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PRIVACY POLICY


(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.