A. Privacy declaration of Polity (“ polityonline.com ”)

The information in this declaration applies to the processing of personal data on or via our website and is intended in particular to inform you of the scope of processing, the purposes of the processing, the recipients, legal bases, storage periods, and your rights. Personal data are all information relating to an identified or identifiable natural person, i.e. a person (hereinafter also referred to as “data subject”), including for example your name, your address, or your email address. Processing of personal data means, in particular, the collection, storage, use, and transmission of such data.

Definitions

“Applicable Data Protection Legislation” means any legislation in force from time to time which implements the European Union Directive 95/46/EC and Directive 2002/58/EC and the General Data Protection Regulation (“GDPR”) 2016/679 of April 27th, 2016 and is applicable to this Agreement and all other applicable laws and regulations that may apply to the transfer of Personal Data.

“Personal Data” shall mean any information relating to a Data subject; an identifiable person is one who can be defined, directly or indirectly, notably by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Contact data and Service Data are Personal Data.

“Contact Data” means any names, phone numbers, e-mail addresses, and certain financial details held within commercial systems to conduct the Parties’ relationship management and billing transactions between the Parties;

“Controller”, “Data Subject”, “Personal Data”, “Process/Processing” and “Processor”, shall have the same meaning as in the European Union Directive 95/46/EC or the General Data Protection Regulation 2016/679 of April 27th, 2016.

“Service Data” means any Party’s Personal Data (that is not Contact Data) held within the Parties’ systems, applications, or databases and that may be accessed, processed, used, or stored as a consequence of performing the services under the Agreement.

“Third Country” means a country that is: (i) outside of the European Economic Area; and (ii) not the subject of a formal decision by the European Commission, made pursuant to Section 25(6) of the European Union Directive 95/46/EC or under Article 45 (1) of the General Data Protection Regulation 2016/679, stating that that country ensures an adequate level of protection for Personal Data.

I. Name and Address of the data controller

The data controller within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is:

Jib Oyun Yazilim ve Pazarlama A.S. Kozyatagi Mh. Gulbahar Sk. 15B/22 Kadikoy, Istanbul Turkey Email: info@jib.gs Website: polityonline.com

II. General information data processing

1. Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for the processing of personal data, the legal basis is Art. 6 para. 1 lit. a GDPR. Insofar as the processing of personal data is required for the performance of a contract to which the data subject is a party, the legal basis is Art. 6 para. 1 lit. b GDPR. This also applies to processing operations that are necessary to carry out pre-contractual measures. Insofar as the processing of personal data is required to fulfill a legal obligation to which our company is subject, the legal basis is Art. 6 para. 1 lit. c GDPR. If the processing of data is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights, and freedoms of the data subject do not outweigh the first-mentioned interest, the legal basis is Art. 6 para. 1 lit. f GDPR.

III. What Data We Collect and Process

Personal data means data that may be used to identify an individual, such as full name, email address, contact address, postal code, position data, title, occupation, personal interests, and other data that you choose to submit.

Data We Collect and Process

• Contact data (such as email address)

• Account registration or registration for on-line game participation (such as user name and password)

• Information in Polity community forums, chats, or when you provide feedback or other user-generated content (such as information that you post, comment or follow in any of our content or services; information sent through chat; information you provide when you request information or support from us or purchase content or services from us, including information necessary to process your orders with the relevant payment merchant; in case of physical goods, shipping providers; or, the information you provide to us when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details)

• Other data you choose to give us (such as data about lost account identification, hacking prevention, consumer services, service maintenance, technical support, and surveys, including but not limited to your age, gender, general hobbies and interests, gameplay interests, and habits, browser and device information, game-related preferences and/or data collected through automated electronic interactions and application usage data)

Data we collect automatically

• Data about your account, game progressions, and any use of polityonline.com

• Internet Protocol (“IP”) address

• Data about your device, such as your device ID, device name, device type, operating system, advertising ID, MAC address, IMEI, CPU, language, and the type of browser

• Cookies and similar technologies (see more as below)

• General location data

Our protocol for deleting inactive user account

• Inactive user accounts will be deleted after the last login of 24 months

IV. Cookies or Similar Technologies

In order to measure the effectiveness of our services, some pages on our websites may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize third party’s tracking-utility, from time to time, to log your IP address in determining the path that users take on our sites and identifying repeat users of our sites, to collect the websites or sources that linked or referred you to our services, and/or to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. Notwithstanding the foregoing, we do not link your IP address to your personal data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits. We use the cookies, web beacons, and similar technologies to personalize your experiences on our services and for various other purposes, including:

• remembering you: cookies, web beacons and similar technologies can help us identify you as a registered user or keep the preferences or data that you have previously provided;

• analyzing how you use our services: we can use cookies, web beacons, and similar technologies to understand what visitors (including users) are doing on our services, or what pages or sections are most popular;

• serving to advertise: cookies, web beacons, and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of your provided data; and/or Our authorized contractors or we may use cookies and similar technologies to provide and personalize the services, prevent fraud, and for other purposes mentioned above. Please note you can disable cookies in your browser settings, while some parts of the JIB Games Services may then not function properly.

V. Securing Your Data

Pertaining to your use of our services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal data, such as organizational controls, technical protection, and other protection measures. Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of the risks of hacking, cyber-attacks, etc. on the Internet. Therefore, we urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures. Please note for security reasons, we store passwords in encrypted form. Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.

VI. How and why do we use/share your personal data?

Based on how and why you provide us with your personal data, we may share it in the following ways:

We share your personal data with our company group, including subsidiaries and our Turkish group company for customer support.

We share your personal data with selected third parties who provide services and functionality for the Property, such as message boards or image hosting services.

We share your personal data with analytics and search engine providers to improve and optimize the Properties.

We do not share your personal data with third parties for direct marketing unless you consent to it for specific activities.

Additionally, we may share your personal data to third parties:

If Polity or its assets are acquired by a third party.
If required by law or to aid in the investigation of crime or disorder.
To enforce our Property's terms of use or to protect the rights, property, or safety of our company, customers, or others. This includes fraud protection and credit risk reduction.

VII. Service Providers

Our service providers offer us various administrative, statistical, and technical services. We only share the necessary minimum amount of personal data with service providers to fulfill the requested services, and we require them to safeguard this data and refrain from using it for any other purposes. Here are some of our key service providers:

• AdMost (AdMost Mediation Ltd.)

• OneSignal (Lilomi, Inc.)

• AdMob (AdMob Google Inc.)

• AdColony (Jirbo, Inc.)

• AppLovin (AppLovin Corporation)

• Appnext (Appnext Ltd.)

• Facebook Audience Network (Facebook, Inc.)

• Unity Ads (Unity Technologies ApS)

• Vungle (Vungle, Inc.)

• SupersonicAds (SupersonicAds Ltd.)

• Flurry RTB (Yahoo! Inc.)

• MobFox (MobFox Mobile Advertising GmbH)

• MoPub (MoPub Inc.)

• Facebook Analytics for Apps (Facebook, Inc.)

• Google Analytics for Firebase (Google Inc.)

• Google Analytics (Google Inc.)

• Crashlytics (Google Inc.)

• Facebook Authentication (Facebook, Inc.)

• Frameplay (Frameplay Corp.)

Links to Third-Party Sites

Please note that when we provide links to third-party websites that are not affiliated with Polity (such as clicking on ads within a Property), those sites are not under our control and are not covered by this Policy. If you choose to visit these third-party sites through the provided links, please be aware that the operators of those sites may collect your personal data according to their own privacy policies. We recommend reviewing their privacy policies before sharing any personal data on those sites.

Data Retention

We will store your personal data on our systems only for the duration necessary to provide you with the requested services or to fulfill the purpose for which the data was collected.

If you subscribe to our email marketing, we will retain your email address in our records in case you choose to "opt-out" of receiving emails. This allows us to respect your opt-out request.

In certain cases, you can request the deletion of your data. For more details, please refer to the "Your Rights" section below.

VIII. Your Rights

You have certain rights regarding your personal data under the Law on Protection of Personal Data No. 6698. Here are the key rights and how you can exercise them:

1. Right of Access: You can request to access the personal data we hold about you. This allows you to check its accuracy and ensure lawful processing. Contact us using the provided details to make a subject access request.

2. Right to Rectification and Erasure: If you believe any of your personal data is incorrect or no longer necessary, you can request correction or deletion. We may need to verify the new data and can retain certain data if we have legal grounds to do so. Contact us with your request, including the basis and any replacement data. If you wish to have your data deleted unconditionally and without any requirements, you can send your request to us at info@jib.gs. As a company, we will respond to your request as soon as possible and make the necessary follow-up.

3. Right to Restrict Processing: If we process your data based on legitimate interests, you can ask us to stop if it affects your rights or if you question the validity of those interests. You can also request processing to stop in case of data dispute, unlawful use with retention preference, or no longer needing the data but requiring its retention for legal purposes. Contact us with the relevant details and reasons for your request.If you wish to have your data deleted unconditionally and without any requirements, you can send your request to us at info@jib.gs. As a company, we will respond to your request as soon as possible and make the necessary follow-up.

4. Right to Data Portability: If you want to transfer certain automated processed personal data to a third party, you can request it in a machine-readable format. While this right may not apply to everyone, we're open to considering such requests if applicable. Get in touch with us for your specific request.

5. Stopping Communications

   You have the right to opt-out of receiving our email marketing communications or other regulated electronic messages. To do this, simply use the "unsubscribe" link in the footer of each communication or follow the equivalent mechanism provided. If you are unable to use these links or prefer to contact us directly, you can unsubscribe by emailing us at info@jib.gs and specifying the communications you wish to stop receiving.

6. Objecting to Automated Decision Making and Profiling

   You have the right to be informed about any automated decision making and profiling involving your personal data. If applicable, you can request meaningful information about the logic behind such processing, as well as its significance and potential consequences for you.

7. Exercising Your Rights

   When making a request to exercise your rights, we may ask you to provide proof of your identity to ensure its validity. It will expedite the processing of your request if you clearly state the right you wish to exercise and provide a specific reason for doing so. The more specific and clear you are, the faster and more efficient we can handle your request. If you fail to provide sufficient information, we may delay actioning your request until we receive additional details, and we will inform you accordingly.

Please note that we will provide you with information on how to exercise your rights under the Law on Protection of Personal Data No. 6698.