Last Updated: 08 January 2024
Agave Games Bilişim Yazılım ve Pazarlama Anonim Şirketi [“Agave”] develops and publishes games for website and mobile devices on which players can use Agave’s services [“Services”]. Agave operates in the scope of our Services under this Personal Data Protection Notice. Agave is the “data controller” of your personal data unless otherwise stated below.
This Personal Data Protection Notice applies whenever your personal data is processed as part of our Services. It describes how we process your personal data when providing these Services to you, and your rights and choices concerning your personal data.
If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. The Personal Information that we collect is used for providing and improving the Service. we will not use or share your information with anyone except as described in this Privacy Policy.
The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Link Journey unless otherwise defined in this Privacy Policy.
1.Which of Your Personal Data is Processed and What are the Purposes of Processing Your Personal Data
A.Information About You That You Share with Us Directly
When you use our Services, you may give us personal data directly (for example, when uploading our Services), and we will and process and store that personal data on our systems for the purposes described in this Privacy Notice.
Depending on the Services, the personal data that we obtain will be relevant to providing those Services and include the following:
| Personal Data | Legal Basis | Purposes of Processing Your Personal Data |
|---|---|---|
| - security information (IP address, device model and brand, operating system and version, device language, universal ID, user contract confirmation record, MAC address, domain) - details about the platforms that you use (Apple Store, Google Play) - your region - your age range - links to your profiles on various social networks and social network ID number |
- Necessary for performance of the contract - Agave’s legal obligations, in particular relating to security, fraud detection and management |
- Provide our Services and create user accounts in those Services - Protecting Agave’s Rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties - Ensuring the security of data controller operations - Launch of products - For security purposes and to prevent fraud or potentially illegal activities, and to enforce the applicable Terms of Service - Protecting the safety of our players - Cooperating with public authorities and law enforcement where lawfully permitted or required |
| - location | - consent | - Marketing, research, analytics and delivering behavioral advertising - Personalizing our Services and our players’ experiences |
B.Information You Generate Using Our Services
When you use our Services, we will obtain personal data about the ways in which you use and interact with our Services.
| Personal Data | Legal Basis | Purposes of Processing Your Personal Data |
|---|---|---|
| - when and for how long you play our games - which game features are used - performance data - transaction security information (IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID) - descriptions of your in-game activity |
- Agave's legitimate interest in improving its Services - Consent |
- Tracking users’ habits and preferences - Execution of activities for user's game satisfaction - Execution of activities for ensuring business continuity - Conducting business activities - Marketing, research, analytics and delivering behavioral advertising |
C.Information We Get About You from Connected Third-Party Platforms
If you access any of our Services on social networks like Facebook, Google or other third-party platforms, Agave may obtain your certain personal data from that third-party platform.
Depending on the Agave’s game you play, your privacy settings, the third-party platforms, Agave may obtain and store some or all of the following from the third-party platform:
| Personal Data | Legal Basis | Purposes of Processing Your Personal Data |
|---|---|---|
| - identification data (your first and surname); - transaction security information (IP address, game achievement, your user identification number, your social network ID number, which may be linked to publicly available information like your profile) - communication data (e-mail address) - your region |
- Necessary for performance of the contract - Agave’s legal obligations, in particular relating to security, fraud detection and management |
- Conducting business activities - Protecting the safety of our players - Provide our Services and create user accounts in those Services - Launch of products - For security purposes and to prevent fraud or potentially illegal activities, and to enforce the applicable Terms of Service - Protecting Agave’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties - Cooperating with public authorities and law enforcement where lawfully permitted or required |
If you connect our Services via a third-party account or access our Services from a third-party platform, we kindly recommend you to read that platform’s terms of service and privacy policy. In order to see what information a third-party platform is sharing with Agave, and to find out more details about their privacy practices and any options available, please visit those platforms.
D.Cookies and Other Automated Information Collection
We use cookies and other similar technologies (e.g. device identifiers) to recognize you and/or your device(s) across different services (both Agave’s Services and third-party services), including for advertising purposes.
Agave uses cookies and other similar technologies to process personal data, including:
| Personal Data | Legal Basis | Purposes of Processing Your Personal Data |
|---|---|---|
| - IP address - the type of device you are using - platform type (like Apple iOS or Android) - your operating system version - your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID) - your browser type and language - referring and exit pages, and URLs - the number of clicks on an app feature - the amount of time spent on an app feature - domain names - landing pages - pages viewed and the order of those pages - what your current progress is in our Services and the date and time of activity |
- Necessary for performance of the contract
- Agave’s legal obligations, in particular relating to security, fraud detection and management - Consent - Agave's legitimate interest in improving its Services |
- Conducting business activities - Ensuring the security of data controller operations - For security purposes and to prevent fraud or potentially illegal activities - Marketing, research, analytics and delivering behavioral advertising - Personalizing our Services and our players’ experiences - Improving, optimizing our Services and our players’ experiences |
2.How We Transfer Your Personal Data
When we transfer your personal data internationally, we process your personal data securely, lawfully, and in accordance with related privacy laws. Please note that the privacy laws vary from jurisdiction to jurisdiction when transferring personal data internationally. Accordingly, the privacy laws applicable to the places where your personal data is processed may be different from the privacy laws applicable to the place where you are resident.
A.Third-Party Advertising Including Behavioral Advertising and Analytics
We share your personal data with advertisers to perform making the advertisements that are tailored for your interests when you use our Services. Accordingly, advertisements may include banner ads on game boards or in Services, such as full-screen ads between moves or games or ads made available via an offer wall (in which advertisers offer virtual currency or other in-game items to players in exchange for watching an advertisement, signing up for an account, completing a survey or performing some other activity). Third-party offer wall providers host offer walls and make the offers.
Advertisers and offer wall providers may obtain, or we may obtain and share with them, the following types of personal data when you use our Services, in order to enable advertisers, advertising intermediaries, and offer wall providers to serve you with more relevant ads:
| Personal Data | Legal Basis | Purposes of Processing Your Personal Data |
|---|---|---|
| - performance data (the number of clicks on an advertisement) - location and your region - your gender - your age range - certain device information (IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID, device model and brand) - a unique identifier, such as your social network ID or Agave’s player ID |
- Consent | - Offerring you targeted advertising in third party services for products and services that are more likely to appeal to you - Undertaking analytics to analyze player activity |
Advertisers or advertising intermediaries may obtain this personal data via cookies and other similar tracking technologies, as explained in our Cookie Notice. If you do not want to see tailored in-application advertisements, please view Your Rights below.
Please note, after clicking on a third-party advertisement or offer, you may no longer be on a website or app controlled by Agave. If you have any questions about how these third-party services use your personal data, you should review their policies and contact them directly.
B.Authorized Persons, Institutions and Organizations
Depending on compliance with a legal obligation, or legal demands of authorized persons, institutions and organizations, we may share your personal data with the public authorities.
| Personal Data | Legal Basis | Purposes of Processing Your Personal Data |
|---|---|---|
| - identification data (first name and surname, nickname) - transaction security information (IP address, device model and brand, operating system and version, device language, user ID, user contract confirmation record) - details about the platforms that you use (Apple Store, Google Play) - links to your profiles on various social networks and social network ID number - information about Agave’s games and about other third-party applications with embedded Services you have on your device |
- Agave’s legal obligations, in particular relating to provide information to authorized persons, institutions and organizations | - Providing information to authorized persons, institutions and organizations - Execution of activities in compliance with the legislation - Execution of legal affairs |
C.Third-Party Service Providers
We will share your personal data with third parties who perform services on Agave’s behalf for the purposes of hosting services, and security of our Services, and our third-party business partners who assist Agave for the purposes of delivering and optimizing our Services.
3.Your Rights
Your rights on data protection are explained below. These rights apply to personal data about you, and their scope and applicability can vary across different regions. For example, they could extend to your household or a legal entity or could be exercised by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times.
Subject to certain exemptions, you have the right to:
- access to your personal data,
- rectification of your personal data,
- erasure of your personal data (subject to any Agave’s needs that should be justified, to retain personal data, for example with respect to its legal obligations),
- restriction of processing of your personal data (subject to limitations provided in applicable regulations),
- object to processing of your personal data (subject to limitations provided in applicable regulations),
- wiithdraw your consent, if the processing of your personal data was based on your consent,
- portability of some of your personal data (subject to limitations provided in applicable regulations),
- provide Agave with instructions regarding the use of your personal data after your death.
4.Security of Your Personal Data
We implement reasonable and appropriate security measures in order to preserve the security, integrity and confidentiality of your personal data, and, in particular, to protect such personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to it in accordance with this Privacy Notice.
Where you access our Services via another account (for example, a social network) please keep that account information secure as well.
5.Our Policies Concerning Children
Our Services are not marketed to, or intended for, children. For these purposes, we use the term “children” to refer to someone who is: (a) under 13 years old or, if older, (b) between 13 and 18 years old but under the age at which they can give valid consent to processing of their personal data under applicable data privacy laws. Agave strives to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our Services.
Children are not permitted to use our Services, and we do not knowingly collect any personal data from children. Though our Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. If we learn that we have inadvertently obtained personal data about a child that is not subject to an exemption under any applicable privacy law, we will take measures to promptly remove that personal data from our systems.
6.How Long We Keep Your Information
Agave undertakes not to keep your personal data beyond the period strictly necessary for the purposes for which it was collected, and in accordance with the applicable regulations, as well as any laws and regulations, including taxing and accounting.
Agave undertakes to anonymize or delete your personal data as soon as the purpose and/or the duration of their established retention expire.
After having served its main purpose, personal data may be archived for auxiliary purposes, such as of researching, investigating, and prosecuting criminal offenses, litigation, or accounting and tax purposes. Archiving implies that this personal data will be subject to limited access restrictions.
7.Contact Us
If you wish you can deliver your requests about processing your personal data,
• By applying to Agave with a valid identity card directly,
• By sending to Agave address “Levent Mah. Üstzeren Sk. Barem Araştırma Blok No: 8 Beşiktaş / İstanbul” together with wet signature and ID photocopy,
• By sending via e-mail address [contact@agavegames.com] belongs to Agave with the petition signed by secure e-signature or mobile signature.
You should express in a clear and understandable way what is requested in the application, which you will make to practice rights mentioned above. Information and documents related to the application should be attached to the application. Although the subject of the request must be related to the person of the applicant, if acting on behalf of data subject, the applicant must be specifically authorized in this regard and this authority must be documented (special power of attorney). Requests made by unauthorized third parties on behalf of data subject shall not be valid.
8.Changes to Our Privacy Policy
We may update our Privacy Notice from time to time. When we do, we will revise the “last updated” date at the top of the policy. We encourage you to periodically check Agave and this Privacy Notice for updates.