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Privacy Notice
Cypher Games Inc. [“Cypher Games”] develops and publishes games for website and mobile devices on which players can use Cypher Games’s services [“Services”]. As a subsidiary of Cypher Games, Cypher Games Yazılım Pazarlama Anonim Şirketi [“Cypher Games TR”] located in Istanbul/Türkiye, and controlled by Cypher Games also operates in the scope of our Services under this Privacy Notice. Cypher Games is the “data controller” of your personal data unless otherwise stated below.
This Privacy Notice applies whenever your personal data is processed as part of our Services, which means our games, services and contents operated by Cypher Games TR who processes personal data on behalf of Cypher Games upon its authorization. It describes how we process your personal data when providing these Services to you, and your rights and choices concerning your personal data. The Privacy Notice’s sections are listed above.
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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 store that personal data on our systems and process it 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:
identification data (first name and surname)
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)
your region
links to your profiles on various social networks and social network ID number
information related to any purchases you make in our Services (user ID, amount of expense and package information)
Legal Basis
Necessary for performance of the contract
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Cypher Games’ legal obligations, in particular relating to security, fraud detection and management
Purposes of Processing Your Personal Data
Provide our Services and create accounts in those Services
Protecting Cypher Games’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
Managing players communications
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
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Cooperating with public authorities and law enforcement where lawfully permitted or required
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
when and for how long you play our games
which game features
other players you interact with
what progress or levels you achieve
gameplay activities in which you participate
performance data (the number of clicks on an advertisement)
certain device 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
Legal Basis
Cypher Games's legitimate interest in improving its Services and its website
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Consent
Purposes of Processing Your Personal Data
Tracking users’ habits and preferences
Execution of activities for user's game satisfaction
Execution of activities for ensuring business continuity
Conducting business activities
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Marketing, research, analytics and delivering behavioral advertising
If you choose to use communication features in Cypher Games’s Services to communicate or share information with other players, then we’ll obtain personal data on what is communicated or shared. This includes:
Personal Data
your participation in player message boards
your public posts or comments on message boards
your non-public messages or invitations to other players, made either directly on our websites or through in-game mechanisms
your chats with other players and/or
your posted drawings, or other user-generated content.
Legal Basis
Necessary for performance of the contract
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Cypher Games's legitimate interest in improving its Services and its website
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Cypher Games’ legal obligations, in particular relating to security, fraud detection and management
Purposes of Processing Your Personal Data
Managing players communications
Protecting Cypher Games’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties
For security purposes and to prevent fraud or potentially illegal activities
Conducting business activities
Protecting the safety of our players
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Execution of activities for user's game satisfaction
Execution of activities for ensuring business continuity
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Cooperating with public authorities and law enforcement where lawfully permitted or required
C. Information We Get About You from Connected Third-Party Platforms
If you play Cypher Games’s games or access any of our Services on social networks like Facebook, Google or other third-party platforms, Cypher Games may obtain your certain personal data from that third-party platform.
Depending on the Cypher Games’s game you’re playing, your privacy settings, the third-party platforms, and, if applicable, your friends’ privacy settings on that third-party platforms, Cypher Games may collect and store some or all of the following from the third-party platform:
Personal Data
identification data (your first and surname, your gender);
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;
your age range.
Legal Basis
Necessary for performance of the contract
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Cypher Games's legitimate interest in improving its Services and its website
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Cypher Games’ legal obligations, in particular relating to security, fraud detection and management
Purposes of Processing Your Personal Data
Helping you to connect with other people you know and other third-party platforms you use, including communicating with other players
For security purposes and to prevent fraud or potentially illegal activities
Conducting business activities
Protecting the safety of our players
Protecting Cypher Games’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties
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Execution of activities for user's game satisfaction
Execution of activities for ensuring business continuity
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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 Cypher Games, 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 Cypher Games’s Services and third-party services), including for advertising purposes. You can see the details about why we do this, and how to use cookies and similar technologies, in the Cookie Notice.
Cypher Games uses cookies and other similar technologies to process personal data, including:
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 or website
the amount of time spent on an app feature or web page
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
Legal Basis
Necessary for performance of the contract
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Cypher Games's legitimate interest in improving its Services and its website
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Consent
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Cypher Games’ legal obligations, in particular relating to security, fraud detection and management
Purposes of Processing Your Personal Data
Conducting business activities
Ensuring the security of data controller operations
For security purposes and to prevent fraud or potentially illegal activities
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Marketing, research, analytics and delivering behavioral advertising
Personalizing our Services and our players’ experiences
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Improving, optimizing our Services and our players’ experiences
We may obtain personal data by using cookies and similar technologies with your social network ID or Cypher Games user ID. If you play Cypher Games’s games on a mobile device, in addition to the data that we obtain via using cookies and similar technologies, we may also obtain:
Personal Data
information about the Cypher Games’s games and about other third-party applications with embedded Services you have on your device.
Legal Basis
Cypher Games's legitimate interest in improving its Services and its website
Purposes of Processing Your Personal Data
Conducting business activities
Improve, optimize our Services and our players’ experiences
Ensuring the security of data controller operations
Launch of products
If you have questions, need further information about the purposes and legal grounds for processing your personal data, or want to withdraw your consent please see the Contact Us section below.
1. 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. People you know and Other Cypher Games Players
In Cypher Games’s games, if you play via a social network or connect to a social network (for example, Facebook), your social network friends who also play a Cypher Games’s game will see descriptions of your in-game activity (including Cypher Games’s games you have played), and your name, your player profile (which may include the personal data described above in Information About You That You Share With Us Directly). Moreover, other players in Cypher Games’s games, regardless of whether they are your social network friends, will be able to see your player profile.
Personal Data
identification data (first name and surname)
Legal Basis
Cypher Games's legitimate interest in improving and optimaziting its Services and its website
Purposes of Processing Your Personal Data
Helping you to connect with other people you know and other third-party platforms you use, including communicating with other players
Execution of activities for user's game satisfaction
B. Cypher Games TR
We share your personal data within the Cypher Games TR to enable Cypher Games to carry out the purposes about personal data processing set out in this Privacy Notice.
C. 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
performance data (the number of clicks on an advertisement);
certain device information (IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
a unique identifier, such as your social network ID or Cypher Games player ID.
Legal Basis
Consent
Purposes of Processing Your Personal Data
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 or visit the applicable Cookie Notice.
Please note, after clicking on a third-party advertisement or offer, you may no longer be on a website or app controlled by Cypher Games or the social network via which you are playing Cypher Games’s games. If you have any questions about how these third-party services use your personal data, you should review their policies and contact them directly.
D. 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
identification data (first name and surname)
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)
your approximate location
links to your profiles on various social networks and social network ID number
information related to any purchases you make in our Services (user ID, amount of expense and package information)
Legal Basis
Cypher Games’ legal obligations, in particular relating to provide information to authorized persons, institutions and organizations
Purposes of Processing Your Personal Data
Providing information to authorized persons, institutions and organizations
Execution of activities in compliance with the legislation
E. Third-Party Service Providers
We will share your personal data with third parties who perform services on Cypher Games’s behalf for the purposes of hosting services, and security of our Services, and our third-party business partners who assist Cypher Games 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:
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access to your personal data,
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rectification of your personal data;
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erasure of your personal data (subject to any Cypher Games’s needs that should be justified, to retain personal data, for example with respect to its legal obligations);
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restriction of processing of your personal data (subject to limitations provided in applicable regulations);
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object to processing of your personal data (subject to limitations provided in applicable regulations);
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withdraw your consent, if the processing of your personal data was based on your consent;
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portability of some of your personal data (subject to limitations provided in applicable regulations);
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provide Cypher Games with instructions regarding the use of your personal data after your death.
4. U.S. Privacy Laws
If you are a Nevada resident, you may be able to exercise additional rights to opt out of future sales of certain covered information that a website operator has collected or will collect about you. If you are a California resident, you may be able to exercise additional rights about personal data protection granted by California Consumer Privacy Act (subject to certain limitations). You may exercise your rights by submitting a request by using the Contact Us channels below.
5. Security of Your Information
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.
6. 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. Cypher Games 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.
7. How Long We Keep Your Information
Cypher Games 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.
Cypher Games 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, ligation, or accounting and tax purposes. Archiving implies that this personal data will be subject to limited access restrictions.
8. Contact Us
If you wish you can deliver your requests about processing your personal data,
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By applying to Cypher Games with a valid identity card directly,
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By sending to Cypher Games address “1401 Pennsylvania Ave, Unit 105, Wilmington, Delaware 19806, USA” together with wet signature and ID photocopy,
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By sending via e-mail address (privacy@cyphergames.com) belongs to Cypher Games 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.
9. Changes to Our Privacy Notice
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. If we make changes that we deem material, we will use reasonable efforts to notify (such as by placing a notice in game or on Cypher Games, or by sending you a notice to the e-mail address you have registered with us, if any). We encourage you to periodically check Cypher Games and this Privacy Notice for updates. If you would like a copy of earlier policies, please get in touch using the Contact Us information above.
