Rotatelab Privacy Policy

Last Updated: May 17, 2017

Privacy Commitment

Rotatelab Yazilim ve Bilisim Teknolojileri Sanayi ve Ticaret A.S., its subsidiaries, parent companies, joint ventures and other corporate entities under common ownership and/or any of their agents, consultants, employees, officers and directors (collectively, “Rotatelab”, “its”, ”our”) is committed to respect the privacy rights and concerns of users of the games, websites, products, and other services (collectively, “Services”) provided by Rotatelab on the Apple App Store, Google Play App Store, Amazon App Store, at Facebook. As such, Rotatelab has established and implemented this Privacy Policy to inform users of the Services of how Rotatelab collects, uses, stores, disclosures, transfers and protect the information we collect through the Services. By visiting, installing, using of or otherwise accessing the Services, you agree to this Privacy Policy and Terms of Services of Rotatelab and give an explicit and informed consent to the processing of your personal information in accordance with this Privacy Policy. Please do not install or use the Services if you do not agree to this Privacy Policy or Terms of Services.

Please note that Rotatelab is not responsible for the actions of third parties, the content of their sites, the use of information you provide to them or any services they may offer.

Rotatelab reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

1. Collection of Information

“Personal Information” means personally identifiable information that specifically identifies you as an individual in the scope of the Privacy Policy. Information that has been de-identified, aggregated, or otherwise made anonymous so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise is not considered as personal information.

Rotatelab may collect use, store, disclosure and/or transfer personal information as it is permitted by legal jurisdictions when you create or sign into an account on the Services; submit a ‘contact us’ request to receive customer or technical support; subscribe to Rotatelab’s newsletter; participate in Services feedback, questionnaires, surveys, or contests or participate in forums discussions. Primary goals in collecting information are to provide and improve our Services, to administer your use of the Services and to enable you to enjoy and easily navigate our Services.

Rotatelab also collects the information you provide including but not limited to your name, email address and mobile telephone number when you submit a resume on our website for job applications and when you upload the resume to Rotatelab’s website. Rotatelab uses this information to contact you regarding setting up an interview or to determine if you are qualified for the position in which you applied.

1.1 Information Collected from Third-Parties

If you play any of the games or the Services on connected third-party applications or connect the Services to any third-party applications, like Apple, Google, Amazon and/or from Social Networking Site (“SNS”) such as Facebook, Google+, Rotatelab may receive certain information about you from the provider of the third-party application. The information received depends the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application

When you connect the Services through an SNS, the information that Rotatelab collects may include your name, your SNS user identification number and/or user name, location, sex, birth date, the login e-mail you provided to that third-party application when you registered with the SNS, profile picture or its URL and the SNS user identification numbers for your friends that are also connected to the Services.

When you use any of the Services, games or applications on a mobile platform, Rotatelab may collect and record certain information such as your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address (if you have connected to Facebook or Google+), and your location based on your Internet Protocol (“IP”) address. This information is useful to Rotatelab for troubleshooting and helps Rotatelab understand usage trends.

If you do not want Rotatelab to track or use location based information through your devices; you may turn it off at the device level.

1.2 Rotatelab Sites

While you are browsing Rotatelab’s sites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring web site addresses may be logged automatically. Rotatelab may use this information to monitor, develop and analyze your use of the Services

1.3 Mobile and Google Analytics

Rotatelab uses mobile analytics software to allow us to better understand the functionality of our Mobile Software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. Rotatelab does not link the information we store within the analytics software to any personal information you submit within the mobile application.

The Services also uses Google Analytics to help Rotatelab learn about who uses the Services and what pages are being viewed. These tracking and analytics services may have access to information such as your device identifier, MAC address, IMEI, location (specific location where a given language is spoken), geo-location information, and IP address for the purpose of providing their services under their respective privacy policies. Rotatelab does not have access or control over these third parties and this Privacy Policy does not cover the use of tracking tools from third parties.

1.4 Other Tracking Tools

Like many websites, Rotatelab employs technologies such as cookies, beacons, scripts, and tags in certain areas of the Services to allow Rotatelab to provide information to make your online experience more convenient and to enhance your experience with the Services.

“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Cookies are not spyware or adware, and can’t deliver viruses or run programs on your computer. A user may configure their web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being set.

Rotatelab does not tie the information gathered by cookies or tracking tools to our customers’ personally identifiable information.

Please note that companies delivering advertisements on the Services may also use cookies or other technologies and those practices are subject to those companies’ own policies.

1.5 Fun Pages and Forum

Rotatelab may offer publicly accessible fun pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in on Rotatelab’s fan pages, blogs, private messages, and community forums, the information is being made publicly available and may be collected and used by Rotatelab or other third parties. When you disclose any information in on the fun pages, blogs, private messages, or community forums; you do so at your own risk.

If you choose to use your Facebook profile to use the fun pages, blogs, private messages, or community forums, the information you provide is tied to your Facebook account. You will need to contact Facebook directly in order to request removal of personal information from the fun pages, blogs, private messages, or community forums.

1.6 Social Media Widgets

The Services includes Social Media Features, such as the Facebook and Twitter button and Widgets, such as the “Share” button or interactive mini-programs that run on the Services. These features may collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on the Services. Your interactions with these features are governed by the privacy policy of the company providing it.

1.7 Push Notifications

Rotatelab may occasionally send you push notifications through Rotatelab’s mobile applications to send you game updates, high scores and other services related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

1.8 Ad Networks

Rotatelab may feature advertising within the Services. The advertisers may collect and use information about you, such as your Services session activity, device identifier, MAC address, IMEI, geo-location information and IP address. They may use this information to provide advertisements based on your interests.

In addition, Rotatelab’s games may be advertised in other services. After clicking on one of these advertisements and installing the games, you will become a user of the Services. In order to verify the installs, a device identifier may be shared with the advertiser.

1.9 Customer Support

Rotatelab may collect your email address when you contact Rotatelab’s customer services group and that email address may be used to contact you about your experience with the Services.

2. Use of Information

Rotatelab may use your personally identifiable information for all legal purposes, including the following:

  • Newsletters: Rotatelab may use your email address or other personally identifiable information to send you commercial or marketing messages including, without limitation, newsletters and email communications about the Products or Services.
  • Push Notifications: Rotatelab may occasionally send you push notifications through the mobile applications to send game updates, high scores, and other services related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
  • Payment Processing: If you purchase goods or services through the Services, third-party applications, like Apple App Store, Google Play App Store, Amazon App Store and/or from Social Networking Site (“SNS”) such as Facebook may ask you to provide certain financial information to exercise a payment transaction on behalf of Rotatelab. As part of the payment processing through third parties, Rotatelab does not collect, store and use personally identifiable information, such as your name, address, credit card number, phone number, and your e-mail address.
  • Game Data: Whenever you play the games, Rotatelab collects data about all of your interactions with the game and with the other players inside the game via server log files. This information may be associated with your player ID, IP address or device ID for the purpose of providing you the Services and improving it.
  • Referral Services: Rotatelab uses the information you provide about your friends via referral services made available through the Services (such as “Tell A Friend”). If you choose to use such a referral services to tell a friend about the Services, Rotatelab will automatically send your friend a one-time email inviting him or her to download our Services.
  • Customer Support: Rotatelab uses the information you provide to contact you in order to answer any customer support or technical support requests regarding the Services.
  • Job Applications: If you submit a resume or job application, Rotatelab may use that information to contact you regarding setting up an interview or to determine if you are qualified for the position in which you applied.

3. Share and Transfer of Information

In accordance with applicable law in force, Rotatelab may share aggregate or anonymous information about you with advertisers, publishers, business partners and other third parties.

Rotatelab also may share the personal information collected from you under the following circumstances in accordance with applicable law in force:

  • Protection of rights: Rotatelab will share personal information if Rotatelab has a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Services, or (iii) such action is appropriate to protect the rights, property or safety of Rotatelab, its employees, clients, or users of the Services.
  • Asset transfers: If Rotatelab becomes involved in a merger, acquisition or other transaction involving the sale of some or all of Rotatelab’ assets or a line of business, user information, including personal information collected from you through your use of the Services, could be included in the transferred assets. Should such an event occur, Rotatelab will use reasonable means to notify you through a prominent notice on the Services. By sharing your personal information with Rotatelab, you are giving Rotatelab consent to transfer your personal information to a third party in an asset transfer described here.
  • Services providers: Rotatelab may share your personal information with third party vendors or services providers that Rotatelab engages for the purpose of fulfilling product orders or processing information on Rotatelab’s and your behalf. For example, Rotatelab may partner with other companies to provide customer services. Additionally, Rotatelab may partner with other companies to process, analyze, and/or store data, including, but not limited to, Analytical Data. While providing services for Rotatelab, these companies may access your personal information. To the extent applicable, Rotatelab requires these entities to comply with this Privacy Policy and appropriate confidentiality and security measures.

4. Your Interactions with Third Parties Independent of Our Services

Please be aware that Rotatelab cannot control the activities of third parties to whom Rotatelab provides or from whom Rotatelab is provided data, and as such Rotatelab cannot guarantee that they adhere to the same privacy and security procedures as Rotatelab.

If you play any of the games or use the Services on connected third-party applications or connect the Services to any third-party applications, like Apple (iOS), Google Play (Android), Amazon, or a Social Networking Site such as Facebook, Google+, Rotatelab may receive certain information about you from the provider of the third-party application. The information Rotatelab receives depends the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application. If you access the Services from a third-party application or connect the Services to a third-party application, you should also read that third-party application’s Privacy Policy.

When you click on a third party logo or URL displayed on the Services that links you to a different website, this Privacy Policy no longer applies and you must read the privacy policy of the third party to see how your personal information will be handled on their website. If you cannot find their privacy policy, then you should contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies. Rotatelab is not responsible for their collection and use of your personal information.

5. Data Retention

Rotatelab retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Rotatelab does not verify the correctness of personal data.

6. Security of Information

The personal information that you provide to Rotatelab is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such information, such as firewalls and data encryption. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while Rotatelab strives to protect your information, Rotatelab cannot ensure or warrants the security of any information you transmit to Rotatelab or through the Services.

In addition, access to personal information is limited to Rotatelab’ employees and agents necessary to fulfill the tasks outlined in this Privacy Policy and for performing technical maintenance.

7. Users’ Rights

Please note that you have the right to (a) know whether or not personal data has been processed; (b) ask for details if your personal data has been processed; (c) know the purpose of such processing and whether your personal data has been used for said purpose; (d) know the third parties to whom your personal data has been transferred in the country or at abroad; (e) ask for correction of any missing or incorrect data; (f) ask for deletion or elimination of your personal data as per applicable regulations; (g) ask for notification of the transactions, which might have been performed as per paragraphs (e) and (f) above, to any transferee third parties; (h) file objections to any consequences that might occur against you as a result of analysis of your personal data solely by automatic systems; and (i) ask for compensation of your damages and losses that might be suffered as a result of processing of your personal data in breach of applicable jurisdictions.

If you wish to use any of the above rights, please send your request to [email protected]. Please include your full name, email address associated with your account, and a detailed description of your data request. We will return to any requests within 30 days.

In some cases, Rotatelab may not be able to delete your information, and will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce the agreements with you.

8. International Transfers

Personal information collected on the Services may be stored and processed in Turkey, the United States or any other country in which Rotatelab or its affiliates, subsidiaries or agents maintain facilities, and by using the Services, you consent to any such transfer of information outside of your country.

9. Dispute Resolution and Applicable Law

If a dispute arises between you and Rotatelab, Rotatelab strongly encourages you to first contact Rotatelab directly to seek a resolution by open a help ticket directly in-game via the help section or contact us at [email protected].

You agree that all disputes between you and Rotatelab shall be governed by the laws of Turkey by a court located in Istanbul without regard to conflict of law provisions, and you agree to submit to the jurisdiction of such court.

10. Policy for Children

The Services are not directed to children under 13 and Rotatelab does not knowingly collect Personally Identifiable Information from children under 13 and if you are under the age of 18, you must have your parent’s permission to access the Services and the games. Rotatelab urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when on-line. If you have any concerns about your child’s personal information, please contact Rotatelab at [email protected].

11. Notification of Changes

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

12. Contact Us

If you have any questions about the privacy practices or this Privacy Policy, please contact Rotatelab by email at [email protected].