PRIVACY POLICY

As Tiplay Studio Oyun ve Teknoloji Anonim Şirketi (hereinafter referred to as “Tiplay”, the "Company", “We”, and through similar words such as “us”, “our”, etc.), we respect your privacy. We provide a website under the domain name of www.pyrmdofficial.com (the “Website”) which is an informative and insightful platform that aims introduce the basics of the game named PYRMD that is developed and owned by Tiplay and published by Steam (“Game”).

The Website (including its all subdomains, other media, features and contents) is a service made by Tiplay.

This Global Privacy Policy (the “Policy”) describes Tiplay’s practices and policies with regards to use and process of personal information while operating the Website and providing the services thereunder (the “Services”). In this regard, this Policy describes the types of personal information we collect through the Website, how we use that information, our legal basis for doing so, with whom we share it, your rights and choices in this regard, and how you can contact us about our privacy practices. This Policy does not apply to Third-Party sites, products, or services, even if they link to our Services or the Website, and you should consider privacy practices of those Third-Parties carefully.

Capitalized words not defined under this Policy shall be understood as described under our Terms of Use (the “Terms”).

By accepting this Policy, you are familiarized yourself with this Policy, understood and are agreeing with the terms and practices described in this Policy (including new versions of the Policy when and as they come into effect), and the Terms, which governs this Policy and contains all disclaimers of warranties and limitation of liabilities.

1. DEFINITIONS

Within the scope of this Policy, following terms shall have the meanings ascribed to them below:

2. OVERVIEW

Tiplay obtains personal information concerning you from various sources to provide the Services and to manage the Website.

a. The Website Visitors

If you access or visit our Website, we may collect your personal information. For example, we collect Personal Data when you contact us by e-mail or when you provide your email address for subscription (“Subscription”)

3. TYPES OF DATA WE COLLECT

a. Personal Data that We Collect from You

While using our Website or the Services, you may provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to first name and last name, e-mail address, and the Usage Data.

In particular, when you contact us via e-mail, we collect your name-surname, e-mail address, and any other information you choose to include in the body of your e-mail.

You may also opt-in to submit information through other methods, including:

• Through our social media accounts or online forums,
• In connection with a real or potential business relationship with us,
• By giving us your business card or contact information,
• In response to your marketing or other e-mail communications.

b. Information that We Collect Automatically on the Website and the Services

Our Website uses cookies and other technologies to function effectively. These technologies record information about your usage of the Website, including:

• Browser and Device Data, such as IP address, Device type, internet browser type, screen resolution, operating system’s name and version, Device manufacturer and model, language, plug-ins, add-ons, brand, model, technical specification and operating system information of the Device used, and language version of the Website you are visiting;
• Usage Data, such as time spent on the Website, pages visited, links clicked, language preferences, Website usage time, communication preferences, approaches to in-platform notifications/campaigns, habits, behaviors, preferences, search activities, segments, cookie records, cookie and ad identifiers, Device ID, and the pages that led or referred you to our Website.
• Preference information, your marketing and communication preferences, your account settings including any default preferences, any preferences you have indicated, the types of services/offers that interest you, the areas of our Services that you have visited or ways that you interact with our Services.
• Logs and Usage Data, such as time spent on the Website/Platform, pages visited, links clicked, bounce rate, roll percentage, language preferences, views, Website usage time, communication preferences, payment amount, payment channels, frequency of login, and the different types of activity undertaken by users such as frequently accessed areas of the Services, approaches to in-platform notifications/offers/campaigns, favorites, likes, search activities, segments, cookie records, cookie and ad identifiers, Device ID, and the pages that led or referred you to our Website/Platform.
• General Location Information, such as IP address and the region in which you are located when you are logging in and using the Services, in accordance with the settings on your device.

We may also collect information about your online activities on the Website and connected Devices over time and across Third-Party sites as indicated below:

Third Parties (Service Providers)

We use Third-Party Service Providers to provide certain Services on our behalf when the information is necessary for them to perform their duties.

The Third-Party Service Providers to help us better operate our platform and for services such as hosting, maintenance, error monitoring, debugging performance monitoring, customer service, database storage and management, SEO services, email automation or heat map. In some cases, these service providers may process or store personal information while providing services. When those service providers receive access to personal information, they undergo a security and privacy review to ensure they meet the necessary safeguards and implement 'the best practice' in their data processing activities. We are also committed to providing that they are contractually bound by a data protection/processing agreement that requires them to comply with applicable regulations, including having the appropriate access controls in place to protect your data.

Third Party Analytics and Advertisements

We also may use Third Party advertisements, analytics, and tracking tools to better understand who is using the Website, how people are using the Website, how to improve the effectiveness of the Services, related content, and our products, and to help us or those Third Parties serve more targeted advertising to you across our media channels. These Third Parties may use technology such as cookies, web beacons, pixel tags, log files, flash cookies, or other technologies to collect and store information. They may also combine information they collect from your interaction with the Website with information they collect from other sources, which combination may be subject to the Third Party’s control and privacy practices thereupon. For further details on how these cookies are used please refer to our Cookie Policy.

4. HOW WE USE PERSONAL DATA

a. Our Services

We rely upon several legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to comply with legal obligations, and to pursue our legitimate business interests.

Legal and regulatory compliance. We use Personal Data to verify identity of our Visitors in order to comply with laws. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties and submit to Third-Party verification audits.

Legitimate business interests. We rely on our legitimate business interests to process certain Personal Data concerning you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against legitimate interests and rights of the individuals whose Personal Data we process.

• Mitigating financial loss, claims, liabilities or other harm to Visitors and Tiplay;
• Responding to inquiries, sending service notices and providing support;
• Promoting, analyzing, modifying and improving our applications, products, systems, and tools, and developing new services;
• Managing, operating and improving performance of our Website and the Services by understanding their effectiveness and optimizing our digital assets;
• Analyzing and advertising our Services;
• Conducting aggregate analysis and developing business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our Website and the Service;
• Sharing Personal Data with Third-Party Service Providers that provide services on our behalf and business partners who help us to operate and improve our business; and
• Ensuring network and information security throughout the Website and our Services.

If we need to use your Personal Data in other ways, we will make a specific notice at the time of collection and we will get your consent if applicable law requires so.

b. Marketing and Events-related Communications

We may send you e-mail marketing communications about Tiplay, the Website and Services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable laws. When we collect your contact details through our participation at trade shows or other events, we may use such information to follow-up with you regarding an event, send you information that you have requested on our Apps, products and Services, and with your permission, include you on our marketing information campaigns.

c. Interest-based Advertising

When you visit our Website, both certain third parties and we collect information about your online activities over time and across different websites to provide you with advertising products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser. Where required by applicable laws, we will obtain your consent prior to processing your information for the purposes of interest-based advertising.

Since we also participate in advertising networks, you may see our ads on other sites or mobile apps. Ad networks allow us to target our messaging to Visitors based on a range of factors, including demographic data, Visitors’ inferred interests and browsing context (for example, time and date of your visit to our Website, pages that you viewed, links that you clicked on). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.

We work with advertising networks (Google AdWords, etc.). To learn how to opt-out from behavioral advertising delivered by Network Advertising Initiative member companies, please visit the Network Advertising Initiative and Digital Advertising Alliance. If you opt-out from interest-based advertising, you may see advertising that is not relevant to you.

5. HOW WE SHARE PERSONAL DATA

Tiplay may share your Personal Data to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our Visitors and the public.

We share Personal Data with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as website hosting, data analysis, information technology and related infrastructure, customer service, e-mail delivery, and auditing services. These Service Providers may need to access Personal Data to perform their services properly. We authorize such Service Providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such Service Providers to contractually commit to protecting security and confidentiality of the Personal Data they process on our behalf. Our Service Providers are predominantly located in the Republic of Turkey, the European Union and the United States of America.

We may disclose information in the aggregate form to third parties relating to Visitor behavior in connection with actual or prospective business relationship with those third parties, such as advertisers and content distributors.

We will encourage our service partners to adopt and post transparent privacy policies. However, use of your personal information by our service partners is governed by their privacy policies and is not under our control. You acknowledge that we are not responsible for the violations caused by our service partners.

We share Personal Data with Third-Party Service Providers when this is necessary to provide our Services to our Visitors.

We share data with parties directly authorized by a Visitor to receive Personal Data. The use of Personal Data by an authorized third party is subject to such third party’s privacy policy.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing such transaction.

We share Personal Data as we believe necessary: (i) to comply with applicable law; (ii) to protect the rights, privacy, safety and property of Tiplay, you or others; and (iii) to respond requests of the courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

6. PDPL PRIVACY

Pursuant to Article 10 of the Personal Data Protection Law numbered 6698 (the “PDPL”), as Tiplay, we would like to inform Website Visitor about our identity, our purposes of processing your personal data, to whom and why we transfer your data, our legal grounds, our processing methods and your rights regarding your use of Website in order to introduce the basics of the Game.

Your personal data processed during your Website use are;

• processed in conformity with the law, good faith and for specific, clear and legitimate purposes,
• kept accurate and up-to-date as needed,
• being relevant, limited and proportionate to the purposes for which data are processed,
• being stored only for the time we have determined in accordance with the relevant legislation.

All data types included in this Privacy Notice are shared with the provider company from which the Platform server and infrastructure services are supplied. This data transfer occurs as the servers are located within the relevant company in order to meet the need for hosting the data types we process on a server; and it does not require an active data transfer and is arising from the nature of the hosting service.

The rights within the meaning of this Information Notice and Privacy Policy you have can be summarized as follows:

You have the right to get information

• whether your personal data is processed or not,

• the purpose of processing your personal data,

• regarding the domestic and international transfer of your personal data.

You have a right to request

• whether your personal data is processed in accordance with its purpose or not,
• rectification of personal data if it is wrong or incomplete, and notification to third parties regarding the rectification,
• destruction if the relevant grounds that required the process have disappeared, and notification to third parties regarding the destruction,
• the compensation for the damages you have suffered due to unlawful processing.

You have a right to object

• to the results obtained by analysis made by the automated systems that are unfavorable to you.

You may send us your request on exercising your above-mentioned rights, together with documents providing your identity and the scope of your request through following channels:

• By sending an e-mail to info@tiplaystudio.com with or without a secured electronic signature,
• Through delivery by hand, by notary, or by certified mail to the address of of Kınıklı Mahallesi 2600 Sokak No: 9/1 Pamukkale/Denizli

We are committed to answering your request as soon as possible, not more than 30 (thirty) days, and free of charge as long as there is no transaction cost.

7. GDPR PRIVACY

Your Rights and Choices Under the GDPR

Tiplay undertakes to respect confidentiality of your Personal Data and to guarantee you can exercise your rights. In this regard, you have the following rights regarding our use and disclosure of your Personal Data, under this Privacy Policy and by law if you are within the European Union:

Right of Access: You have the right to obtain confirmation from us as to whether or not Personal Data concerning you are processed, and, where that is the case, you have the right to request and get access to such Personal Data.

Right to Rectification: You have the right to request rectification by us of inaccurate Personal Data and you have the right to provide additional Personal Data to complete any incomplete Personal Data.

Right to Erasure (“Right to be Forgotten”): In certain cases, you have the right to request from us erasure of your Personal Data.

Right to Restriction of Process: You have the right to request from us restriction of process, for a certain period and/or for certain situations.

Right to Data Portability: You have the right to receive your Personal Data from us in a structured format and you have the right to (let) transmit such Personal Data to another Data Controller.

Right to Object: In certain cases, you have the right to object process of your Personal Data, including with regards to profiling. You have the right to object to further process of your Personal Data in so far as such data has been collected for direct marketing purposes.

Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing.

Right to Filing Complaint: You have the right to file complaints with the applicable data protection authority on our process of your Personal Data.

Right to Compensation of Damages: In case we breach applicable legislation on process of your Personal Data, you have the right to claim damages from us for any damages such breach may cause to you.

Exercising Your Data Protection Rights arising from the GDPR

You may exercise your rights of access, rectification, cancellation and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond you as soon as possible.

You have the right to complain to a data protection authority about our process of your Personal Data. For more information, if you are in the European Economic Area (the “EEA”), please contact your local data protection authority in the EEA.

8. CCPA PRIVACY

Your Rights and Choices Under the CCPA

Under this Policy, and by law, if you are a resident of California, you have the following rights:

• Right to Notice: You must be properly notified which categories of Personal Data are being collected and purposes for which the Personal Data is being used.
• The Right to Access/Request: The CCPA permits you to request and obtain from the Company information regarding disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
• The Right to Say No to the Sale of Personal Data: You have the right to ask the Company not sell your Personal Data to third parties. You can submit such a request by visiting our Website and contacting through the channels provided on the Website.
• The Right to Know about Your Personal Data: You have the right to request and obtain from the Company information regarding disclosure of the following:

• The categories of Personal Data collected
• The sources from which the Personal Data was collected
• The business or commercial purpose for collecting or Selling the Personal Data
• Categories of third parties with whom we share Personal Data
• The specific pieces of Personal Data we collected about You

• The Right to Delete Personal Data: You also have the right to request deletion of your Personal Data that have been collected in the past 12 months.
• The Right not to be Discriminated against: You have the right not to be discriminated against for exercising any of your rights as a Consumer, including the following:

• Denying to provide goods or services to you
• Charging different prices or rates for goods or services, including discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to you
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your Data Protection Rights arising from the CCPA

In order to exercise any of your rights under the CCPA as a California resident, you can contact us through the channels (i.e., phone number or e-mail address) provided on the Website.

The Company will disclose and deliver the information required free of charge and within 45 days of receiving your verifiable request. The time period to provide the information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell personal information. However, the service partners with whom we have partnership (for example, our advertising partners) may use technology on the Service that "Sells" personal information as defined by the CCPA.

If you wish to opt out use of your personal information for interest-based advertising purposes and these potential Sales as defined under the CCPA, you may do so by following the instructions below.

Website

You can opt out of receiving ads that are personalized as served by our service partners by following our instructions presented on the Service:

• From Our "Cookie Consent" notice banner
• Or from Our "CCPA Opt-out" notice banner
• Or from Our "Do Not Sell My Personal Information" notice banner

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Please note that any opt out is specific to the browser you use. You may need to opt out on every browser that you use.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices

You can also stop collection of location information from your mobile device by changing the preferences on your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some Third-Party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track feature by visiting the preferences or settings page of your web browser.

9. SECURITY AND RETENTION

We are making reasonable efforts to provide you with an appropriate level of security for the risks associated with process of your Personal Data. We take organizational, technical, and administrative measures designed to protect your Personal Data against unauthorized access, destruction, loss, alteration, or abuse. Your Personal Data may only be accessed by a limited number of personnel who need access to such information in order to perform their duties properly. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have a reason to believe that your interaction with us is no longer secure, please contact us immediately.

If you are a Visitor of the Website, we retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services to you, to the extent necessary to comply with our legal and regulatory obligations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data due to our contractual commitments to our financial and business partners. Where we retain data, we do so in accordance with any limitation periods and record retention obligations that are imposed by applicable laws.

10. COOKIE POLICY

Cookies are small text files stored in a computer’s web browser memory. They help website providers to understand how people use a website, remember a Visitor’s login details, and store website preferences. This article explains how we use cookies and other similar technologies to help us ensure that our Services function properly, prevent fraud and other harm, and analyze and improve the Services in accordance with our Policy.

a. How We Use Cookies 

Cookies play an important role in helping us provide effective and secure Services. We use cookies on our Website. We change the cookies periodically as we improve our Services or add new service; however, we generally use cookies for the following purposes:

To Operate Our Services: Some cookies are essential to the operation of our Website and Services. We use those cookies in several different ways, including:

• Authentication
• Security
• Functional
• Preferences / Features/ Services
• Analytics and Research

To Analyze and Improve Our Services: Cookies help us understand how to make our Website and Services work better for you. Cookies tell us how people reach our Website, and they give us insights into improvements or enhancements we need to make to our Website and Services.

For Better Advertising: Cookies can help us provide more effective advertising on our Website. For example, we might use a cookie to help prevent you from seeing same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on.

b. How We Use Other Technologies

What are the 1st Party Cookies?

1st Party cookies are used in our Website with the purposes stated above, and in accordance with the governing law. 1st Party cookies are located in www.pyrmdofficial.com web domain and have significant importance for your usage of services provided by us. In case of a deactivation or erasing activity on such cookies, you may lack of some basic functions relevant to the Website.

1st Party Cookies We Use

What are the 3rd Party Cookies?

3rd Party cookies are the cookies that belong to the websites other than the Website with the domain name of  www.pyrmdofficial.com The purpose of these cookies is to integrate some additional features to the Website.        

3rd Party Cookies We Use

d. How to Manage Cookies

Your web browser may allow you to change your cookie preferences, including to delete and disable cookies. Please consult help section of your web browser to understand your options, but please note that if you choose to disable the cookies, some features of our Website or Services may not operate as intended.

11. INTERNATIONAL DATA TRANSFERS

 Personal Data will be stored and processed on our Service Provider servers in the European Union, United States of America and Hong Kong. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Policy. In certain circumstances; courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

12. USE BY MINORS

The Services are not directed to individuals under age of eighteen (18), and they shall not provide Personal Data through the Website or the Service. If you have a reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us.

13. UPDATES TO THIS POLICY AND NOTIFICATIONS

We may change this Policy from time to time to reflect new services, changes in our Personal Data practices, or relevant laws. The “Lastly Revised” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Website. We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our Website and by contacting you through the e-mail address you provided (if any).

14. LINKS TO OTHER WEBSITES

The Services may provide the ability to connect to other sites. These sites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you to review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of such website, or the privacy practices of the website’s operator.

15. JURISDICTION

Tiplay focuses on multinational compliance regulations including but not limited to the PDPL, the GDPR and United States State and Federal Privacy Laws,  to make sure privacy is a “go-to” rather than a thing to be worried. You have the right to request further information on our personal data processing activities based on your country's laws.

16. CONTACT US

If you have any questions or complaints about this Policy, please contact us at info@tiplaystudio.com.