Privacy Policy

REVEL GAMES PRIVACY POLICY

1. INTRODUCTION

1.1. Welcome to the Revel Games. Revel Oyun Yazılım ve Pazarlama Anonim Şirketi  (individually and collectively, “Revel“, “we“, “us” or “our“) takes its responsibilities under applicable privacy and personal data protection laws and regulations (“Privacy Laws“) seriously and is committed to respecting the privacy rights and concerns of all users of our games (“Games”) and website accessible at Revel Games – Casual Mobile Games and mobile applications (the “Site“) (we refer to the Games, Site and the other services referred to in our Terms of Service      collectively as the “Services“). Users refers to a user who registers for an account or who otherwise uses or accesses the Services (individually and collectively, “Users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, disclose, transfer and/or process the personal data you have provided to us and/or possess about you, as well as to assist you in making an informed decision before providing us with any of your personal data. Capitalised terms used in this Privacy Policy that are not otherwise defined have the meanings given to them in the Revel Terms of Service.

1.2.Personal Data” or “personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include name, identification number, and contact information.

1.3. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on the Site or on the related platform which you can access to our Services. We reserve the right to amend this Privacy Policy at any time.

1.4. This Policy applies in conjunction with other notices, contractual clauses, consent clauses (if any) that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

2. WHEN WILL REVEL COLLECT PERSONAL DATA?

We will collect personal data about you:

  • when you register and/or use our Services, Games or Site, or open an account with us;
  • when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
  • when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
  • when you interact with us, such as via telephone calls (which may be recorded), letters,  face-to-face meetings, social media platforms and emails;
  • when you use our Services or interact with us via our Games or Site. This includes, without limitation, through cookies which we may deploy when you interact with our Games or Site;
  • when you grant permissions on your device to share information with our mobile application or Site;
  • when you link your Revel account with your Social Media Account (defined in Article 3 below) or other external account or use other social media features, in accordance with the provider’s policies;
  • when you carry out transactions through our Games or Site (where applicable) or with our authorized third-party payment service providers. Revel does not collect personal data relating to your payment process such as credit card number, e-mail address that you share with the relevant platforms for the payment, and only payment information for the items you purchase is being shared with us to fulfill your order and to introduce the purchased items to your account;
  • when you provide us with feedback or complaints;
  • when you register for a contest, for games or game specific events; and
  • during your gameplay.

3. PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

Data Categories

Purposes

Legal Ground

User Data (name, username and user ID, email address, telephone number, and/or address, gender, age, and/or date of birth, photographs processed in connection with your account creation with us)

  • To manage, operate, provide and/or administer your use of and/or access to our Services, Site and Games, and your relationship and user account with us
  • To respond to or process your transactions in connection with the Services and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions
  • Performance of a contract
  • To fulfill and handle your requests
  • To enforce our Terms of Service and investigate any actual or suspended fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us
  • Performance of a contract
  • Legitimate interest
  • For marketing and advertising and for sending marketing communication

Consent

Device Data (device identifier, Internet protocol (IP) number, the brand, model and operating system version (such as IOS or Android) of your device, location information according to your IP address, time zone, the internet browser used in connection with the device you use and your connection)

  • To manage, operate, provide and/or administer your use of and/or access to our Services, Site and Games, and your relationship and user account with us
  • To respond to or process your transactions in connection with the Services and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions
  • To maintain and administer and improve any software updates and/or other updates, to support the Services, including to troubleshoot, report, or address any issues that may be required from time to time to ensure the smooth running of the Games and/or our Services

Performance of a contract

  • To fulfill and handle your requests
  • To enforce our Terms of Service and investigate any actual or suspended fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us
  • Performance of a contract
  • Legitimate interest
  • To run analytics, research and analysis and understand how users interact with our Games, Site and Services in order to continuously improve our Services and user experience
  • To serve advertising tailored to your preference and interests

Legitimate interest

Usage Data (data regarding your activities on our Games, Site and Services and notably the way in which you interact with our Games, Site and Services. For instance, the time you spent while playing our Games, number of ads served, potential clicks, your in-app purchases.)

  • To run analytics, research and analysis and understand how users interact with our Games, Site and Services in order to continuously improve our Services and user experience
  • To serve advertising tailored to your preference and interests

Legitimate interest

  • To respond to or process your transactions in connection with the Services and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions

Performance of a contract

  • To fulfill and handle your requests
  • To enforce our Terms of Service and investigate any actual or suspended fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us
  • Performance of a contract
  • Legitimate interest

Your above stated Personal Data will also be processed for the purposes of responding to legal processes or fulfilment of our legal obligations as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction on the basis of compliance with a legal obligation. Your Personal Data are collected directly from you or by automated means, as you access or use any of our Services.

4. HOW DOES REVEL PROTECT AND RETAIN PERSONAL DATA?

4.1. We implement a variety of security measures and operational controls, and we strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.

4.2. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interest warrant further retention of such personal data. If you cease using our Services, or your permission to use the Site, Games and/or the Services is terminated or withdrawn, we will either (i) continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws or (ii) subject to applicable law, we will securely dispose of your personal data without prior notice to you.

5. TRANSFER OF YOUR PERSONAL DATA

In conducting our business, your personal data may be transferred to our third-party service providers and/or our affiliates or subsidiaries, whether sited in Turkey or outside of Turkey, for the below-stated purposes:

  • our subsidiaries or affiliates for the purposes of providing a better entertainment experience and optimization and marketing of the games.
  • third party service providers and business partners for procurement of the respective services. These include (i) cloud service providers for procurement of hosting and data storage services, (ii) payment or financial services providers or app stores for processing your payments, (iii) advertisement business partners that allows us our Services to be provided free or for low cost, (iv) analytic companies for the purpose of conducting analytical reviews, reporting and research activities regarding the use of our Services;
  • governmental or regulatory authorities having jurisdiction over Revel; and
  • a buyer or other successor in the event of a merger, divestiture, restructuring, re-organization, dissolution or other sale or transfer of some or all of Revel’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Revel about our users is among the assets transferred; or to a counterparty in a business asset transaction that Revel or any of its affiliates or subsidiaries is involved in.

6. INFORMATION ON CHILDREN

Our Services are not intended for the use by children. We do not knowingly collect personal data from users who are considered children under applicable national laws. Under our Terms of Service, children are not permitted to use our Services.

7. DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES:

7.1. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above. Revel shall have no responsibility with respect to damages caused by attacks on the system or captured by third parties despite all security measures taken by Revel.

7.2. In an attempt to provide you with increased value, we may choose various third-party websites to link to, and frame within, the Site or Games. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third-party web sites (even if offered on or through our Site or Games) may not be received by us.

7.3. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience, and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Site and Games and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

8. INTERNATIONAL TRANSFERS 

8.1. Your personal data and/or information may be transferred to, stored or processed outside of your country. Revel will only transfer your information overseas in accordance with applicable Privacy Laws and this Policy. We process and store your personal data through Amazon Web Services and Google Cloud on servers located in the United States of America, European Union, United Kingdom and other countries where Amazon Web Services and Google Cloud has a server.

When we transfer your Personal Data outside of Turkey, we will take reasonable steps to ensure compliance with Turkish Personal Data Protection Law. In addition, because different jurisdictions may have different data protection requirements, we take steps to implement adequate safeguards to protect your data and comply with the appliable Privacy Laws.

8.2.  More information about the transfer out of the EU, of personal data and/or information relating to users who are located in the EU, can be found in the section titled “Additional Provisions for EU Users Only”.

9. YOUR RIGHTS

Subject to the applicable privacy laws, with respect to the processing of your personal data, you have the following rights: (i) to learn whether his/her personal data is being processed, (ii) to request information regarding the processing of his/her personal data, (iii) to learn the purposes for which his/her data is being processed and whether the data are used in accordance with these purposes, (iv) to know the third parties to whom his/her personal data are transferred domestically or abroad, (v) to request a rectification of his/her personal data in the event the data are incompletely or inaccurately processed, (vi) to request the deletion or destruction of his/her personal data, (vii) to request the transmission to third-parties who have received transfers of his/her personal data of requests for correction, deletion and destruction of his/her personal data, (viii) to object to the processing of personal data that leads to an unfavorable consequence for the data subject, in cases where the processed data has been analyzed only through automatic systems, (ix) to request compensation for damage arising from the unlawful processing of their personal data.

10.  ADDITIONAL PROVISIONS FOR EU USERS ONLY:

The provisions in this Section only apply if you are a user who is located in the European Union (“EU”). These provisions take precedence over any inconsistent provisions in the remainder of this Privacy Policy.

10.1. Your Rights

If you are a user who is located in EU, you have the following rights in relation to your personal data: (i) access: Subject to the statutory provisions, you have the right to request access to your personal data processed by us and a copy of this data (right of access); (ii) rectification: Subject to the statutory provisions, you have the right to have any incorrect data rectified and, taking into account the purposes of the processing, to have incomplete personal data completed (right to rectification); (iii) erasure: Subject to the statutory provisions, you have the right, if there are justified grounds, to request the erasure of your data (right to erasure); (iv) restriction of processing: Subject to the statutory provisions, you have the right to request the restriction of processing of your data, provided that the statutory prerequisites apply (right to restriction of processing); (v) data portability: Subject to the statutory provisions and provided that the statutory prerequisites apply, you have the right to receive the data provided by you in a structured, commonly used and machine-readable format and to transmit those data to another controller or, to the extent that this is technically feasible, have them transmitted by us (right to data portability); (vi) right to object: Subject to the statutory provisions, you have the right, on grounds relating to your particular situation, to object to any processing of your data for the purposes of legitimate interests pursued by us or a third party (right to object). If data is processed by us for direct marketing purposes, you have the right to object at any time to such processing without any particular reasons being required; (vii) automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, provided the statutory prerequisites do not apply. We do not conduct an automated decision-making; (viii) withdrawal of consent: If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent will not affect the lawfulness of processing your personal data based on consent before this consent was withdrawn; (ix) complaint: Notwithstanding any other remedies, you are also entitled anytime to file a complaint with a supervisory authority in your habitual residence, place of work or place of the alleged infringement.

10.2. Transfer of Personal Data outside the EU

Your Personal Data may be transferred outside of the EU.  We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality, and we implement measures such as appropriate contractual clauses to ensure that the recipients of such transfer protect and treat your Personal Data in accordance with all applicable personal data protection laws.

10.3.   Information on Children

The Services are not intended for children under the age of 16 who are located in the EU. We do not knowingly collect or maintain any personal data or non-personally identifiable information from anyone under the age of 16 who is located in the EU, nor is any part of our Site, Games or other Services directed to children under the age of 16 who are located in the EU. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted by any child under the age of 16 who is located in the EU.

11. ADDITIONAL NOTICE FOR USERS WHOSE DATA IS SUBJECT TO CALIFORNIA LAW

11.1. For purposes of the California Consumer Privacy Act (“CCPA”), we do not “sell” personal information and in the past twelve months prior to the effective date of this Policy not sold any personal information of our users, as defined under the CCPA. The California “Shine the Light” law also gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

11.2. The personal information that Revel collects, uses and/or discloses and has collected, used, and/or disclosed from users as set forth above in the twelve months prior to the effective date of this Policy, may include personal information as defined under the CCPA, depending on how you have accessed the Site and interacted with us.

11.3. In accordance with the CCPA or other applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of your personal information or ask us to send that information to another company; (iv) restrict our uses of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, depending on applicable law; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information held about you by Revel, subject to certain exceptions prescribed by law.

11.4. If you would like to exercise any of these rights, please contact us as set forth below by sending an email to our Company. We will process such requests in accordance with applicable laws. To protect your privacy, we may need to take steps to verify your identity before fulfilling your request. If you are a California resident, you have the right not to receive discriminatory treatment by us for the exercise of your rights conferred by the CCPA.

12. QUESTIONS, CONCERNS OR COMPLAINTS CONTACT US

If you have any questions, concerns or complaints about our privacy practices you can contact us at any time at [email protected].

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