DATA PROTECTION POLICY
This policy sets out Ging Games’ commitment to ensuring that any personal data, excluding special category personal data but including without limitation contact information, IP address, accessing information (date and time etc.), approximate location, purchase history, app activity, crash logs & diagnostics, device or other IDs that allow us to recognize a device across apps, general technical information about visitor’s/user’s device.
Information received from advertising and analytics partners which Ging Games processes, is carried out in compliance with the applicable data protection law. Ging Games processes the personal data of staff from all over the world but is committed to ensuring that all the personal data that it processes is done in accordance with data protection law. Ging Games ensures that good data protection practice is imbedded in the culture of our staff and our organisation.
Ging Games’ other data protection policies and procedures are:
• record of processing activities
• privacy notices
• personal data breach reporting process and a breach register
• data protection impact assessment process
• IT security policies
Subject to your approval, there are two ways we apply for data collection; direct collection which comprises of directly collecting data from your device through the Titles and/or indirect collection which comprises of indirect collection via our advertising and analytics partners. For this purpose, we engage with analytics partners that collect the information on our behalf. Processing your personal data signifies all types of transactions performed on the data such as; obtaining, recording, storing, preserving, disclosing, transferring, acquiring, making accessible, alignment and preventing access as well as supporting requests directly to Ging Games or to our business partners and service providers located abroad for the purposes of improving our services to you, interact with third party advertisements presented in our games including usage of the personal data shared for marketing purposes or interact with Ging Games advertisements presented in other platforms in order to provide better service to you, to make suggestions, to improve its services, to improve and update our services, to facilitate the use of our games at the works related to your interest and preferences, pursuant to the applicable legal legislation.
Please be informed that we will be sharing your data with
• other advertising and marketing solution partners to receive, to deliver, to achieve advertising purposes, to achieve campaigns,
• our corporate affiliates from which we receive services, such as IT, security, storage, and any other operations,
• as well as service providers to receive services such as fraud detection and prevention, analytics, reporting, and storage.
Please be informed that if the personal data provided to Ging Games by you is requested by official institutions/organizations as necessitated by the law, the data may be transmitted to the relevant authorities and courts if requested by the courts.
This policy applies to all personal data processed by Ging Games and is part of Ging Games’ approach to compliance with applicable data protection law. All Ging Games staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal.
Data protection principles
Ging Games complies with the data protection principles set out below. When processing personal data, it ensures that:
• it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
• it is collected for specified, explicit purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
• it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
• it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’)
• it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’)
• it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)
Ging Games will facilitate any request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.
Ging Games will:
• ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law
• not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice
• ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights
• only collect and process the personal data that it needs for purposes it has identified herein in advance
• ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible
• only hold onto your personal data for as long as it is needed, after which time Ging Games will securely erase or delete the personal data – Ging Games’ data retention policy sets out the appropriate period of time as per the applicable law
• ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely
Ging Games will ensure that all staff who handle personal data on its behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised.
Breaching this policy may result in disciplinary action for misconduct, including dismissal. Obtaining (including accessing) or disclosing personal data in breach of Ging Games’ data protection policies may also be a criminal offence.
Data Subject Rights
Ging Games has processes in place to ensure that it can facilitate any request made by an individual to exercise their rights under data protection law. All staff have received training and are aware of the rights of data subjects. Staff can identify such a request and know who to send it to.
All requests will be considered without undue delay and within one month of receipt as far as possible.
Subject access: the right to request information about how personal data is being processed, including whether personal data is being processed and the right to be allowed access to that data and to be provided with a copy of that data along with the right to obtain the following information:
• the purpose of the processing
• the categories of personal data
• the recipients to whom data have been disclosed or which will be disclosed
• the retention periods
• the source of the information if not collected direct from the subject, and
• the existence of any automated decision making
Erasure: the right to have data erased and to have confirmation of erasure, but only where:
• the data is no longer necessary in relation to the purpose for which it was collected, or
• where consent is withdrawn, or
• where there is no legal basis for the processing, or
• there is a legal obligation to delete data
Restriction of processing: the right to ask for certain processing to be restricted in the following circumstances:
• if the accuracy of the personal data is being contested, or
• if our processing is unlawful but the data subject does not want it erased, or
• if the data is no longer needed for the purpose of the processing but it is required by the data subject for the establishment, exercise or defence of legal claims, or
• if the data subject has objected to the processing, pending verification of that objection
Object to processing: the right to object to the processing of personal data relying on the legitimate interests processing condition unless Ging Games can demonstrate compelling legitimate grounds for the processing which override the interests of the data subject or for the establishment, exercise or defence of legal claims.
Special category personal data
This includes the following personal data revealing:
• racial or ethnic origin
• political opinions
• religious or philosophical beliefs
• trade union membership
• the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person
• an individual’s health
• a natural person's sex life or sexual orientation
• criminal convictions or offences
Ging Games does not process and collect special category data of visitors and users and any third parties.
Responsibility for the processing of personal data
The partners of Ging Games take ultimate responsibility for data protection.
If you have any concerns or wish to exercise any of your rights under this Policy, then you can contact the data protection lead in the following ways:
Name: Necmi Lider Serçemeli
Address: Kavaklıdere Mah. Ballı Sok. No8/2 Çankaya/ Ankara/ Turkey
Telephone : +90 (539) 667 02 01
Monitoring and review
This policy was last updated in August 2022 and shall be regularly monitored and reviewed, at least every two years.