Privacy Policy

1. Introduction

Your privacy is very important to us. We are committed to protecting your personal information and being transparent about how we collect, use, and safeguard your data. We only request personal information when it is necessary to provide our services, improve your experience, or comply with legal requirements. We do not sell, rent, or trade your personal data to third parties for marketing purposes.

This Privacy Policy explains in detail how we collect, use, share, and protect your personal information when you access or use any of our Applications (collectively referred to as the "Applications"). By using any of our Applications, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with this policy or our practices, please do not use our Applications.

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or new services. While we strive to notify you of significant changes through the Applications or other communication channels, there may be times when updates are made without direct notification. Therefore, we encourage you to review this Privacy Policy periodically to stay informed of any changes.

Your trust is very important to us, and we strive to handle your personal data with the utmost care and respect.

2. Information We Collect

2.1 Personal Data Collected

Device Permissions and Access

Depending on the type of device and platform you use to access our Applications, we may request permission to access certain device features and data to provide and improve functionality. These permissions are requested explicitly and must be granted by you before the Application can access the corresponding data or device capabilities.

Here is a detailed overview of the permissions we may request, based on platform and purpose:

• Contacts Permission:
  • Purpose: To access, read, and modify contacts stored on your device. This enables features such as inviting friends, syncing contacts for social features, or identifying connections within the Application.
  • Platforms: Mobile phones, tablets, smartwatches, desktops.
• Microphone Permission:
  • Purpose: To capture audio for voice commands, voice search, audio messaging, or recording functionality. Audio data is processed only as needed and stored or transmitted according to applicable privacy and security policies.
  • Platforms: Mobile devices, desktops, smart TVs, connected cars, smartwatches.
• Social Media Accounts Permission:
  • Purpose: To access profiles and basic account information from linked social media platforms (such as Facebook, Twitter, Instagram) for social login, sharing content, or syncing social features. This permission does not grant access to your passwords or private messages.
  • Platforms: Mobile devices, desktops, web applications.
• Storage Permission:
  • Purpose: To read from and write to your device’s storage, enabling caching of content, saving media files (e.g., images, audio, video), downloading updates, and storing user preferences or offline data.
  • Platforms: Mobile devices, tablets, desktops, smart TVs, connected cars.
• Location Permission:
  • Purpose: To access your device’s location information to provide location-based services such as personalized content, local recommendations, geo-fencing, or targeted notifications. Location data is collected only if you opt in or activate location-based features.
  • Platforms: Mobile phones, tablets, connected cars, smartwatches.
• Camera Permission:
  • Purpose: To allow the Application to capture photos or videos, which may be used for profile images, video calls, or augmented reality features.
  • Platforms: Mobile devices, desktops, smart TVs, connected cars.
• Bluetooth Permission:
  • Purpose: To communicate with nearby devices or accessories, such as wearables or IoT devices, enabling features like device pairing, data sync, or remote control functionality.
  • Platforms: Mobile devices, desktops, connected cars.
• Notification Permission:
  • Purpose: To send push notifications or alerts about updates, promotions, or important information related to the Application.
  • Platforms: All platforms supporting notifications (mobile, desktop, smart TV, connected cars).

2.2 Other Information We Collect

In addition to Personal Data collected via permissions, we may also gather the following information to enhance service delivery and security:

• Usage Data:
  Includes data about how you use the Applications, such as session durations, feature usage, clicks, navigation paths, error reports, and device/system specifications (OS version, browser type, device model). This data helps improve performance, usability, and detect issues.
• Diagnostic and Crash Data:
  Information about application errors, crashes, or malfunctions collected automatically to diagnose and fix bugs and improve stability.
• Log Data:
  Server logs may collect IP addresses, timestamps, access times, request URLs, and other metadata when you interact with the Applications.
• Device Identifiers:
  Unique device IDs, advertising IDs, or tokens used for analytics, personalization, fraud prevention, and targeted notifications.
• Location Data:
  If you have granted location permission, we may collect precise or approximate geographic location information from GPS, Wi-Fi, or network signals.

2.3 How We Use Device Permissions and Data

• All permissions are used strictly to enable features and services you choose to activate.
• Data accessed through permissions is processed according to applicable privacy laws and industry best practices.
• Permissions can be revoked at any time through your device settings. Revoking permissions may limit or disable certain Application functionalities.
• We do not access or collect data beyond the scope of permissions granted by you.
• Any data collected through device permissions is stored securely and retained only as necessary to fulfill the purposes described.

3. How We Use Your Data

We use the Personal Data we collect for a variety of purposes to operate, maintain, and improve our Applications, as well as to communicate effectively with you. Below are the primary ways in which your data is used:

• Analytics and Performance Monitoring:
  We use tools like Google Analytics and similar services to collect information about how users interact with our Applications. This includes tracking usage patterns, session duration, features accessed, and technical performance data. These insights help us understand user behavior, diagnose technical issues, optimize user experience, and improve the overall quality and functionality of our services.
• Communication and Marketing:
  When you subscribe to newsletters, mailing lists, or opt in for promotional messages, we use your email address and contact information to send you updates, announcements, special offers, surveys, and other marketing communications related to our Applications and services. You can opt out of marketing communications at any time by following the unsubscribe instructions included in the messages or by contacting us directly.
• Permissions-Based Functionality:
  We access device capabilities only with your explicit permission to enable specific features and functionalities within the Applications. This includes, but is not limited to, accessing your contacts for social features, microphone for voice commands, storage for caching and media, location for personalized content, and other permissions as outlined in this policy. Your data accessed through these permissions is used solely to provide and enhance the corresponding features and is protected under strict privacy controls.
• Security and Fraud Prevention:
  Personal Data is also used to maintain the security and integrity of our Applications. We monitor for unauthorized access, fraudulent activities, and other potential security threats to protect both our users and our services.
• Customer Support and Service Management:
  We may use your information to respond to your inquiries, provide customer support, process transactions, and manage your account or subscription preferences.
• Legal Compliance:
  In certain cases, we may use or disclose your Personal Data as required by law, regulation, legal process, or governmental request to comply with legal obligations or protect our rights.

4. Sharing and Disclosure of Personal Data

We are committed to safeguarding your Personal Data and do not sell, rent, or trade your Personal Data to third parties for marketing or any other purposes. However, to provide, maintain, and improve our services, we may share your data with trusted third parties under strict conditions and for specific purposes, as outlined below:

• Service Providers and Contractors:
  We may share your Personal Data with third-party service providers and contractors who perform services on our behalf, such as hosting and cloud storage providers, payment processors, customer support, marketing agencies, analytics providers, and IT service companies. These partners are authorized to use your Personal Data only as necessary to deliver the contracted services and must adhere to strict confidentiality and security obligations.
• Legal Authorities and Compliance:
  We may disclose your Personal Data to law enforcement agencies, government officials, or other third parties if we believe it is necessary to comply with applicable laws, regulations, legal processes, or governmental requests. This may include responding to subpoenas, court orders, or to investigate, prevent, or take action regarding illegal activities, suspected fraud, security threats, or violations of our terms of service.
• Application Operation and Business Transfers:
  In certain cases, your data may be shared with third parties involved in the operation, maintenance, and improvement of our Applications, such as software developers, security auditors, or platform partners. We ensure these parties maintain strict confidentiality agreements and implement appropriate data protection measures.
  Additionally, in the event of a merger, acquisition, reorganization, or sale of assets, your Personal Data may be transferred to the acquiring entity or successor, provided that the receiving party agrees to protect your data in accordance with this Privacy Policy.
• Aggregated and Anonymized Data:
  We may share aggregated, de-identified, or anonymized data that does not identify you personally with third parties for research, marketing, or analytical purposes. Such data cannot be used to identify individual users.
• With Your Consent:
  We may share your Personal Data with third parties when you have explicitly given your consent to do so, such as when you choose to link your social media accounts or participate in joint promotions.

5. Data Storage and Security

We take the security and confidentiality of your Personal Data very seriously. We implement a range of appropriate technical and organizational measures designed to protect your information against unauthorized or unlawful access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encryption:
  Sensitive Personal Data is encrypted both in transit using industry-standard protocols such as TLS (Transport Layer Security) and at rest using strong encryption algorithms. This helps ensure that your data is protected from interception or unauthorized access during transmission and while stored on our servers.
• Access Control:
  Access to Personal Data is strictly limited to authorized personnel who need the information to perform their job functions. We enforce role-based access controls (RBAC) and the principle of least privilege, ensuring that employees, contractors, and service providers can only access the data necessary for their specific roles. Strong authentication mechanisms, including multi-factor authentication, are employed to prevent unauthorized access.
• Regular Security Assessments and Audits:
  We conduct routine security assessments, penetration testing, vulnerability scans, and internal audits to identify and mitigate potential security risks. Our security practices are continuously reviewed and updated in line with industry best practices and emerging threats.
• Data Minimization and Anonymization:
  We limit the collection and retention of Personal Data to what is necessary for the purposes described in this Privacy Policy. Where feasible, we use anonymization or pseudonymization techniques to reduce the identifiability of Personal Data.
• Secure Development Practices:
  Our development teams follow secure coding standards and conduct code reviews to prevent common security vulnerabilities. Security is integrated into every stage of the Application development lifecycle.
• Incident Response:
  We maintain an incident response plan to promptly address any suspected or actual data breaches. In the event of a security incident affecting your Personal Data, we will take immediate steps to contain the issue, assess the impact, and notify affected users and regulatory authorities as required by law.

Limitations of Security

While we strive to protect your Personal Data, no method of electronic transmission, storage, or security system is completely infallible. Therefore, despite our efforts, we cannot guarantee absolute security of your data. We encourage you to take steps to protect your account information, such as choosing strong passwords and safeguarding your login credentials.

6. Data Retention

We retain your Personal Data only for as long as is necessary to fulfill the purposes for which it was collected, including providing our services, complying with legal obligations, resolving disputes, and enforcing our agreements.

• Purpose-Based Retention:
  Personal Data is retained to support the provision and improvement of our Applications and related services. This includes retaining data for account management, customer support, analytics, and marketing purposes where applicable.
• Legal and Regulatory Requirements:
  In some cases, we may be required by law or regulation to retain certain types of data for specified periods. For example, financial or transactional records may be kept to comply with tax, audit, or other legal requirements.
• User Requests for Data Management:
  You have the right to request the deletion, correction, or suspension of your Personal Data at any time. Upon receiving such a request, we will take reasonable steps to comply, subject to any overriding legal obligations or legitimate business interests. For instance, we may retain certain information if necessary to protect against fraud, resolve disputes, or enforce our terms and conditions.
• Data Minimization and Periodic Review:
  We regularly review the Personal Data we hold and securely delete or anonymize information that is no longer required. This helps minimize the amount of data we keep and reduces privacy risks.
• Backup and Archival:
  Some data may be stored in backup or archival systems for disaster recovery or business continuity purposes. These backups are protected with the same security measures and are purged according to our data retention schedules.

7. User Rights

You have important rights regarding your Personal Data. Depending on your jurisdiction and applicable laws, you may exercise the following rights:

• Right to Access:
  You have the right to request access to the Personal Data we hold about you. Upon request, we will provide you with a copy of your data in a clear and understandable format. Please note that the specific format of the data provided will be determined by Playary, considering technical feasibility and industry standards. Along with your data, we will inform you about how it is being used and with whom it has been shared.
• Right to Rectification:
  If you believe that any Personal Data we hold is inaccurate, incomplete, or outdated, you have the right to request correction or update of your information. We will take reasonable steps to amend your data promptly.
• Right to Erasure (Right to be Forgotten):
  You may request the deletion or anonymization of your Personal Data when it is no longer necessary for the purposes it was collected, or if you withdraw consent and there is no other legal basis for processing. Please note that in certain situations, we may be legally obligated to retain some data or may need to retain it for legitimate business purposes.
• Right to Object:
  You have the right to object to the processing of your Personal Data based on our legitimate interests or for direct marketing purposes. Upon receipt of your objection, we will stop processing your data unless we demonstrate compelling legitimate grounds to continue.
• Right to Withdraw Consent:
  If our processing of your Personal Data is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing performed prior to withdrawal.
• Right to Data Portability:
  You may request to receive your Personal Data in a structured, commonly used, and machine-readable format to facilitate portability. Please note that the specific format of the data provided will be determined by Playary, taking into account technical feasibility and industry standards.
• Right to Restrict Processing:
  In certain circumstances, you can request that we limit how we process your Personal Data, for example, while we verify a complaint or during a data dispute.

How to Exercise Your Rights

To exercise any of these rights, please contact us using the contact information provided below. We may require you to verify your identity before processing your request to ensure your privacy and security. We will respond to your request within the timeframe required by applicable laws, usually within one month.

8. Device Permissions and Their Management

Certain features of our Applications require your explicit permission to access specific functionalities on your device. These permissions enable us to provide a richer, more personalized, and seamless user experience. The permissions we may request include, but are not limited to:

• Contacts:
  Access and modify your contacts stored on your device. This permission allows features such as inviting friends, syncing contacts for social interactions, and enhancing your social experience within the Applications.
• Microphone:
  Record audio through your device’s microphone to enable interactive features such as voice commands, voice messaging, audio recording, or voice search functionalities.
• Social Media Accounts:
  Access your social media profiles from platforms such as Facebook, Twitter, or others you connect with. This facilitates social login, content sharing, and syncing social features with your account.
• Storage:
  Read from and write to your device’s shared storage. This permission is used for caching content, saving media files (like images, audio, or videos), downloading updates, and storing user preferences or offline data.
• Location:
  Access your device’s location data to provide location-based services such as personalized content, recommendations, geo-fencing, and location-aware notifications.
• Camera:
  Capture photos and videos using your device’s camera for features like profile pictures, video calls, or augmented reality experiences.
• Bluetooth:
  Connect and communicate with nearby devices and accessories, enabling functionalities like device pairing and data synchronization.

Managing Permissions

• Granting Permissions:
  Permissions are requested explicitly and only when needed for the respective feature to function properly. You have full control to grant or deny these permissions based on your preferences.
• Revoking Permissions:
  You can revoke or modify permissions at any time through your device’s system settings. Revoking permissions may affect or disable certain features within the Applications.
• Impact of Revoking Permissions:
  Please be aware that revoking critical permissions may limit the functionality or prevent certain features from working as intended. We recommend reviewing the impact before disabling any permissions.
• Privacy and Security:
  We only access data or device features for the purposes explicitly stated in this Privacy Policy and do not collect or use information beyond the scope of granted permissions.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience across our Applications, improve functionality, and provide personalized content. These technologies help us understand how you interact with our services and enable certain features. Below is an overview of how we use cookies and your control options:

What Are Cookies and Tracking Technologies?

Cookies are small text files stored on your device by your web browser or Application. Similar technologies include web beacons, pixel tags, local storage, and device identifiers, which collect and track information about your usage.

Purposes of Cookies and Tracking Technologies

• Ensuring Application Functionality:
  Some cookies are essential to the operation of our Applications, enabling basic features such as authentication, session management, and user preferences. Without these cookies, certain services may not function correctly.
• Analyzing Usage Patterns:
  We use cookies and tracking tools to collect information about how users navigate and use our Applications. This data includes pages visited, time spent, click patterns, device types, and error reports. Analyzing this data helps us improve performance, user experience, and troubleshoot issues.
• Personalizing Content and Advertising:
  Cookies allow us to deliver tailored content, offers, and advertisements based on your interests and behavior. This personalization enhances relevance and engagement with our services.
• Third-Party Analytics and Advertising:
  We may use third-party services, such as Google Analytics and advertising networks, which deploy their own cookies to collect data on our behalf. These third parties have their own privacy policies governing their data collection and use.

Managing and Controlling Cookies

• Browser and Device Settings:
  Most browsers and devices allow you to control, block, or delete cookies through their settings or preferences menus. You can typically choose to disable all cookies, allow only certain types, or clear cookies regularly.
• Impact of Disabling Cookies:
  Disabling cookies or restricting tracking technologies may impair the functionality of our Applications and limit your ability to use certain features. For example, you may not be able to stay logged in, save preferences, or receive personalized content.
• Opt-Out Tools:
  Some third-party services we use provide opt-out mechanisms to control personalized advertising or analytics tracking. Links to these tools are often available in their respective privacy policies.

10. Third-Party Services

Our Applications may use third-party services to help provide, analyze, and improve our services. These third parties collect, store, and process data on our behalf under strict agreements and are responsible for complying with their own privacy and security practices. Some of the key third-party services we use include:

• Google Analytics:
  Used to analyze web and application traffic, understand user behavior, and generate reports to help improve the user experience.
• Mixpanel:
  An analytics platform that tracks user interactions and engagement within our Applications, helping us optimize features and user retention.
• Firebase:
  A development platform that provides services such as analytics, crash reporting, performance monitoring, and cloud messaging to ensure stable and responsive Applications.

These third-party providers operate independently and have their own privacy policies governing their data handling practices.

11. International Data Transfers

Our servers currently reside in the United States of America (USA), where your Personal Data may be stored and processed. Because the USA may have different data protection laws than your country of residence, please be aware that your data could be subject to access requests by government authorities under applicable laws.

In the future, we may expand our infrastructure and operate servers or use cloud services in other countries around the world to improve service availability and performance. In such cases, your Personal Data may be transferred, stored, and processed in those locations.

Safeguards for International Transfers

To protect your Personal Data when it is transferred internationally, we implement appropriate safeguards in accordance with applicable laws. These may include:

• Ensuring that any data transfers comply with recognized legal frameworks, such as Standard Contractual Clauses (SCCs), or other appropriate mechanisms approved by regulatory authorities.
• Contractual commitments with our third-party service providers requiring them to adhere to strict data protection and confidentiality obligations.
• Applying security measures to protect Personal Data regardless of where it is stored or processed.

12. Children’s Privacy

The minimum age to use Playary and its Applications is 13 years old, or the minimum age required by applicable law in your jurisdiction. This age requirement is explicitly stated in our Terms of Service, which all users must agree to before using our services.

Our Applications and services are not intended for individuals under the age of 13, and we do not knowingly collect, use, or disclose Personal Data from children under this age without obtaining verifiable parental or guardian consent where required by law.

Protection Measures

• We design our Applications to avoid knowingly collecting Personal Data from children under 13. Where we offer services or features that may be accessed by minors, we take steps to limit data collection to what is appropriate and necessary.
• If we discover that Personal Data has been collected from a child under the age of 13 without verifiable parental consent, we will promptly delete this information from our systems in accordance with applicable legal requirements.

Parental Rights and Responsibilities

• Parents and legal guardians have the right to review, request correction, or request deletion of their child’s Personal Data that we have collected. We encourage parents to actively monitor their children's online activities and educate them about safe internet practices.
• To exercise these rights or if you believe we have collected Personal Data from a child under 13 without parental consent, please contact us immediately using the contact details provided in this Privacy Policy.

How to Contact Us Regarding Children’s Privacy

If you have concerns or questions about how we handle children’s Personal Data, or if you want to request removal of such data, please reach out to us promptly. We will work diligently to address your requests in a timely and thorough manner.

We are committed to protecting the privacy and safety of children and complying with applicable laws such as the Children’s Online Privacy Protection Act (COPPA) in the United States and similar regulations elsewhere.

13. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or for other operational reasons. When we make material changes, we will update the Last Updated date displayed within this Privacy Policy and post the revised policy on this page.

Please note that we may not always notify you directly of changes. It is your responsibility to periodically review this Privacy Policy to stay informed about how we collect, use, and protect your Personal Data.

How We Notify You of Changes

• Notification: For significant changes that affect your rights or the handling of your Personal Data, we may provide additional notice through email, in-application messages, or other appropriate communication channels.
• Review: We encourage you to review this Privacy Policy regularly to stay informed about any updates.

Your Continued Use

Your continued use of our Applications after the posting of any changes to this Privacy Policy constitutes your acceptance of those changes. If you do not agree with the updated terms, please stop using the Applications and contact us to request removal of your Personal Data.

Right to Data Removal

If you object to any changes or wish to have your Personal Data deleted, please contact us promptly using the contact details provided in this Privacy Policy. We will process your request in accordance with applicable laws and our data retention policies.

14. Contact Information

If you have any questions, concerns, or requests regarding your Personal Data, this Privacy Policy, or any related matter, please do not hesitate to contact us. We are committed to addressing your inquiries and protecting your privacy.

How to Contact Us

Data Controller / Owner: PLAYARY YAZILIM DONANIM BİLİŞİM TİCARET TAAHHÜT VE SANAYİ LİMİTED ŞİRKETİ
Email: [email protected]

15. Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:

Personal Data

Any information that relates to an identified or identifiable natural or legal person. This may include, but is not limited to, a name, email address, phone number, user ID, location data, IP address, or any combination of data that could be used to identify a user directly or indirectly.

Usage Data

Information collected automatically through the use of the Application or from the infrastructure of the Application itself (for example, the duration of a page visit). This may include data such as your device’s Internet Protocol (IP) address, browser type, browser version, visited pages, time and date of your visit, time spent on those pages, and other diagnostic or interaction data.

Data Controller

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. For this Application, the Data Controller is PLAYARY YAZILIM DONANIM BİLİŞİM TİCARET TAAHHÜT VE SANAYİ LİMİTED ŞİRKETİ.

Data Processor

A natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Data Controller. The Data Processor acts only on instructions from the Controller and is bound by contractual obligations to safeguard the data.

Cookies

Small text files that are stored on your device (computer or mobile device) when you visit a website or use an app. Cookies may be used for a variety of purposes, including storing preferences, enabling certain functionalities, tracking user behavior for analytics, and delivering personalized advertisements.

Cookies may be classified as:

• Session Cookies: These are temporary and deleted when you close your browser or application.
• Persistent Cookies: These remain on your device for a set period or until deleted manually.
• First-Party Cookies: Set directly by the website or app you are using.
• Third-Party Cookies: Set by domains other than the one you are visiting, usually for tracking and advertising purposes.

You can manage your cookie preferences through your browser or device settings at any time.