NBT İLETİŞİM YAZILIM VE BİLİŞİM TEKNOLOJİLERİ A.Ş. PRIVACY POLICY

The purpose of this policy is to provide you with all the important information and explanations about how and why some of your data may be collected and processed by NBT İletişim Yazılım ve Bilişim Teknolojileri A.Ş. (“NBT (Next Big Thing)”) when you use one of our applications or browse on our website. This privacy policy governs and details the main principles that NBT (Next Big Thing) applies to the data we collect and process to:

When you install and use NBT (Next Big Thing) mobile applications, we can collect and process some of your data for different legitimate purposes. You accept, acknowledge and promise that your personal information and data might be used in limited manner by NBT (Next Big Thing) and/or through NBT (Next Big Thing) to the extent that it is limited to the format and purposes set forth in this Privacy Policy. Every type of information related to an identified or identifiable natural person constitutes personal data. Processing your personal data signifies all types of transactions performed on the data such as; obtaining, recording, storing, preserving, altering, re-arranging, disclosing, transferring, acquiring, making accessible, alignment and preventing access.

1. What is the purposes of collecting and processing personal data?

NBT (Next Big Thing) collects your personal data automatically whenever you download our Games to your device or play the Games, whenever you send us your feedbacks or convey your information or support requests directly to NBT (Next Big Thing) or interact with third party advertisements presented in our Games or interact with NBT (Next Big Thing) advertisements presented in other platforms.

In general, the information we collect about you relates to your device and helps us to identify your device. NBT (Next Big Thing) also collects data from the Apple App Store and Google Play App Store (Referred to as “Platforms” together) platforms and the business partners. NBT (Next Big Thing) might collect the your personal information (user name, name if provided, IP address, the date and time of access, the pages accessed while being on Game) and the activities taken place under NBT (Next Big Thing) in order to provide better service to you, to make suggestions, to improve its services, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “settings” page .

Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests.

2. When is personel data is collected?

• Personal data that is collected while you are playing NBT (Next Big Thing) Games:

  NBT (Next Big Thing) might collect the your personal information and the activities taken place under NBT (Next Big Thing) in order to provide better service to you, to make suggestions, to improve its services, to improve and update our Games, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

  When you download and/or play the Games via Platforms, NBT (Next Big Thing) collect certain personal data from you and/or your device. In this regard, NBT (Next Big Thing) collect your advertising ID (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), device identifier, operating system, model, producer information, hardware type, operating system version, memory usage, country, time zone and preferred language information, internet protocol (IP) number, location information according to your IP address, operator and browser information, information about properties of mobile application through which a consumer interacts with the Games, data regarding your in-game interactions (the time you spent while playing our games, your in-game expenses, level information, the amount of time for watching advertisements, the advertisements watched) and time of installation and first opening of the application.

  The aforementioned advertising IDs (IDFA and GAID) are unique identifiers for mobile devices that advertisers use for personalized advertising and consistent across all mobile applications and thus allow cross-app tracking. You may disable this option by activating “limit advertisement tracking” from the privacy settings of Apple devices. As for the Google Android devices, you may change your advertisement setting by activating the “disable advertisement personalizing” option. Advertising IDs, are non-permanent identifiers, which are uniquely associated with your device.

  We would like to remind that you have an option to play the Games without watching advertisements by using our no-ads feature, which is subject to a fee.

  Your user name and score can be viewed by other users in our games that include a scoreboard feature. Payments for in-app purchases are being carried out by the Platforms. NBT (Next Big Thing), does not collect personal data such as your name, surname, credit card number and e-mail address that you share with the Platforms for the payment, and only payment information for the items your purchase is being shared with us in order to fulfil your order.

• Personal data that is collected when you contact with us.

  • When you contact with us:

    We may ask for contact information (e-mail) when you request information about our Games, request technical support or contact with us anyhow. Your contact information will be processed for the purposes of fulfilling your requests and communicating with you.

  • Comments:

    You may share data that contains your personal data when you share your comments and views about our Games. The content of user comments is composed fully of data that you voluntarily provided. We process your shared personal data to solve the issues you encountered and to fulfil your request.

3. Data that is collected by third parties:

If the personal data provided to us by you is requested by official authorities as necessitated by the law, the data may be transmitted to the relevant authorities and courts if requested by the Courts.

Our business partners or service providers can use server log files, cookies, pixel labels, web beacons or other tracking tools in our Games. Our advertisement business partners and analytics service providers mentioned in the part 3 below, can collect data regarding your IP address your advertising identifier (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), cookie identifiers, advertisement ID, your mobile device’s type, operating system, version, model, hardware type, other device identifiers that are automatically determined for your device when you connect to the internet, web browser information, websites you visited, connections you have within the Games and your preferences about the visited websites by using the stated technologies. You may access to the privacy policies of these third parties from section 3.

NBT (Next Big Thing) stores your data for as long as it is necessary to provide our Games and deletes it when the purposes of the data processing cease to exist. Personal data is deleted in case the reasons which necessitate processing within the context of the stated purposes in this privacy notice cease to exist and after 2 years as of the registration date of the relevant record at thelatest.

4. Children data:

NBT (Next Big Thing) never knowingly or willingly collect any personal data concerning children under 16 years of age.

5. The legal grounds of processing your personal data:

The legal grounds that NBT (Next Big Thing) relies upon while processing your personal data are the following:

1. Explicit consent and/or your request
2. In cases where it is necessary to disclose such information in accordance with applicable laws or regulations or a court judgment or administrative order issued
3. Being necessary for the establishment and execution of an agreement
4. Being necessary for NBT (Next Big Thing) to fulfil its legal obligations as a data controller
5. Being necessary for the establishment, exercise and protection of any right
6. Without prejudice to your fundamental rights and freedoms, being compulsory for NBT (Next Big Thing)’s statutory interests

In data processing activities where your personal data is processed based on the explicit consent, you have the right to withdraw your consent at any time.

NBT (Next Big Thing)’s statutory interest in processing your device and usage data is provide better service to you, to make suggestions, to improve its services, to improve and update our Games, to facilitate the use of Games at the works related to your interest and preferences, within the framework of legal legislation.

NBT (Next Big Thing) undertakes to keep the your data and any confidential information strictly private and confidential, without prejudice to the contents hereof, to regard it as an obligation to keep confidentiality, to take all measures and act in due diligence to prevent all or any part of your information from entering into the public domain or be subject to unauthorized use, or to take measures to prevent the confidential information from disclosure to any third party. If, despite all necessary data security measures taken by NBT (Next Big Thing), the confidential information is damaged as a result of attacks on the system or captured by third parties, NBT (Next Big Thing) shall have no responsibility with that respect.

NBT (Next Big Thing) shall not be responsible for damages caused by the use of information that you disclose in comments made or messages given by third parties in public areas. If you share your name, password, etc. used by you when creating the membership record with third parties, the NBT (Next Big Thing) shall not be responsible for any damages that may arise from the information shared with third parties.

6. The transfer of your personal data

Your personal data may be transferred to our business partners and service providers located abroad for the purposes of improving our Games and providing our Games to you, providing personalized advertisements according to your interests, measuring NBT (Next Big Thing)’s and third parties’ advertisement effectiveness and carrying out measurements and analysis regarding your use of our games. In case a public institution is authorized to request personal data by the law, your personal data can be transferred to such authorized public institution in accordance with the applicable personal data protection legislations. Requests from judicial authorities will also be fulfilled in accordance with the applicable legislation.

Your personal data may be shared with following categories of recipients listed above.

• Analytics services. Your personal data may be transferred to our service providers and business partners for the purpose of conducting analytical reviews, analyses, reporting and research activities regarding the use of our Games.
• Cloud computing services. Your personal data is stored in the servers of the Amazon Web Services.
• Advertisement business partners. Your personal data may be transferred to our advertisement partners who enable the Games to be provided free or for low cost.

You may find the list of our service providers and business partners and their privacy policies below:

7. Your Rights Regarding the Protection of Your Personal Data

According to the relevant legislation, you have the right to;

• learn whether or not your personal data is being processed,
• request information as to processing if it has been processed,
• learn the purpose of personal data processing and whether the personal data is used appropriately in line such purposes,
• know the third parties to which your personal data is transferred domestically or abroad,
• to request correction if your personal data is incompletely or incorrectly processed,
• to request deletion or destruction of your personal data,
• to request the transmission of your correction, deletion and destruction requests to third parties to whom your personal data has been transferred,
• to object to any consequence occurred against you by analyzing your processed data through automated systems
• request compensation in case you incur any damage due to the unlawful processing of personal data.,
• request restriction of data processing activities,
• request data portability,
• object to the occurrence of an adverse consequence by analyzing the processed data exclusively through automated systems, and
• to lodge a complaint with the relevant data protection authority and have the right to claim damages in case of impairment because your personal data is processed in violation of the relevant legal legislation.

You can submit all your claims and questions with respect to such rights to info@nbtdigital.com. Your requests will be answered as soon as possible and within thirty days at latest.

NBT İletişim Yazılım ve Bilişim Teknolojileri A.Ş.

Mersis No: 06300808640