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Privacy Notice

Personal Data
 

Identification data (first name and surname)
 

Transaction security information (IP address, device model and brand, operating system and version, device language, user ID, user contract confirmation record)
 

Details about the platforms that you use (Apple Store, Google Play)
 

Your region
 

Links to your profiles on various social networks and social network ID number


Information related to any purchases you make in our Services (user ID, amount of expense and package information)

Cypher Games Inc. [“Cypher Games”] develops and publishes games for website and mobile devices on which players can use Cypher Games’ services [“Services”]. As a subsidiary of Cypher Games, Cypher Games Yazılım Pazarlama Anonim Åžirketi [“Cypher Games TR”] located in Istanbul/Türkiye and controlled by Cypher Games, also operates in the scope of our Services under this Privacy Notice. Cypher Games is the “data controller” of your personal data unless otherwise stated below.
 

This Privacy Notice applies whenever your personal data is processed as part of our Services, which means our games, services, and contents operated by Cypher Games TR, who processes personal data on behalf of Cypher Games upon its authorization. It describes how we process your personal data when providing these Services to you and your rights and choices concerning your personal data. The Privacy Notice’s sections are listed above.
 

  1. Which of Your Personal Data is Processed and What are the Purposes of Processing Your Personal Data?

 

A. Information About You That You Share with Us Directly
 

When you use our Services, you may give us personal data directly (for example, when uploading our Services), and we will store that personal data on our systems and process it for the purposes described in this Privacy Notice.
 

Depending on the Services, the personal data that we obtain will be relevant to providing those Services and include the following:

 

​​​​​

 

Legal Basis

 

Necessary for performance of the contract

                                     ***

Cypher Games’ legal obligations, in particular relating to security, fraud detection, and management

Purposes of Processing Your Personal Data

Provide our Services and create accounts in those Services
 

Protecting Cypher Games’ Rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties
 

Ensuring the security of data controller operations
 

Managing players communications
 

Launch of products

For security purposes and to prevent fraud or potentially illegal activities, and to enforce the applicable Terms of Service
 

Protecting the safety of our players

           
                                   ***

Cooperating with public authorities and law enforcement where lawfully permitted or required
​
​

 B. Information You Generate Using Our Services

​​

When you use our Services, we will obtain personal data about the ways in which you use and interact with our Services.

Personal Data
 

When and for how long you play our games

​​

Which game features

​

Other players you interact with

​

What progress or levels you achieve

​

Gameplay activities in which you participate

​

Performance data (the number of clicks on an advertisement)

​

Certain device information (IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID)

​​

Descriptions of your in-game activity

​

Survey information

​

Parental information

Legal Basis
 

Cypher Games' legitimate interest in improving its Services and its website

​

​​​​​​​​​​​​​​                                  ***​​

​​Consent

Purposes of Processing Your Personal Data
 

Tracking users’ habits and preferences
 

Execution of activities for user's game satisfaction
 

Execution of activities for ensuring business continuity
 

Conducting business activities

           
                                   ***

Marketing, research, analytics and delivering behavioral advertising
​
​

If you choose to use communication features in Cypher Games’ Services to communicate or share information with other players, then we’ll obtain personal data on what is communicated or shared. This includes:

Personal Data

 

Your participation in player message boards

​

Your public posts or comments on message boards

 

Your non-public messages or invitations to other players, made either directly on our websites or through in-game mechanisms

 

Your chats with other players and/or

 

Your posted drawings, or other user-generated content

Legal Basis
 

Necessary for performance of the contract

​ 

​​​​​​​​​​​​​​                                  ***
​
​

Cypher Games' legitimate interest in improving its Services and its website

                                  ***

Cypher Games’ legal obligations, in particular relating to security, fraud detection and management

 

Purposes of Processing Your Personal Data


Managing players communications


Protecting Cypher Games’ rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties
 

For security purposes and to prevent fraud or potentially illegal activities
 

Conducting business activities
 

Protecting the safety of our players

                                ***

Execution of activities for user's game satisfaction
 

Execution of activities for ensuring business continuity

        
                                 ***

Cooperating with public authorities and law enforcement where lawfully permitted or required

 

C. Information We Get About You from Connected Third-Party Platforms

​​

If you play Cypher Games’ games or access any of our Services on social networks like Facebook, Google or other third-party platforms, Cypher Games may obtain your certain personal data from that third-party platform.

​

Depending on the Cypher Games’ game you’re playing, your privacy settings, the third-party platforms, and, if applicable, your friends’ privacy settings on those third-party platforms, Cypher Games may collect and store some or all of the following from the third-party platform:

Personal Data
​
Identification data (your first and surname, your gender)

 

Transaction security information (IP address, game achievement, your user identification number (your social network ID number, which may be
linked to publicly-available information like your profile)

​

Communication data (e-mail address)

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Your region​


Your age range

Legal Basis

​Necessary for performance of the contract

​​​​​​​​​​​​​​                                  ***​​

​​Cypher Games' legitimate interest in improving its Services and its website

                                 ***

Cypher Games’ legal obligations, in particular relating to security, fraud detection and management

 

Purposes of Processing Your Personal Data
 

Helping you to connect with other people you know and other third-party platforms you use, including communicating with other players
 

For security purposes and to prevent fraud or potentially illegal activities
 

Conducting business activities
 

Protecting the safety of our players
 

Protecting Cypher Games’ rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties


                                   ***
 

Execution of activities for user's game satisfaction
 

Execution of activities for ensuring business continuity


                                   ***

Cooperating with public authorities and law enforcement where lawfully permitted or required​​

​

If you connect our Services via a third-party account or access our Services from a third-party platform, we kindly recommend you to read that platform’s terms of service and privacy policy. In order to see what information a third-party platform is sharing with Cypher Games, and to find out more details about their privacy practices and any options available, please visit those platforms.

D. Cookies and Other Automated Information Collection

​

We use cookies and other similar technologies (e.g. device identifiers) to recognize you and/or your device(s) across different services (both Cypher Games’ Services and third-party services), including for advertising purposes. You can see the details about why we do this, and how to use cookies and similar technologies in the Cookie Notice.

 

Cypher Games uses cookies and other similar technologies to process personal data, including:

Personal Data
​​

IP address

 

The type of device you are using

platform type (like Apple iOS or Android)

 

Your operating system version

 

Your mobile device’s identifiers, like

 

Your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID)

​

Your browser type and language

 

Referring and exit pages, and URLs

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The number of clicks on an app feature or website

 

The amount of time spent on an app feature or web page

 

Domain names

 

Landing pages

 

Pages viewed and the order of those pages

 

What your current progress is in our Services and the date and time of activity

Legal Basis

​Necessary for performance of the contract

​​​​​​​​​​​​​​                                 ***​
​​
Cypher Games’ legal obligations, in particular relating to security, fraud detection and management

                                 ***

Consent

                                 ***

Cypher Games' legitimate interest in improving its Services and its website

Purposes of Processing Your Personal Data
 

Conducting business activities
 

Ensuring the security of data controller operations
 

For security purposes and to prevent fraud or potentially illegal activities


                                   ***
 

Marketing, research, analytics and delivering behavioral advertising

 

Personalizing our Services and our players’ experiences


                                    ***

Cooperating with public authorities and law enforcement where lawfully permitted or required

                                    ***


Improving, optimizing our Services and our players’ experiences

​

We may obtain personal data by using cookies and similar technologies with your social network ID or Cypher Games user ID. If you play Cypher Games’ games on a mobile device, in addition to the data that we obtain via using cookies and similar technologies, we may also obtain:

Personal Data
​​

Information about Cypher Games’ games and about other third-party applications with embedded Services you have on your device

Legal Basis

Cypher Games' legitimate interest in improving its Services and its website

Purposes of Processing Your Personal Data
 

Conducting business activities
 

Improve, optimize our Services and our players’ experiences
 

Ensuring the security of data controller operations
 

Launch of products

​

​

2. How We Transfer Your Personal Data
 

When we transfer your personal data internationally, we process your personal data securely, lawfully, and in accordance with related privacy laws. We disclose personal data to our data processors and third-party advertisers in locations including the EU, the US, the UK and Türkiye. We take measures to ensure that data processors and third-party advertisers in Türkiye and the United States provide an adequate level of data protection.

A. People you know and Other Cypher Games Players

​

In Cypher Games’ games, if you play via a social network or connect to a social network (for example, Facebook), your social network friends who also play a Cypher Games’ game will see descriptions of your in-game activity (including Cypher Games’ games you have played), and your name, your player profile (which may include the personal data described above in Information About You That You Share With Us Directly). Moreover, other players in Cypher Games’ games, regardless of whether they are your social network friends, will be able to see your player profile.

Personal Data
​​

Descriptions of your in-game activity
 

Identification data (first name and surname)

Legal Basis

Cypher Games' legitimate interest in improving and optimaziting its Services and its website

Purposes of Processing Your Personal Data
 

Helping you to connect with other people you know and other third-party platforms you use, including communicating with other players

​Execution of activities for user's game satisfaction

B. Cypher Games TR
 

We share your personal data within the Cypher Games TR to enable Cypher Games to carry out the purposes about personal data processing set out in this Privacy Notice.

​

C. Third-Party Advertising Including Behavioral Advertising and Analytics

​​

We share your personal data with advertisers to perform making the advertisements that are tailored for your interests when you use our Services. Accordingly, advertisements may include banner ads on game boards or in Services, such as full-screen ads between moves or games or ads made available via an offer wall (in which advertisers offer virtual currency or other in-game items to players in exchange for watching an advertisement, signing up for an account, completing a survey or performing some other activity). Third-party offer wall providers host offer walls and make the offers. You can access our third-party advertisers list here.

​​

For users residing in the European Economic Area, UK, Switzerland, or Türkiye, we ask for your consent to implement targeted advertising practices when you first launch our games. If you provide your consent, you may later withdraw it at any time by Settings.

​

Advertisers and offer wall providers may obtain, or we may obtain and share with them, the following types of personal data when you use our Services, in order to enable advertisers, advertising intermediaries, and offer wall providers to serve you with more relevant ads:

Personal Data
​​

Performance data (the number of clicks on an advertisement)

​

Certain device information (IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID)

 

A unique identifier, such as your social network ID or Cypher Games player ID

Legal Basis

Consent

Purposes of Processing Your Personal Data
 

Offering you targeted advertising in third party services for products and services that are more likely to appeal to you
 

Undertaking analytics to analyze player activity

Advertisers or advertising intermediaries may obtain this personal data via cookies and other similar tracking technologies, as explained in our Cookie Notice. If you do not want to see tailored in-application advertisements, please view Your Rights below or visit the applicable Cookie Notice.

​

Additionally, you can prevent your device’s ad identifier from being used for interest-based advertising, or you can reset your device’s ad identifier by adjusting your device settings. Although these settings may vary by device, they are typically found under “privacy” or “ads” in your device’s settings.

​

Please note, after clicking on a third-party advertisement or offer, you may no longer be on a website or app controlled by Cypher Games or the social network via which you are playing Cypher Games’ games. If you have any questions about how these third-party services use your personal data, you should review their policies and contact them directly.


D. Authorized Persons, Institutions and Organizations

​​

Depending on compliance with a legal obligation, or legal demands of authorized persons, institutions and organizations, we may share your personal data with the public authorities.

Personal Data
​​

Identification data (first name and surname)

 

Transaction security information (IP address, device model and brand, operating system and version, device language, user ID, user contract confirmation record)

 

Details about the platforms that you use (Apple Store, Google Play)

​

Your approximate location
 

Links to your profiles on various social networks and social network ID number

 

Information related to any purchases you make in our Services (user ID, amount of expense and package information)

Legal Basis

Cypher Games’ legal obligations, in particular relating to provide information to authorized persons, institutions and organizations

Purposes of Processing Your Personal Data
 

Providing information to authorized persons, institutions and organizations

 

Execution of activities in compliance with the legislation

E. Third-Party Service Providers

​

We will share your personal data with third parties who perform services on Cypher Games’ behalf for the purposes of hosting services, and security of our Services, and our third-party business partners who assist Cypher Games for the purposes of delivering and optimizing our Services.

 

3. Your Rights
 

Your rights on data protection are explained below. These rights apply to personal data about you, and their scope and applicability can vary across different regions. For example, they could extend to your household or a legal entity or could be exercised by you or by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times.

 

Subject to certain exemptions, you have the right to:

  • access to your personal data,

  • rectification of your personal data;

  • erasure of your personal data (subject to any Cypher Games’ needs that should be justified, to retain personal data, for example, with respect to its legal obligations);

  • restriction of processing of your personal data (subject to limitations provided in applicable regulations);

  • object to the processing of your personal data (subject to limitations provided in applicable regulations);

  • withdraw your consent if the processing of your personal data was based on your consent;

  • portability of some of your personal data (subject to limitations provided in applicable regulations);

  • provide Cypher Games with instructions regarding the use of your personal data after your death.

 

If you remove or delete our games from your mobile device, we will no longer gather personal data through them, and any information related to our Services stored on your device—including your game progress—might be erased. However, please note that we may continue processing any personal data collected from you prior to the removal. In addition, you can reset your mobile advertising identifier via your device’s settings, which will cause you to be recognized as a new user by us and our advertising partners, with no ties to your previous activity or data.

 

If you decide to deactivate your account, you can disconnect your Facebook/Google/Other Third-Party Platform accounts from our mobile games and uninstall the games from your devices. Keep in mind that completely deactivating your account will result in the loss of all your game progress and any unused virtual items, which may not be recoverable in the future. Moreover, any personal data gathered from you before the deactivation may still be processed by us.

 

If you enable push notifications on your device, our mobile apps may occasionally send you updates and other relevant notices. You can opt out of receiving these messages at any time by adjusting the appropriate settings on your mobile device.

​

4. Our Global Operations

​

Cypher Games operates globally to provide the Services users worldwide with a better experience. It means that we can process personal data in connection with your use of the Services in places outside the region where you reside. The data protection laws in these countries may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate.

 

A. ​Data Transfers

 

a. European Economic Area Union, United Kingdom, and Switzerland

​

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, Cypher Games processes personal data under the General Data Protection Regulation and applicable laws. Cypher Games takes appropriate measures to ensure that all transfers of collected personal data outside of the EEA, the UK, and Switzerland meet the requirements of applicable EU and UK data protection legislation. You can see the Privacy Notice for the users who are residing in the UK.

 

b. United States

​

If you are a Nevada resident, you may be able to exercise additional rights to opt out of future sales of certain covered information that a website operator has collected or will collect about you. If you are a California resident, you may be able to exercise additional rights about personal data protection granted by the California Consumer Privacy Act (subject to certain limitations). You may have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (2) request deletion of your personal information; (3) opt out of sale of your personal information (if any); and (4) not be discriminated against for exercising these rights.

 

c. Canada

​

If you are a Canadian resident, Cypher Games processes your personal data under the privacy regulations in Canada and with respect to the information explained in the sections of this Privacy Notice.

​

You may exercise your rights by submitting a request by using the Contact Us channels below.

​

5. Security of Your Information

 

We implement reasonable and appropriate security measures in order to preserve the security, integrity, and confidentiality of your personal data and, in particular, to protect such personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to it in accordance with this Privacy Notice.

 

Where you access our Services via another account (for example, a social network) please keep that account information secure as well.

 

6. Our Policies Concerning Children

 

Our Services are not marketed to or intended for children. For these purposes, we use the term “children” to refer to someone who is: (a) under 12 years old or, if older, (b) between 12 and 18 years old but under the age at which they can give valid consent to processing of their personal data under applicable data privacy laws. Cypher Games strives to follow the different minimum age guidelines set by the laws of individual regions when determining the age which children can access certain features of our Services.

 

Children are not permitted to use our Services, and we do not knowingly collect any personal data from children. Though our Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. If we learn that we have inadvertently obtained personal data about a child that is not subject to an exemption under any applicable privacy law, we will take measures to promptly remove that personal data from our systems. In this context, if a child under the age of 12 provides us with personal data, the child's parent or guardian may request we remove the personal data from our systems. Please contact us if you know that we are processing any personal data of or relating to children. If we learn that a user is not yet a minor, we may change the personal data processing to comply with applicable law.

 

Parents can manage chat, in-app payments, and other select features through the parental control settings in the “Settings” menu. Once activated, these controls can only be modified with a pre-set password.

​

7. How Long We Keep Your Information

​

Cypher Games undertakes not to keep your personal data beyond the period strictly necessary for the purposes for which it was collected and in accordance with the applicable regulations, as well as any laws and regulations, including taxing and accounting.

 

Cypher Games undertakes to anonymize or delete your personal data as soon as the purpose and/or the duration of their established retention expires.

 

After having served its main purpose, personal data may be archived for auxiliary purposes, such as researching,

investigating, and prosecuting criminal offenses, ligation, or accounting and tax purposes. Archiving implies that this personal data will be subject to limited access restrictions.

 

8. Contact Us

​

If you wish, you can deliver your requests about processing your personal data,

  • By applying to Cypher Games directly with a valid identity card,

  • By sending to Cypher Games address “1401 Pennsylvania Ave, Unit 105, Wilmington, Delaware 19806, USA” together with wet signature and ID photocopy,

  • By sending via e-mail address (privacy@cyphergames.com) belongs to Cypher Games with the petition signed by secure e-signature or mobile signature.

 

You should express in a clear and understandable way what is requested in the application, which you will make to practice rights mentioned above. Information and documents related to the application should be attached to the application. Although the subject of the request must be related to the person of the applicant, if acting on behalf of the data subject, the applicant must be specifically authorized in this regard, and this authority must be documented (special power of attorney). Requests made by unauthorized third parties on behalf of data subjects shall not be valid.

 

9. Changes to Our Privacy Policy

​

We may update our Privacy Notice from time to time. When we do, we will revise the “last updated” date at the top of the policy. If we make changes that we deem material, we will use reasonable efforts to notify (such as by placing a notice in-game or on Cypher Games or by sending you a notice to the e-mail address you have registered with us, if any). We encourage you to periodically check Cypher Games and this Privacy Notice for updates. If you would like a copy of earlier policies, please get in touch using the Contact Us information above.

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