Privacy Policy

Last updated: March 19, 2026

This Privacy Policy explains how Nevzat Atilla Ozder ("we", "us", "our") collects, uses, shares, and protects information when you use our mobile games (the "Apps") and when you visit our website (the "Site").

We publish multiple Apps over time. This Policy applies to all Apps we publish unless an App displays a different privacy policy.

1) Data Controller (who is responsible)

2) Quick summary

3) What information we collect

We and our service providers may collect the following categories of data depending on your device settings and how you use the Apps:

A) Identifiers (including "User ID" / "Device ID")

Important clarification: "User ID" here refers to an SDK/app identifier, not your Apple ID. We do not ask for or collect login credentials in the Apps.

B) Usage Data (including "Product Interaction", "Advertising Data", and "Other Usage Data")

Firebase features used: Analytics, Crashlytics, Performance Monitoring, Remote Config, Messaging.

Important: We do not send user-provided text to analytics events.

C) Diagnostics

D) Location

E) Push notifications (optional)

F) Purchases (In-App Purchases)

4) What we do not collect

We follow data minimization principles and collect only the information reasonably necessary for the purposes described in this Policy.

Based on current App design, we do not collect:

5) How we use information

We use information to:

Profiling / automated decisions: Our advertising partners may use limited profiling to show relevant ads (where permitted). However, we do not use automated decision-making that produces legal effects or similarly significant effects on you (for example, decisions about your legal status, credit, employment, or eligibility for essential services).

6) Legal bases and processing grounds (GDPR/UK GDPR and Turkiye KVKK)

A) For users in the EEA/UK (GDPR / UK GDPR)

We process personal data under these legal bases:

B) For users in Turkiye (KVKK - Law No. 6698)

For users in Turkiye, we process personal data in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK") and related legislation and decisions of the Personal Data Protection Authority. Your rights under KVKK are described in Section 15.

We obtain granular consent (opt-in) for specific processing purposes as required by KVKK. Cross-border transfers of personal data comply with KVKK requirements, including obtaining explicit consent where required by law or relying on other lawful transfer mechanisms recognized by the Personal Data Protection Authority.

VERBIS note: Depending on our scale and legal criteria, we may have an obligation to register with the Data Controllers' Registry (VERBIS). If registration is required for us, we will comply. (Even if registration is not required, KVKK obligations may still apply.)

Enforcement note: In accordance with updated enforcement requirements (including Decision No. 2025/2451), we will notify the Personal Data Protection Authority within 72 hours of becoming aware of any data breach, and affected individuals as soon as possible thereafter.

7) App Tracking Transparency (ATT), IDFA, and ad personalization

8) U.S. state privacy laws (opt out of targeted ads)

Some U.S. state privacy laws provide the right to opt out of the "sale" or "sharing" of personal information for targeted advertising (also called cross-context behavioral advertising). This includes rights under the California Consumer Privacy Act (CCPA/CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and similar laws in other U.S. states.

You can control targeted advertising in these ways:

Note: If you do not see the in-app privacy message in your region/device scenario, you can still email us for help and opt-out handling. We do not discriminate against users for exercising privacy rights.

9) Sharing of information

We do not sell or share (as those terms are defined under CCPA/CPRA) your personal information for monetary or other valuable consideration, including for cross-context behavioral advertising. We may share information with:

A) Service providers (processors)

We use third-party services to provide analytics, diagnostics, ads, and messaging. These providers process data under their own policies and/or on our behalf.

While we select service providers with care, each provider processes data under its own privacy policy and terms. We are not responsible for the independent data processing activities of our third-party service providers beyond what is required by applicable law.

B) Legal and safety reasons

We may disclose information if reasonably necessary to comply with law, respond to lawful requests, protect users, prevent fraud/abuse, or enforce our terms.

10) International transfers

Our servers and/or our service providers' servers may be located in the United States and other countries. This includes processing by partners such as Google (Firebase/AdMob) and Unity (Unity Ads), as listed in Section 9.

If you are in the EEA/UK, transfers outside your region may be protected by safeguards such as Standard Contractual Clauses (SCCs) or other lawful transfer mechanisms, depending on the provider and circumstances.

For users in Turkiye, cross-border transfers are conducted in accordance with KVKK requirements, including obtaining explicit consent where required by law or relying on other lawful transfer mechanisms recognized by the Personal Data Protection Authority.

11) Data retention

We keep information only as long as needed for the purposes described in this Policy:

12) Security

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect information. No method of transmission or storage is 100% secure.

13) Do Not Track signals (DNT)

Our Apps are mobile applications and do not respond to web browser "Do Not Track" signals.

14) Children's privacy

Our Apps are intended for general audiences and are not designed to knowingly collect personal information from children under 13. If you believe a child provided personal data to us, contact support@atillaozder.com and we will take appropriate steps (including deletion where feasible).

Children's Privacy Policy: Click Here

15) Your rights and how to exercise them (GDPR/UK GDPR and KVKK)

A) EEA/UK users (GDPR/UK GDPR)

Depending on your location, you may have rights such as access, correction, deletion, restriction, objection, portability, and the right to withdraw consent. You may also have the right to lodge a complaint with your local data protection authority.

B) Users in Turkiye (KVKK - Law No. 6698, Article 11)

For users in Turkiye: You have rights under Article 11 of KVKK, including (among others) the right to:

C) U.S. residents

If you are a resident of a U.S. state with applicable privacy legislation, you may have the following rights:

We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law.

To exercise these rights, see the instructions below or refer to Section 8 for opt-out methods.

How to exercise rights (email only)

To exercise your rights, email support@atillaozder.com and include:

No account deletion note (Apple)

We do not create user accounts in our Apps. If you request deletion, we will delete or restrict personal data we control where feasible. Some data may be held by our service providers (e.g., advertising/analytics providers) under their own retention settings; we will assist by applying available controls and/or directing you to relevant provider controls where appropriate.

16) Third-party links

Our Apps or Site may contain links to third-party websites/services. Their privacy practices are governed by their own policies.

17) Changes to this Policy

We may update this Policy from time to time. We will post the updated version with a new "Last updated" date. If changes are material, we may provide additional notice (such as an in-app notice).

18) Contact