Privacy Policy

We at PAPIGAME ELEKTRONIK HIZMETLER VE TICARET LTD. STI. ("Papi Game", "we", "us" or

"our") respect your privacy and recognise the importance of providing a secure environment

for your personal data. Therefore, we are committed to being transparent about how we collect and process your

personal data.



The purpose of this privacy notice ("Privacy Notice") is to inform you as a user about why

and how we process your personal data (that is any information that can be linked or attributed to you,

"Personal Data") when you play our games and visit

www.papigame.com ("Website"). This includes information

regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in

relation to the processing.



This Privacy Notice applies whenever you visit our Website or play a game from our Website or use any of our

other services, all of which together we refer to as "Services".



In this Privacy Notice, we will give you general information about how we

process your Personal Data. We will furthermore give you more detailed information

on the processes within our Services.



GENERAL INFORMATION



In this part of our Privacy Notice, you will find general information about how we process your Personal

Data when you use our Services. For specific information with more details about our processing activities,

please see the service specific information below.



Who is responsible for the processing of your Personal Data



Cumhuriyet Mah. D-100 Karayolu Cad. Adm

Konaklama Outlet Park Avm No: 374 IC Kapi No: 63

Buyukcekmece / Istanbul / Turkiye is responsible

("the data controller") for the processing of your Personal Data in Papi Game.





What types of Personal Data do we process and how do we collect it?



When you use our Services, we collect, use, store and transfer different kinds of Personal Data. As a general

principle, we do not collect and do not ask you to provide any "special categories of Personal Data", which

is any particularly protected information such as data concerning health, religion, political opinions or

philosophical beliefs, sexual preferences or orientation.



The information we collect depends on which of our games or Services you use and how you use them. We

process the following types of your Personal Data:



Personal Data provided by you



When you use our Services, you provide or be asked to give us certain information, including:





  • Game ratings:


    We collect rating information if you use the voting button on our Websites.


  • Favorite games:


    You have the option to easily access your favorite games.


  • Like/Dislike Button:


    We collect the data when you click like or dislike buttons to suggest games to you accordingly.


  • Your account information:


    On our Website, you have the option to sign up for an account. If you choose to

    create an account, we collect your log-in data (your email address, username and password).


  • Information provided in relation to our customer service:


    When you contact support, we collect information about your request

    (subject and content of your request) and your contact details.





Personal Data we receive or generate from your use of our Services



When you use our Services, we also process device-related information and information about how you interact

with our Services, including:





  • Technical information:


    We collect information about your device/device settings you use for the purposes

    described below. The information we obtain from your devices includes the type of your device, online

    identifiers (your IP address), device IDs, game/site ID, geolocation data (based on your IP address),

    browser settings, screen resolution and other technical information.


  • Cookie data:


    As further described in our Cookie Notice ("Cookie Notice"), we use cookies and similar

    technology such as pixels or local storage and allow third parties to use cookies and similar technology

    for the purposes described below. The exact process of placing cookies, and the scope of the data that may

    subsequently be processed is set out in our Cookie Notice.


  • Your usage:


    We collect information about how you use our Services. This information includes your

    preferences
    , such as your interests in certain categories of games, the actions you take, the time and

    duration of your activity. Based on the time that you spend while playing the games, you will earn points

    and badges. Furthermore, we collect information about the websites that led you to our Website.





Personal Data we collect from other third parties



In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with

applicable data protection laws and regulations. Your Personal Data be provided by the following third parties:





  • Social Networks and connected third-party platforms:


    If you choose to connect our Services with Facebook or Google account by using your credentials

    with our log-in process, we receive certain information about you from Social Networks such as your

    public profile, first and last name, your profile picture, your email address, and your authentication token.


  • Other third parties:


    We also receive information about your approximate geolocation (the country you are

    located in) from third parties (e.g. Google). We use this information to comply with our legal obligations

    applying to the processing of your Personal Data, customize certain services to your location, and for

    fraud or abuse prevention purposes.



To learn more about which data is processed, please see the section with service specific informationbelow.



For What Purpose we process your data?



Depending on which Services you are using and which privacy settings you have selected, we process your

Personal Data for the following purposes:



Provision and improvement of our Services





  • to allow you to play our games, including third-party games available on our Website




  • to allow you to use our Services




  • to create and manage your account




  • to restore your account if you ever lose access




  • to communicate with you in context of account activation, password management




  • to simplify the registration process




  • to facilitate content sharing on social networks




  • to provide technical support and respond to your requests




  • to identify and correct any bugs/errors




  • to indicate the popularity of our Services




  • to assess the quality of our Services




  • to understand and improve your online experience




  • to aggregate financial reports to pay our business partners




  • to pay our business partners for the promotion of our Services





Personalization of your game experience





  • to remember your preferred game settings




  • to show you your preferred games




  • to recommend games you may like based on your preferences




  • to personalize advertising for you




  • to remember you next time you visit our Services





Marketing and analytics





  • to deliver (targeted and non-targeted) advertising in our Services




  • to pay our business partners for the promotion of our Services




  • to measure the effectiveness of advertising




  • to send you marketing communications, informing your about new content and in-game offers




  • to acquire new users on social media platforms





Prevention of fraud and illegal activity





  • to investigate fraud and illegal behaviour




  • to enforce our policies and terms of use





Compliance with our legal or regulatory obligations





  • to determine the legal requirements for processing of your Personal Data (based on your location such as your country)




  • to respond to your requests related to your data subject rights




  • to comply with our legal obligations (e.g. tax and accounting obligations)




  • to inform you about any changes to this Privacy Notice





Please see the section with service specific information below. for a more detailed description of the

purposes for which we process your Personal Data.



Do we engage in profiling activities?



If you consent to this via the cookie consent pop-up, We use tracking mechanisms to track your Personal Data

for profiling purposes. This allows us to serve relevant content to you and adjust our services and ads to

your interests. You have the right to object to this type of processing. You can also go to your privacy settings

to review and amend your privacy choices related to this type of processing at any time.



On Which legal basis do we process your Personal Data?



We process your Personal Data for the purposes described in this Privacy Notice, based on the following legal grounds:





  • Your consent:


    We process your Personal Data if you have provided your consent for a specific purpose. For

    example, when you use our Services for the first time, we ask for your consent for the data processing in

    context of sending newsletters, personalized advertising, analytics, profiling, social media and games

    from external publishers. We also show you just-in-time contextual notifications and consent pop-ups to

    obtain your consent for further processing activities. You have the right to withdraw your consent at any

    time, for example by changing your privacy settings. Please note that this will not affect any processing

    carried out before you withdraw your consent.


  • Performance of a contract:


    We process your Personal Data for the performance of a contract to which you

    are a party, for example, in the context of customer service, where it is necessary for the creation and

    administration of your account, to support the operation of our games or facilitate the delivery of

    requested services.


  • Compliance with legal obligations to which we are subject:


    We process your Personal Data tocomply with legal obligations. for example,

    for tax and accounting purposes or legal disputes.


  • Legitimate interests:


    We also process your Personal Data to the extent that the processing is

    necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect

    your privacy. For example, we process your Personal Data for improvement of the service provided to you or

    to provide you with a better user experience.





Please see for additional information the section with service specific informationbelow.



With whom do we share your Personal Data?



We will not disclose your Personal Data to any party who is not authorised to process them. To manage our

services, we will share your Personal Data internally with members of our responsible departments and

technical support involved in the gaming process and in each case only if access to your Personal Data is

necessary for the performance of their roles.



Moreover, and only when necessary to fulfil the purposes mentioned above, we disclose your Personal Data to

the following recipients or categories of recipients or allow the following third parties to collect your

Personal Data in connection with your use of our Services:





  • External service providers:


    We share your Personal Data with external service providers who

    perform

    services on our behalf, like IT services, hosting and content delivery services, web/social analytics

    services, data management services, video hosting service, and user notification services. Where we share

    your Personal Data with external service providers, we have appropriate agreements in place to ensure that

    your Personal Data is processed in compliance with applicable data protection laws.


  • Third-party game Distributors:


    On our Websites, we offer games from third-party game distributors.

    By playing a third-party game, yourPersonal Data can be processed by the third-party game distributors

    (directly or through the use of cookies or similar technology). Please note that by choosing third-party

    games, you will be able to play the game in the third-party game developer's environment over which we

    have no control. We only receive anonymized statistics and revenue reports from third-party game

    distributors. We therefore advise you to check the privacy policies of any such game distributor before

    starting the game. Furthermore, you can find the third parties your Personal Data may be processed by

    playing our games or Websites in the following link: 3rd Party list.


  • External advertising companies:


    With your consent, we share your Personal Data with third-party

    advertising companies or allow third-party advertising companies to collect your Personal Data when you

    use our Services. If you choose not to receive personalised ads at all, we will still show you ads, but

    they may not reflect your interests as those ads will be content specific and not user specific. Please

    note that by clicking on a third-party advertisement, you are redirected to the third-party advertiser's

    environment over which we have no control.


  • Connected third-party platforms:


    We have included a Facebook and Google button and pixel on our website

    to enable users to integrate with their social media profiles as and when they see fit to do so. Such

    parties may capture some of your data that way. These parties are controllers of the data for their own

    purposes. Learn more about our marketing activities in the service specific section below..


  • Law enforcement, government authorities or courts:


    We disclose your Personal Data in response to

    lawful

    requests to public authorities, including law enforcement, government authorities, or courts.


  • Other third parties:


    We also disclose your Personal Data in the event of any contemplated or

    actual

    reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any

    portion of our business or assets (including in any insolvency or similar proceedings).





Please see the section with service specific information below for more information about the third parties

we may share your data with. Furthermore, you can find the third parties your Personal Data may be shared

with by clicking on the following link:[Papi Game Third Party Partners List]



Where will my Personal Data be processed?



In general, Your personal data is stored on servers within the European Union (EU) / the European Economic Area (EEA).



However, your data may also be shared outside the EU / EEA. Some of the non-EEA countries are recognized by

the European Commission as providing an adequate level of data protection according to EEA standards (the

full list of these countries is availablehere).



For the transfer of Personal Data from the EEA to countries not considered by the European Commission to

provide an adequate level of protection, we have taken appropriate measures, such as standard contractual

clauses adopted by the European Commission, to protect your Personal Data. You can obtain an overview of

these measures by clickinghere.



We are aware of theruling of the EU Court of Justice of 16 July 2020 with implications for the transfer of



Personal Data. We are currently investigating how best to absorb and adapt to the consequences of



this ruling. Privacy is very important to us and we will take all reasonable measures to find an appropriate



solution. Once we have developed an appropriate solution, we will inform you via this Privacy Notice.



How do we protect your Personal Data



We have implemented appropriate technical and organizational security measures designed to protect your

Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure

or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps

to assure that third parties to whom we transfer your Personal Data provide sufficient protection of

Personal Data.





How long do we store your Personal Data?



We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was

collected or to fulfil our legal obligations or necessary for the establishment, exercise of defence of legal

claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please seebelow for

information about how long we will retain your Personal Data. Additional information on how long your

Personal Data is stored by our service partners can be found in the respective third-party list available here.





What are your rights in respect of your Personal Data?



To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:




  • Access the Personal Data we hold about you


  • Request the update or correction of your Personal Data


  • Receive your Personal Data in a structured, commonly used and machine-readable format


  • Request the deletion of your Personal Data


  • Restrict the processing of your Personal Data


  • Withdraw your consent





Right to object



In the event and to the extent that we process your Personal Data based on our legitimate interests, you

have

the right to object to the processing on specific grounds relating to your particular situation. In such

cases

we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing

which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal

claims.



You also have the right to object where we are processing your Personal Data for direct marketing purposes

(including profiling). In such a case, we will stop processing your Personal Data for marketing

purposes.



You can exercise these rights by sending a request to the contact details set out

below, providing your name,

your email address as well as a description of your request.



How can you contact us?



If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our

customer support support@papigame.com or our Data Protection Officer via

e-mail to info@papigame.com.



Please specify in your request, insofar as possible, to which Personal Data your request relates and what

right you wish to exercise, and provide evidence to demonstrate that you are the individual to whom the

Personal Data relates. We aim to respond to your request within a period of one month.



Queries, comments, or complaints



If you have any questions, comments, or complaints about this Privacy Notice, please feel free to contact us.

If you believe we have not complied with our obligations under applicable data protection laws and

regulations, you can lodge a complaint with a competent data protection authority, for example, the

istanbul Adliyesi in the Turkiye.



How often do we update this Privacy Notice?



We regularly review and update this Privacy Notice. When there is an important change that will have a

relevant impact on the processing of your Personal Data, we will inform you by email if we have your email

address. If we do not have your email address, for example because you did not create an account, we will

inform you with a banner on our Website.





This Privacy Notice was last updated on:18/10/2022



SERVICE SPECIFIC INFORMATION



In this part of our Privacy Notice, you will find specific information on how your Personal Data is

processed. For general information about data processes that apply, please seeabove.



Hosting and content delivery



Papi Game is hosted by external companies providing web servers and web content delivery. Every time you make a

request, for example by clicking on a link on our platform, the information allowing this request (e.g.

device information and information on requested content) as well as online identifiers (your IP address)

will be sent to the external servers. This data is used to show you the content you requested in a faster

way. We process this data on the basis of our legitimate interest, to provide and improve our service and

ensure its functionality.



Creation/administration of your account



In our Website, you have an option to create an account. We store your log-in data (your username, email

address and password account ID, account creation technical details (e.g. time of account creation)) to

allow you to log in on different devices, based on the performance of a contract.



If you choose to register using your e.g. Facebook or Google account, or enter our Website from a

third-party platform (e.g. Facebook or Google), we receive certain information about you from the respective

third-party provider like e.g. your name, your profile picture, your email address, and the authorization

token. This information will be stored in your Papi Game account.



Your account data will be stored for as long as your account exists, based on the performance of a

contract. You can delete your Papi Game account at any time, for example by submitting a deletion request to our

support team or by contacting our Data Protection Officer.



Google Button



Our website also employs the Google Button, which is operated by Google Inc., 1600 Amphitheatre Parkway,

Mountain View, CA 94043, United States (Google). The link can be identified by the "SIGN IN WITH GOOGLE"

symbol against a white or color background.



We're offering you the opportunity to sign up for our Services through Google Button. In order to do this,

you will be redirected to Google where you can log in using your Google user data. Your Google account will

then be linked to our Services.



Depending on your Google settings, linking your account will allow the following data to be transmitted to

us and/or retrieved by us: email address and other data that you have set to the public on your Google

profile.



We shall only use this information for identification purposes and contract processing. For more

information on Google and the privacy settings, please refer to the Privacy Policy and Terms of Use of

Google Inc.



The purpose and scope of data collection via Google, the processing and use of such data, as well as your

rights thereof and personal settings regarding privacy protection can be found in the Google privacy

settings section

https://policies.google.com/privacy?hl=en-US



If a user is a Google member and does not wish to have their data collected and linked to their saved

Google member data via our web presence, the user must log out of their Google Plus account before visiting

our websites.



You can unlink the accounts at any time and revoke the transfer of data with future effect by changing your

settings on Google (here).



Customer service



If you contact us for customer support by using your name and email address, we will process the content of

your request in order to provide you with support. The request history helps us to solve a newer request and

is stored to defend possible future legal claims. We process this data on the basis of performance of

contract to provide you with customer support, and store this data on the basis of our legitimate interest,

to improve our services, and to be able to defend possible future legal claims.



Analytics



We use analytics services to understand which features you like in our Services and how popular our games

are on social media and to monitor traffic on Papi Game, for example following changes to the website. For this

purpose, we process information about your device, request data (including the URL of the current webpage

and the website visited before) and special event data (for example if you share a link with your friends in

the social media platform). We also process your full IP address to allow us to better understand how you

use our Services and to improve our games and websites.



By activating IP anonymisation on this Website, the IP address is shortened prior to transmission within

the EEA or in other states party to the Agreement on the EEA.



We process this information based on your consent, provided in the consent pop-up which will be shown to

you when you access Papi Game for the first time.



Game distributors



On Papi Game, we offer Games from third-party game distributors which process your Personal Data. As also

explained in the general information part, in that case you will play the game in the third-party game

developer's environment over which the third party is in control. It is the third-party game distributors

that processes your data when you play their game and who should therefore obtain your valid consent. We

only receive anonymized statistics and revenue reports from third-party game distributors.



We therefore advise you to check the privacy policies of any such game distributor before starting the

game. Furthermore, you can find the third parties your Personal Data may be processed by playing our games

in the following link: 3rd Party list.



Last played games



To make your game experience more convenient, we will show you the 3 games you last played. This

information will be stored locally on your device and will be deleted when the browser cache is cleared

manually or automatically. We process this information based performance of a contract to provide you with a

convenient user experience.



Advertising



On our Website, we show advertising from different advertising companies. These adverts can be personalized

or non-personal content related ads. In order to show you personalized ads and only if you have provided

your consent, we will share your Personal Data (your IP address, advertising identifiers and the information

that you have provided your consent for personalized ads) through our advertising platform provider with

third-party advertisers and ad networks.



We also use this information to measure how effective these ads are. In our consent pop-up which will be

shown to you the first time you enter our Website, you can choose from which advertising company you would

like to receive personalised ads or choose not to accept receiving personalised ads at all. You can adjust

your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all,

we will still show you ads, but they may not reflect your interests as those ads will be content specific

and not user specific.



Data management platform



Based on your consent, we process your Personal Data to show you relevant games and ads, based on the

information about the games you are playing on our Website. For this purpose, your device information, IP

address and information about the category of the game you played is collected and sent to an external data

management platform provider.



Rating function



You can rate the games on our Website, by choosing a thumbs up or thumbs down icon. It is in our legitimate

interest to provide our users an overview which games are most popular and best rated. When you click on a

rating button, we will store the aggregated voting data. The result of all the submitted ratings is used to

generate a score between 1 and 5 for each game. In addition, a local text file will be stored to prevent

multiple ratings for the same game. We will store this data in your browser's local storage and we will not

share this data with other partners.



Recaptcha



We use Google reCAPTCHA from Google Inc. (1600 Amphitheater Parkway Mountain View, CA 94043, USA) to

prevent spam.



The legal basis for use is Article 6 (1) f (lawfulness of processing), as there is a legitimate interest in

protecting this website from bots and spam



reCAPTCHA is a free service that protects websites against spam and abuse. It uses advanced risk analysis

techniques to keep people and bots apart. With the new API, a significant number of your valid human users

will pass the reCAPTCHA challenge without having to solve a CAPTCHA. We use reCAPTCHA to secure forms.



By using reCAPTCHA, data will be transmitted to Google using Google to determine whether the visitor is

human or spam. To see what data Google collects and what this data is used for, visit

https://policies.google.com/privacy?hl=en-AT.



Further documentation can be found here:

https://developers.google.com/recaptcha/,

https://www.google.com/recaptcha/admin/create



Third parties:



If you click here, you will see

an overview of the third parties we may share your

Personal Data with, or that may share your Personal Data with us.