Introduction
Welcome:

Boraq Group Teknoloji Medya Ticaret Limited Şirketi (“us”, “our”, “we”, “Boraq Group”) are committed to protecting and respecting your privacy.
This privacy policy (the “Policy”) sets out the types of personal data we collect and use when you access and visit boraq-group.com or when you use one of our apps or games (each a “Property” and together the “Properties”) and how we may use that data. We hope that your experience with our App will be challenging enjoyable and rewarding. Again, Welcome!

Purpose of this Policy:
This Policy covers our collection, processing and use of personal data when you use any of our Property.
When you supply any personal data to us we have legal obligations towards you in the way we use that data.
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Properties at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you first download and begin using a Property, or that may be displayed where you are given the opportunity to sign up to receive email updates from us) so that you are fully aware of how and why we are using that data.
By visiting or otherwise using our Properties, you are agreeing to the practices set out in this Policy to the extent permitted by data protection legislations. If, for any reason, you do not agree to the terms of this Policy, please stop using the Properties.

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavor to let users of the relevant Properties know. However, it is your responsibility to check this Policy before each use of the Properties for ease of reference the top of this Policy indicates the date on which it was last updated.

What is Personal Data and what do we collect?

• What is personal data?

Where this Policy refers to “personal data” it is referring to data about you from which you could be identified such as your name, your date of birth, your contact details and even your IP address.

By law all organizations in Turkey are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organizations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights.

• Data we collect from you when you use the Property
• Voluntary Provision of Data

When you voluntarily supply your personal data to us, for example where you; use the Property to upload or send personal data (by filling out a form on our website, entering your details into a profile page on one of our game Properties, contacting our customer support team, subscribing to one of our publications or newsletters, or similar activities in which you volunteer data about yourself); contact us by post, telephone, email or SMS; report a problem with a Property; we may collect, store and use the personal data that you disclose to us.

The personal data we collect from you may include your title, name, address, email address, phone number, financial and/or credit card information but will depend on precisely what details you volunteer to us as you interact with the Properties.

• Automated Collection of Data

We may also collect personal data about you when you visit a Property (in particular the Boraq Group website) through the use of technologies such as cookies. The following are examples of data we may collect:
– information about your device, browser or operating system (including unique identifiers which identify that device, such as your “Identifier for Advertising” or “IDFA”);
– your IP address and information about the network you are using to access our Properties;
– information about links that you click in Properties and pages you view on our Property
– length of visits to certain pages on the Properties;
– data about how you play our games such as your scores, progress and global ranking;
– data about purchases you make via our Properties (e.g. in-app micro transactions) including details of the purchases you have made and the value of those transactions;
– details about other users with whom you have connected via our apps (e.g. your Friend lists) and any communications you send/receive to such people;
– subjects you viewed or searched for;
– page response times;
– records of download errors and/or broken links;
– page interaction information (such as details of your scrolling, clicks, and mouse-overs);
– methods used to browse away from the page; and
– the full Uniform Resource Locators (URL) click stream to, through and from our Property (including date and time).
We use the data described above for several different reasons. Firstly, we use it to ensure that the Properties work properly and that you are able to receive the full benefit of them. Second, we use the data to monitor online traffic and audience participation across the Properties. The relevant data is processed due to the fact that it is mandatory for the legitimate interests of Boraq Group, provided that this processing shall not violate the fundamental rights and freedoms of the users.
We also use the data described above to provide a range of services to you these include answering your support queries, giving you access to in-game functions such as records of high scores, enabling you to purchase items in-game, and letting you connect with and communicate with your friends across our Properties.
Our Properties may include various functionality which lets you connect to social media (such as Facebook) if you choose to use this functionality then we will collect various data from you in order to enable those connections and to enable us to keep accurate records of the connections that you have made.

• Third Party Resources

Our Properties contain various features that serve advertisements to you. In order to make those advertisements as relevant as possible we use third party advertising networks, which collect and use details about you and your interests in order to target relevant advertisements to you (rather than showing all Property users the same material).
Where we use these services, we will give you the opportunity to disable the collection and transmission of information about you to those networks. Any such refusal will not cause you to cease seeing adverts, but it will decrease the relevancy of the adverts which are shown to you.

Sharing Your Personal Data

Depending on how and why you provide us with your personal data we may share it in the following ways:
o we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, we may share your Personal Data with our Saudi group company, which deals with customer support requests where they arise;
o with selected third parties who we sub-contract to provide various services and/or aspects of the Property’s functionality, such as where third-party plugins provide functionality such as message boards or image hosting services; and
o with analytics and search engine providers that assist us in the improvement and optimization of the Properties as described above.
We will not share your personal data with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition where a third party is providing the prize) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your personal data may be used, which you will be notified of at the relevant time.
We may also disclose your personal data to third parties in the following events:
o if Boraq Group or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
o if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
o in order to enforce or apply our Property’s terms of use or terms and conditions; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Boraq Group may feature advertising within the Services. The advertisers may collect and use information about you such as:
o Performance and game contextual data like your Games session activity;
o Aggregated and/or de-identified information that is not intended to specifically identify a user; and
o Technical information such as device identifier, Advertising ID, and IP address.
o Ad Networks may use this information to provide interest-based or targeted advertisements to you.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. The following is a list of our major service providers:
o AdMob (AdMob Google Inc.)
o Unity Ads (Unity Technologies ApS)
o Facebook Audience Network (Facebook, Inc.)
o Google Analytics for Firebase (Google Inc.)
o OneSignal (Lilomi, Inc.)
o Unity Analytics (Unity Technologies)

• Links to third party sites

Where we provide links to third party websites that are not affiliated with Boraq Group (for example. where you click or tap on adverts in a Property) such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those Properties.

Inform You about Our Games, Products and Services

Boraq Group may use Personal Information to provide you with materials about offers, products and Services that may be of interest, including new games, content or Services. Boraq Group may provide you with these materials by in-game offers, push notification, Facebook notification, online or offline marketing or email, as permitted by applicable law, including:

o to deliver advertising and marketing and promotional information to you;
o to tailor content, advertisements and offers;
o to notify you about products and services or upcoming special offers/events that may be interest of you; and
o to notify you about rewards, surveys, contests or other promotional activities or events sponsored or managed by us or our Business Partners.
You can opt out at any time from receiving the such materials by clicking on the opt out link provided in all marketing mailings, by turning off notifications from mobile device or SNS settings or by sending an e-mail through our website boraq-group.com without incurring any costs.

Third-party Websites, Social Media Platforms and Software Development Kits

The Site may contain links to other websites, and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and we do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. We encourage our users to read the privacy policies of each and every website and application with which they interact. You visit these other websites or applications at your own risk.

Boraq Group Services may include publicly accessible blogs, community forums or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their Cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information that you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when you interact with a social media platform, and by using such services, you assume the risk that the Personal Information you provided may be viewed and used by Third Parties for any number of purposes.

For how long do we keep your personal data?

We will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.
Where you sign up to receive email marketing from us, we will retain your email address on file should you ever “opt-out” of receiving emails from us. We will retain your email address in this way in order to ensure that we continue to honor and respect that opt-out request.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.

International Transfer

All Personal Information collected via or by Boraq Group may be stored anywhere in the world, including, but not limited to, in Turkey, KSA, the United States, the European Union, in the cloud, on our servers and on the servers of our affiliates or the servers of our Service Providers. When we transfer your Personal Information internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in may be different from the privacy laws applicable to the place where you are resident.
By providing information to Boraq Group, you consent to the storage of your Personal Information in these locations.
If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Turkey and the United States and to Processing of your data globally.
By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Turkey and the adjudication of any disputes arising in connection with Boraq Group or the Site will be in accordance with the Terms Services.

Data Retention

Boraq Group retains the Personal Information collected as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

Security

Boraq Group takes the protection of your personal data very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the data provided to us is stored on secure servers once we receive it.
Boraq Group may store your personal data on secure servers either on our premises or in secure third-party data centers.
Please note that some of our service providers may be based outside of Turkey. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
In particular, if you engage with us for support services (e.g. if you report a problem with one of the Properties) it is highly likely that your complaint will be dealt with by our support team in Turkey.
If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Property, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you.
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out in our website and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

• Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third-party, we are happy to consider such requests.

• Exercising your rights

When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case, we will tell you).

Children’s Privacy

The Services are not directed to children under 13, and Boraq Group does not knowingly collect Personally Identifiable Information from children under 13. If you are a parent or legal guardian of a child under the age of 13 (or under 16 in certain jurisdictions in the European Union) who uses our games, please contact us. We will delete your child’s Personal Information if we are able to identify your child unless you provide us with your verifiable consent for your child to continue to use our games.

Changes to Our Privacy Policy and Practices

Revision to the Privacy Policy. We may revise this Privacy Policy at our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.
Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Boraq Group will notify you by email or as otherwise required by applicable law. We will post adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. When consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Boraq Group will endeavor to comply with the law or contract.

Contact Info of Data Controller

If you have any questions about the privacy practices or this Privacy Policy, please contact Boraq Group data protection officer by email at support@boraq-group.com