(Last updated on May 22, 2018)
This
Privacy Policy is designed to provide clarity about the personal
information and data SNG Bilişim Yazılım Danışmanlık ve Pazarlama
Dış Ticaret Limited Şirketi and/or any of its agents, consultants,
employees, officers and directors (“SNG”, “its”, “our”, “we”)
collect, how it is collected, why it is being processed, how and
where it is used, how long it is being retained, and whether it is
being shared with any other parties. By installing and playing a
game or any other application provided by SNG on the Apple App
Store, Google Play App Store, or Facebook, you give your explicit
and informed consent to the processing of your personal
information in accordance with this Privacy Policy and Terms of
Service.
As per
definition, “personal data is any information relating to an
individual, whether it relates to his or her private, professional
or public life. It can be anything from a name, a home address, a
photo, an email address, bank details, posts on social networking
websites, medical information, or a computer’s IP address.”
Information We Collect
SNG collects data from you, through your
interactions with our games. SNG facilitates third-party
advertisement, tracking and analytics services and these services
also collect both non-personal and personal data.
First type
of data we collect is the Process Data acquired through your
direct interaction with our game. This data is related solely to
your progress at our games and you cannot be personally identified
through this type of data. Thus, this type of data is
non-personal. Non-personal information includes technical
information, behavioural data and statistical data. Also, we do
not ask of you to submit any personal information at any of our
games as they do not require registration. Third-party services
might also collect non-personal information. Non-personal
Information collected by third-parties may include the following
technical information: type of operation system (e.g. Android,
iOS, etc.), type of browser (e.g. Explorer, Firefox, Chrome,
Safari, etc.), screen resolution (e.g. 800×600, 1024×768, etc.),
language (e.g. English), device type (e.g. Galaxy, HTC, iPhone,
etc.), geo-location – only general location may be collected.
However,
third-party advertisement, tracking and analytics services that we
use, and Google and Facebook, if you use your Google and Facebook
accounts to play one of our games, may have access to personal
information such as your device identifier, MAC address, IMEI,
location (specific location where a given language is spoken),
geo-location information, and IP address for the purpose of
providing their services under their respective privacy policies.
SNG does not have control over these third parties and has access,
as provided by these services, to the collective, anonymous data.
Exceptions to
majority of our games are Gin Rummy Online and Pişti Online games.
As these games both require online interaction of real people,
registration of users and retainment of collected information is
necessary. At Gin Rummy Online, Game Sparks’ service is used. Only
personal information collected at Gin Rummy Online are Facebook or
Google identities, depending on login preference of the user,
public profile information like friends list, profile picture and
name of the user, and geo-location (city, country). At Pişti
online, Facebook id, public profile information like list of
friends, profile picture and name of the user are collected as
data.
How Do We Collect Information
As mentioned, we work with third-party
advertisement and analytics services. Below a concise list of such
services, type of personal information they collect, and a link to
their own Privacy Policies, if there is one is provided. Links to
their own Privacy Policies are embedded on the name of each
service provider. We might use one or more of these services at
our different games.
Analytics:
| Service Provider |
Personal Information |
| Google Analitics |
Cookies, unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example) and Usage Data
|
| Flurry Analytics |
Various types of Data as specified in the privacy policy of
the service
|
| Admost Analytics |
Cookies, unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example) and Usage Data
|
| Fabric |
Cookies, unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example) and Usage Data
|
| Crashlytics |
geographic position, unique device identifiers for
advertising (Google Advertiser ID or IDFA, for example) and
various types of Data as specified in the privacy policy of
the service
|
| Firebase |
Various types of Data as specified in the privacy policy of
the service
|
Advertisement:
| Service Provider |
Personal Information |
| Applovin |
Cookies and Usage Data |
| Google AdMob |
Cookies, unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example) and Usage Data
|
| Google Adsense |
Cookies and Usage Data |
| Unity Ads Privacy |
Cookies and Usage Data |
| Facebook Audience Network |
Cookies, unique device identifiers for advertising (Google
Advertiser ID or IDFA, for example) and Usage Data
|
| Chartboost |
Cookies and Usage Data |
| Mopub |
Cookies and Usage Data |
| Tapjoy |
Cookies and Usage Data |
| Fyber |
Cookies and Usage Data |
| Heyzap |
Cookies and Usage Data |
If you contact us directly,
such as to request information, report a bug, or for Customer
Support, we may receive additional information about you, such as
your contact information and the contents of your communication.
Why Do We Collect Information
Process Data is collected to record your
progress in our games. It is only functional and has no analytical
purpose.
SNG uses
third-party advertisement and analytics services. Data is
collected by these services. In return, they provide us with
anonymous statistical data. This statistical data is analysed and
bugs, flaws in the flow of games are corrected. All of our games
are shaped according to the users’ preferences in order to give a
more fulfilling and fun experience to them.
SNG will use
your information to communicate with you, including to respond to
your inquiries and to send emails to an email address you provide
to us for customer-service or technical-support purposes.
Where and How Long Do We Retain Information
SNG does not retain any kind of
information, except for Pişti Online, where the data collected is
retained at secured servers. Information collected at Gin Rummy
Online is retained ad Game Sparks servers. Both data are retained
for the duration necessitated by the law, or until user’s request
for erasure is granted. The data related to our other games you
use, Process Data, is retained at your own device. They are kept
at your device until you delete the game from your device.
Analytical data collected through third party advertisement,
tracking and analytics services is retained by those services
themselves. We have no control over this data and have limited
access to the anonymous data provided by these services. Duration
of this data’s retainment is at these services’ discretion.
Do We Share Information We Collect
SNG is not a data mining company and we do
not share your information with any other third party. On the
other hand, the third-party services that we use at our games
might share the personal information they collect with other
parties under the conditions put forward at their own Privacy
Policies. We do not disclose any part of your information unless
it is required by law. We may disclose information about you: (i)
if we are required to do so by law, regulation, or legal process,
such as a court order or subpoena; (ii) in response to requests by
government agencies, such as law enforcement authorities; (iii)
when we believe disclosure is necessary or appropriate to protect
against or respond to physical, financial or other harm, injury,
or loss to property; or (iv) in connection with an investigation
of suspected or actual unlawful activity. SNG may further disclose
your Personal Information with your consent.
Your Rights
You have the right to access your personal
data and information about how this personal data is being
processed.
You have the
right to request erasure of personal data, which we retain at our
own servers, related to you.
Not all of
our games are intended for children under the age of 13 and we do
not knowingly collect any personal information from such children.
SNG cannot be held liable in case a child under the age of 13 uses
one of our games with certain age limitations and his/her personal
information is collected. In the event that we learn we have
inadvertently gathered personal information from children under
the age of 13, we will take reasonable measures to promptly erase
such information from our records.
Contact Us
If you have any questions, comments or
concerns regarding our Privacy Policy and/or practices, please
send an e-mail to support@sngict.com.
SNGICT
Üniversiteler Mah. İhsan Doğramacı Blv.
ODTÜ/Teknokent
Çankaya, Ankara,
Turkey 06800
Updates to
this Privacy Policy
We will
post any adjustments to this Privacy Policy on this page, and the
revised version will be effective when it is posted. If we
materially change the ways in which we use or share Personal
Information previously collected from you through our products, we
will notify you through our product, by email, or other
communication.