1) Who is responsible and how to contact us

Nevzat Atilla Ozder
Cavus Mah. Muhtesem Sk. 6B/16 Sile / Istanbul, Turkiye
Telephone: +90 539 389 06 22
Email: support@atillaozder.com

Nevzat Atilla Ozder operates the services described here and determines which personal information is processed, why it is used and which providers receive it. He is the data controller for that processing.

2) App-specific services

The table below identifies the services used by each app. Requests depend on feature availability and relevant settings. Kid Doodle’s separate Children’s Privacy Policy covers its data practices, not the advertising description below.

Advertising partners and optional integrations do not all receive every category of information. The feature-specific descriptions below explain their purposes. The table does not classify each app as suitable for every age.

3) Information processed

A) Identifiers and technical information

Depending on the app, we and its providers process app-instance or user identifiers, device identifiers, IP address, device model, operating system, app version, language and related connection information. IDFA is available only with Apple ATT authorization. ATT does not control every other identifier or replace separately required consent.

B) Usage and analytics

Advertising and analytics services process interactions, screens, sessions, crashes, performance, advertising impressions or clicks, and applicable purchase events. In MineColor, InkBlox, Colortnite and Brawl Art, entered profile/display names are also included in Firebase analytics events; those events can contain up to the first 100 characters of the entered name. Do not include unnecessary private information in a display name.

For participating apps, page-view, favourite, completed-colouring-session and unlock events reach our server with app/page identifiers and times. The iOS app sends its vendor identifier, IDFV; our server receives it and stores a salted hash with the event record to limit duplicates and misuse and measure page popularity. Hashing is not a promise of anonymity.

C) Profiles, online rooms and content

Çakmak can create an anonymous technical Firebase account when you join an online room without asking you to register with a name/password. Online rooms process and share the display name, optional avatar, user/player identifiers, premium status, game state, messages, reactions and presence needed for room play. Other people in the room can see information supplied there. Firebase identity, room records and analytics/subscription records are distinct services.

D) Purchases

Apple or the applicable Store processes payments; we do not receive payment-card details. Purchase reporting can include product, transaction, price, currency and subscription information. MineColor, InkBlox, Colortnite and Brawl Art record purchase events through Firebase; Çakmak uses RevenueCat for subscription reporting and Apple Search Ads attribution. Kid Doodle’s own-server purchase verification and credit records are described in its separate children’s policy.

E) Notifications, cloud and sharing

Where an app uses Firebase Messaging, its push token and relevant topics can be processed for notifications; topics may reflect language, region or subscription tier. Cloud sync or Game Center uses Apple’s services when enabled. Choosing a social or system sharing destination sends the content and technical information needed by that destination. Installed integrations and available share buttons vary by app.

F) Support and website visits

If you email us, we receive the address, message and attachments you send. Our hosting and delivery providers receive connection/request information needed to serve and secure atillaozder.com and app resources, such as IP address, time, app/browser information and requested resource. The website loads Google Fonts; Google receives the connection information needed to supply the fonts. Authentication/security cookies may be used where those functions require them. The app advertising services described here apply to the apps identified in section 2. Website processing is described separately in this policy.

4) Information boundaries

We do not ask for payment-card details, government identifiers, biometric identifiers or health data as part of these described features. Information voluntarily entered into profiles, rooms, sharing or support can still contain personal information. Some services assign account identifiers automatically, even when you do not register.

5) Why information is used

• Provide the requested app content, online rooms, purchases and supported features.
• Measure use, diagnose faults, improve performance and plan content.
• Deliver and measure advertising where offered and permitted.
• Limit abuse, secure services and prevent duplicate or fraudulent events.
• Respond to support/privacy requests, meet legal duties and handle legal claims.

6) Legal grounds and Türkiye notices

We process information necessary to fulfil contracts and meet legal obligations. We rely on legitimate interests for necessary service delivery, security and support, subject to your rights.

A parent’s contract does not automatically establish a basis for a child’s information. You can contact us about processing affecting you and exercise the Article 11 rights in section 15.

Where KVKK requires notification, we notify the Personal Data Protection Board without delay and within 72 hours after becoming aware of unlawful acquisition of personal data. We notify affected individuals as soon as reasonably possible after identifying them.

7) ATT and advertising choices

Where an app requests tracking authorization, it uses Apple’s ATT interface. We do not access IDFA or perform tracking requiring ATT unless authorized. Available Google UMP messages and privacy choices depend on the app, region and service configuration. Device permissions do not replace any separate consent required for processing. Contact us about the privacy choices for your app.

8) US privacy choices

Disclosures to advertising providers may constitute sale or sharing under applicable US privacy laws even without a payment for the data. You can contact us to exercise applicable opt-out and other privacy rights; the available in-app controls depend on the app. We do not discriminate against you for exercising rights. We handle applicable requests and legally recognized preference signals as required by law.

9) Recipients

Providers process information on our instructions where they act as processors; some services also process data independently under their own terms. Our use of providers does not remove our responsibility for our processing.

• Google Firebase: the analytics, diagnostics, configuration, messaging, identity or room services identified for the app.
• Google: AdMob/UMP where integrated, and Google Fonts for website delivery.
• Advertising integrations, where enabled: AppLovin, Meta, IronSource/LevelPlay and Unity.
• RevenueCat and its DPA: Çakmak’s purchase reporting and attribution. Kid Doodle’s separate purposes are explained in its children’s policy.
• Apple: Store purchases, Game Center, optional diagnostics and cloud features.
• Sharing destinations you choose, including TikTok where an app offers it and the system share sheet.
• Hosting/content-delivery providers, including DigitalOcean for applicable file delivery, and email services used for support.

We also disclose information where legally required or reasonably necessary to protect rights, prevent misuse or address legal claims. Business transfers remain subject to applicable privacy obligations.

10) International processing

We are based in Türkiye. Our app servers and file storage are in the United States. The service providers identified in this policy may also process information in other countries. Contact us for information about processing locations and safeguards.

11) Retention

We keep service records to provide requested services, measure use, account for purchases and prevent misuse. Retention depends on the type of record, its purpose and any applicable legal requirements. Page-event records on our server are deleted after 60 days. We keep support emails only as long as needed to respond and for record-keeping, disputes or legal requirements. You can ask us to delete them at any time. We may retain statistics that cannot be linked to an individual. You can request deletion at support@atillaozder.com. We may retain limited records where required by law.

Google Analytics is configured with a 14-month retention period for user- and event-level data covered by this setting. The setting does not affect standard aggregated reports. New activity restarts the retention period for user-level data.

12) Security

We use reasonable administrative, technical and organizational measures to protect information we process. No transmission or storage system is completely secure, and we cannot guarantee absolute security.

13) Browser and device signals

You can manage some choices through your browser or device settings, such as an app’s tracking permission. If the choice you want is not available in your app, contact us.

14) Children and age restrictions

Kid Doodle is designed for young children and has a separate Children’s Privacy Policy. Other apps have their own age ratings, shown on their Store listings. Please follow them, including the age restriction for Çakmak. Parents or guardians can contact us to review concerns or request access/deletion relating to a child.

15) Rights and requests

Where applicable, you may request access, correction, deletion, restriction, portability or object to processing. Where processing relies on consent, you can withdraw it at any time using the available privacy choices or by contacting support@atillaozder.com. Withdrawal does not affect processing that was lawful before it. You may complain to a competent regulator without contacting us first.

Türkiye — KVKK Article 11

• Learn whether personal data is processed and obtain information about it.
• Learn its purposes and whether use is consistent with them; know recipients in Türkiye and abroad.
• Request correction and, where applicable, deletion or destruction, and notification of those steps to recipients.
• Object to an adverse result from exclusively automated analysis and seek compensation for unlawful processing.

Send requests to support@atillaozder.com with the app and enough information to locate the relevant records. We ask only for information reasonably needed to verify and handle your request and respond within applicable legal deadlines. For UK data-protection complaints, we acknowledge receipt within 30 days, investigate without undue delay and communicate the outcome.

16) External links

Independent services you choose to visit have their own terms and privacy practices. Our use of processors does not remove our obligations for our own processing.

17) Updates

We may update this policy and post the revised version with a new "Last updated" date. We notify you of material changes as required by law and obtain any new consent required before changing how we use personal information. Updating this policy does not itself provide consent for additional processing.

18) Contact

Nevzat Atilla Ozder
Cavus Mah. Muhtesem Sk. 6B/16 Sile / Istanbul, Turkiye
Telephone: +90 539 389 06 22
Email: support@atillaozder.com

For Kid Doodle, contact support@kiddoodle.app.