Privacy Policy

Last Updated: October 26, 2023

Mysia Studios (collectively, "Mysia Studios", "us", "our", or "we") provides this Privacy Policy (this "Policy") to describe the types of information we collect and the ways we collect, store, use, and manage this information, including personal information, that our users ("users", "your", or "you") provide or we collect in connection with your activity on the Mysia Studios website (the "Website") and any Mysia Studios game provided on a mobile platform or other platforms (each a "Game," collectively with the Website and other services we may provide, the "Services").

Please note that the scope of this Policy is limited to information and data collected or received by Mysia Studios through your use of the Services. Mysia Studios is not responsible for the actions of individuals with no relationship to Mysia Studios or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

1. Information We Collect

We may collect information about you in a variety of ways when you use our Services. This information includes:

A. Information You Provide to Us Directly

We collect information that you voluntarily provide to us, such as when you:

• Contact us via email or through our Services for support or inquiries. This may include your name and email address.
• Participate in surveys, contests, or promotional activities.
• Register for an account or subscribe to our newsletters (if applicable).

B. Information Collected Automatically When You Use Our Website

When you access our Website, our servers may automatically collect information, including:

• Derivative Data / Log Information: Your IP address, browser type and settings, operating system, access times, pages viewed, and referring web page addresses.

C. Information Collected Automatically When You Play Our Games

When you play our Games, we may automatically collect information that helps us identify your device and understand your gameplay, including:

• Device Information: Technical features of your terminal equipment and software, such as unique device identifier (e.g., UDID), Advertising ID (such as Apple's Identifier for Advertisers (IDFA) or Google Advertising ID (GAID)), device type and model, operating system type and version, screen size, time zone, and general (city/country) location (based on your IP address or device settings if location services are enabled). A device identifier is a sequence of numbers and letters unique to your mobile device.
• Gameplay Data: Game session time, in-app purchases (please note, we do not receive or store your payment card information; this is handled by the respective platform's payment processor), resource events (e.g., acquisition or spending of virtual currencies or items), progression events that mark your progress in the Game, and install timestamp (the time of the first event received from the app).
• Usage Data: Information about how you use the Games, such as features accessed, game settings, and interactions with other players (if applicable).

Our Games are developed using the Unity engine, and we may use SDKs such as GameAnalytics and others for analytics, advertising, and to improve your gaming experience. These third-party services may collect data according to their own privacy policies. We encourage you to review their policies:

• Unity: https://unity.com/legal/privacy-policy
• GameAnalytics: https://gameanalytics.com/privacy/
{/* Add links to other SDK privacy policies as applicable */}

D. Push Notifications

We may occasionally send you push notifications through our mobile Games to send you game updates, high scores, and other service-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 (usually by going to the settings for the app itself or the notification settings for your device).

E. Advertising IDs and Opting Out of Interest-Based Advertising

Advertising IDs (like Apple's IDFA and Google's GAID) are unique, user-resettable identifiers for mobile devices that advertisers use for personalized advertising. They can be consistent across mobile applications, allowing for cross-app tracking. You can limit or opt out of interest-based advertising through your device settings:

• On iOS devices: Go to Settings > Privacy & Security > Tracking, and turn off "Allow Apps to Request to Track." You can also go to Settings > Privacy & Security > Apple Advertising and toggle off "Personalized Ads."
• On Android devices: Go to Settings > Google > Ads, and enable "Opt out of Ads Personalization" or "Delete advertising ID." (The exact path may vary by device and Android version).

Please note that opting out will not stop you from seeing ads, but they may be less relevant to your interests.

2. Legal Basis for Processing Your Information

We collect and process your personal information based on one or more of the following legal bases, depending on the specific purpose of processing:

• Your Consent: In some cases, we ask for your consent to process your personal information, for example, for certain types of marketing communications or when using certain cookies or tracking technologies. You can withdraw your consent at any time.
• Performance of a Contract: We may process your information when it is necessary to perform a contract with you, such as to provide you with access to our Games and Services as described in our Terms of Service.
• Legal Obligations: We may process your information to comply with applicable legal or regulatory obligations.
• Legitimate Interests: We may process your information where it is necessary for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests. Our legitimate interests include improving and optimizing our Services, ensuring security, preventing fraud, and for analytics and research purposes.

3. How We Use Your Information

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Services to:

• Provide, operate, maintain, and improve our Services, including our Website and Games.
• Create and manage your account (if applicable).
• Personalize and improve your experience with our Services, such as by providing tailored content and features.
• Respond to your comments, questions, and provide customer service and technical support.
• Send you technical notices, updates, security alerts, and support and administrative messages.
• Communicate with you about products, services, offers, promotions, rewards, and events offered by Mysia Studios and others, and provide news and information we think will be of interest to you (with your consent, where required).
• Monitor and analyze trends, usage, and activities in connection with our Services to understand player behavior, troubleshoot issues, and optimize our Services.
• Conduct research and create reports for internal use to improve our Games and Services.
• Detect, investigate, and prevent fraudulent transactions, unauthorized access, and other illegal activities.
• Link or combine information we get from others to help understand your needs and provide you with better service.
• Serve advertisements within our Games (our Games may be free to play due to advertising).
• Cross-promote our Games and Services.
• For any other purpose disclosed to you at the time we collect your information or with your consent.

4. How We May Share or Disclose Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

• With Third-Party Service Providers: We may share your information with third-party vendors, consultants, and other service providers who perform services on our behalf, such as analytics providers (e.g., Unity Analytics, GameAnalytics), cloud hosting services, customer support tool providers, and advertising partners. These service providers will only have access to your information to the extent necessary to perform their functions and are obligated to protect your information.
• With Our Affiliates: We may share your information with our affiliated companies for operational, analytical, or marketing purposes consistent with this Policy.
• For Analytics and Research: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, with partners for industry analysis, demographic profiling, and other research purposes.
• In Response to Legal Process or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process (e.g., a subpoena or court order), to investigate or remedy potential violations of our policies or law, or to protect the rights, property, and safety of Mysia Studios, our users, or others, we may share your information as permitted or required by any applicable law, rule, or regulation.
• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. You will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• With Your Consent: We may share your information with other third parties when we have your explicit consent to do so. For example, with your consent, we may share anonymous or aggregated information with advertisers, publishers, business partners, and sponsors.

Our third-party SDKs (like Unity, GameAnalytics) may collect and analyze user and device-related data on our behalf. This can include application usage, access and session times, interactions with advertising, device make/model/OS, carrier, screen size, network connection type, IP Address, and Advertising ID (IDFA/GAID). This data is used for purposes such as providing their services, enabling advertising, auditing, research, and ensuring their technologies function properly. We encourage you to review their privacy policies, linked in Section 1C.

5. Your Privacy Rights

Depending on your location and applicable data protection laws, you may have certain rights regarding your personal information. These rights may include:

• Right to Access: You may have the right to request access to the personal information we hold about you.
• Right to Rectification: You may have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
• Right to Erasure (Right to be Forgotten): You may have the right to request that we delete your personal information under certain conditions.
• Right to Restrict Processing: You may have the right to request that we restrict the processing of your personal information under certain conditions.
• Right to Data Portability: You may have the right to receive your personal information in a structured, commonly used, and machine-readable format and to have it transmitted to another controller, where technically feasible.
• Right to Object: You may have the right to object to the processing of your personal information under certain conditions, such as for direct marketing purposes or when processing is based on our legitimate interests.
• Right to Withdraw Consent: If we process your personal information based on your consent, you have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information infringes applicable data protection laws.

To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before processing your request. We will respond to your request within the timeframes required by applicable law.

6. Data Retention

We retain your personal information for as long as necessary to provide you with our Services, fulfill the purposes outlined in this Policy, comply with our legal obligations (e.g., for tax and accounting purposes), resolve disputes, and enforce our agreements. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide Services to you (e.g., for as long as you have an account with us or keep playing our Games).
• Whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of your transactions for a certain period of time before we can delete them).
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

Data collected via cookies or similar tracking technologies for analytics or advertising is typically kept for a maximum period of [Specify retention period, e.g., 13-25 months, or refer to specific third-party policies]. Please consult the privacy policies of our third-party partners for details on their data retention practices.

7. Security of Your Information

We use administrative, technical, and physical security measures to help protect your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties.

8. Children's Privacy

Our Services are not directed to children under the age of 13 (or the equivalent minimum age in the relevant jurisdiction), and we do not knowingly collect personal information from children under this age without verifiable parental consent. If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us at [email protected]. If we learn that we have collected personal information from a child under the age of 13 (or equivalent) without verifiable parental consent, we will take steps to delete that information as quickly as possible.

9. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. This includes Turkey, where Mysia Studios is based, and other countries where our third-party service providers operate.

If you are located in the European Economic Area (EEA), Switzerland, or the UK, we will ensure that any transfers of your personal data to countries outside these regions are subject to appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission or other recognized legal mechanisms, or we will rely on your explicit consent where appropriate. By using our Services or providing us with your information, you consent to these transfers, provided that we implement such safeguards where required by applicable law.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by revising the "Last Updated" date at the top of this policy and, in some cases, we may provide you with more prominent notice (such as by adding a statement to our Website homepage or sending you a notification). We encourage you to review this Privacy Policy periodically to stay informed about our information practices and the choices available to you.

11. Contact Us

If you have questions or comments about this Privacy Policy, please contact us at:

Mysia Studios
Balikesir, Turkey
[email protected]