CRAFTERA GAMES - PRIVACY POLICY

Effective Date: November 19, 2023

1. INTRO

Craftera Games is a technology company that creates and develops mobile games. We respect your privacy and aim to be transparent about how and why we collect, store, share, and use your personal data in accordance with the laws of the countries where we operate. This Privacy Policy is designed to provide you with clear explanations about our data practices.

This Privacy Policy considers "personal data" to include any information or data that identifies a specific individual or household, that can be linked to that individual or household, or that is directly or indirectly related to them for reasonable purposes. By "data", we mean "personal data" and any other information that meets the definition of "personally identifiable information".

This Privacy Policy is applicable to a wide range of services that we offer, including our websites, mobile applications, forums, blogs, offline services, marketing, and advertising activities on all platforms. We may also provide other services to you from time to time, all of which are collectively referred to as "Services" in this policy. However, it's important to note that this Privacy Policy does not apply to Craftera Games job applicants, employees, or any other personnel.

Craftera Games is responsible for the personal data we hold about you in connection with your use of the Services. This means we determine how your personal data is used and we are responsible for it. Under this Privacy Policy, your personal data will be processed for the purpose of providing the Services when you download our mobile application, access or play our games, or interact with our Services. If you have any other concerns about providing data to us or it being used as described in this Privacy Policy, you may contact us and use your rights explained under Security section of this Privacy Policy.

2. HOW WE COLLECT YOUR PERSONAL DATA

Our company may collect personal data from you directly or from third-party companies who have legal permission to share such data with us (including advertising platforms, partners, and data aggregators who have obtained it) This data may include information about your interests, demographics, and general location, as well as other games and services you use. We will use your personal data in accordance with the guidelines stated in this Privacy Policy.

2.1 Personal Data Collected Directly from You

When you download our mobile game, access our game, or use any of our other services, Craftera Games will process your personal data to provide you with the best possible experience. Most of the data we collect comes directly from you. We collect the following information that you provide when using our services:

• Contact Information, such as your country, region, or username.
• User-Generated Content, which includes files, documents, videos, images, data, or information that you choose to upload or transmit during your communication with us or while using our Services.
• Survey Information, which comprises the feedback and evaluations you give regarding our Services.
• Inferences, which are predictions about your interests and preferences and generated information while you use our services.

We use this information to enable you to use our game and to provide the Services to you, to increase the efficiency of our Services, to customize our in-game offers and to confirm purchases. We would also like to point out that we will use your data to achieve other purposes specified in this Privacy Policy.

2.2 Information We Collect Automatically

Depending on the specific Services you use, we may collect or process the following personal data:

• Analytics Data, which includes information about your interactions with our games, advertising and other Services. (For example, such as which device you used to access our Services, when and how you used them, and information about profile visits.)
• Device Data, which includes your device's unique ID (permanent/temporary), Advertising ID (IDFA), Merchant ID (IDFV), Game Center ID, and other identifiers.
• Location Data, which includes your approximate location based on your Internet Protocol ("IP").
• Business Information, which includes details about products and services you've purchased, obtained, or reviewed, as well as other purchasing or consuming history or tendencies.

We may use this information to differentiate you from other users of our Services. This helps us analyze and monitor how you use and interact with our Services, and enables us and our partners to identify products and services that may be of interest to you. Please see the International Transfer section of this Privacy Policy for the detailed information.

2.3 Data Collected from Third Parties

As mentioned above, the majority of the information we gather about you is obtained directly from you when you engage with our Services or play our games. However, if you permit third-party companies to access your personal data (such as by downloading our mobile applications via the App Store or Google Store and linking your Facebook account to our mobile applications), we may also collect information from these third-party sources.

• Social Media: When you engage with our Services through social media platforms such as Facebook, Twitter, Google, etc. by liking, following, or sharing our content, we may obtain some information about you that you authorized the social network to share with third-party services. This data may include your name, profile picture, and friends list, and is dependent on the privacy settings you have chosen on the social network.

It is important to review and adjust your privacy settings on third-party websites, social media networks, and services before linking or connecting them to other services, and sharing information. We use this information to provide you with the features and functionality of our Services, as well as to communicate with you directly, such as sending you emails about products and services that may be of interest to you.

• Service Providers: When you install or purchase items related to our mobile apps (such as those you can purchase/download via App Store or Google Store), Craftera Games cannot access your credit card or bank account data. However, the third-party payment processors mentioned above may share non-financial information with us about your purchases, such as the items you bought to fulfill your order. The personal data we receive from third-party companies will depend on the privacy settings of the relevant third-party applications.
• Information Obtained from Verification Services Connected to Our Services: Some parts of our services may allow you to log in through a third-party social network or authentication service such as Facebook. These services verify your identity and provide us with specific personal data, which may include your name, email address, user ID associated with the third party, profile picture, and the names and avatars of your Facebook friends who have previously played our game.

The data we acquire is subject to the policies of the third party and your privacy settings on that third-party site. In applicable cases, you may access functionalities in our games and other services, such as seeing which friends are playing the same game and their progress (they can also see you and your progress) or inviting your friends to play. When linking your Craftera Games profile with any login method (Google, Apple, Facebook, GameCenter, Google Play Services), you can specify through the dialogue box that you do not want us to access your email address.

It is important to note that using these login methods does not imply that we will make a post on your Facebook page without your permission. Additionally, we want to emphasize that we will not obtain any data about friends who do not play the game. If you do not want your Facebook friends to see your progress, you can either disconnect the game from Facebook or revoke permission through Facebook settings. If you choose not to create a Craftera Games profile by connecting your Facebook account, the personal data we collect when you play our games will be anonymous, but we will continue to collect device identifiers and other information related to the mentioned identities.

• Depending on the chosen method: We recommend periodically reading and ensuring that you fully understand the privacy policies of the relevant service, depending on the chosen login method.
• Other Sources: Additionally, we may collect personal data about individuals through public sources, third-party data providers, brand partnerships, or company mergers or acquisitions—information that we would not normally obtain. We use this information to manage, maintain, and provide features and functionality to our services.

3. PURPOSES OF PROCESSING YOUR PERSONEL DATA

We acquire and process your personal data for the following purposes:

• Provide our games, execution of in-game transactions, and delivery of customer support services to you;
• Enhancement of our games for your benefit and optimization for the device you utilize, along with the presentation of personalized in-game activities, offers, and promotions;
• Administration of our organization and its day-to-day operations;
• Verification of your identity and your entitlement to use our products or services, both upon reaching out to us and when seeking access to our services;
• Requesting your participation in surveys pertaining to our organization, partner entities, and services;
• Maintenance of the safety, security, and integrity of our assets, services, technological infrastructure, and operations;
• Operational, developmental, and improvement efforts for our game and services;
• Customization of our services, measurement of user experiences, and integration of those experiences into our game;
• Facilitation of access to specific segments, functionalities, and features within our services;
• Correspondence with you regarding service-related information, including approvals, technical notifications, updates, security alerts, and support and administrative communications;
• Facilitation of user communication within our mobile application;
• Addressing comments and requests made within the scope of customer support services;
• Prevention of potentially illicit or unlawful activities and safeguarding players from situations such as cheating or fraud;
• Measurement of interest levels in our services;
• Internal quality control assurance;
• Adherence to applicable laws, fraud prevention, confirmation of compliance with our terms of use, and the defense, enforcement, and acknowledgment of our legal rights, inclusive of those under the terms of service as necessary;
• Fulfillment of contractual obligations and requirements, as well as adherence to legal obligations and requirements;
• Provision of assistance through our customer service channels upon request;
• Conducting internal research and analyses; and
• Other purposes explicitly articulated in this Privacy Policy or mandated or sanctioned by laws.

4. SHARING OF YOUR PERSONEL DATA

We may share, transfer, disclose, provide access to and use your personal data with certain third parties for the purposes specified in this Privacy Policy. We share your personal data with our third-party service providers to provide the Services, comply with legal obligations, and protect and defend our rights and properties, as outlined in this Privacy Policy.

• Other Users: If you participate in our online communities or purchase goods or services through our Services, we may share your public profile and any information you choose to share with other community members.
• Contests, Sweepstakes, and Survey Providers: In order to ensure the smooth operation of our contests, sweepstakes, or survey offerings, we may share personal data with third-party service providers who assist us in conducting and processing these activities.
• Business Partners: As part of our marketing efforts, we have established partnerships with advertisers and other companies that offer products and services we think may appeal to our users. In order to help those marketing partners provide you with relevant information, we may share personal data and other information that we collect through our Services.
• Service Providers: We may share your personal data with our service providers(data processors). These providers offerus with technical support and similar services, deliver requested information and services, provide customer support services, offer services related to the development and improvement of the Services concerning analytics and search engine activities, and provide technical support for our Services. To ensure compliance with applicable legal requirements, Craftera Games has entered into agreements with relevant service providers, which ensure that your personal data is not used or shared for any purpose other than the provision of the relevant service.
• Disclosures to Protect Our Rights, Your Rights or the Rights of Others (e.g., as Required by Law and Similar Disclosures): Our company may access, retain, and share your personal data, account information, and content for various reasons such as complying with national security requests, legal processes, and other legal requirements. Additionally, we may use your data to respond to your requests, protect your, our, or others' rights, properties, or safety, and enforce our policies or contracts. We may also collect debts owed to us, prevent physical harm or financial loss associated with the investigation or prosecution of suspected or actual illegal activity, or share information in good faith situations where we believe it is necessary or appropriate.
• Advertising Networks and Advertising Partners: We work with third-party advertising networks and partners to provide personalized content and advertisements on our Services, other websites, and other devices. These third parties may collect information directly from users through the use of cookies or other data collection technologies when they visit our Services. This data is used to provide services related to reporting, attribution, analysis, and market research, as well as to deliver and improve personalized advertisements. For more information, please refer to the section on Third-Party Data Collection and Online Advertising.
• With Your Consent: We may share an individual's personal data with specific third parties or publicly, but only if we have their consent or instruction and in accordance with their preferences. For instance, we may share an individual's opinions on our Sites or related publications only when we have received their consent or instruction.
• Sale of Assets and Change of Control: Please note that in the event of a sale of Craftera Games' assets, corporate restructuring, or a change in control of Craftera Games' ownership structure, the third party acquiring or taking control of the relevant assets of Craftera Games will have the right to use your personal data and other information provided to us through the Services in accordance with this Privacy Policy. This means that your data may still be used even if there is a change in ownership or control of Craftera Games.
• Legal Obligations and Rights:

We may share personal data for the following reasons;

• We may access, retain, and share personal data if we believe it is necessary for the detection, enforcement, or defense of legal claims.
• We may access, retain, and share personal data to comply with laws or respond to legal requests and legal processes.
• We may access, retain, and share personal data to enforce our contracts and policies, including the protection of our rights and properties, as well as the rights and properties of others.
• Personal data may be accessed, retained, and shared to detect, prevent, or address fraud.
• We may access, retain, and share personal data for reasons related to the protection of our and others' health and safety.
• Personal data may be shared with third parties such as legal counsel and legal authorities as required by applicable laws.

4.1. Data Collected by Third Parties and Online Advertisements

We utilize interests based on your browsing history to present personalized advertisements on subjects that may interest you and collaborate with third-party advertising companies. By allowing third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our online services over time, we aim to display ads on our Services, other websites or services you may use, and other devices you may use.

Our advertising partners can help us present advertisements to you by combining the data they collect from various sources with your personal data. This data is collected when you use their services or third-party websites. Our partners use this information to understand your preferences and show you ads that you might be interested in. If our partners find that you may be interested in Craftera Games Services, they may show you Craftera Games ads while you are using other websites and services. We use ad identifiers and similar technologies on your device to provide you with our Services and to collect data from your device.

The relevant technologies provide us and our third-party promotional partners with the following:

• Recognition of you and your device;
• Presentation of advertisements to you on subjects that may interest you;
• Ensuring the interaction of our Services with third party social communication networks or platforms (if permitted);
• Providing us and third parties with personalized services to you, for example, providing the Services in the correct language.

Data used for presenting advertisements on subjects that may interest you is generally collected through tracking technologies such as cookies, web beacons, embedded codes, and location determination technologies. These technologies recognize the device you use and collect data such as clickstream data, browser type, the time and date you visit sites, AdID, precise geographic location information, and various data using similar technologies. To potentially identify you across devices, our third-party promotional partners may use a shared account identifier with us (such as an encrypted email address or user number).

We and our third-party partners may use the data we collect from you, to show you relevant ads according to your interests while browsing online. We may also use this data to provide services for reporting, analysis, and market research related to advertising. Additionally, we may use the services of third parties, such as social media platforms, to present customized ads to you and other users on specific platforms. To achieve this, we may share an encrypted version of your email address or other data with the platform provider.

Currently, we use the following types of cookies:

• Functionality cookies: These cookies are essential in allowing a website to remember information that affects the way the site looks or operates, such as your preferred language or location. We use these cookies to provide and maintain our Services, which is in our legitimate interests.
• Analysis/performance cookies: These cookies helps us improve the functionality of our website and provide better user experience by making it easier for our visitors to find what they are looking for.

Please be advised that by engaging in our gaming activities, and unless you expressly choose to opt out of interest-based advertising as explained in this section, your personal data shall be used by our marketing partners to gather and analyze information about you. This data shall be utilized to enhance advertising, targeting, and measurement systems, as further elaborated in their privacy policies.

It is possible to configure your web browser to alert you when websites attempt to place cookies on your computer or to restrict the types of cookies permitted. However, cookies utilized by our website operate in a distinct manner from browser cookies, and the cookie management tools available in web browsers may not be effective in removing them. We would like to apprise you that disabling cookies may result in the loss of certain features and functionalities of our website since cookies are indispensable for tracking and enhancing your online activities. It is therefore advisable to consider the ramifications of disabling cookies before proceeding to do so.

To acquire knowledge on how to opt-out of receiving advertisements that are personalized and focused on topics that may interest you, please refer to the section titled "Control Over Your Informatıon" below.

5. CONTROL OVER YOUR INFORMATION

• Deleting or Resetting Our Services: If you want to have greater control over the personal data we have collected from you, there are a few options available. Firstly, you can delete any games we have provided from your mobile device. Furthermore, you can opt to reset your mobile advertising identifier.
• Limiting Access to Your Device Information: You have the option to adjust the access of our Services to your device information by accessing the "Settings" application on your device. For example, you can revoke permission for Services to access your network devices and geographic location or integration with other applications.
• Changing or Deleting Your Information: If you have any questions regarding the reviewing, changing, or deleting of your information, feel free to contact us through any of the methods listed in the "Contact Us" section below. However, please note that in some circumstances, it may not be possible for us to make changes or delete your information.
• Instant Notifications: We understand that staying up to date with the latest information about our games and other topics of interest is important to you. That's why we offer instant notifications to keep you informed about game updates, high scores, and other news. You can customize your notification preferences and opt-out of receiving such communications at any time by accessing the settings on your mobile device. We value your privacy and will always respect your right to control the type of information you receive from us.
• Online Advertisements: If you do not want your personal data to be used for personalized ads based on your interests, you can let us know by contacting us at info@crafteragames.com. Please keep in mind that if you opt out of personalized ads, you will still see ads, but they will not be tailored to your interests using your personal data.

• Opting out of Interest-Based Ads on Devices: If you do not want to see ads that are based on your interests, you can prevent the use of your device's advertising identifier or reset it by changing your device settings. The location of these settings may differ depending on your device, but they are typically found under the "privacy" or "advertising" tab in your device settings.
• Opting out of Facebook Ads: To manage your advertising preferences on Facebook, log in to your account and update your settings from the "Ads" tab in the "Settings" menu.

• Cookies: It's possible to set up your web browser to notify you whenever a website tries to save a cookie on your computer. You can also restrict the permissions for certain types of cookies. It's important to note that Flash cookies work differently from regular browser cookies. Tools that are effective in removing browser cookies may not work for Flash cookies. Cookies are necessary for tracking and improving the performance of our Services. Disabling cookies may lead to the loss of some of our Services' features and functions.

To make opt-out requests for businesses under the DAA's CCPA Application-Based Opt-Out Tool concerning mobile applications on your device, you can download the relevant application from https://www.privacyrights.info/.

6. YOUR RIGHTS

You have certain rights regarding your personal data and how we process them. In some cases, if the exercise of these rights (such as the request for deletion of personal data) limits our ability to process personal data, we may no longer be able to provide our products and services to you or interact with you. You can exercise these rights by contacting us at info@crafteragames.com.

These rights include:

• Access to Personal Data: You have the right to access the personal data that Craftera Games uses.
• Correction or Deletion of Personal Data: If your personal data is inaccurate or incomplete, you may request Craftera Games to correct or complete it. Furthermore, under certain circumstances, you can request the deletion of your personal data from Craftera Games.
• Deactivation of Your Account: If you want to completely deactivate your account, you can do so by unlinking our mobile games from your Facebook account and deleting the games from your device. Please keep in mind that deactivating your account will result in the loss of all your progress in the game, as well as any virtual currencies that you have not used.
• Limitation of Processing Personal Data: You can request Craftera Games to limit the use of your personal data under certain conditions.
• Objection to Processing Personal Data: You have the right to object to the use of your personal data by Craftera Games under certain conditions.
• Portability of Personal Data: You have the right to receive your personal data in a structured and commonly used format. Under certain conditions, you can use this right to transfer the data to another company.
• Right to Opt Out:

• Personalized Ads: You have the right to request that your personal data not be processed by us for the purpose of delivering personalized ads to you.
• Certain Profiling Types: You have the right to request that your personal data not be processed by us for certain profiling activities.

• Right to Equality: You have the right to be free from discrimination for exercising your rights. However, please note that if you exercise certain rights, such as the right to delete personal data, it may limit our ability to process your personal data. In such cases, we may not be able to provide our products and services to you or interact with you.
• Right to Appeal: If we deny your requests to exercise these rights, you have the right to appeal.
• Right to Withdraw Consent: There may be occurrences where we require your consent to process your personal data. In these circumstances, if you have previously given your consent, you have the right to withdraw it at any time. It is important to note that withdrawing your consent does not affect the legality of your personal data before the withdrawal.

In certain situations, we may need to verify your identity and confirm that you reside in California. In order to do this, you will need to either verify your account or provide us with enough information that matches the information we have hold for you. This process may require additional personal data from you, such as your email address, phone number, and the date of your most recent purchase of our services.

We may not be able to fulfill your request to exercise your rights in some situations. This could be due to reasons such as inability to verify your identity or inability to find the relevant information in our systems. If we are unable to comply with any or all parts of your request, we will provide you with an explanation for our refusal.

For Residents of Europe:

You have the right to file a complaint with the local data protection authority. If you reside in the European Union, please visit this website for information on how to contact the local data protection authority.

If you are resident in the United Kingdom or Switzerland, your local data protection authority UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address).

For Residents of California:

Authorized Agents: Under certain conditions, you have the right to use an authorized agent (as defined by CCPA) to make requests on your behalf, who we can confirm can process requests on your behalf, based on the relevant methods specified in this California Notice.

To fulfill requests for information, deletion, or correction of personal data, the following information is required for verification purposes.

a. A valid power of attorney under California law provided by you or your authorized agent; or

b. Adequate proof that you have accomplished the following.

• Provide a signed authorization document to the authorized agent stating that they can act on your behalf.
• Directly verify your identity by us according to the instructions specified in this California Notice.
• Directly verify that you have authorized an authorized agent to make requests on your behalf.

7. CHILDREN

We do not intentionally or knowingly collect personal data from children. The term "child" is used to define individuals who are (a) under the age of 13, or (b) under the age for providing valid consent for the processing of personal data, as defined by applicable local or regional laws, ranging from 13 to 17 years old.

We want to make it clear that we do not intentionally or knowingly collect personal data from children. If a child under the age of 13 has provided us with personal data, we strongly encourage the child's parent or guardian to contact us to request the removal of the child's personal data from our systems. If you believe that we may have any information about or from children, please do not hesitate to contact us.

8. INTERNATIONAL TRANSFER

It is important to know that Craftera Games may store any personal data collected from you in any part of the world, including but not limited to the United States, the European Union, and the Republic of Turkey. When we transfer your personal data internationally, we take all necessary measures required by law to ensure the security of your personal data. However, please keep in mind that privacy laws may differ from region to region and the laws governing where you reside may not provide the same level of protection as the country where your data is transferred, stored, or processed. We assure you that we will take all necessary measures to protect your personal data.

We rely on appropriate security measures recognized by applicable laws, such as adequacy decisions and standard contractual clauses, when transferring personal data associated with you outside of Europe.

If you are using our services from the European Union or from another region that has laws regulating data collection and use, please be aware that by sharing your personal data with us, you are giving your consent to the processing of your personal data in the aforementioned locations.

By choosing to use the services or otherwise providing us with data, you agree that any disputes related to privacy or the terms in this Privacy Policy will be subject to the laws of the Republic of Turkey and that any disputes arising from the use of our services will be resolved in accordance with the Craftera Games Service Terms.

9. SECURITY

Craftera Games takes the security of the personal data you provide very seriously. Your information is stored on servers located in secure facilities and is protected by industry standard protocols and procedures, including security walls and data encryption. However, it is important to note that no server, computer, communication network, system, or data transmission over the internet can be guaranteed to be 100% secure. While Craftera Games takes every technical measure to protect your personal data and makes significant efforts to ensure information security, we cannot guarantee the absolute security of the information you submit to us or share through the Services.

By using our Services or sharing personal information with us, you acknowledge that we may contact you electronically concerning security, privacy, and administrative matters related to your use of our Services. In the event of a security breach in our system, we may notify you either through a notification on our website or via email.

10. LEGAL BASİS (FOR USERS İN THE EUROPEAN ECONOMİC AREA)

If you are a natural person located in the European Economic Area (EEA), we obtain and process your personal data only when there is a legal basis under EU legislation. The relevant legal bases are as follows:

• Contractual Necessity: This basis covers the data we use to provide you with Services such as games, customer services, chat functions, and third-party social network connections that you request and we agree to provide.
• Legal Obligation: This basis covers the data we use to comply with legal obligations such as maintaining records related to taxes or responding to valid legal requests concerning certain data.
• Legitimate Interests: This basis covers the data we use for purposes that can be reasonably expected in the context of your use of the Services and are not detrimental to your privacy. Such purposes may include marketing, advertising, analysis, research, and optimization of our games and other Services.
• Consent: This basis is used in the context of when you download our game, we collect data from your device, such as device information, advertising identifiers, IP addresses, and country/region information. This data is used for promotional purposes by us and our business partners. By downloading our game, you give us your consent to collect this data. If you want to withdraw your consent, you can do so by deleting our game from your device.

This Privacy Policy provides information about your right to withdraw consent regarding the processing of your personal data. If we process your data based on your consent, you can withdraw it at any time as outlined in this policy. However, unless stated otherwise, if you continue using our Services, we will collect and process your personal data. If you do not want us to collect any personal data related to you, you must stop using our Services.

11. THIRD-PARTY WEBSITES

Our Services may contain links to third-party websites, plugins, and applications. Please note that unless we explicitly state, direct, or use these third-party services, or explicitly reference them in this Privacy Policy, their personal data activities are not covered by this Privacy Policy, and we cannot be held responsible for them. We recommend that you visit the respective Privacy Policies of third-party services to learn more about their personal data activities.

12. RETENTION

We will keep your personal data as long as your game account is active or necessary for providing services.

In case you want to retrieve your personal data, we will keep it until we have fulfilled our legitimate purposes, such as meeting legal obligations, resolving disputes, and enforcing contracts.

13. CHANGES TO THE PRIVACY POLICY

We want to let you know that we may modify this Privacy Policy periodically, and the updated version will be posted on this page. The date indicated at the beginning of the Policy will be changed with every update. If there are significant changes to this Policy, you will be notified through an email sent to the email address you provided, prominent announcements on our Services, or other appropriate communication channels. The updated Policy will be effective from the date it is published by us.

14. CONTACT US

To contact us and/or exercise your rights stated in this Privacy Policy, please contact us at:

İstinye Mah. Altın Damla Sok. No: 33 D: 7 Sarıyer / İstanbul