PRIVACY POLICY

August 17, 2022

WORDYLLA is a game produced and owned by R. Volkan Özcan (Tax ID : 6710400222 Kartal Tax Office) in Turkey. WORDYLLA (also referred to as "we", "our" or "us") respect the rights and obligations regarding the privacy and personal information of our users (user may also referred to as "you").

The purpose of this Privacy Policy (the “Policy”) and clarification text is to convey to you in detail which personal data WORDYLLA may process and for what purposes. We care about your privacy and protect all your personal data that you have transmitted to us in accordance with the general principles of data protection law, especially the Turkish Law on the Protection of Personal Data No. 6698 (“PDPL”) the General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) and the general principles of these regulations.

Please note that the scope of this Policy is limited to information collected or received by WORDYLLA through your use of the services. WORDYLLA is not responsible for the actions of third party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies. As used herein, the term "use" shall mean use, access, play, install, sign into, connect with, download, visit or browse our sites or services. By using the Service, you are expressing your agreement to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. You should not use our Services if you do not agree with this Policy.

INFORMATION AND DATA WE MAY COLLECT FROM YOU

WORDYLLA’S primary goals in collecting and using information is to create your account, provide services to you, improve our Service, contact you, conduct research and create reports for internal use and marketing new products to you. We store only limited information about game stats on our servers.

User Data

Personal data that you provide or that we collect for your registration and use of WORDYLLA depends on your sign-up method. Your name, username, age, gender and email address may be collected. Your profile picture can be collected if you upload it. Exactly what personal data is collected depends on the way you create an account with which you sign up and whether you use third-party log-in services (e.g. Facebook, Apple, Google). Since an account cannot be opened directly in Wordylla and a third-party service is used to create an account in the game, your personal data will be collected by us through this third-party service only if you allow within that third-party service to share your data with us.

When you use our Services we may record certain information and data, such as your application usage, access, session times and in-app purchases, your unique device ID (persistent / non-persistent), hardware type, media access control ("MAC") address, international mobile equipment identity ("IMEI"), the version of your operating system ("OS"), your device name, your email address (if you have connected to Facebook, Apple or Google), and your location (based on your Internet Protocol ("IP") address). This information is useful to us for troubleshooting and helps us understand usage trends and improve and optimize the Services and your user experience, and may also be utilized for other purposes, such as interest based advertising as described elsewhere in this Policy.

In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your profile information to track the game you are playing.

HOW WE COLLECT AND USE INFORMATION

We may collect your personal data in automatic ways through our website and mobile applications. We may also collect such information through third parties

If you create a membership by signing up through Apple, Facebook and Google services,
If you use our game,
If you submit your information to us through relevant forms and other means,

We may collect the following information and data from you:

Contact information (such as name and email address)
Username
Profile information that you voluntarily provide while using the Services (such as profile photo, gender, age or birthday, links to profiles on other social networking websites)
Automatically collected data (such as IP Address, your device's operating system, browser type and language)
Mobile device identifiers (such as your unique device ID (persistent/non-persistent, hardware type, media access control ("MAC") address, international mobile equipment identity ("IMEI"), and your device name
General location information for the purpose of providing you with the correct version of the application
Game data (such as your interactions with the game and with the other players inside the game via server log files, your player ID)

THIRD PARTY SERVICES AND DATA COLLECTED FROM THIRD PARTIES

Our services may contain third party tracking tools from our service providers, examples of which include Unity Analytics and Facebook. Such third parties may use cookies, APIs, and SDKs in our services to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as your device identifier, Media Access Control ("MAC") address, International Mobile Equipment Identity ("IMEI"), locale (specific location where a given language is spoken), geo-location information, and IP address.

HOW WE USE THE INFORMATION WE COLLECT

Since an account cannot be created directly in Wordylla and a third-party service is used to create an account in the game, your personal data will be processed by us through this third-party service only if you allow that third-party service to share your data with us .We may use the information we collect through your use of the Services for a variety of purposes, primarily related to providing and improving the quality of our Services. For example, we may use the information we collect in the following ways:

HOW WE SHARE YOUR INFORMATION

We transfer the personal data we process to the relevant domestic and international service providers for the purpose of carrying out business processes, and to authorized public institutions and organizations in order to fulfill our legal obligations.

We will share your personal data to third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the games. We do not control or influence these third parties’ tracking technologies or how they may be used.

If you opt-in or otherwise agree to have your information shared with a third party for marketing purposes, we will share your information with the third party (or third parties) in which case the third party’s use of your information is subject to the third party’s own privacy policy.

We may share your personal data for following purposes:

Third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
Providers that help us generate and collate reviews in relation to our goods and services;
Our advertising and promotional agencies and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or service providers that assist us in providing our services, in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.

We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our services.

We may share your information with third party companies that perform services on our behalf, including payment processing, order fulfillment, data analysis, marketing services, e-mail campaigns, hosting services, and customer service. While providing the services for us, these companies may access your personal information, and are required to use it solely as directed by us for the purpose of our requested service.

Therefore, please note that we may transfer your data abroad in accordance with Art. 9 PDPL and other applicable data protection laws. By approving you will be given explicit consent for sharing your data abroad under this article.

RETENTION OF YOUR PERSONAL DATA

Wordylla stores personal data in accordance with the scope of business for the purpose of processing personal data. For the security of stored personal data, all kinds of technical and administrative measures foreseen within the scope of KVKK and GDPR are taken. Personal data is stored until the end of the period required by the relevant legislation, in case the purpose and/or reason for processing has disappeared, taking into account our legal and legal obligations. When the purpose and reason for the processing of personal data ceases, personal data will be destroyed when the statute of limitations required to fulfill our obligations arising from the law is completed.

CHILDREN UNDER 16

Considering the actual difficulty of tracking children on the Internet, the traffic in question must be carried out under the supervision of the parents and in cases where explicit consent is required for the processing of data, explicit consent must be given by the parents. Our services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. In order to request the deletion of personal data, for any reason, please contact us.

CHANGES TO THE POLICY

We reserve the right to change this Policy at any time. If we decide to change this Policy, we will post those changes on this page and update the date at the top of the page Changes will be effective when published and in-game change notification will be madePlease check this page on a regular basis so that you remain aware of what information we collect and how we use it.

OPTING OUT OF TARGETED ADVERTISING AND TURNING OFF OF PUSH NOTIFICATIONS

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and turning off “Allow Apps to Request to Track” or selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of Interest Based Ads" (Android).

We may occasionally send you push notifications through our mobile applications to send you game updates, high scores and other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

USER’S RIGHTS ACCORDING TO PDPL

Everyone has the following rights in accordance with Article 11 of the PDPL;

1. Learning whether personal data is processed or not,

2. Requesting information on personal data if it has been processed,

3. To request information on the purpose of processing personal data and whether they are used in accordance with the purpose,

4. Knowing the third parties to whom personal data is transferred in the country or abroad,

5. Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

6. To request the deletion or destruction of personal data in the event that the reasons requiring its processing have disappeared, although it has been processed in accordance with the provisions of the PDPL and other relevant laws, and to request the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

7. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

8. To request the compensation of the damage in case of loss due to unlawful processing of personal data.

You can send us your requests within the scope of Article 11 of the PDPL, which "regulates the rights of the person concerned". Requests will be evaluated and decided free of charge as soon as possible and ultimately within thirty (30) days at the latest. In case the evaluation and decision-making process requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be taken as the basis.

USER’S RIGHTS IN THE EUROPEAN COUNTRIES

We are a data controller with respect to any personal information collected from individuals accessing or using our services. If you are located in the European Union, European Economic Area, United Kingdom, or Switzerland, you have the following data protection rights:

The Right of Access / The Right to Know You may request a copy of your personal information in our files without undue delay and free of charge, unless we are permitted by law to charge a fee. You may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller,” where technically feasible.

The Right to Rectification You may request to correct or update any of your personal information in our files.

The Right to Deletion You have a right to have your personal information in our files deleted.

The Right to Restriction You have the right to restrict our processing of your personal information.

The Right to Object You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests.

Automated Individual Decision-Making, Including Profiling You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

Please contact us to exercise your above rights,

USER’S RIGHTS IN THE CALIFORNIA

For players in California: The California Consumer Privacy Act ("CCPA") gives residents of the US state of California the right to prevent businesses from selling their personal information to third parties. Please see the THIRD PARTY SERVICES AND DATA COLLECTED FROM THIRD PARTIES section for more information on how we work with our advertising partners. Sharing information in this way may be considered “selling” for the purposes of the CCPA. We do not “sell” your personal information to third parties for any other purpose. If you would prefer that your personal information is not shared with third parties for this purpose, you can submit a “Do not sell my personal information” request to contact@wordylla.com.

If you are a California resident, you may be able to exercise additional rights granted by California law in relation to your personal information that we process (subject to certain limitations).

CONTACT INFORMATION

If you have any questions, comments or concerns about this Policy, please contact us at contact@wordylla.com (or contact form https://www.wordylla.come/en/contact )

Data Controller: R. Volkan Özcan

E Mail: contact@wordylla.com

Website: https://www.wordylla.com