Privacy Policy

This Privacy Policy was prepared by Funjitsu Oyun ve Teknoloji Anonim Şirketi (“Funjitsu”) with its headquarters at İnciraltı Mahallesi. Mithatpaşa Caddesi Morfoloji Blok No:56-20 İç Kapı No:Z, Balçova, İzmir as the data controller in order to inform you about the methods of collection, processing, use, transfer and destruction of your personal data under Article 10 “Data Controller’s Disclosure Obligation” and Article 11 “Rights of the Data Owner” of the Personal Data Protection Law 6698 (“PDPL”).

Funjitsu shall process your personal data within the scope of the personal data processing conditions and purposes specified by the PDPL and

• in accordance with the law and the rules of honesty,
• by preserving the accuracy and most up-to-date version of the personal data you share,
• for specific, explicit and lawful purposes,
• in connection with the purpose for which they are to be processed, in a limited and measured manner,
• according to the conditions and purposes stipulated in the relevant legislation or as required by the purpose for which they are processed.

Collection of Personal Data, Processed Personal Data and Purpose

Collection

Your Personal Data are directly collected directly you during your visit to funjitsugames.com website. In addition, Funjitsu directly receives data from you during your contact with the customer service.

We use Google Analytics, a web analytics service, on our website. In other words, your browsing behavior may be analyzed statistically and especially by using cookies and analysis software when you visit our website. Your browsing behavior is generally analyzed anonymously and is not used to track you. You can object to this type of analysis without using specific tools, or you can prevent this type of analysis.

Google Analytics is provided by Google LL, registered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Information for Mobile Applications

No personal data is transferred to Funjitsu when you download mobile games published by Funjitsu, while using mobile games or make in-game purchases in mobile games. All of your purchases or downloads and usage transactions are completed through the Apple AppStore and GooglePlay app stores.

Even in the presence of your explicit consent for personalized advertisements, Funjitsu and its suppliers process the transactions or activities you carry out on the application and your reactions to the advertisements anonymously.

Funjitsu, works with third parties to provide Funjitsu with analytical, analysing, storage, advertising and marketing services. You can access to the list of our business partners and service providers and their own privacy policy’s through the table below.

Funjitsu shall only be able to send notifications to the device you connect to the games through the games upon your explicit consent. At this stage, no personal data is processed by Funjitsu. You can change the notification settings on your device at any time.

Legal Grounds for Data Processing

Data processing is used for reasons expressly provided by the following in order to benefit from and purchase Funjitsu games, provide customer service and support;

• for legal purposes under sub-paragraph (a) of PDPL,
• if it is directly related to the establishment or performance of the contract under sub-paragraph (c),
• if it is mandatory for Funjitsu to fulfill its legal obligations as the data controller under sub-paragraph (ç),
• if it is necessary to establish, protect and exercise a right of Funjitsu pursuant to sub-paragraph (e).

The processing of these data is not subject to your consent. In this respect, we inform you that you do not have the right to request the deletion or destruction of your personal data until the end of the retention periods required by the service you use or the law.

Transfer of Personal Data to Third Parties

In order to comply with the obligations arising from the law and/or to fulfill its responsibilities arising from the service and purchase contract or if it is necessary in order to fulfill its legal obligation and/or to establish, exercise or protect a right, Funjitsu may, without the need for your consent, transfer your personal data

1. to third parties, in particular technical support units within Funjitsu, and to other third parties such as banks, audit firms, lawyers, attorneys’ offices, financial advisors and suppliers, as required by the work and/or those it receives service from, limited to and proportionate to the service received solely for the performance of obligations, and
2. to the police units, judicial authorities, relevant ministries and directorates and other public institutions authorized by law.

The transfer of data within Turkey shall be limited to the cases where it is mandatory by law in accordance with sub-paragraph (a), for the establishment and/or performance of the contract in accordance with sub-paragraph (c), for the fulfillment of a legal obligation in accordance with sub-paragraph (ç) and for the establishment, use or protection of a right in accordance with sub-paragraph (e) of Article 8/2 (a) of the PDPL.

Information about third parties and /or categories of third parties to whom your data is disclosed in Turkey is always available for your information and review.

Access to Personal Data from Abroad

Funjitsu stores personal data on its servers in Turkey.Such access is based on your explicit consent obtained from you through the website. Your explicit consent’s legal basis is Article 9/1 of PDPL.

Protection, Retention Period and Destruction of Personal Data

Funjitsu is obliged to take all kinds of physical, technical and administrative measures to ensure an adequate level of security in order to prevent unlawful processing of, unlawful access to your personal data, and to ensure the protection of your personal data, and takes these measures to the maximum extent.

Your personal data are stored for ten (10) years from the last date your user account was active and your personal data processed for purchasing transactions are stored for ten (10) years from the last purchase date until the end of the retention period.

The processing of your personal data for marketing purposes is limited to two (2) years following the last date you were active on funjitsugames.com. Funjitsu will not use your personal data to contact you for marketing purposes after a period of two (2) years.

At the end of these periods, your personal data will be deleted, destroyed or anonymized during the first disposal period.

Funjitsu has prepared separate specific information texts (clarification text) for users, employees, employee candidates, suppliers and managers. These clarification texts have been delivered to the related persons or access has been provided.

Your Rights

As the data owner, you have (a) the right to request information about whether your personal data are processed and how they are processed (Article 11/(a), (b)), (b) to learn the purpose of processing and whether they are used in accordance with the purpose (Article 11/c), (c) to know the third parties to whom they are transferred (Article 11/ç) (d), to request correction (Article 11/d), (e) to request the deletion of your personal data in case the reasons for processing are eliminated (Article 7, Article 11/e), (f) to request the notification of the relevant transactions to the third parties to whom your personal data is transferred (Article 11/f), (g) to object to the results obtained as a result of analysis of your data (Article 11/g), (h) to request the limitation of processing (Article 7/g), (i) to request the compensation of the damage suffered in case of unlawful processing (Article 11/ğ).

Your aforementioned rights are limited to the law and may only be granted by us under certain circumstances. (Please refer in particular to Articles 10 and 13 of the PDPL). You can forward these requests listed above to e-mail address.

Data Controller: Funjitsu Oyun ve Teknoloji Anonim Şirketi

Mersis No: 0781092400800001

Address: İnciraltı Mahallesi. Mithatpaşa Caddesi Morfoloji Blok No:56-20 İç Kapı No:Z, Balçova, İzmir

E-Mail Address: [email protected]

Your personal data can always be updated upon your request.

In order to use your right to complaint to the Board, (PDPL art. 13, 14, 15)

Board: Personal Data Protection Board

Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat-Çankaya/ Ankara,

Phone: +90 312 216 5000

Website: http://www.kvkk.gov.tr/