Privacy Policy

How we collect, use, and protect your personal information

PLAYIN PRIVACY POLICY

1. Purpose

This Privacy Policy is part of the Playin Terms of Service ("Terms of Service"). "Playin" and "we" refers to Playin Bilişim Teknolojileri ve Yazılım Ticaret A.Ş. Company. This Privacy Policy explains our online and offline practices regarding the data, the types of the data that we collect, our intention to use, store, protect, disclose and share this data, how you can waive your consent for this data to be used in a certain way, and the way you can correct this data or update this data. "Services" refers to all the products and services available from Playin. By using the Website or Services, or any services offered by Playin and/or by sending any Personal Data to us means that you accept the terms of this Privacy Policy.

The use of the Website and the Services provided by us, for those who accept or "Services", is subject to this Privacy Policy. Any person who is authorized/employed to use the Website or Services accepts that we collect and protect data by complying with this Privacy Policy. This Privacy Policy is intended to inform all users (including those persons authorized/employed by the person or entity that has a contract with us) regarding our practices regarding data and the way in which we obtain, use, maintain, protect and disclose data. If you do not refuse this Privacy Policy or the Terms of Service, we recommend that you do not send us any data and discontinue use of our Services and Website.

2. Changes

We will inform you in any case of material changes made to this Privacy Policy and we are likely to make changes from time to time or even unannounced. We reserve the right to change/update this Privacy Policy and if you continue to use the Services or Website after the update is published, you accept that you agree with this Privacy Policy.

3. Data We Collect

We may collect Personal Data and non-Personal Data from you depending on the Services and use. "Personal Data" refers to the data which can identify you or help with your identification. For example, the full name, email address, mailing address, phone number and financial information you send to us regarding a payment is included. "Non-Personal Data" refers to the data which cannot identify you or help with your identification. The data we collect can be categorized as follows:

3.1. Data Transferred by the User

Personal Data transferred by the user. We collect the data that you submit or send to us proactively. E.g. when you contact us, send us comments, complaints, requests or questions or when you wish to become a subscriber/customer.

3.2. Data We Obtain from You

3.2.1 Data We Collect Automatically. We collect certain Personal Data or non-Personal Data automatically when you use the Services or Website. For example, we might collect the data on your browser, IP address, the domain from which you are visiting us and certain statistical data.

3.2.2 We can access the data on your general and specific geographic location by various monitoring technologies such as GPS (if enabled by the user), other location technologies, and/or IP address. We can also collect the data of application performance, access, and session duration including the page response times, the length of visits, the page interaction data (e.g., scrolling, mouse clicks, mouse movements) and the methods used to navigate to the exit page.

3.3. Cookies and Tracking Technologies

We and third-party advertising services use various monitoring technologies on the Website and the Services, for example we use Local Storage, Flash Cookies, JavaScript, ETags (entity tags), Gifs and Cookies. Third-party analytics services can also use the technologies in Article 3.3 of this Privacy Policy.

"Cookies" are small portions of data stored on your device or computer. A Cookie is sent by a server in a domain and saved on your browser. You should note that there is a difference between Cookies that are only on your device/computer in a browsing session and the Cookies that are permanent and stay on your device/computer. Generally speaking, Cookies are used to make the websites remember you when you access it later. The service provider uses Cookies for advertising and marketing activities.

Local Storage is similar to Cookies but you can store even more data with Local Storage. Flash Cookies (also called Local Shared Objects) are similar to normal Cookies but they can be much larger and are stored in different parts of your computer.

Tracking pixels (also known as Action Tags, 1-by-1 gifs, image tags, Clear Gifs, and invisible Gifs) are small images containing a unique ID that allow Playin to measure user actions through the Services and/or Website and collect statistics about use of the Services and Website.

JavaScript are codes executed on your browser.

ETags are pieces of data sent between a server and client (such as a browser).

While we allow you to use some of our services without registration or sending Personal Data to us or without agreeing to the use of such technologies or if you have disabled such technologies, they can become necessary for you to access certain features. If you would like to avoid such technologies, please ensure that you set your browser settings accordingly.

4. How We Use Data

We may use the data obtained from you for various purposes, for example, but are not limited to:

  • To provide you with our Services
  • To get in contact with you to talk about the Services
  • For verification and payment purposes
  • To develop, improve, refine, track, and/or personalize services
  • For our marketing purposes, in case you have not refused our sharing
  • To manage our customer relationships
  • For research and for the optimization of operations
  • To learn the Services you are interested in
  • To determine demographic data
  • To send commercial emails to you; e.g., data regarding our special offers, promotions, or other marketing content regarding the Services we provide.
  • To communicate with you and to answer your requests/questions and for customer service
  • To monitor compliance with our Terms of Service
  • For data analysis and data transfer purposes for our partners
  • For data analysis, reporting, tracking, research and similar purposes; To create and maintain the reliability and security of the Services and the Website
  • To protect the rights and the property of third parties, Playin or our business partners and to ensure the user security
  • To comply with legal requirements

5. Sharing and Disclosure of Data

We may share and disclose data only in the cases specified below. We do not sell Personal Data:

5.1. Service Providers

We may share Personal Data and non-Personal Data with our third-party service providers for our business purposes including but not limited to the provision of Services, customer and technical support services, data analysis and insight for the Website and Services or for marketing purposes. Our partners may use the data to provide Services to us and may save data as stated in this Privacy Policy (with our Third-Party service providers and/or clients).

Marketing. We may share your Personal Data with third-party marketing partners or permit them to collect data from our Websites for their marketing or other purposes. If you would not like to receive marketing from these third-party marketing partners you can refuse this pursuant to Article 9 below.

5.2. Legal Requirements

Playin may maintain or disclose your Personal Data or other data to the extent that this is needed to: (i) comply with a legal obligation or request; (ii) protect the rights or the property of Playin or third parties; (iii) take action regarding fraud or illegal activities or (iv) protect the personal security of any individual.

5.3. Modification of Organization or Bankruptcy/Insolvency

If we get involved in a merger, acquisition, transfer, sale of our business, bankruptcies, restructuring, or sale of assets, data, including Personal Data may be sold or transferred as part of that transaction. This Privacy Policy continues to apply to your data and the transferee to use Personal Data in a manner consistent with the Privacy Policy. By submitting the Personal Data to us, you accept this sharing in these situations.

5.4. Other

We may share your data (i) when you wish or command this, (ii) when you make your data public, for example when you comment or (iii) with third parties for purposes that are in compliance with this Privacy Policy. By submitting the data to us, you accept that the Personal Data is handled securely, lawfully and as described in our Privacy Policies.

6. External Links

We may add external links or connections on our Website, which are not possessed or managed by us. We are not responsible for the protection of the data and the content you disclose or share with a third-party website/service. Any data/content is subject to the Privacy Policy and the Terms of Use of the third-party website. Before you disclose or share data with any third-party website, we recommend you to examine the Terms of Service and Privacy Policy of said website.

7. Where and How Long is Data Stored?

We are an international company and your data can be transferred to, stored, and processed at any location where we provide Services and/or are performing activities. This Privacy Policy will be governed by the law of the Republic of Turkey and that your data can be transferred to other countries outside the European Economic Area (EEA). These countries may not have the same data protection laws as the country you are situated in. By accepting the use of our Services or the Terms of Use, when you visit the site, use the Services and otherwise provide data to us, you accept that your data can be transferred to countries which might not have data protection laws similar to your country.

How Long is the Data Stored? We intend to keep your Personal Data as long as required to reach the purposes described in this Privacy Policy or to the extent that this is needed to comply with legal or regulatory requirements or to establish, exercise or defend legal claims. While we will not keep it for longer than needed, we have a professional obligation to maintain the data for a reasonable period.

8. Security

Playin has put technical, physical and administrative security precautions in place intended to protect the Personal Data submitted to us. However, you should keep in mind that there is always a risk to send data in an environment like the Internet and/or save the data and we cannot guarantee total security. We hold no liability for how third-party partners protect your Personal Data.

9. Your Rights and Choices

9.1. Refusal of Non-Essential Cookies. You have the right to refuse cookies by visiting our Website. You should note that some cookies may be necessary for certain features and that by refusing or disabling certain cookies, you might not be able to access some features. In addition, if you refuse the use of such technology, you might be asked to re-enter your data the next time you visit our Website. If you would like to know more about your cookies and similar technologies, you should check your browser settings. Generally, a new Web browser accepts cookies by default; however, you can usually change this in your browser settings.

For Google Analytics, you can prevent Google Analytics to recognize you when you visit our Website again from the same device by disabling cookies on your browser.

9.2. Ad Choices. The ads you see can be based on information obtained from your use of mobile websites and apps. To refuse interest-based ads on mobile devices, please adjust your personal advertisement settings on your mobile device (these settings may be inaccessible on some devices). You can also refuse the use of data for the in-app ads for many mobile devices through your device settings. For a better understanding of these opt-outs or others, you can visit www.aboutads.info and click Your Ad Choices. You can visit the Network Advertising Initiative's website at www.networkadvertising.org or Adobe's Website and make changes using the Global Privacy Settings Panel, www.adobe.com/privacy/opt-out.html or by contacting us.

You should note that if you refuse interest-based ads, you will still receive ads, but they will not be interest-based (related to your interests). In addition, if you refuse, you cannot see certain offers that may be useful for you. Refusal of all cookies means that some features on the Website may not be accessible.

9.3. Email Choices. Email opt-out: If you want to refuse emails from us, you can click the unsubscribe link in the relevant email. Please note that even if you refuse marketing or commercial emails, you can still be sent certain transactional emails related to your account, transactions, etc.

9.4. Refuse Further Processing or Request the Deletion of Your Data. Depending on the country you live in, you may have the right to refuse our processing (collection, etc.) your Personal Data or request the deletion of your Personal Data. If you wish to refuse, please send your refusal request with the section EXCLUDE MY PERSONAL DATA FROM YOUR DATABASE to privacy@playin.com.tr. Please note that this objection applies to any type of data processing as described in this Privacy Policy. A copy of your identification is required to confirm your identity. Please note that if you exercise this right, you cannot receive our Services any more since the provision of Services depends on the processing of your Personal Data. We are still legally obliged to and may keep certain data.

9.5. Do Not Track. The Website does not support "Do Not Track" browser settings.

9.6. CA Residents. If you are situated in California, please note that we have not disclosed Personal Data to any third parties for their own direct marketing purposes during the previous year. If you are situated in California, you can request information about the way Playin shares certain categories of Personal Data with third parties and affiliates for their own direct marketing purposes. Contact us as described in Article 11 to request a copy of the data shared and the names and addresses of third parties that have received the data. We will answer such requests in a reasonable manner. Please be mindful that we do not have to respond to requests submitted to addresses other than the addresses stated in Article 11 of this Privacy Policy and that we do not have to respond to requests made via the means other than as stated in Article 11.

9.7. EU Residents. Depending on the conditions, you may have legal rights regarding your Personal Data if you are situated in the EU. This can include:

  • The right to be informed if your Personal Data is being processed;
  • The right to access your Personal Data and copies;
  • The right to correct inaccurate or incomplete data;
  • The right to delete your Personal Data;
  • The right to prohibit the processing of your Personal Data;
  • The right to data transfer, i.e., to receive your Personal Data in an accessible and commonly used format and to request us to provide this data to another data controller;
  • The right to object to the processing or use of your Personal Data in certain situations; and
  • The right to reject certain direct marketing communications from us.

We can require you to confirm your identity to the extent permitted by applicable law and to provide the data requested by you. Any request made regarding these rights will be assessed on a case-by-case basis. Some of these rights may differ, can be limited to or cannot be available depending on whether we are the controller or the processor of your Personal Data. Please use the contact data in Article 11 to submit a request. We may not be obliged to comply with your request to the extent permitted by applicable law. For example, we may reject your request if complying with the request would disclose data of another person or if you ask us to delete data which we are legally entitled to maintain.

10. How Long Do We Keep Your Data?

We intend to keep your data including Personal Data as long as needed to provide Services to you and keep your data as long as necessary for the purposes outlined in Article 4 above. We may also keep your Personal Data as specified in this Privacy Policy, as long as you use our Services and for a reasonable time period thereafter. If we collect data for a specific purpose, we will not use it for another purpose unless we have obtained your consent to such other purpose or we have determined that such other purpose is compatible with the original purpose. For reasons such as technical limitations and security control measures, data deletion may not occur on our active databases immediately after deletion but in compliance with our backup protocols or may be anonymized. We may keep your Personal Data and/or other data for longer periods than usual if we have to or we are permitted to comply with a legal or regulatory requirement or other legitimate purposes such as preventing fraud or maintaining security. Your Personal Data may be archived and saved by us in case we have to do this pursuant to legal, regulatory or contractual requirements or legitimate interests.

11. Contact Us

If you have any complaints, requests or you have any questions regarding our privacy practices or Privacy Policy, please contact us at:

Playin Bilişim Teknolojileri ve Yazılım Ticaret A.Ş.
privacy@playin.com.tr
Kazımdirik Mah. 372/6 Sk. No:8
Bornova, İzmir, Turkey.

12. Terms of Use

These terms were last updated on December 24, 2020.

These Terms of Use ("Terms") govern the use of this Website and the subdomains. BY USING THIS SITE, YOU AGREE TO THESE TERMS AND CONDITIONS.

Definitions.

  • Playin; Playin Bilişim Teknolojileri ve Yazılım Ticaret A.Ş.
  • Website; The website operated by Playin Bilişim Teknolojileri ve Yazılım Ticaret A.Ş. at https://www.playin.com.tr address and its subdomains,
  • Privacy Policy and Practices
  • Privacy Policy; At our sole discretion, our privacy policy may be amended from time to time. Any revision to this document will be posted on the Website.

Last updated: December 24, 2020