PRIVACY POLICY

This Privacy Policy (the “Policy”) describes the collection, use, disclosure, storage, and protection of information by ENTERTALE GAMES OYUN YAZILIM DANIŞMANLIK VE PAZARLAMA ANONİM ŞİRKETİ (“Entertale Games,” “Company,” “we,” “us,” or “our”) in connection with its games, mobile applications, websites, and related services (collectively, the “Services”).

By accessing or using the Services, the user acknowledges that personal data may be processed as described in this Policy. If the user does not agree, the Services must not be used.

1. Data Controller and Contact

If required by applicable law, the Company will designate and publish contact details for a data protection officer and/or an EU/UK representative.

2. Scope

This Policy applies to information processed in connection with:

• Mobile games and applications published by the Company (including Snazzle! Puzzle and future titles);
• Websites and pages operated by the Company that link to this Policy (including entertale.games);
• Customer support communications; and
• Marketing and advertising activities related to the Services.

This Policy is intended to operate as a master policy. Features and third-party partners may vary depending on the specific title, platform, region, and user settings.

3. Definitions

“Personal data” or “personal information” means information that identifies, relates to, describes, or can reasonably be linked to an individual or device, consistent with applicable law.

4. Categories of Information Collected

Information is collected through: (A) information provided by the user, (B) information collected automatically, and (C) information received from third parties.

A. Information Provided by the User

Depending on the title and enabled features, the Company may collect:

• Account identifiers: email address, username/display name, player ID;
• Profile information: avatar/profile photo and other optional profile fields;
• User content and communications: chat messages, guild/clan messages, and other content submitted through social features;
• Customer support information: email address used to contact the Company, support requests, and any information submitted voluntarily (including screenshots).

B. Information Collected Automatically

Depending on the title, device settings, and permissions, the Company may collect:

• Device and technical information: device model, operating system version, language, time zone, app version, and network information;
• Identifiers: device/app identifiers and advertising identifiers where available and permitted (including Android Advertising ID/GAID and iOS IDFA when authorization is provided);
• IP address and approximate location: including location derived from IP address (such as country/city/region). Precise geolocation is not collected unless a feature requires it and device permissions allow it;
• Usage and gameplay data: session activity, progression, interactions, and feature engagement;
• Advertising-related data: ad impressions, interactions, rewarded ad completion, frequency controls, and anti-fraud signals;
• Diagnostics: crash logs, performance data, and related troubleshooting signals.

C. Information Received from Third Parties

The Company may receive information from:

• App platforms and stores: installation signals and performance reporting;
• Payments through app stores: purchases are processed by the platform provider, and full payment card details are not received by the Company. The Company may receive transaction metadata necessary to fulfill purchases and provide support (including purchase confirmations, items purchased, timestamps, country/region, and transaction identifiers);
• Social sign-in providers: information authorized by the user and provided by the relevant provider;
• Advertising, analytics, and attribution partners: measurement results, attribution signals, and fraud-prevention signals related to advertising campaigns.

Certain information is necessary for core functionality (including saving progress, enabling online features, fulfilling purchases, and preventing fraud). If information is not provided or permissions are disabled, some features may be unavailable.

5. Purposes of Processing

The Company processes information for the following purposes:

• Provision and operation of the Services, including gameplay features, progression, accounts, and purchases;
• Customer support and communications, including responding to requests and troubleshooting;
• Analytics, diagnostics, and improvement, including service performance monitoring, bug fixing, balancing, and optimization;
• Advertising and measurement where advertising is enabled, including serving ads, managing frequency, measuring effectiveness, and preventing ad fraud, and offering required controls for personalized advertising or measurement;
• Safety and integrity, including detection and prevention of cheating, abuse, spam, suspicious activity, enforcement of rules, investigations, and user protection;
• Legal compliance and protection of rights, including compliance with legal obligations, responding to lawful requests, and establishing, exercising, or defending legal claims.

The Company may apply limited automated processing for analytics, security, and advertising measurement/personalization where permitted by law. Such processing is not intended to produce legal or similarly significant effects on individuals.

6. Legal Bases for Processing (where required)

Where a lawful basis is required, the Company relies on one or more of the following:

• Performance of a contract;
• Legitimate interests, including operating, securing, improving, and measuring the Services and preventing fraud, in a manner consistent with applicable law and user settings;
• Consent, where required;
• Legal obligation.

Where processing is based on consent, consent may be withdrawn at any time through available controls or by contacting the Company.

7. Third-Party Services

The Company uses third-party services to operate, measure, monetize, and secure the Services. Third-party partners may change over time.

Categories of third parties may include:

• Analytics and diagnostics (e.g., Firebase Analytics, Firebase Crashlytics);
• Attribution/measurement (e.g., Tenjin, Adjust);
• Advertising mediation and advertising partners (e.g., AppLovin MAX and partners that may include Unity Ads, AdMob, Meta Audience Network, ironSource, Mintegral, Vungle/Liftoff, InMobi, Fyber/Digital Turbine, Moloco).

Third parties may process information such as device identifiers, advertising identifiers (where available), IP address, approximate location derived from IP address, usage data, and ad interaction data in order to provide their services.

8. Disclosures of Information

The Company may disclose information to:

• Service providers and vendors providing hosting, analytics, diagnostics, attribution, advertising, security, and support services, subject to contractual restrictions, unless a vendor acts as an independent controller under its own policy;
• Other users where social features exist, to the extent information is public by design (including display name, avatar, leaderboard information, guild/clan information, and chat content);
• Authorities and third parties for legal, safety, and enforcement purposes where reasonably necessary to comply with law, protect rights and safety, investigate fraud or abuse, or enforce policies;
• Successor entities in connection with a merger, acquisition, reorganization, bankruptcy, or sale of assets, subject to applicable law.

9. International Transfers

Information may be processed in countries other than the user’s country of residence. Where required, the Company implements appropriate safeguards for cross-border transfers, including contractual protections such as Standard Contractual Clauses.

10. User Choices and Controls

The Services may provide controls depending on region, platform, and title, including:

• Consent choices for advertising and measurement where required;
• iOS AppTrackingTransparency permission prompts where applicable;
• Device-level controls for advertising identifiers and ad personalization;
• Device-level controls for push notifications where used;
• Social controls within the game where provided.

11. Data Retention

Information is retained only for as long as reasonably necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

Retention is determined based on factors including the nature of the data, the purposes for which it is processed, user settings, fraud prevention and security needs, dispute resolution, audit requirements, and legal obligations.

• Account/profile data: retained while an account remains active and thereafter for a reasonable period to complete deletion, prevent fraud/abuse, resolve disputes, and comply with legal obligations.
• Gameplay and analytics data: retained as necessary to operate, improve, and secure the Services and may be aggregated or de-identified over time.
• Support communications: retained as necessary to resolve issues and for recordkeeping and audit purposes.
• Transaction metadata: retained as required for accounting, tax, audit, fraud prevention, and customer support.
• Advertising data: retained as necessary for measurement, frequency capping, fraud prevention, and reporting.
• Chat data: where chat exists, messages may be retained for moderation, safety, and enforcement purposes for approximately 90 days and thereafter deleted or anonymized unless further retention is required for compliance, dispute resolution, or investigations.

Residual copies may remain in backups for a limited period and are overwritten or deleted in the ordinary course of backup operations.

12. Children

The Services are not directed to children under 13, and the Company does not knowingly collect personal information from children under 13. If a parent or guardian believes a child under 13 has provided personal information, the Company must be contacted at privacy@entertale.games, and commercially reasonable steps will be taken to delete the information.

13. Security

The Company maintains reasonable administrative, technical, and organizational measures designed to protect information. No method of transmission or storage is completely secure, and absolute security cannot be guaranteed.

14. Privacy Rights and Additional Regional Disclosures

A. General Rights

Depending on applicable law, users may have rights including access, correction, deletion, restriction or objection to certain processing, portability, withdrawal of consent, and the right to lodge a complaint with a competent supervisory authority.

Requests may be submitted to privacy@entertale.games. Identity verification may be required.

B. Account Deletion

Where a title provides account creation, an account deletion mechanism is made available within in-game settings or equivalent in-app menus. Where in-app deletion is not available, a deletion request may be submitted to privacy@entertale.games.

Deletion removes account-related personal data from active systems within a reasonable period, subject to retention required for legal obligations, security, fraud prevention, dispute resolution, enforcement, and backup cycles.

C. United States State Privacy Disclosures (California; Virginia; and similar laws)

Where required by applicable U.S. state law, users may have rights to access/know, delete, correct, obtain a portable copy, and opt out of certain processing.

Certain advertising and measurement activities may constitute “sharing” for cross-context behavioral advertising under California law or “targeted advertising” under other state laws. Opt-out mechanisms are provided through available in-app privacy/consent settings, device-level advertising settings, and any consent prompts presented in the Services.

Where required by law, the Company processes legally recognized opt-out preference signals, including Global Privacy Control.

Where required by law, users may submit requests through an authorized agent, subject to verification of authorization and identity.

Where an appeal right is required by law, an appeal may be submitted by replying to the Company’s response or by emailing privacy@entertale.games with the subject line “Appeal.”

D. Canada (PIPEDA)

The Company provides a method to request access and correction and to challenge compliance with this Policy by contacting privacy@entertale.games.

15. Third-Party Links and Services

The Services may include third-party integrations (including advertising, analytics, attribution, social login) and may link to third-party services. Third-party privacy practices are governed by their own policies.

16. Changes to this Policy

The Company may update this Policy from time to time. The updated Policy will be made available through the website and/or within the relevant game. Material changes will be communicated as required by law.

17. Contact

Privacy: privacy@entertale.games

Support: support@entertale.games

ENTERTALE GAMES OYUN YAZILIM DANIŞMANLIK VE PAZARLAMA ANONİM ŞİRKETİ
OĞUZLAR MAH. 1381 SK. NO: 6 İÇ KAPI NO: 23 ÇANKAYA / ANKARA, Türkiye