KURUMSAL
Privacy Policy
PERSONAL DATA PROCESSING CONDITIONS AND PRIVACY POLICY (‘Privacy Policy’)
Welcome to Coconut Games Privacy Policy!
The terms detailed below include the conditions for the collection, processing, storage, use, and sharing of personal data between you ('Member, You, User') and the data controller, Coconut Games Software and Trade Marketing Joint Stock Company (together referred to as ‘we’, ‘Coconut Games’, ‘data controller’).
Data Controller
Coconut Games Software and Trade Marketing Joint Stock Company Central Registration System Number - 0211131445600001
Levent Mh. Ülgen Sk. 4. Journalists' Site A19/2 Block 142/1 Beşiktaş P.K. 34330 - Istanbul - Turkey
INTRODUCTION
COCONUT GAMES operates a gaming platform (‘PLATFORM’) accessible via websites and embedded applications through which various games can be played (‘CONTENT’). By creating an account, accessing any of the CONTENT, or accessing the platform through a gift card or a code, and/or interacting with them, you are deemed to have accepted the USER AGREEMENT, ADDITIONAL AND SUPPLEMENTARY TERMS (‘TERMS’). You have the discretion to allow your personal data to be processed under the Privacy Policy, and it is possible to use the platform without sharing your personal data. However, if you do not share your personal data, it may not be possible to benefit from some additional services and content.
The CONTENT, PLATFORM, and SERVICES are for users over the age of 13. If you are under the age limit, please stop using the service and do not provide us with any personal data! If you are the parent of a child under the age limit and become aware
that your child’s personal data is being processed by Coconut Games, please contact us.
The Privacy Policy explains our system for collecting and processing your personal data, your rights regarding your personal data, and the reasons, methods, and circumstances under which we collect, store, share, and use your personal data, as well as the conditions under which our stakeholders may access and process your data (‘Data Processing’). We assure you that we will take the necessary measures to protect your personal data with respect to all service providers and third parties to whom your data is transferred.
If there is any material change in how we collect, process, or store your personal data, we will inform you and present the updated Privacy Policy for your approval. Unless otherwise stated, new or additional services will be subject to this Privacy Policy.
The Privacy Policy is separate and binding and is a supplementary term of the User Agreement. If you do not accept the terms listed below, it may not be possible for us to provide you with services. You may stop using the Coconut Games service at any time, and you can terminate the User Agreement under permitted conditions. Even
after the User Agreement ends, you may still exercise your legal rights regarding your personal data against third parties to whom your data was transferred.
For terms not defined in this Privacy Policy, please refer to the European Union General Data Protection Regulation (GDPR) 2016/679. Please read the Privacy Policy carefully before approving it and feel free to contact us at [email protected] for any questions, disputes, or requests.
A. Methods of Data Collection
1. When you create an account on the platform, use the service, or access the content,
2. When you request support services, communicate with customer services, send emails to contact addresses, or submit documents to us by mail,
3. When you install and/or use the platform and/or services,
4. When you visit our website and fill out the forms there,
5. When you register and/or log in to the platform through third parties like Apple, Google, Facebook, and similar social networks (‘SNS’),
We collect data through forms, automated methods, and third parties to whom you have permitted the transfer of your data.
B. Data We Collect
1. As personal data, we collect and process the following information via forms filled out by you or third parties to whom you have permitted the transfer of your data, with your explicit consent:
a) Your name,
b) Your postal and/or email address,
c)Your phone number,
d) Your date of birth,
e) Your gender,
f) SNS data, including user number, username, profile picture, URL, location, and login email.
2. As usage data, we collect and process the following information through automated methods or third parties you have authorized:
a) Your unique device ID (permanent/non-permanent),
b) Your device’s operating system, version, model, CPU, device quantity,
c) RAM and disk space, hardware type,
d) Advertising Identifier (IDFA),
e) Advertising ID,
f) Device name,
g) Game Center ID,
h) Your IP-based location, MAC addresses, and other device identifiers,
i) Data accessed through tracking technologies like cookies, web beacons, and tracking pixels,
j) Browser type and language,
k) Data you provide by interacting with the platform interface,
l) Network connection information (WiFi, 3G, 4G, LTE, Bluetooth, etc.),
m) Operator, network, and device performance information,
n) Digital rights management information,
o) Application version,
p) Technical data such as mobile sensor data.
C. Payment Data
As part of payment transactions made through third parties, Coconut Games does not collect, store, or use financial payment data such as your credit/debit card number. Coconut Games has no access to your credit card or bank account data. Third-party payment processors may share non-financial information related to your purchases, such as the products purchased, with us to fulfill your order.
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II. Data Sharing Policy
Coconut Games creates advertising spaces on the platform and in the content. Advertisers and advertising networks may collect the following data about you and use it to deliver interest-based or targeted advertisements:
1. Performance and contextual game data, such as your game session activity,
2. Aggregated and/or de-identified data that does not aim to identify a specific user,
3. Technical data such as device identifiers, Advertising IDs, and IP addresses.
B. Social Media Widgets
The platform includes social media features such as Facebook, Twitter, TikTok, and YouTube buttons, as well as interactive mini-programs like the "Share" button that operate on the services. These features may collect your IP address and information about which page you are visiting on the services and may set a cookie to enable the feature to function correctly. Social media features and widgets are hosted either by a third party or directly on the platform. Your interactions with these features are governed by the privacy policy of the third party providing them. To protect you from the transfer of data to social media providers, we have implemented technical safeguards (‘two-click solution’), allowing you to choose whether or not to enable the sharing button with social media providers. You can revoke this permanent agreement at any time.
C. Third-Party License Providers
Coconut Games may share personal data and usage data with third-party license providers in order to demonstrate compliance with agreements, fulfill our obligations, and calculate license fees.
D. Service Providers We may share the data we collect with service providers.
1. Authorized personnel employed by Coconut Games who are involved in data processing activities, such as customer support teams you are in contact with,
2. Authorized personnel employed by subcontracted service providers assigned by Coconut Games who are involved in data processing activities, such as those providing services for the Coconut Games web store.
We share your personal data with service providers for the following purposes:
a) Provision of IT-related services,
b) Providing the information and services you requested,
c) Payment processing,
d) Customer service activities,
e) Verification and fulfillment activities related to the services and additional features.
E. Business Partners
Coconut Games may share personal data for internal business purposes with our affiliates or to provide the services you have requested. Coconut Games may also share personal data with business partners with whom we jointly offer products or services. In such cases, both Coconut Games and the business partner's names will appear.
F. Friends and Other Users
Our services may allow you to interact with other players. If you play our games via a social network or register through a social network (e.g., Facebook Connect), your friends on the social network may be able to see your name, profile picture, and descriptions of your game activity. Similarly, other players, whether they are your social network friends or not, may see descriptions of your game activity, communicate with you through the chat feature in our services, and view your game profile. Your profile may include your name or username and profile picture. In certain circumstances, your profile picture may reveal your social network identity or player identity, and having access to a social network identity or player identity may allow others to view public information related to your social network profile or game account. Additionally, messages you send may be displayed across various interfaces of the content. We are not responsible for the privacy practices of other users who will view and use the information you post. You are solely responsible for sharing your personal data and usage data with your friends and other users through the services or platform.
G.Mergers, Sales, or Other Transfers of Assets
In the event we are involved in a due diligence process, restructuring, bankruptcy, sale of company assets, or transfer of services, platform, or content to another provider, your data may be sold or transferred as part of such a transaction and/or contract, to the extent permitted by law. In such a case, Coconut Games will ensure
that the acquiring third party agrees to use the personal data in accordance with this Privacy Policy.
H. Authorities
We may share data with government authorities when legally required, or as part of an investigation to verify compliance with Coconut Games’ policies and applicable laws. We may also disclose user data when we believe it is necessary to protect the rights, property, or safety of Coconut Games, our partners, customers, or others.
İ. Data Sharing with Third Parties
We may share data as described in this Privacy Policy (e.g., providing services through third-party service providers, complying with legal obligations, protecting our rights and property) or with your consent.
III. Locations Where Data is Stored and Processed
A. We store the data we collect on our servers located in Germany, and we process it with our service providers in the United States and Turkey.
B. By agreeing to the Privacy Policy, you consent to the transfer of your data from your country of residence to Germany, the United States, Turkey, or third-country data centers.
C. If you use our services from the European Union or other regions with data collection and use laws, you consent to the transfer of your data to Turkey, the United States, and its global processing.
D. When transferring or retransferring your data, we ensure protection at least under GDPR, store and process personal data in accordance with GDPR, and ensure that third parties to whom we transfer data also comply with GDPR.
E. Please be aware that laws differ across jurisdictions, meaning that the data protection laws applicable in the location where data is transferred, stored, used, or
processed may differ from the data protection laws of the jurisdiction where you reside.
IV. Purposes for Using Data
A. The general purposes for which we collect, process, store, use, and handle personal data are listed below:
1.To operate, develop, and optimize our games and services,
2.To create accounts and allow users to play our games,
3.To personalize services and content and enhance user experience,
4.To provide access to certain service functions and content,
5.To inform about content updates, new content, or offers,
6.To provide communications such as confirmations, technical notifications, security alerts, customer support, and assistance messages,
7.To allow users to communicate with each other in games or via our social media accounts,
8.To prevent illegal activities and protect our players from potential cyber threats,
9.To measure interest in the content and services,
10. To ensure internal quality control,
11. To fulfill legal obligations,
12. To authenticate identities, enforce legal limits,
13. To prevent service rule violations,
14. To provide advertising and marketing activities,
15. To enforce licensing restrictions,
16. To comply with regulatory authorities, courts, and administrative legal requests.
B. The general purposes for which we collect, process, store, use, and handle usage data are listed below:
1. To create anonymized and aggregated information,
2. To measure interest in parts or features of the services and content,
3. To fulfill legal purposes for Coconut Games and third parties,
4. To create compatibility with various mobile devices and create special usage patterns,
5. To provide specially designed services and content. V. Your Rights Regarding Your Personal Data
A. You can exercise the following rights regarding your personal data by submitting a support request within the platform or by sending an email to [email protected] or a letter to Levent Mh. Ülgen Sk. 4. Journalists' Site A19/2 Block 142/1 Beşiktaş P.K. 34330 - Istanbul - Turkey.
B. Your communication can be in your native language or a secondary language you use. If necessary, we will use automated translation tools to respond to your request.
C. Please note that you are required to verify that you are the data subject in order for your personal data requests to be evaluated and processed. Do not hesitate to seek support from us in this process.
D. We will make every reasonable effort to facilitate the use of your rights and ensure that exercising your legal rights is free of charge wherever possible.
E. You have the following rights regarding your personal data, and we encourage you to exercise them and inform us about your use of our services:
1. Right to be informed: You have the right to be informed about how your personal data is collected, processed, and stored. In this Privacy Policy, we explain how personal data is collected, processed, and stored. We commit to adhering to this Privacy Policy and ensuring at least this level of protection for your personal data.
2. Right of access: You can request access to your personal data associated with you. This includes information about how your personal data is used, with whom it is shared, and for what purposes it is processed.
3. Right to rectification: You have the right to request the correction of your personal data. This allows you to request the rectification of incomplete or inaccurate data. This right applies when the data we process is: (i) inaccurate; (ii) incomplete or irrelevant to the purpose for which it was collected; or (iii) used in a manner that contradicts current laws.
4. Right to withdraw consent: If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time using the contact details provided above. Withdrawing consent does not affect the lawfulness of processing based on your consent before its withdrawal. If you withdraw your consent, Coconut Games will no longer process your data for the purpose you initially agreed to. However, we may continue to process your data for other purposes, such as complying with legal retention requirements.
5. Right to erasure (‘right to be forgotten’): You have the right to request the deletion of your personal data. This right allows you to request the deletion of your personal data in the following situations: (i) when the data is no longer necessary, (ii) when you withdraw your consent, (iii) when you object to data processing, (iv) when the data has been unlawfully processed, (v) when the data must be erased to comply with a legal obligation, or (vi) when the data was collected in connection with information society services. However, in the following cases, we may not be able to fulfill your deletion request: (i) to exercise the right of freedom of expression and information, (ii) to comply with a legal obligation, (iii) for reasons of public interest in the area of public health, (iv) for archiving purposes, or (v) when necessary for the
establishment, exercise, or defense of legal claims.
6. Right to restriction of processing: The right to restriction means that Coconut Games will continue to store your personal data but will not otherwise process it. Essentially, you have this right when Coconut Games no longer has a legal basis for processing your data or when the existing legal basis has expired or is disputed.
7. Right to data portability: You have the right to request that your personal data be provided to you in a structured, commonly used, and machine-readable format, or to request that it be transferred to another data controller. Please note that this right only applies when processing activities are carried out by automated means and when the legal basis for such processing is your consent or the performance of a contract to which you are a party.
8. Right to object: You have the right to object to the processing of your data in cases where processing is based on legitimate interests. If your data is being processed for direct marketing purposes, we will always honor your request. In other cases, we will stop processing unless we have compelling legitimate grounds that override your interests, rights, and freedoms, or if the processing is related to the establishment, exercise, or defense of legal claims. In such cases, we will inform you of the compelling grounds and the balance of interests.
9. Rights related to automated decision-making and profiling: You have the right to be protected from decisions made solely by automated processing that significantly affect you. We want to inform you that we do not use automated decision-making methods that significantly affect you when processing your personal data. You may request human intervention regarding decisions related to automated processing, or you may object to such decisions.
10. Right to lodge a complaint: In addition to the rights mentioned above, you have the right to lodge a complaint with a supervisory authority in the country where you reside, work, or where an infringement has occurred. However, we ask that you allow us the opportunity to address your concerns before filing a complaint.
11. Children’s privacy: The services, content, and platform are not intended for children under the age of 13, and Coconut Games does not knowingly collect personal data from children under 13. If you are the parent or legal guardian of a child under 13 (or in certain jurisdictions in Europe, under 16), please contact us at [email protected]. If we become aware of a child’s personal data being processed, we will delete it unless we have verifiable consent from the child’s parent or guardian.
F. Once you make a request regarding your personal data, we will provide information about the status of your request without delay and in principle within one month of receiving the request. The complexity of the request, the number of requests, and applicable law may extend this period. If such an extension is necessary, we will inform you within one month of receiving your request. Applicable law may allow or require us to deny your request. If we are unable to fulfill your request, we will inform you of the reasons.
VI. Data Retention Period and Security
A. Coconut Games will retain your data for as long as it is necessary for the purposes outlined above.
1. We will retain your account and associated personal data until you request the deletion of your account. You can delete your account at any time through the account settings section. Please note that deleting your account is permanent, and you will no longer have access to any purchases or rewards associated with your account.
2. In the event of prolonged inactivity on your account, Coconut Games may delete or archive your personal data. If we have your email address, we will notify you before such deletion or archiving.
3. There are certain situations where we may need to retain your data for a longer period:
a) Legal Obligations: We may be required to retain data to comply with applicable laws and regulations.
b) Legal Processes: We will retain your personal data as long as necessary for legal claims, disputes, or proceedings.
c) Fraud and Abuse: Data may be retained for a longer period to prevent fraud, abuse, or security threats.
B. Personal data you provide to Coconut Games is stored on secure servers located in secure facilities, protected by firewalls and data encryption protocols designed to ensure industry-standard security of such information. However, no virtual measure, server, computer, network, or system or data transmission can be guaranteed to be 100% secure. As a result, while Coconut Games strives to protect your data, it does not and cannot guarantee the security of your data.
C. All personnel working within Coconut Games, as well as those assigned by service providers to process data, are obligated to respect the confidentiality of personal data.
D. Coconut Games maintains internal documentation explaining how an appropriate level of technical and organizational security is ensured to safeguard personal data. Additionally, we have a data breach procedure that explains how potential data breaches should be handled. In cases required by applicable law, we will notify the relevant supervisory authority and data subjects of any data breaches.
VII. Revisions to the Privacy Policy
A. We may unilaterally revise this Privacy Policy. In the event of significant changes to the Privacy Policy, Coconut Games will inform you via email or other means as required by applicable law.
B. By continuing to visit the platform, access content, or use the service, you consent to the changes.
C. We will provide the date of the most recent changes to the Privacy Policy at the beginning of the document.
D. You can always access the latest version of the Privacy Policy on our website.
E. Revised versions will take effect immediately upon publication (or notification, if applicable).
F. If you are concerned about how your data is being used, we recommend bookmarking this page and reviewing the Privacy Policy periodically.
A. If you have any questions about our privacy practices or this Privacy Policy, please contact Coconut Games via email at [email protected] or;
B. Send a letter to:
Levent Mh. Ülgen Sk. 4. Journalists' Site A19/2 Block 142/1 Beşiktaş P.K. 34330 - Istanbul - Turkey.
C. The data controller for this Privacy Policy is Coconut Games Software and Trade Marketing Joint Stock Company, registered in Turkey under Central Registration System Number 0211-1314-4560-0001, with its headquarters at Levent Mh. Ülgen Sk. 4. Journalists' Site A19/2 Block 142/1 P.K. 34330 Turkey.