data.
You can exercise this right at any time by writing to FuGaWo using the contact details set out here and telling FuGaWo that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that FuGaWo corrects personal data that FuGaWo hold about you which you believe is incorrect or inaccurate. You may also ask FuGaWo to erase personal data if you do not believe that FuGaWo needs to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that FuGaWo may ask you to verify any new data that you provide to FuGaWo and may take our own steps to check that the new data you have supplied FuGaWo with is right. Further, FuGaWo is not always obliged to erase personal data when asked to do so; if for any reason FuGaWo believes that FuGaWo has a good legal reason to continue processing personal data that you ask FuGaWo to erase, FuGaWo will tell you what that reason is at the time FuGaWo responds to your request.
You can exercise this right at any time by writing to FuGaWo by using the contact details set out here and telling FuGaWo that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want FuGaWo to replace inaccurate data with new data, you should tell FuGaWo what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where FuGaWo process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why FuGaWo uses your information) you are entitled to ask FuGaWo to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
FuGaWo may process your data on the basis of a legitimate interest in the following ways:
– To optimize the content of our games and improve their technical functioning;
– To evaluate the popularity of our games and the features included within them;
– To provide technical support to you where FuGaWo detects a problem in the functioning of a game;
– To monitor and prevent antisocial behaviour within our games;
– More generally for the purposes of administrating our company and running our internal business.
You may also ask FuGaWo to stop processing your personal data (a) if you dispute the accuracy of that personal data and want FuGaWo verifies that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want FuGaWo to erase it; (c) where FuGaWo no longer needs to process your personal data (and would otherwise dispose of it) but you wish for FuGaWo to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason FuGaWo believes that FuGaWo has a good legal reason to continue processing personal data that you ask FuGaWo to stop processing, FuGaWo will tell you what that reason is, either at the time FuGaWo first respond to your request or after FuGaWo has had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to FuGaWo by using the contact details set out here and telling FuGaWo that you are making a request to has FuGaWo stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that FuGaWo holds about you, which is processed by automated means, to a third party you may write to FuGaWo and ask FuGaWo to provide it to you in a commonly used machine-readable format.
Because of the kind of work that FuGaWo does and the systems that FuGaWo uses, FuGaWo does not envisage this right being particularly relevant to the majority of individuals with whom FuGaWo interacts. However, if you wish to transfer your data from FuGaWo to a third party, FuGaWo is happy to consider such requests.
Your Right to Stop Receiving Communications
Where FuGaWo sends you email marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the “unsubscribe” link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact with FuGaWo directly, you can unsubscribe by writing to FuGaWo at info@fugawo.com and telling FuGaWo which communications you would like FuGaWo to stop sending you.
Your Right to Object to Automated Decision Making and Profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising Your Rights
When you write to FuGaWo making a request to exercise your rights, FuGaWo is entitled to ask you to prove that you are who you say. FuGaWo may ask you to provide copies of relevant ID documents to help FuGaWo to verify your identity.
It will help FuGaWo to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently FuGaWo can deal with your request. If you do not provide FuGaWo with sufficient information then FuGaWo may delay working on your request until you have provided FuGaWo with additional information (and where this is the case FuGaWo will tell you).
7. Contact Details
If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above or if you think that the Policy has not been followed, please contact us at info@fugawo.com