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This Application collects some Personal Data from its Users.

Owner and Data Controller

YAL GROUP IS MAKINELERI ITHALAT VE IHRACAT LIMITED SIRKETI
Address: FULYA MAH. BÜYÜKDERE CAD. TORUN CENTER D BLOK NO: 74 D İÇ KAPI NO: 10 ŞİŞLİ/ İSTANBUL

Contact Email: [email protected]

Types of Data Collected

This Application collects various types of Personal Data, either independently or through third parties. The collected data includes:

  • Trackers
  • Usage Data
  • Unique Device Identifiers (e.g., Google Advertiser ID, IDFA)
  • Device Information
  • Geographical Data (Region)
  • User Metrics: Number of Users, sessions, session duration
  • App Activity: In-app purchases, app launches, updates, and opens
  • Crash Reports
  • Device Logs
  • Operating System Details
  • Universally Unique Identifier (UUID)
  • Country Information
  • Payment Data
  • Approximate Location Data (non-continuous)
  • Various Other Types of Data

Detailed information about each data type collected is provided in the relevant sections of this privacy policy or in specific notices displayed before data collection.

Personal Data can be voluntarily provided by the User or, for Usage Data, automatically collected during the use of this Application. Unless explicitly stated otherwise, all data requested by this Application is mandatory for providing services. Refusal to supply mandatory data may prevent the Application from functioning properly.

If specific data is marked as optional, Users can opt not to share it without affecting the service. Users unsure about which data is mandatory are encouraged to contact the Owner.

The use of cookies or other tracking technologies by this Application, or third-party services associated with it, is intended to support the User experience and fulfill purposes described in this document and the Cookie Policy (if applicable).

Users must ensure that any third-party Personal Data shared through this Application is provided with proper consent from the third party involved.

Mode and Place of Processing the Data

Methods of Processing

The Owner implements robust security measures to safeguard Personal Data from unauthorized access, disclosure, alteration, or destruction. Data processing is performed using computers and/or IT tools, strictly adhering to organizational policies and methods aligned with the specified purposes.

In some cases, access to Personal Data may extend to specific individuals involved in the operation of this Application, such as personnel in administration, sales, marketing, legal, or system administration roles. External entities, such as third-party service providers, mail carriers, hosting providers, IT companies, or communications agencies, may also access the Data as necessary. These external parties act as Data Processors under agreements with the Owner.

Users may request an up-to-date list of these third parties from the Owner at any time.

 

Legal Basis of Processing

The Owner is authorized to process Personal Data related to Users under any of the following circumstances:

  • User Consent: Users have provided explicit consent for one or more specific purposes.
    Note: In certain jurisdictions, the Owner may process Personal Data without requiring consent, provided the User has not opted out. This exception does not apply where European data protection laws are in effect.

  • Contractual Necessity: Processing is required for the fulfillment of a contract with the User or to carry out pre-contractual obligations.

  • Legal Obligation: Processing is necessary to comply with a legal requirement to which the Owner is subject.

  • Public Interest or Official Authority: Processing is required to perform a task carried out in the public interest or in the exercise of official authority vested in the Owner.

  • Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by the Owner or a third party.

If Users are unsure about the specific legal basis for processing their data or whether the provision of Personal Data is mandatory, they are encouraged to contact the Owner for clarification.

Place

Personal Data is processed at the Owner’s operational offices and at any other locations where parties involved in the processing are situated. Depending on the User’s geographic location, their data may be transferred to a country different from their own. For further details about such transfers, Users can review the relevant sections of this document related to Personal Data processing.

Users have the right to inquire about the legal grounds for transferring their data to a country outside the European Union or to an international organization governed by public international law (e.g., the United Nations). They can also request information about the security measures implemented by the Owner to ensure their data is protected during such transfers.

For more details on data transfers or to address specific questions, Users may contact the Owner using the information provided in the contact section.

Retention Time

Personal Data is processed and stored only for the duration necessary to achieve the purposes for which it was collected.

Specifically:

  • Contractual Obligations: Personal Data collected for purposes related to a contract between the Owner and the User is retained until the contract is fully executed.

  • Legitimate Interests: Personal Data processed to fulfill the Owner’s legitimate interests is stored for as long as required to meet these purposes. Details regarding these interests can be found in relevant sections of this document or by contacting the Owner.

In addition:

  • If the User has provided consent for processing, the data may be retained until the consent is withdrawn.
  • Legal obligations or authoritative orders may require the Owner to store Personal Data for a longer period.

Once the retention period ends, the Personal Data is permanently deleted. As a result, rights such as access, rectification, erasure, and data portability cannot be exercised after this time.

The Purposes of Processing

The Personal Data collected from Users is utilized to enable the Owner to:

  • Provide its services
  • Fulfill legal obligations
  • Respond to enforcement requests
  • Protect its rights and interests, as well as those of Users or third parties
  • Identify and prevent fraudulent or malicious activity

Additional purposes include:

  • Advertising
  • Social Features
  • Content Performance and Features Testing (A/B Testing)
  • Infrastructure Monitoring
  • Analytics
  • Managing Contacts and Sending Messages
  • Handling Payments
  • Platform Services and Hosting
  • Beta Testing
  • Data Transfers Outside the EU
  • Device Permissions for Accessing Personal Data
  • Hosting and Backend Infrastructure

For detailed information on the specific types of Personal Data processed for each purpose, Users can refer to the section titled “Detailed Information on the Processing of Personal Data” in this document.

Device Permissions for Personal Data Access

This Application may request certain permissions from the User’s device to access specific types of Personal Data, as outlined below.

Granting and Revoking Permissions

By default, Users must grant these permissions before the Application can access the associated data. Permissions can be revoked at any time through the User’s device settings or by contacting the Owner for support using the details provided in this document.

The procedure for managing permissions may vary based on the User’s device model and operating system.

Impact of Revoking Permissions

Revoking permissions may affect the Application’s functionality or limit its ability to provide certain services.

Data Processing via Permissions

If the User grants any of the requested permissions, this Application may access, modify, or remove the associated Personal Data.

Approximate Location Permission (Non-Continuous)

This Application may request access to the User’s approximate device location to provide location-based services. The User’s geographic location is determined in a non-continuous manner, meaning the Application cannot track the User’s approximate position on an ongoing basis.

Detailed Information on the Processing of Personal Data

Personal Data is processed for the purposes outlined below using the following services:

Advertising

Advertising services enable the Application to utilize User Data for promotional purposes. These advertisements, which may include banners or other formats, can be displayed based on User interests.

Not all Personal Data collected is necessarily used for advertising purposes. Specific details and terms of use for each service are provided below.

Some advertising services use Trackers to identify Users or apply behavioral retargeting, which involves displaying ads tailored to User interests and activity, including those tracked outside the Application.

For more information, Users can review the privacy policies of the respective services.

Opt-Out Options

Users can opt out of certain advertising features by:

Advertising Services

Below are the advertising services utilized by this Application. These services may use Personal Data such as Trackers or unique device identifiers to deliver targeted advertisements. Users can opt out through provided links or by adjusting device settings.

AdMob (Google Ireland Limited)

AdMob is a service provided by Google Ireland Limited. For details on how Google uses data, see their partner policy.

  • Personal Data Processed: Tracker, unique device identifiers (e.g., Google Advertiser ID, IDFA), Usage Data
  • Place of Processing: Ireland
  • Privacy Policy – Opt-Out

Facebook Audience Network (Facebook Ireland Ltd)

This service, provided by Facebook Ireland Ltd, uses device identifiers (e.g., Android Advertising ID, iOS Advertising Identifier) and cookies to show ads. Ads are based on User preferences.

  • Personal Data Processed: Tracker, unique device identifiers, Usage Data
  • Place of Processing: Ireland
  • Privacy Policy – Opt-Out

Adjust (Adjust GmbH)

Adjust provides advertising services to enhance ad targeting.

Appsflyer (AppsFlyer Limited)

Appsflyer is a service provided by AppsFlyer Limited that offers analytics and marketing solutions. This service enables tracking and analysis of User behavior and interactions to support marketing campaigns and improve application performance..

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: United States
  • Privacy Policy

AdColony (AdColony, Inc.)

AdColony is a video-focused advertising service.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Tapjoy (Tapjoy, Inc.)

Tapjoy provides in-app advertising services.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Liftoff (Liftoff Mobile, Inc.)

Liftoff specializes in mobile app advertising.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

PubMatic (PubMatic, Inc.)

PubMatic enables targeted advertising through auctions.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Smaato (Smaato, Inc.)

Smaato facilitates programmatic advertising.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

TripleLift (TripleLift, Inc.)

TripleLift focuses on native advertising.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Unruly (Unruly Group Ltd.)

Unruly provides video advertising services.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United Kingdom
  • Privacy Policy – Opt-Out

InMobi

InMobi offers mobile advertising services.

Mintegral (Mintegral International Ltd.)

Mintegral provides app advertising solutions.

AppLovin (AppLovin Corporation)

AppLovin enables in-app advertising campaigns.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

myTarget (MGL MY.COM (CYPRUS) LIMITED)

myTarget delivers personalized advertising.

DT Exchange (Digital Turbine Inc.)

DT Exchange supports mobile app advertising.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Pangle (Bytedance Pte. Ltd.)

Pangle is a video ad platform by Bytedance.

Google Ad Manager (Google Ireland Limited)

Google Ad Manager supports external advertising campaigns.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: Ireland
  • Privacy Policy

Google AdSense (Google Ireland Limited)

Google AdSense provides context-based advertising.

Unity Ads (Unity Technologies ApS)

Unity Ads provides in-game advertising.

Aarki (Aarki Inc.)

Aarki offers app retargeting and video ads.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Fluct (Fluct Inc.)

Fluct provides programmatic advertising services.

Vungle

Vungle specializes in video-based advertisements.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Chartboost (Chartboost Inc.)

Chartboost is a mobile game-focused advertising service.

  • Personal Data Processed: Tracker, Usage Data
  • Place of Processing: United States
  • Privacy Policy – Opt-Out

Ironsource (Ironsource Mobile Ltd.)

Ironsource provides in-app advertising solutions.

Analytics

The analytics services described in this section enable the Owner to monitor and analyze web traffic, providing insights into User behavior within this Application.

Google Analytics for Firebase (Google Ireland Limited)

Google Analytics for Firebase, also known as Firebase Analytics, is a tool provided by Google Ireland Limited for monitoring application performance and User interactions. Detailed information on how Google processes data can be found in Google’s partner policy.

Firebase Analytics may share data with other Firebase tools, such as:

  • Crash Reporting
  • Authentication
  • Remote Config
  • Notifications

Users can review this privacy policy to learn more about how these additional tools function.

This Application leverages device identifiers and technologies similar to cookies to implement Firebase Analytics.

Opt-Out Options:
Users can opt out of certain Firebase Analytics features by:

  • Adjusting their device’s advertising settings.

  • Following specific instructions detailed in Firebase-related sections of this privacy policy.

  • Personal Data Processed:

    • Application opens
    • Application updates
    • Device information
    • Geography/region
    • In-app purchases
    • Launches
    • Number of sessions
    • Number of Users
    • Operating systems
    • Session duration
    • Tracker
    • Unique device identifiers for advertising (e.g., Google Advertiser ID, IDFA)
    • Usage Data

  • Place of Processing: Ireland

  • Privacy Policy

Flurry Analytics (Flurry, Inc.)

Flurry Analytics, provided by Yahoo! Inc., is a mobile-focused analytics service. It collects various device-related data, as outlined in the Flurry Analytics privacy policy.

Users can opt-out of Flurry tracking, and upon doing so, Flurry will cease tracking data associated with the identified device’s MAC address and/or device identifier across all applications within the Flurry network.

  • Personal Data Processed:

    • Tracker
    • Usage Data
    • Various types of data as specified in the service’s privacy policy

  • Place of Processing: United States

  • Privacy Policy – Opt-Out

GameAnalytics (GameAnalytics ApS)

GameAnalytics is a service used to monitor the performance of our games and analyze user interactions. This tool helps us track in-game behaviors and interactions to enhance user experience.

The data collected may include device information, in-game progress, scores, and similar usage data. This data is used solely to improve our games and does not include personally identifiable information. For more details, please refer to GameAnalytics’ privacy policy. (gameanalytics.com)

Opt-Out Options: Users can opt out of certain GameAnalytics features by adjusting their device’s advertising settings.

Personal Data Processed:

  • Application opens
  • Application updates
  • Device information
  • Geography/region
  • In-app purchases
  • Session count
  • Number of users
  • Operating systems
  • Session duration
  • Tracker
  • Unique device identifiers for advertising (e.g., Google Advertiser ID, IDFA)
  • Usage Data

Place of Processing: Denmark

Privacy Policy

Facebook Ads Conversion Tracking (Facebook Pixel) (Facebook Ireland Ltd)

Facebook Ads Conversion Tracking, also known as Facebook Pixel, is an analytics service offered by Facebook Ireland Ltd. It links data from the Facebook advertising network to actions performed within this Application.

This service allows the tracking of conversions, such as purchases or registrations, that are attributed to ads shown on Facebook, Instagram, and the Audience Network.

  • Personal Data Processed:

    • Tracker
    • Usage Data

  • Place of Processing: Ireland

  • Privacy Policy

Beta Testing

Beta testing services enable the management of User access to this Application, either partially or entirely, for testing specific features or the complete Application. These services may automatically collect data, including crash reports and usage statistics, in a form that may identify the User.

Google Play Beta Testing (Google Ireland Limited)

Google Play Beta Testing is a service offered by Google Ireland Limited for managing beta testing phases of Android applications.

  • Personal Data Processed:

    • Country
    • Device information
    • Device logs
    • Tracker
    • Usage Data
    • Various types of data as specified in the service’s privacy policy

  • Place of Processing: Ireland

  • Privacy Policy

TestFlight (Apple Inc.)

TestFlight, provided by Apple Inc., is a beta testing platform for iOS applications.

  • Personal Data Processed:

    • App information
    • Country
    • Device logs
    • Tracker
    • Usage Data
    • Various types of data as specified in the service’s privacy policy

  • Place of Processing: United States

  • Privacy Policy

Content Performance and Features Testing (A/B Testing)

Services in this category enable the Owner to monitor and analyze User responses to changes in the structure, text, or other components of this Application.

Firebase Remote Config (Google Ireland Limited)

Firebase Remote Config is a service provided by Google Ireland Limited for A/B testing and application configuration. It allows the Owner to test various features and content performance.

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: Ireland
  • Privacy Policy

Appsflyer (AppsFlyer Limited)

Appsflyer is a service provided by AppsFlyer Limited that offers analytics and marketing solutions. This service enables tracking and analysis of User behavior and interactions to support marketing campaigns and improve application performance..

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: United States
  • Privacy Policy

Data Transfer Outside the EU

The Owner may transfer Personal Data collected within the EU to third countries (outside the EU) based on specific legal grounds. These transfers adhere to one of the legal bases outlined below. Users can contact the Owner for detailed information on the applicable legal basis for specific services.

Data Transfer Based on Standard Contractual Clauses

When applicable, the transfer of Personal Data from the EU to third countries is carried out under “standard contractual clauses” approved by the European Commission. These clauses ensure that Data recipients process Personal Data in accordance with EU data protection standards.

For more details or further inquiries, Users are encouraged to reach out to the Owner via the contact information provided in this document.

Device Permissions for Personal Data Access

This Application may request permissions from Users to access specific data on their devices. The permissions required and their purpose are summarized below and further detailed within this document.

Device Permissions for Personal Data Access (This Application)

The following permissions may be requested by this Application to enable its functionality:

  • Approximate Location Permission (Non-Continuous): Accesses the User’s approximate location for location-based services.

  • Storage Permission: Provides access to the device’s internal or external storage for saving and retrieving files.

  • Personal Data Processed: Various types of data as described above.

Users can grant or revoke these permissions at any time through their device settings. However, disabling certain permissions may limit the functionality of the Application.

Handling Payments

This Application processes payments using external payment service providers. Payment methods may include credit cards, bank transfers, or other payment solutions. Users are generally required to provide payment details and Personal Data directly to these providers. This Application does not collect or process payment information directly; instead, it only receives confirmation of successful transactions from the relevant payment provider.

RevenueCat (RevenueCat, Inc.)

RevenueCat is a service provided by RevenueCat, Inc. It enables the Owner to monitor and analyze User purchase history and behaviors.

  • Personal Data Processed:

    • Application opens
    • Device information
    • Tracker
    • Unique device identifiers (e.g., Google Advertiser ID, IDFA)
    • Usage Data

  • Place of Processing: United States

  • Privacy Policy – Opt-Out

Payments Processed via the Apple App Store (Apple Inc.)

This Application facilitates payments via the Apple App Store, a service provided by Apple Inc., for app purchases and in-app transactions.

  • Personal Data Processed: Payment information required for completing purchases.
  • Place of Processing: United States
  • Privacy Policy

Payments Processed via the Google Play Store (Google Ireland Limited)

This Application enables payments through the Google Play Store, managed by Google Ireland Limited, for app purchases and in-app transactions.

  • Personal Data Processed: Payment information required for completing purchases.
  • Place of Processing: Ireland
  • Privacy Policy

Hosting and Backend Infrastructure

Hosting and backend services are used to store data and files required for this Application’s operation and distribution. These services also provide the infrastructure necessary to support specific features or components of the Application. Some of these services may use geographically distributed servers, making it challenging to determine the exact location where Personal Data is stored.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

AWS is a hosting and backend service provided by Amazon Web Services, Inc.

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: United States
  • Privacy Policy

Infrastructure Monitoring

Infrastructure monitoring services track the use and behavior of the Application’s components to enhance performance, support maintenance, and troubleshoot issues. The type of Personal Data processed depends on the specific implementation of the service.

Firebase Performance Monitoring (Google Ireland Limited)

Firebase Performance Monitoring is a service provided by Google Ireland Limited to monitor the performance of this Application.

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: Ireland
  • Privacy Policy

Crashlytics (Google Ireland Limited)

Crashlytics, a monitoring service by Google Ireland Limited, identifies and reports app crashes to improve functionality and user experience.

  • Personal Data Processed:

    • Crash data
    • Device information
    • Universally Unique Identifier (UUID)

  • Place of Processing: Ireland

  • Privacy Policy

Managing Contacts and Sending Messages

This category of services enables the management of a database containing email, phone, or other contact details to facilitate communication with Users. These services may also collect metadata, such as when a message was viewed or interacted with, including clicks on links embedded in the message.

Firebase Notifications (Google Ireland Limited)

Firebase Notifications, provided by Google Ireland Limited, is a service for sending messages to Users. It can integrate with Firebase Analytics to target specific audiences and track events such as message opens and conversions.

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: Ireland
  • Privacy Policy

Platform Services and Hosting

Platform and hosting services allow this Application to run key components within a unified system. These platforms provide functionalities like analytics, user registration, commenting, database management, e-commerce, and payment processing. Some operate via distributed servers, making the exact location of Personal Data storage difficult to determine.

Apple App Store (Apple Inc.)

This Application is distributed via Apple’s App Store, which is a platform provided by Apple Inc. for distributing mobile apps.

Apple collects basic analytics data and offers reporting tools that allow the Owner to monitor app performance and usage. Much of this data collection operates on an opt-in basis.

  • Personal Data Processed: Usage Data
  • Place of Processing: United States
  • Privacy Policy

Google Play Store (Google Ireland Limited)

This Application is distributed through the Google Play Store, a platform provided by Google Ireland Limited for the distribution of mobile applications.

By being hosted on the Google Play Store, Google collects usage and diagnostics data and shares aggregated information with the Owner. Most of this data collection is conducted on an opt-in basis.

Opt-Out Options:
Users can opt out of this analytics feature by adjusting their device settings. Detailed instructions for managing these settings are available here.

  • Personal Data Processed: Usage Data
  • Place of Processing: Ireland
  • Privacy Policy

 

Social Features

 

Firebase Dynamic Links (Google Ireland Limited)

Firebase Dynamic Links, provided by Google Ireland Limited, is a tool for creating social and referral features. These links allow tracking within Firebase or Google Analytics for Firebase, providing the Owner with details of the User’s journey to and interaction with this Application.

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: Ireland
  • Privacy Policy

Firebase Invites (Google Ireland Limited)

Firebase Invites, provided by Google Ireland Limited, is a social sharing feature that allows Users to share this Application via email or SMS. Shared links may include referral codes or content from within the Application. These sharing activities are tracked using Google Analytics for Firebase, enabling the Owner to determine if the Application was opened or installed through an invite.

  • Personal Data Processed: Various types of data as specified in the service’s privacy policy
  • Place of Processing: Ireland
  • Privacy Policy

 

Further Information About Personal Data

 

Push Notifications

This Application may send push notifications to Users to support the purposes outlined in this privacy policy.

Opt-Out Options:
Users can typically opt-out of push notifications by:

  • Adjusting their device settings under notification preferences for this Application.
  • Managing notification settings for individual or all apps on their device.

Impact of Disabling Notifications:
Disabling push notifications may reduce the effectiveness of certain Application features or limit its overall functionality.

 

The Rights of Users

Users have the right to exercise certain rights regarding their Personal Data processed by the Owner. These rights include:

Withdraw Consent

Users may withdraw their consent at any time if they have previously provided it for the processing of their Personal Data.

Object to Processing

Users have the right to object to the processing of their Personal Data if the processing is based on legal grounds other than their consent. Specific details about this right are provided in the section below.

Access Their Data

Users are entitled to:

  • Confirm whether their Data is being processed by the Owner.
  • Obtain disclosure of certain processing activities.
  • Receive a copy of the Data being processed.

Verify and Rectify Data

Users can verify the accuracy of their Personal Data and request corrections or updates where necessary.

Restrict Data Processing

Under specific circumstances, Users can request restrictions on the processing of their Data. In such cases, the Owner will process the Data solely for storage purposes.

Request Deletion of Data

Users have the right to request the deletion or removal of their Personal Data under certain conditions.

Receive and Transfer Their Data

Users can request their Data in a structured, commonly used, and machine-readable format. If technically feasible, they may also request the transfer of their Data to another controller. This right applies when:

  • The Data is processed by automated means.
  • The processing is based on User consent, a contract involving the User, or pre-contractual obligations.

Lodge a Complaint

Users have the right to file a complaint with their local data protection authority if they believe their rights have been violated.

Details About the Right to Object to Processing

Users can object to the processing of their Personal Data when:

  • The processing is carried out in the public interest.
  • It involves the exercise of official authority vested in the Owner.
  • It is necessary for the purposes of legitimate interests pursued by the Owner or a third party.

In cases of direct marketing, Users can object to processing without providing any specific justification.

When Personal Data is processed:

  • For public interest purposes
  • In the exercise of official authority vested in the Owner
  • To fulfill the legitimate interests of the Owner or a third party

Users may object to such processing by providing specific reasons related to their unique situation.

Direct Marketing Exception:
If Personal Data is processed for direct marketing purposes, Users have the right to object at any time without providing a justification. To determine whether the Owner processes Personal Data for direct marketing, Users can consult the relevant sections of this document.

How to Exercise These Rights

Users can direct their requests regarding the exercise of their rights to the Owner using the contact details provided in this document.

  • Cost: Requests can be submitted free of charge.
  • Response Time: The Owner will address these requests as promptly as possible, always within one month of receiving them.

Additional Information About Data Collection and Processing

For further details on how Personal Data is collected, processed, or used by this Application, Users may refer to other sections of this document or contact the Owner directly.

Legal Action

The Owner may use the User’s Personal Data for legal purposes, such as in Court proceedings or in preparatory stages leading to legal action resulting from misuse of this Application or its Services. Users acknowledge that the Owner may be obligated to disclose Personal Data upon a lawful request from public authorities.

Additional Information About User’s Personal Data

Beyond the details provided in this privacy policy, Users may request additional or contextual information regarding specific services or the collection and processing of their Personal Data.

System Logs and Maintenance

For operational and maintenance purposes, this Application and any third-party services it uses may collect system logs—files that record User interactions with the Application. These logs may also include Personal Data, such as the User’s IP address.

Information Not Contained in This Policy

If more details about the collection or processing of Personal Data are required, Users can contact the Owner at any time using the contact details provided at the beginning of this document.

How “Do Not Track” Requests Are Handled

This Application does not accommodate “Do Not Track” requests. Users seeking information on whether third-party services integrated with this Application honor such requests should consult the respective privacy policies of those services.

Changes to This Privacy Policy

The Owner reserves the right to update this privacy policy at any time. Users will be notified of changes through:

  • Updates to this page.
  • Notifications within the Application.
  • Notices sent to Users using any contact information available to the Owner, when feasible and appropriate.

Users are encouraged to check this page frequently and refer to the date of the last modification, listed at the bottom, for updates.

If the changes impact processing activities that rely on User consent, the Owner will obtain new consent from the User where required.

Definitions and Legal References

Personal Data (or Data)

Personal Data refers to any information that, either on its own or when combined with other data, can directly or indirectly identify a natural person. This includes identifiers such as a personal identification number.

Usage Data

Usage Data refers to information collected automatically by this Application or through third-party services utilized by this Application. This can include:

  • IP addresses or domain names of the devices used by Users
  • Uniform Resource Identifier (URI) addresses
  • Time and date of requests
  • Methods used to submit requests to the server
  • File sizes of responses received
  • Numerical codes indicating server response status (e.g., successful outcome, errors)
  • Geographic location (country of origin)
  • Browser and operating system details
  • Time spent on each page
  • Navigation paths and sequence of pages visited
  • Other parameters related to the device’s operating system and IT environment

User

The individual utilizing this Application. Unless specified otherwise, the User is the Data Subject.

Data Subject

The natural person whose Personal Data is being collected or processed.

Data Processor (or Data Supervisor)

A natural or legal person, public authority, agency, or other entity that processes Personal Data on behalf of the Data Controller, as outlined in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency, or other entity that determines the purposes and means of processing Personal Data. This includes defining the security measures for the operation and use of this Application. Unless specified otherwise, the Owner of this Application acts as the Data Controller.

This Application

The platform through which the Personal Data of the User is collected and processed.

Service

The specific functionalities or offerings provided by this Application, as described in the relevant terms and conditions.

European Union (or EU)

For the purposes of this document, references to the European Union include all current EU member states as well as members of the European Economic Area (EEA).

Cookie

A Cookie is a small set of data stored on the User’s browser. Cookies are a type of Tracker used for various purposes, such as enhancing functionality or tracking User activity.

Tracker

A Tracker refers to any technology—such as Cookies, unique identifiers, web beacons, embedded scripts, e-tags, or fingerprinting—that tracks Users by accessing or storing data on their devices.

Legal Information

This privacy statement complies with multiple legislations, including Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation or GDPR).

This privacy policy pertains exclusively to this Application unless explicitly stated otherwise.

Latest Update: January 2, 2025

Magic Play