Data protection (KVKK)
Arkazor Games · Last updated:
This text is available in English and Turkish. For users in Türkiye the Turkish version prevails; for everyone else the English version prevails.
This notice is provided under Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Procedures and Principles of the Obligation to Inform, for users of the mobile apps published as Arkazor Games, visitors of the arkazorgames.com website and people who contact us. Details specific to each app are in that app’s privacy policy. This English text is a translation; the Turkish version prevails.
1. Data controller
Data controller: Ilga Ongunsu (individual developer; publisher name: Arkazor Games)
E-mail: support@arkazorgames.com
2. Data, purposes and legal bases
| Whose data | Which data | Purpose | Legal basis |
|---|---|---|---|
| App users — personalised ads | Advertising ID, app set ID, IP address and the approximate location derived from it (no device location), device and app information, ad interactions | Showing ads based on interests | Explicit consent (KVKK Art. 5(1)) |
| App users — non-personalised ads | The same data (without building a profile) | Delivering ads, frequency capping, measurement and aggregated reporting, preventing fraud and abuse | Legitimate interest (KVKK Art. 5(2)(f)): offering the apps free of charge and keeping ads secure |
| App users — Google Play reports | Aggregated install statistics; technical crash reports if the user allowed it (device model, Android version, cause of the error) | Fixing errors and improving the apps | Legitimate interest (KVKK Art. 5(2)(f)) |
| Website visitors | IP address, date and time, requested page, browser information (server logs) | Running the website and keeping it secure | Legitimate interest (KVKK Art. 5(2)(f)) |
| People who contact us | Name (if given), e-mail address, message content | Answering questions, feedback, complaints and KVKK applications | Establishing or performing a contract (Art. 5(2)(c)), legal obligation (Art. 5(2)(ç)), legitimate interest (Art. 5(2)(f)) |
The apps have no accounts and never ask for a name, e-mail, phone number, contacts, photos or location (GPS). Game progress, settings and statistics are stored only on the user’s device and are not sent to us. We do not process special categories of personal data.
3. How data is collected
Advertising data is collected automatically by electronic means through the Google Mobile Ads SDK built into the apps; Google Play reports are provided by Google; website logs are recorded automatically by the server; contact data is collected directly from you by e-mail.
4. Recipients and transfers abroad
- Google (Google LLC, USA; Google Ireland Limited for the EEA and Switzerland): delivering, measuring and securing ads and, if allowed, personalising them; Google Play and Android services. For these data Google is an independent controller for its own purposes and may process them on servers in the USA and other countries.
- Hosting provider: hosting the website and keeping server logs.
- E-mail service provider: handling e-mail correspondence.
- Authorised public authorities and courts: only where required by law and to the extent requested.
Transfers abroad are carried out in accordance with the conditions of Article 9 of the KVKK (adequacy decision, appropriate safeguards or incidental transfer cases). We do not sell personal data.
5. Retention
Data on a device stays there until the user deletes it or uninstalls the app. Website server logs are kept for at most 30 days, or longer only where the law requires it. E-mails are kept for at most two years after the request has been handled. Data processed by Google is subject to Google’s retention policies. Data whose retention period has ended is deleted, destroyed or anonymised.
6. Your rights under Article 11 of the KVKK
You have the right to learn whether your personal data is processed; to request information about it; to learn the purpose of processing and whether it is used accordingly; to know the third parties in Türkiye or abroad to whom it is transferred; to request correction of incomplete or inaccurate data; to request deletion or destruction under Article 7; to request that third parties be notified of these actions; to object to a result against you arising exclusively from automated analysis; and to claim compensation for damage caused by unlawful processing. You can withdraw your consent at any time in the apps under Settings → Ad privacy choices.
7. How to apply
Under the Communiqué on the Procedures and Principles of Application to the Data Controller, applications must be in Turkish and include your name and surname, your signature if the application is in writing, your Turkish ID number (for foreigners: nationality and passport or ID number), your address for notifications, your e-mail address and phone number if any, and the subject of your request. You can send it:
- Signed with a secure electronic or mobile signature, or from an e-mail address you have previously given us and that is registered in our system, to: support@arkazorgames.com
For your convenience we also handle applications sent from other e-mail addresses, after reasonably verifying your identity, and we accept requests in English. Applications are answered free of charge as soon as possible and within 30 days at the latest; if the action involves an additional cost, the fee set by the Personal Data Protection Board may be charged. If your application is rejected, the answer is insufficient or no answer is given in time, you can complain to the Personal Data Protection Board under Article 14 of the KVKK.
Because the apps send us no data, in most cases we hold no data about you. For data processed by Google, you can use Google’s tools or contact Google directly.