Privacy Policy

1. Information We Collect

1.1 Information You Provide

• Account information (username, email address, if you create an account)
• In-game communications and user-generated content
• Support requests and feedback

1.2 Information Automatically Collected

• Device Information: Device type, operating system, unique device identifiers (such as Device ID, Advertising ID), device language, screen resolution
• Game Data: Game progress, achievements, scores, gameplay statistics, virtual currency and items
• Technical Information: IP address, network information, crash reports, performance data
• Usage Information: How you interact with our games, features used, session duration, timestamps

1.3 Information from Third Parties

• Social Media: If you connect your social media account (Facebook, Google, Apple Sign-In), we may receive your profile information, friends list, and other information you authorize
• App Stores: Payment and transaction information from Apple App Store and Google Play Store
• Analytics Providers: Aggregated analytics data from third-party analytics services
• Advertising Networks: Device and usage information from advertising partners for ad targeting and measurement

2. How We Use Your Information

We use the collected information for the following purposes:

• To Provide and Improve Our Services: Deliver games, maintain your game progress, improve gameplay experience, fix bugs, and develop new features
• Analytics and Performance: Analyze game usage, understand player behavior, optimize game performance, and improve user experience
• Personalization: Customize game content, recommend features, and personalize your experience
• In-App Purchases: Process transactions, manage virtual currency and items, prevent fraud
• Advertising: Show relevant advertisements, measure ad effectiveness, prevent fraud
• Customer Support: Respond to your inquiries, provide technical support, resolve issues
• Legal Compliance: Comply with applicable laws, regulations, and legal processes
• Security: Detect and prevent fraud, abuse, and security threats

3. Third-Party Services and Data Sharing

We use the following third-party services that may collect and process your information:

3.1 Analytics Services

• Firebase Analytics (Google): Game analytics, user behavior tracking, crash reporting. Google Privacy Policy | Firebase Privacy Policy
• GameAnalytics: Game performance analytics, player behavior analysis. GameAnalytics Privacy Policy
• ByteBrew: Mobile game analytics and attribution. ByteBrew Privacy Policy

3.2 In-App Purchase Services

• RevenueCat: In-app purchase management and subscription handling. RevenueCat Privacy Policy
• Apple App Store: Payment processing for in-app purchases on iOS devices. Apple Privacy Policy
• Google Play Store: Payment processing for in-app purchases on Android devices. Google Privacy Policy

3.3 Advertising Services

We work with advertising partners to show you relevant ads. These partners may collect information about your device and app usage to provide personalized advertising. Our advertising partners include:

• Google AdMob: Mobile advertising platform. Google Privacy Policy | AdMob Privacy Information
• Unity Ads: Video advertising network. Unity Privacy Policy
• Facebook Audience Network: Advertising network. Facebook Data Policy
• Other Advertising Partners: We may work with additional advertising networks and partners. These partners may use cookies, device identifiers, and other technologies to collect information about your device and app usage.

Opt-Out Options: You can opt out of personalized advertising through your device settings:

• iOS: Settings → Privacy → Apple Advertising → Limit Ad Tracking. Learn more about iOS ad tracking
• Android: Settings → Google → Ads → Opt out of Ads Personalization. Learn more about Android ad settings
• Digital Advertising Alliance: You can also opt out through DAA Opt-Out Page (US) or Your Online Choices (EU)

3.4 Cloud and Infrastructure Services

• Amazon Web Services (AWS): Cloud hosting and infrastructure services. AWS Privacy Policy
• Google Cloud Platform: Cloud services and infrastructure (if used). Google Cloud Privacy

3.5 Social Media Services

If you choose to connect your social media account to our Services, we may receive information from these platforms:

• Facebook: If you use Facebook Login or connect your Facebook account. Facebook Data Policy
• Google Sign-In: If you use Google Sign-In to access our Services. Google Privacy Policy
• Apple Sign-In: If you use Apple Sign-In on iOS devices. Apple Privacy Policy

You can disconnect your social media account at any time through your account settings.

3.6 Data Sharing

We may share your information with:

• Service Providers: Third-party companies that help us operate our Services (analytics, cloud hosting, customer support, payment processing)
• Advertising Partners: Ad networks and attribution providers for advertising purposes (see Section 3.3)
• Business Partners: Partners with whom we collaborate to provide Services (subject to confidentiality agreements)
• Legal Requirements: When required by law, court order, or government regulation
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with notice to users)
• With Your Consent: When you explicitly consent to sharing your information

4. Your Rights and Choices

4.1 General Rights

• Access: Request access to your personal data
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal data (subject to legal requirements)
• Portability: Request a copy of your data in a structured format
• Objection: Object to processing of your personal data
• Restriction: Request restriction of processing in certain circumstances

4.2 GDPR Rights (EU Users)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR):

• Right to access, rectify, erase, restrict, or object to processing of your personal data
• Right to data portability
• Right to withdraw consent at any time
• Right to lodge a complaint with a supervisory authority

4.3 CCPA Rights (California Users)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You have the right to know what personal information we collect, use, disclose, and sell (we do not sell personal information)
• Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions
• Right to Opt-Out: You have the right to opt out of the "sale" of personal information. While we do not sell personal information, you can opt out of sharing for advertising purposes
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights
• Right to Data Portability: You have the right to receive your personal information in a portable format

How to Exercise Your CCPA Rights:

• Email us at info@sentiagames.com with "CCPA Request" in the subject line
• Specify which right you wish to exercise
• We will respond within 45 days of receiving your request
• We may need to verify your identity before processing your request

California "Shine the Light" Law: California residents may request information about how we share certain categories of personal information with third parties for their direct marketing purposes. To make such a request, please contact us at info@sentiagames.com.

4.4 KVKK Rights (Turkey Users)

If you are located in Turkey, you have additional rights under the Turkish Personal Data Protection Law (Kişisel Verilerin Korunması Kanunu - KVKK, Law No. 6698):

• Right to Learn (Öğrenme Hakkı): You have the right to learn whether your personal data is being processed
• Right to Request Information (Bilgi Talep Etme Hakkı): You have the right to request information about your personal data if it has been processed
• Right to Access (Erişim Hakkı): You have the right to learn the purpose of processing your personal data and whether it is used in accordance with its purpose
• Right to Rectification (Düzeltme Hakkı): You have the right to request correction of incomplete or inaccurate personal data
• Right to Erasure (Silme Hakkı): You have the right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the KVKK
• Right to Object (İtiraz Etme Hakkı): You have the right to object to the processing of your personal data if it results in negative consequences for you
• Right to Request Compensation (Tazminat Talep Etme Hakkı): You have the right to claim compensation for damages arising from the unlawful processing of your personal data
• Right to Complain (Şikayet Etme Hakkı): You have the right to file a complaint with the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu - KVKK) if you believe your rights have been violated

How to Exercise Your KVKK Rights:

• Email us at info@sentiagames.com with "KVKK Request" in the subject line
• Specify which right you wish to exercise and provide necessary identification information
• We will respond to your request within 30 days as required by KVKK
• We may request additional information to verify your identity
• If your request is rejected, we will provide a written explanation of the reasons

Personal Data Protection Authority (KVKK): If you believe your rights under KVKK have been violated, you may file a complaint with the Personal Data Protection Authority:

• Website: www.kvkk.gov.tr
• Address: Nasuh Akar Mahallesi 1407. Sokak No:4 06520 Balgat, Çankaya/Ankara, Turkey
• Phone: +90 312 216 50 00

Data Controller Information (Veri Sorumlusu): In accordance with KVKK, Sentia Games is the data controller (veri sorumlusu) for the personal data processed through our Services. Our contact information is provided in Section 11 of this Privacy Policy.

5. Children's Privacy (COPPA Compliance)

Our Services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. In compliance with the Children's Online Privacy Protection Act (COPPA), we:

• Do not knowingly collect, use, or disclose personal information from children under 13
• Require users to be at least 13 years old to create an account or use our Services
• If we learn that we have collected personal information from a child under 13, we will delete that information immediately
• If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us immediately at info@sentiagames.com

If you are between 13 and 18 years old (a "minor" in some jurisdictions), you must have your parent's or guardian's permission to use our Services. Your parent or guardian must read and agree to these Terms and our Privacy Policy on your behalf.

Parental Rights: Parents of children under 13 have the right to:

• Review their child's personal information
• Request deletion of their child's personal information
• Refuse to allow further collection or use of their child's information
• Revoke consent at any time

To exercise these rights, parents should contact us at info@sentiagames.com with "COPPA Request" in the subject line.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit using SSL/TLS protocols
• Encryption of sensitive data at rest
• Regular security assessments and vulnerability testing
• Access controls and authentication mechanisms
• Employee training on data protection and privacy
• Secure data centers and infrastructure
• Regular backups and disaster recovery procedures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

6.1 Data Breach Notification

In the event of a data breach that may affect your personal information, we will:

• Investigate the breach immediately
• Notify affected users and relevant authorities as required by law
• Provide information about the nature of the breach and steps we are taking to address it
• Take appropriate remedial measures to prevent future breaches

We will notify you of any data breach affecting your personal information within 72 hours of becoming aware of the breach, where required by applicable law.

7. Data Retention

We retain your personal information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods are as follows:

• Account Data: Retained for the duration of your account and up to 3 years after account deletion, unless required by law to retain longer
• Game Progress and Statistics: Retained for the duration of your account and up to 1 year after account deletion
• Transaction Records: Retained for 7 years as required by financial regulations
• Support Communications: Retained for 3 years after the last communication
• Analytics Data: Aggregated and anonymized data may be retained indefinitely for business analytics purposes
• Legal Requirements: Some data may be retained longer if required by law, court order, or regulatory requirements

When you delete your account, we will delete or anonymize your personal information within 30 days, except where we are required to retain it by law or for legitimate business purposes.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including but not limited to the United States, European Union, and other countries where our service providers operate. These countries may have different data protection laws than your country of residence.

We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy, including:

• Standard contractual clauses approved by the European Commission
• Privacy Shield Framework (where applicable)
• Other legally recognized transfer mechanisms

By using our Services, you consent to the transfer of your information to countries outside your country of residence, including countries that may not have the same data protection laws as your country.

9. Cookies and Similar Technologies

We and our partners use cookies, pixel tags, device identifiers, and similar technologies to collect information about your device and usage of our Services. These technologies help us:

• Remember your preferences and settings
• Analyze how our Services are used
• Deliver personalized content and advertisements
• Measure advertising effectiveness
• Prevent fraud and ensure security

9.1 Types of Technologies We Use

• Cookies: Small text files stored on your device
• Pixel Tags: Small images embedded in content that track usage
• Device Identifiers: Unique identifiers associated with your device (Device ID, Advertising ID)
• Local Storage: Data stored locally on your device for app functionality
• SDKs: Software development kits from third-party services integrated into our games
• Web Beacons: Small transparent images used to track user behavior
• Fingerprinting: Techniques used to identify devices based on their characteristics

9.2 Managing Cookies and Tracking

You can control cookies and tracking through:

• Device Settings: Adjust privacy settings on your mobile device to limit tracking
• App Settings: Some tracking can be controlled through in-app privacy settings
• Third-Party Opt-Outs: Use opt-out tools provided by advertising networks (see Section 3.3)
• Browser Settings: If accessing our Services through a web browser, adjust your browser's cookie and tracking settings

Note: Disabling certain tracking technologies may affect the functionality of our Services and your user experience.

9.3 Do Not Track Signals

Some browsers and devices support "Do Not Track" (DNT) signals. Currently, there is no industry standard for responding to DNT signals. We do not currently respond to DNT signals, but we respect your privacy choices through the opt-out mechanisms described in this Privacy Policy.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

11. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

11.1 Data Protection Officer

For privacy-related matters, you may contact our Data Protection Officer:

11.2 Supervisory Authorities

European Economic Area (EEA) Users:

If you are located in the EEA and believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with your local data protection supervisory authority. You can find your local authority at European Data Protection Board.

Turkey Users:

If you are located in Turkey and believe your rights under KVKK have been violated, you may file a complaint with the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu):

• Website: www.kvkk.gov.tr
• Address: Nasuh Akar Mahallesi 1407. Sokak No:4 06520 Balgat, Çankaya/Ankara, Turkey
• Phone: +90 312 216 50 00
• Email: kvkk@kvkk.gov.tr