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Privacy Policy

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: [email protected] 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. 2. Data deletion and storage time The personal data of the data subject will be deleted or processing restricted as soon as the purpose of storage ceases to apply. In certain cases, data can be stored if this has been provided by the European or national legislator in EU regulations, laws, or other provisions to which the data controller is subject. 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. 1. 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) 2. 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 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. Who May Access Your Personal Data In addition to JIB Games and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data. 1. Other Users Other users may, for example in a group challenge, see your in-game activities in a group challenge. Other users may also see your display data and read the messages you have posted on or through the JIB Games Services. You confirm that the JIB Games Services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users and you acknowledge that any data you posted to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time. 2. Competent Authorities We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose a certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users, or a portion of the public. In addition, to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if you are violating any agreements between us, such as the Terms of Service and this Privacy Policy or otherwise damage us; you are infringing third parties’ rights and interests (including but not limited to intellectual property rights); and/or we believe that it is necessary to prevent fraud or other illegal activities. 3. Third-Party Contractors JIB Games works with a number of (if any) social media contractors, advertising serving contractors, analyzing contractors, payment contractors, fraud-detection contractors, and other third-party contractors on or through our services. We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties. Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. For example, users purchasing products or services will be required to provide additional data to third party payment contractors, such as a valid credit card number, expiration date. Such third-party payment contractors may collect, process, retain your data to process payments, and resolve subsequent payment disputes and inquiries. We may also receive, process, and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history, and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries. Please be aware that we cannot control the activities of such third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. Since those contractors may access your data as a data controller and operate under their own privacy policies, we strongly encourage you to check their privacy policies on their official websites and learn more about their data processing practices. 4. 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.