(Last updated on May 22, 2018)
This Privacy Policy is designed to provide
clarity about the personal information and data SNG Bilişim Yazılım Danışmanlık ve Pazarlama Dış
Ticaret Limited Şirketi and/or any of its agents, consultants, employees, officers and directors
(“SNG”, “its”, “our”, “we”) collect, how it is collected, why it is being processed, how and
where it is used, how long it is being retained, and whether it is being shared with any other
parties. By installing and playing a game or any other application provided by SNG on the Apple
App Store, Google Play App Store, or Facebook, you give your explicit and informed consent to
the processing of your personal information in accordance with this Privacy Policy and Terms of
Service.
As per definition, “personal data is any
information relating to an individual, whether it relates to his or her private, professional or
public life. It can be anything from a name, a home address, a photo, an email address, bank
details, posts on social networking websites, medical information, or a computer’s IP address.”
Information We Collect
SNG collects data from you, through your
interactions with our games. SNG facilitates third-party advertisement, tracking and analytics
services and these services also collect both non-personal and personal data.
First type of data we collect is the Process
Data acquired through your direct interaction with our game. This data is related solely to your
progress at our games and you cannot be personally identified through this type of data. Thus,
this type of data is non-personal. Non-personal information includes technical information,
behavioural data and statistical data. Also, we do not ask of you to submit any personal
information at any of our games as they do not require registration. Third-party services might
also collect non-personal information. Non-personal Information collected by third-parties may
include the following technical information: type of operation system (e.g. Android, iOS, etc.),
type of browser (e.g. Explorer, Firefox, Chrome, Safari, etc.), screen resolution (e.g. 800×600,
1024×768, etc.), language (e.g. English), device type (e.g. Galaxy, HTC, iPhone, etc.),
geo-location – only general location may be collected.
However, third-party advertisement, tracking and
analytics services that we use, and Google and Facebook, if you use your Google and Facebook
accounts to play one of our games, may have access to personal information such as your device
identifier, MAC address, IMEI, location (specific location where a given language is spoken),
geo-location information, and IP address for the purpose of providing their services under their
respective privacy policies. SNG does not have control over these third parties and has access,
as provided by these services, to the collective, anonymous data.
Exceptions to majority of our games are Gin Rummy
Online and Pişti Online games. As these games both require online interaction of real people,
registration of users and retainment of collected information is necessary. At Gin Rummy Online,
Game Sparks’ service is used. Only personal information collected at Gin Rummy Online are
Facebook or Google identities, depending on login preference of the user, public profile
information like friends list, profile picture and name of the user, and geo-location (city,
country). At Pişti online, Facebook id, public profile information like list of friends, profile
picture and name of the user are collected as data.
How Do We Collect Information
As mentioned, we work with
third-party advertisement and analytics services. Below a concise list of such services, type of
personal information they collect, and a link to their own Privacy Policies, if there is one is
provided. Links to their own Privacy Policies are embedded on the name of each service provider.
We might use one or more of these services at our different games.
Analytics:
Service Provider |
Personal Information |
Google Analitics |
Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA,
for example) and Usage Data |
Flurry Analytics |
Various types of Data as specified in the privacy policy of the service |
Admost Analytics |
Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA,
for example) and Usage Data |
Fabric |
Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA,
for example) and Usage Data |
Crashlytics |
geographic position, unique device identifiers for advertising (Google Advertiser ID
or IDFA, for example) and various types of Data as specified in the privacy policy
of the service |
Firebase |
Various types of Data as specified in the privacy policy of the service |
Advertisement:
Service Provider |
Personal Information |
Applovin |
Cookies and Usage Data |
Google AdMob |
Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA,
for example) and Usage Data |
Google Adsense |
Cookies and Usage Data |
Unity Ads Privacy |
Cookies and Usage Data |
Facebook Audience Network |
Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA,
for example) and Usage Data |
Chartboost |
Cookies and Usage Data |
Mopub |
Cookies and Usage Data |
Tapjoy |
Cookies and Usage Data |
Fyber |
Cookies and Usage Data |
Heyzap |
Cookies and Usage Data |
If you contact us directly, such as to request
information, report a bug, or for Customer Support, we may receive additional information about
you, such as your contact information and the contents of your communication.
Why Do We Collect Information
Process Data is collected to
record your progress in our games. It is only functional and has no analytical purpose.
SNG uses third-party advertisement and
analytics services. Data is collected by these services. In return, they provide us with
anonymous statistical data. This statistical data is analysed and bugs, flaws in the flow of
games are corrected. All of our games are shaped according to the users’ preferences in order to
give a more fulfilling and fun experience to them.
SNG will use your information to communicate
with you, including to respond to your inquiries and to send emails to an email address you
provide to us for customer-service or technical-support purposes.
Where and How Long Do We Retain Information
SNG does not retain
any kind of information, except for Pişti Online, where the data collected is retained at
secured servers. Information collected at Gin Rummy Online is retained ad Game Sparks servers.
Both data are retained for the duration necessitated by the law, or until user’s request for
erasure is granted. The data related to our other games you use, Process Data, is retained at
your own device. They are kept at your device until you delete the game from your device.
Analytical data collected through third party advertisement, tracking and analytics services is
retained by those services themselves. We have no control over this data and have limited access
to the anonymous data provided by these services. Duration of this data’s retainment is at these
services’ discretion.
Do We Share Information We Collect
SNG is not a data mining
company and we do not share your information with any other third party. On the other hand, the
third-party services that we use at our games might share the personal information they collect
with other parties under the conditions put forward at their own Privacy Policies. We do not
disclose any part of your information unless it is required by law. We may disclose information
about you: (i) if we are required to do so by law, regulation, or legal process, such as a court
order or subpoena; (ii) in response to requests by government agencies, such as law enforcement
authorities; (iii) when we believe disclosure is necessary or appropriate to protect against or
respond to physical, financial or other harm, injury, or loss to property; or (iv) in connection
with an investigation of suspected or actual unlawful activity. SNG may further disclose your
Personal Information with your consent.
Your Rights
You have the right to access your personal data and
information about how this personal data is being processed.
You have the right to request erasure of
personal data, which we retain at our own servers, related to you.
Not all of our games are intended for
children under the age of 13 and we do not knowingly collect any personal information from such
children. SNG cannot be held liable in case a child under the age of 13 uses one of our games
with certain age limitations and his/her personal information is collected. In the event that we
learn we have inadvertently gathered personal information from children under the age of 13, we
will take reasonable measures to promptly erase such information from our records.
Contact Us
If you have any questions, comments or concerns
regarding our Privacy Policy and/or practices, please send an e-mail to support@sngict.com.
SNGICT
Üniversiteler Mah. İhsan Doğramacı Blv.
ODTÜ/Teknokent
Çankaya, Ankara, Turkey 06800
Updates to this Privacy Policy
We will post any adjustments to this Privacy
Policy on this page, and the revised version will be effective when it is posted. If we
materially change the ways in which we use or share Personal Information previously collected
from you through our products, we will notify you through our product, by email, or other
communication.