1. The collection of your personal data and the purposes of processing

Asey collects your personal data automatically whenever you download our Services to your device or play the Services, whenever you send us your feedbacks or convey your information or support requests directly to Asey or interact with third party advertisements presented in our Services or interact with Asey advertisements presented in other platforms. In general, the information we collect about you relates to your device and helps us to identify your device. Asey also collects data from the Apple App Store and Google Play App Store (“Platforms”) platforms and the business partners mentioned in the section 3.

Personal data that is collected while you are installing and playing our games

When you download and/or play our games via Platforms, we collect certain personal data from you and/or your device. In this respect, we collect your advertising ID (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), device identifier, operating system, model, producer information, hardware type, operating system version, memory usage, country, time zone and preferred language information, internet protocol (IP) number, location information according to your IP address, operator and browser information, information about properties of mobile application through which a consumer interacts with the Services, data regarding your in-game interactions (the time you spent while playing our games, your in-game expenses, level information, the amount of time for watching advertisements, the advertisements watched) and time of installation and first opening of the application.

The aforementioned advertising IDs (IDFA and GAID) are unique identifiers for mobile devices that advertisers use for personalized advertising.and consistent across all mobile applications and thus allow cross-app tracking. You may disable this option by activating “limit advertisement tracking” from the privacy settings of Apple devices. As for the Google Android devices, you may change your advertisement setting by activating the “disable advertisement personalizing” option. Advertising IDs, are non-permanent identifiers, which are uniquely associated with your device.

We would like to remind that you have an option to play our games without watching advertisements by using our no-ads feature, which is subject to a fee.

Your usage data and data regarding your device which stated in detail above, are processed for the purposes of providing our Services, conducting analysis and measurements regarding your usage, enhancing and improving user experience, providing advertisements that may draw your attention for your interests and behaviours, improving and updating our games and solving issues about our Services and fulfilling your requests.

Your user name and score can be viewed by other users in our games that include a scoreboard feature.

Payments for in-app purchases are being carried out by the Platforms. Asey, does not collect personal data such as your name, surname, credit card number and e-mail address that you share with the Platforms for the payment, and only payment information for the items your purchase is being shared with us in order to fulfil your order.

Personal data that is collected when you contact with Asey

• When you contact with us: We may ask for contact information (e-mail) when you request information about our Services, request technical support or contact with us anyhow. Your contact information will be processed for the purposes of fulfilling your requests and communicating with you.

• Comments: You may share data that contains your personal data when you share your comments and views about our Services. The content of user comments is composed fully of data that you voluntarily provided. We process your shared personal data to solve the issues you encountered and to fulfil your request.

Data that is collected by third parties

Our business partners or service providers can use server log files, cookies, pixel labels, web beacons or other tracking tools in our Services. Our advertisement business partners and analytics service providers mentioned in the part 3 below, can collect data regarding your IP address your advertising identifier (IDFA for IOS devices and GAID for Android devices), other device identifiers (IDFV for IOS devices), cookie identifiers, advertisement ID, your mobile device’s type, operating system, version, model, hardware type, other device identifiers that are automatically determined for your device when you connect to the internet, web browser information, websites you visited, connections you have within the Services and your preferences about the visited websites by using the stated technologies. You may access to the privacy policies of these third parties from the section 3.

Asey stores your data for as long as it is necessary to provide our Services and deletes it when the purposes of the data processing cease to exist. Personal data is deleted in case the reasons which necessitate processing within the context of the stated purposes in this privacy notice cease to exist and after two (2) years as of the registration date of the relevant record at the latest.

2. The legal grounds of processing your personal data

The legal grounds that Asey relies upon while processing your personal data are the following:

• Explicit consent
• Being necessary for the establishment, exercise and protection of any right
• Being necessary for Asey to fulfil its legal obligations as a data controller
• Being necessary for the establishment and execution of an agreement
• Without prejudice to your fundamental rights and freedoms, being compulsory for Asey's legitimate interests

In data processing activities where your personal data is processed based on the explicit consent, you have the right to withdraw your consent at any time.

Asey's legitimate interest in processing your device and usage data is for analysing, measuring and reporting related to the use of games and for enhancing and improving your user experience. By virtue of the analysis and measurement activities, we are able to provide our Services more efficiently and effectively, to carry the user experience to higher levels and to provide our Services to our users free or for low costs.

3. The transfer of your personal data

Your personal data may be transferred to our business partners and service providers located abroad for the purposes of improving our Services and providing our Services to you, providing personalized advertisements according to your interests, measuring Asey's and third parties’ advertisement effectiveness and carrying out measurements and analysis regarding your use of our games. In case a public institution is authorized to request personal data by the law, your personal data can be transferred to such authorized public institution in accordance with the applicable personal data protection legislations. Requests from judicial authorities will also be fulfilled in accordance with the applicable legislation.

Your personal data may be transferred to our business partners and service providers stated below:

Analytics services. Your personal data may be transferred to our service providers and business partners for the purpose of conducting analytical reviews, analyses, reporting and research activities regarding the use of our Services.

Cloud computing services. Your personal data is stored in the servers of the Amazon Web Services and Google.

Advertisement business partners. Your personal data may be transferred to our advertisement partners who enable our Services to be provided free or for low cost.

You may find the list of our service providers and business partners and their privacy policies below:

Service provider/Business Partner	Privacy Policy
Analytics services
Adjust	https://www.adjust.com/terms/privacy-policy
Facebook	https://www.facebook.com/about/privacy
Google LLC (Firebase)	https://firebase.google.com/support/privacy
SafeDK	https://www.safedk.com/privacy
Cloud computing services
Amazon Web Services Inc.	https://aws.amazon.com/privacy/
Google LLC (Google Cloud Platform)	https://cloud.google.com/security/privacy/
Advertisement business partners (advertisement networks)
Facebook Inc. (FB Ads, FB Audience Network)	https://www.facebook.com/about/privacy
Google LLC (Google Ads)	https://policies.google.com/privacy
ironSource Ltd.	https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Unity Technologies (Unity Ads)	https://unity3d.com/legal/privacy-policy

4. Your Rights Regarding the Protection of Your Personal Data

As per the relevant legislation, you have the right to; (i) learn whether or not your personal data is processed, (ii) request information as to processing if your data is processed, (iii) learn the purpose of personal data processing and whether the personal data is used in accordance with such purposes, (iv) know the third parties to which your personal data is transferred domestically or abroad, (v) to request correction if your personal data is incompletely or incorrectly processed,(vi) to request deletion or destruction of your personal data,(vii) To request the transmission of your correction, deletion and destruction requests to third parties to whom your personal data has been transferred, (viii) to object to any consequence occurred against you by analyzing your processed data through automated systems (ix) request compensation in case you incur any damage due to the unlawful processing of personal data., (x) request restriction of data processing activities, (xi) request data portability, (xii) object against personal data processing, and (xiii) to lodge a complaint with the relevant data protection authority.

You may submit all your claims and questions with respect to such rights to privacy@aseygames.com. Your requests will be answered as soon as possible and within thirty days at latest.

ASEY GAMES BİLİŞİM YAZILIM VE PAZARLAMA TİCARET ANONİM ŞİRKETİ

Mersis No: 0086129248200001