Last Updated: January, 2, 2023

We have the utmost respect for your privacy and understand you care a lot about your personal information. Accordingly, MIDLUND YAZILIM ve TASARIM A.Ş (collectively, “Midlund”, “us”, “our” or “we”) provides this Privacy Policy (this “Policy”) to describe the types of personal information we may collect online and the ways we collect and process personal information of our users (“users”, “your” or “you”), in connection with the Midlund website and any of our applications provided on a mobile platform (each a “Service”, collectively, the “Services”).

General

This Policy does not apply to the practices of third parties that Midlund does not own or control.

This Policy is merely informative about how Midlund collects, stores, uses and discloses your personal information. We are not asking you to consent to this Policy. If we require your consent, we will ask for it in a separate notice and consent forms. Please not that if you provide us with consent, you have the right to withdraw this consent at any time by contacting us at info@midlundgames.com.

BY USING THE SERVICES, YOU EXPRESSLEY AGREE TO THE COLLECTION, STORE AND USE OF YOUR INFORMATION, IN ACCORDANCE WITH THE TERMS OF THIS POLICY. If you do not agree to the terms and conditions set forth herein and in our Terms and Conditions, please do not use the Services. Unless otherwise defined in this Policy, terms used in this Policy have the same meanings as in our Terms and Conditions.

Data We Collect

We do not collect or use information that identifies you personally (i.e., name, address, e-mail, phone number, etc.). However, we do collect and process certain identifiers of our users that your mobile device or browser sends, which does not identify you personally, rather it simply enables us to compile statistics about our users and their use of the Services, and to enable advertisers working with us to improve the compatibility of their ads to their target audience. Such usage data may include information such as the following:

  • Your device and browser data. Your browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
  • Cookie information. Your country, regional and language settings, time zone setting, the type of mobile device you use, your mobile device unique ID, your mobile operating system, mobile carrier, the screen size or processor of your device, the type of mobile internet browser you use, browser plug-in types and versions, page response times and download errors. Please see the Cookies section below for more information about the information we automatically collect about you.
  • Gameplay data. Data pertaining to your activities on our applications and notably the way in which you interact with them (for instance, how and when you use the applications, session time, in-app purchases, install timestamp, etc.) and with the advertisements we display (for instance, time spent on them, potential clicks, etc.). We never receive your payment or credit card information.
  • Advertising ID. Identifier for Advertisers on Apple and Google Advertising Identity, or other unique identifiers that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking.

If you contact us via email (e.g., to contact customer support), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We may use your personal information submitted in your communications to contact and respond to you.

Purpose of Use

The data we collect, and process is used to:

  • Provide our applications;
  • Guarantee use and improvement of our applications;
  • Provide game updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Services, and administering the applications;
  • Develop new applications;
  • Understand your preferences and provide you with new game content and services, tailor our products;
  • Understand your centers of interests and, thanks to this profiling, propose you targeted and relevant advertisements (SDK advertising);
  • Make statistics on your use of the games, including the number of games played, your duration of use or the advertisements you are watching, which allows us to improve your gaming experience (analytical SDK).Communicate with you, notably when you contact us by any means whatsoever.

Under the data protection laws applicable, we must have a legal basis to process your personal data. By using the Services, your consent to collect and process your personal data is provided. Should you choose to provide your consent, you may later withdraw your consent from the “Settings” page in our various applications. Please note that the withdrawal of consent will not affect processing which has already occurred. You may notify us at any time if you do not wish to receive promotional communications by emailing us at the address set forth at the “Contact Us” section or by clicking “unsubscribe” in the relevant message.

Cookies and other Tracking Technologies

We may use server log files and data collection tools, such as cookies, web beacons, tags, scripts,  and other similar tracking technologies to track the activity on our Services in order to enhance your experience when you access or use our Service. These Data Collection Tools automatically track and collect certain technical information from your computer or device, such as your browser types, browser language, referring and exit pages, URLs, platform type, the number of clicks, domain names, landing pages, clickstream data, pages viewed and the order of those pages, the amount of time spent on particular pages, game information and the date and time of activity on our Service, and other similar information.

By using our Services, you consent to our use of cookies web beacons, tags, scripts, and other similar tracking technologies.  We use cookies, web beacons, and Data Collection Tools for a variety of reasons, including to:

  • Analyze the usage of our Service
  • Provide a more personalized experience
  • Manage advertising
  • Help make your use of our Service more efficient and more valuable by providing you with a customized experience and recognizing you when you return.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Use of Your Data by Third Parties

Our Services contain third party tracking and data collection and analytics tools from our service providers. Such third parties may use cookies and SDKs in our Services to enable them to collect and analyze user and device-related data and information on our behalf. The third parties may have access to and collect data and information about you. Such information includes, but is not limited to the following:

  • Application usage, access, and session times;
  • Your viewing of and interactions with advertising;
  • Device manufacturer, model, and operating system;
  • Device properties related to screen size and orientation;
  • Mobile carrier; Country, time zone and local settings (country and preferred language);
  • Network connection type and speed;
  • IP address;
  • Internet browser used to access the Services Identifier for advertisers (IDFA).

Our Data Processors and Sub-processors

We also use these companies to automatically collect data from you, provided you gave your consent, when you use our apps in order to help us identify the advertising that are served to you and what you do after seeing those advertising. In addition, we share data with providers of analytic services which we use to analyze your use of our apps. Below is a list of third parties we use on our Services:

The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.

Data Sharing

Except as set forth in this Policy, Midlund does not share your personal information with any third parties. We may share your information with third parties in the following circumstances:

  • To our affiliates and service providers that perform, support and provide the Services on our behalf.
  • For analytics and research purposes, in order to analyze our Services and their performances.
  • By virtue of legislation, as part of legal proceedings, a dispute and/or request issued by the competent courts and/or regulatory authorities.
  • If disclosure is necessary for national security, application of legislation or any other matter of public interest.
  • In the event of restructuring, transfer, merger or sale to the third party concerned.
  • In order to protect and defend our legal rights or property.
  • In order to prevent or investigate possible wrongdoing in connection with the Services.
  • In order to protect the personal safety of users of the Services or the public.
  • In order to protect against legal liability.
  • We may share anonymized information about you with advertisers, publishers, business partners, sponsors, and other third parties

The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.

Data Transfer

We may transfer your information outside your country of residence, including possibly to countries that do not provide a level of data protection equivalent to your country of residence. we implement appropriate safeguards to protect the personal information that we transfer in accordance with applicable data protection requirements. Where required by law, we put in place standard contractual clauses to protect your personal information.

Privacy Rights

You have certain rights in connection with your information and the manner in which we handle it. Some of these rights may be subject to some exceptions or limitations. The following is a non-closed list of privacy rights you may exercise:

  • Right to Access Your Information. At any time, you may contact Midlund at the address provided in the “Contact Us” section herein, and request to access the information that Midlund holds about you.
  • Correcting Your Information. Midlund may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, please provide Midlund with the necessary information in order to correct it.
  • Withdrawing Your Consent. You are entitled to contact us if you would like to withdraw your consent to the processing of your information. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.
  • Deleting or Restricting Access to Your Information. You may request to delete or restrict access to your information. We may postpone or deny your request if your information is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why. If you have any concerns about the way we process your information, you are welcome to write to us at the address set forth in the “Contact Us” section. We will look into your request and make good faith efforts to resolve any concern you may have.

Data Retention

We retain your information for as reasonably necessary in accordance with applicable law. Generally, for as long as needed to provide you with our Services and for an additional period of 7 years from the end of the Services in case we need to resolve any dispute before the competent courts and authorities, unless we are required by law to delete it or if we accept your request to delete the information. The data collected by cookies or related-tracking technology are kept for a maximum of [13] months.

Security

Midlund takes reasonable measures to protect your information from loss, theft, misuse and unauthorized access, disclosure or any form of unlawful use. Although we make good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee its absolute security.

Third Party Sites and Services

Our Services may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites, services or products. The scope of this Policy is limited to information and data collected or received by us through your use of the Services.

Children’s Privacy

Our Services do not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from Children without the consent of their parent or guardian. If you are a parent or a guardian and you are aware that your Child has provided us with personal information, please contact us. This is also relevant if the age of legal majority where you reside has an older age of majority. If we become aware that we have collected personal information from Children without verification of parental consent, we will take reasonable steps to remove or cease any use of that information.

Changes to this Policy

We may update this Policy at any time. We will notify you of any changes by posting the new Policy on this page. You are advised to review this Policy periodically for any changes, notably pursuant to legal and/or regulatory provisions. Changes to this Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this policy, please contact us: