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Privacy policy


PRIVACY POLICY AND PERSONAL DATA

Unipoly Games This Privacy Policy and Personal Data Text (Policy) is prepared for the purpose of informing Data Subjects on terms and conditions regarding the use of the data collected or to be collected and the ways in which the data is processed from Data Subjects in any method and/or Users accessing applications that they can install on their devices through https://unipolygames.com/ domain website and virtual stores and/ or the persons who visit the Website managed and operated by Unıpoly Yazılım ve Teknoloji Anonim Şirketi (Unipoly or Company).

Definitions and General Explanations

Terms used herein shall have the following meanings:

Website: The website “https://unipolygames.com/” owned by Unipoly or the website operated by Unipoly under another domain name.

Application(s): Applications released by Unipoly that Users install on their devices through virtual stores,

Platform: Separately or together, Website and Application,

Visitor(s): Person who uses the Website without creating an account, and/or who visits the Website,

Player(s): Person who accesses the Application by creating an account

User(s): Separately or together, Visitor and Player,

Data Subject(s): Separately or together, Visitor or User whose personal data is processed,

User(s): Terms of Use on the Platform that Data Subjects have accepted by accessing the Platform.

Unipoly adopts this Policy regarding the confidentiality, use and other related issues of the information processed regarding Data Subjects. Personal data refers to all the information relating to an identified or identifiable natural person. For this reason, provisions regarding personal data in this text will be applied if the relevant information belongs to a natural person. If the relevant information belongs to a legal person, provisions apart from provisions related to personal data in this text shall be applied. Unipoly regards the confidentiality of data and takes care to be transparent about the storage of information. This Policy is the privacy policy that covers information about what kind of data is collected, how this data is used, with whom this data is shared, if necessary, what are the rights regarding personal data and how these rights can be exercised and the principles adopted by Unipoly relating to confidentiality. Platform may contain links to other websites unknown to Unipoly, whose content is not checked. These linked websites may contain different terms and conditions than texts belonging to Unipoly. Unipoly cannot be held responsible for the use or disclosure of information that these websites may process. Likewise, Unipoly will not have any liability when a link is provided to Unipoly’s Platform from other websites.

Personal data is processed in accordance with the following principles:

  • Lawfulness and fairness,
  • Being accurate and keeping up to date where necessary,
  • Being processed for specified, explicit, and legitimate purposes,
  • Being relevant, limited and proportionate to the purposes for which they are processed,
  • Being stored for the period laid down by relevant legislation or the period required for the purpose for which the personal data are processed.

Enlightening/Informing the Data Subject

With this Policy, Unipoly aims to enlighten/inform the natural persons whose data will be processed during the acquisition of personal data on the following aspects:

  • The identity of the data controller and of its representative, if any,
  • The purpose of data processing,
  • To whom and for which purposes the processed personal data may be transferred,
  • The method and legal basis of collection of personal data,
  • The rights of Data Subject.

In this context, Unipoly aims to make the necessary clarification. Unipoly is the data controller in accordance with the Law only for the personal data of the Data Subjects, whose purposes and legal causes are clearly stated in this Policy.

  • Collection of Personal Data, Method of Collection and Lawful Basis

Information that Data Subjects send to, share with Unipoly and/or store in an accessible form while using the Platform, and information that is collected by automatic means through Platform, may be included in the scope of personal data. If you access the Platform, we collect the following information about you:

  • Identity and contact information:

Name-surname, username as identification information and e-mail address as contact information are optionally processed by you accessing the Raidfield Application. In addition, you will be able to share their name-surname, username and e-mail address information to convey your requests/complaints with Unipoly.

  • Usage data:

When you access the Platform, usage data is collected about you. These data may include you visiting the Platform, what you click on, when you perform these actions, etc. Also, like many websites today, our network servers keep log files; these files save data every time a device accesses them. Log files contain data on the nature of each access, such as source IP addresses, internet service providers, files displayed on your site (e.g. HTML pages, graphics, etc.), operating system versions and timestamps.

  • Device data:

Data such as your IP address, operating system version, device type, system and performance information, and browser type are collected from the devices and applications you use to access the Platform.

In Applications where this feature is provided, you can save the progress you have made in the Application to the accounts of application stores such as Facebook, Apple ID, Instagram and they can continue from the progress point on another device by connecting accounts of the application stores such as Facebook, Apple ID, Instagram to the Application on another device and transferring this progress. In this context, the privacy policies/notices of the related application stores shall be applied in addition to this Policy to personal data processed by those application stores. If you make an in-app purchase, your payment information is not shared with Unipoly by the virtual store you purchased from. Unipoly does not process your payment information and other information related to your payment (card number, account number, etc.) in any way. In the case of such in-app purchases, the terms and conditions of the related application stores such as AppStore, Play Store etc. shall be applied.


  • Data Categories and Data Types
Player Identity Name surname, Username
Contact E-mail Address
Location General Location Data(Country)
Social Media Accounts Facebook, Apple ID, Instagram account information
Customer Transaction Application progress and information of level within the games, Metamask Wallet data
Process Security Data collected through pc/e-mail/system and application user transaction information, internet traffic data (network movements, IP address, visit data, time and date information) device name, in-app purchase history, the identifier for advertisers designated in your mobile device used in accessing our services (if you give permission, the Identifier for Advertisers-IDFA), the identifier for vendors/developers designated your mobile device (The Identifier for Vendors-IDVF)
Marketing Data IDFA, IDVF
Visitor Process Security Data collected through pc/e-mail/system and application user transaction information, internet traffic data (network movements, IP address, visit data, time and date information)
Location General location data (country)
  • Lawful Basis

Your personal data may be processed for the purposes that are the subject of your disclosure to Unipoly and for the purposes listed below in terms of each data category, in accordance with the relevant legislation. The lawful basis for each data category are explicitly stated below:

Player Identity Information
Contact Information
Social Media Accounts
Location
• Processing is necessary for the establishment, exercise or protection of any right
• Processing is necessary for our legitimate interests, provided that the fundamental rights and freedoms of data subjects are not harmed
• In situations where it is necessary to process the data subjects’ personal data, in order to build a contractual relationship or processing is directly related to the execution or performance of the agreement.
Marketing Data •Your explicit consent
Customer Transaction • In situations where it is necessary to process the data subjects’ personal data, in order to build a contractual relationship or processing is directly related to the execution or performance of the agreement
Process Security • Processing is expressly provided for by the laws
• Processing is necessary for our compliance with a legal obligation
Visitor Process Security • Processing is expressly provided for by the laws
• Processing is necessary for our compliance with a legal obligation
Location • It is necessary to process your personal data for our legitimate interests, provided that your fundamental rights and freedoms are not harmed.
• Processing is necessary for the establishment, exercise or protection of any right.
  • For What Purposes Your Personal Data Is Processed

The information collected by Unipoly can be used collectively in various ways in order to provide services to you by Unipoly, to optimize and improve the services, and to improve the service offered to those who access the Platform through this database by enriching the database. Unipoly may use this information for website and application management, security, research and analysis. Within the scope of this text, Data Subjects’ personal data is processed for the following purposes in compliance with the general conditions specified above:

Player Identity Information
Contact Information
Social Media Accounts
• Carrying out the activities in accordance with legislation
• Conducting of company/product/service loyalty operations
• Conducting / audit of business activities
• Conducting after-sales support services for goods/services
• Conducting of customer relationship management processes
• Conducting activities for customer satisfaction
• Monitoring requests / complaints
Location • Execution of company/product/service commitment operations
• Conducting storage and archive activities
• Execution of agreement processes
Marketing Data • Conducting marketing analysis studies
• Execution of advertising/campaign /promotion processes
Customer Transaction • Conducting / audit of business activities
• Conducting after-sales support services for goods/services
• Conducting of good / service sale process
• Conducting of agreement processes
• Conducting business continuity
• Monitoring requests / complaints
Process Security • Conducting of information security processes
• Carrying out the activities in accordance with legislation
• Conducting of supervision / ethical activities
• Conducting of access authorization
• Conducting / audit of business activities
• Conducting business continuity
• Informing authorized person, authority and organizations
Visitor Process Security • Conducting of information security processes
• Carrying out the activities in accordance with legislation
• Conducting of supervision / ethical activities
• Conducting of access authorization
• Conducting / audit of business activities
• Conducting business continuity
• Informing authorized person, authority and organizations
Location • Execution of company/product/service commitment operations
• Conducting storage and archive activities
• Execution of agreement processes

Every time you visit the Platform, your IP address, operating system, connection time and duration information and similar information are automatically recorded. It is possible to use this information anonymously, which is obtained without the need to take your consent.

  • Technical and Administrative Measures

Unipoly stores the personal data it processes in accordance with relevant legislation for periods stipulated in relevant legislation or required for the purpose of processing. Unipoly undertakes to take all necessary technical and administrative measures and to take the due care to ensure the confidentiality, integrity and security of personal data. In this context, it takes the necessary measures to prevent unlawful processing of personal data, unauthorized access to data, unlawful disclosure, modification or destruction of data. Accordingly, Unipoly takes the following technical and administrative measures regarding the personal data it processes:

Anti-virus application. On all computers and servers in Unipoly's information technology infrastructure, a periodically updated anti-virus application is installed.

Firewall. The data centre and disaster recovery centres hosting Unipoly servers are protected by periodically updated software-loaded firewalls; the relevant next-generation firewalls control the internet connections of all staff and provide protection against viruses and similar threats during this control.

User identifications. Unipoly employees' authorization to Unipoly systems is limited only to the extent necessary by job descriptions; in case of any change of authority or duty, systemic authorizations are also updated.

Information Security Management System (ISMS). At the ISMS meetings made within Unipoly, the topics contained in the control forum are audited monthly by the director of information technology and the director of financial operations.

Physical data security. It ensures that personal data on papers is necessarily stored in lockers and accessed only by authorized persons.

Erasion of cookies. Personal data processed through cookies belonging to third parties from which service is received are deleted from the systems of third parties if the membership is terminated.

In the event that the personal data is damaged as a result of attacks on the Platform or on the Unipoly system, despite Unipoly taking the necessary information security measures, or the personal data is obtained by unauthorized third parties, Unipoly notifies this situation to Data Subjects’ immediately and, if necessary, to relevant data protection authority and takes necessary measures.

  • Transfer of Your Personal Data

Unipoly may transfer the personal data obtained from Data Subject to its domestic or overseas servers or suppliers in order to perform the services provided by Unipoly through the Platform and to fulfill the obligations specified in this Policy. Unipoly may also transfer personal data related to Data Subjects to third parties and for the following purposes:

Subject Purpose of Transfer and Transferred Group
Player Sharing process security information with authorized public institutions and organizations for the purpose of execution of activities in compliance with legislation, monitoring and execution of legal affairs, informing authorized persons, institutions and organizations;
Sharing information with overseas suppliers that storage services are received from, for the purpose of conducting retention and archive activities;
Sharing process security and marketing information with overseas suppliers and business partners for the purpose of conducting marketing activities;
Sharing process security and customer transaction information with domestic or overseas suppliers whose services are used in business processes for the purpose of conducting and auditing business activities;
Sharing customer transaction information with third-party providers in case any transaction is linked to a wallet;
Sharing customer transaction and process security information with Application developers, if any, within the scope of the agreement and the development of the Applications.
Visitor Sharing information with overseas suppliers that storage services are received for the purpose of conducting retention and archive activities;
Sharing information with authorized public institutions and organizations for the purpose of informing authorized persons, institutions and organizations.

In case the Data Subject is a citizen of the European Union, in the event that personal data is transferred to third parties located outside the European Economic Area (EEA) or Turkey, Unipoly takes the necessary security measures by confirming that that (i) the third parties are certified under the Privacy Shield or (ii) the Binding Company Rules approved by the relevant data protection authority are in force or (iii) Standard Contractual Clauses approved by the European Commission have been concluded with the third party.

  • Retention of Personal Data

In the event that the retention and processing conditions for the periods of processing of personal data obtained by Unipoly are ceased, the following criteria are used in determining the destruction periods:

  • If the relevant legislation provides for a period of time for such personal data retention, this period shall be followed. After the expiration of the specified period, the necessary operations shall be performed.
  • If no time is stipulated for the expiry of the period in the relevant legislation or for the retention of the data in question, principles shall be adopted for retention of the information , for example; it is questioned whether Unipoly has a legitimate purpose in the retention of data. Although it has been processed in accordance with the legislation, the data of which reasons requiring its processing are ceased, shall be deleted, destroyed or anonymized.
  • Minor’s Privacy

The Platform provided by Unipoly does not address anyone under the age of majority according to the applicable of such jurisdiction which is the country of the User located. Unipoly does not knowingly collect personally identifiable information from anyone under the age of majority and if you are a parent or guardian and you are aware that your minor has provided the Platform with Personal Data without your consent, you may contact Unipoly through email at [[email protected]]

  • Changes and Updates

As a data controller, Unipoly has the right to change the policy provided that it complies with the relevant legislation and that the personal data are better protected. This Policy can be rearranged and updated as new features are added to digital platforms or new suggestions are received from Data Subjects. However, in this case, we shall notify you by publishing the changes on the Platform. We may notify such changes, in some important cases, by e-mail or by any other conspicuous method reasonably designed to notify you, with additional notices as appropriate. Upon being notified about these changes, if you continue to access the Platform and use or access the Platform without benefiting from the services offered by Unipoly after the notification period, you shall be deemed to have allowed the changes in the Policy. If you do not agree to the terms of this Policy or of an updated privacy policy and personal data text, you reserve the right (if any) to close your account at any time or not to respond to surveys. Therefore, we recommend that you re-examine the policy every time you access to the Platform. This document was last updated on [30/12/2023]. If the Policy provisions change, they become effective on the date of publication.

  • Your Rights as a Data Subject

As data subjects, in order to express your requests regarding your rights and to exercise your rights on your personal data; file your request and take actions such as making necessary changes, updates and/or deleting by sending them to the Company's official e-mail address [[email protected] ] or to Unipoly's address, Esentepe Mah. Haberler Sk. No: 1 İç kapı no: 1 Şişli/İstanbul; with following information:

  • Applicant's name and surname,
  • If the applicant is a citizen of the Republic of Turkey, the Turkish Identity Number, if not, the nationality with passport number or identity number if there is one,
  • Applicant's residence or business address for correspondence,
  • Applicant's e-mail address, telephone or fax number for correspondence,
  • Subject of request,
  • Information and documents related to the subject of request,
  • Application methods and
  • Signature if the application is written.

If you submit your requests to us by the specified methods, Unipoly shall conclude the request as soon as possible and within thirty days at the latest, free of charge depending on the nature of your request. However, if the transaction requires an additional cost, a fee that can be requested by Unipoly in accordance with the relevant legislation shall be charged.

In cases where the Personal Data Protection Law no. 6698 is applicable, data subjects have the following rights:

      to learn whether personal data is processed or not,
      to request information on whether his/her personal data has been processed,
      to learn the purpose of the processing of the personal data and whether this information is used within the intended purposes,
      to know the third parties to whom the personal data is transferred in domestic or abroad
      to request the rectification of the incomplete or inaccurate processed personal data, if any,
      to request the erasure or destruction of the personal data under the conditions stipulated in Article 7 of the Personal Data Protection Law,
      to request notifying third parties to whom the personal data has been transferred, the transactions made pursuant to subparagraphs (d) and (e),
      to object to the processing, exclusively by automatic systems, of the personal data, which leads to an unfavorable consequence for the person
      to request compensation for the damage arising from the unlawful processing of personal data.

Where GDPR is applicable, data subjects have the following rights:

  • Right of access - Learning whether personal data is being processed and, if so, accessing your personal data and the information regarding the processing of your personal data,
  • Right to correction -To request the correction of information that you believe is inaccurate or the completion of information that you believe is incomplete by Unipoly,
  • Right to erase – To request erasure of personal data under the conditions stipulated in GDPR,
  • The right to restrict processing - To request the restriction of the processing of personal data under the conditions stipulated in the GDPR,
  • Right to object to processing - To object to the processing of personal data under the conditions stipulated in the GDPR,
  • Right to data portability - To request the data collected by Unipoly to be transferred directly to another organization or under certain conditions,
  • Objection to the occurrence of a result against the person himself/herself, by analyzing the processed data exclusively through automatic systems, including profiling.

In the application that includes your explanations about the right you have as the data subject and exercise your rights stated above and that you request to exercise; your request must be explicit and understandable, if the subject of your request is related to you or if you are acting on behalf of someone else, you must be specially authorized in this regard and your authority must be documented, the application must contain the identity and address information and documents proving your identity must be attached to the application. In the scenario where transactions related to the Application/Platform take place on the blockchain, we would like to emphasize that the right to rectification or deletion cannot be applied due to technical impossibility. In this case, our Company will show its best effort to apply a protective measure for the User. The relevant text has been prepared in accordance with the Law on the Protection of Personal Data No. 6698. If you believe that we or someone with whom we have transferred your data is violating your rights, you can file a complaint to the data protection authority in your country and to other competent supervisory authorities.

Company Title: Unıpoly Yazılım ve Teknoloji Anonim Şirketi

Address: Esentepe Mah. Haberler Sk. No: 1 İç kapı no: 1 Şişli/İstanbul

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