Version
effective date: December 22, 2024
We, MOONJOY LIMITED, issues this Supplemental Türkiye Privacy
Statement. This
document supplements our Privacy Policy.
If you are located in Türkiye, the
Law No. 6698 on Protection of Personal Data ("DPL") applies to the
processing of your personal data.
The data controller is:
You are not legally required to
provide personal data to us but we cannot provide our websites, mobile
applications, forums, blogs or other services (collectively, "Services") without receiving
some personal data from you. If you provide personal data, we rely on the
following legal bases to process it:
·
Necessary for us to perform a contract with you
or take steps at your request prior to entering into a contract per Article
5(2)(c) of the DPL ("Contract
Performance Legal Basis");
·
Necessary for us to comply with an applicable
legal obligation per Article 5(2)(ç) of the DPL ("Legal Obligations Legal Basis");
·
Necessary for us to realize a legitimate
interest based on an assessment of that interest and your privacy and other
fundamental interests per Article 5(2)(f) of the DPL ("Legitimate Interest Legal Basis");
or
·
According to your consent per Article 5(1) of
the DPL ("Consent Legal
Basis"). In these cases, you can withdraw your consent at
any time with future effect by emailing us at cointalesvip@rjoy.com.
The following table outlines the
legal basis along with processing purposes and processed data categories (where
appropriate).
|
Data Categories |
Purposes of Processing |
Legal Basis |
|
l Contact
information l User
generated content l Profile
and gameplay information (including Rjoy Games ID
defined to user) l Device
information l Commercial
information (the purchased products and services within Services, including
data received from application store providers) |
l To
enable us to provide our games (including the social elements of our games,
such as team play and competitions), to ensure that your purchases are
activated in the games, to provide you with player support if you need it; l To
provide access to certain areas, functionalities and features of our
Services, including social features and multiplayer competitions; l To
enable us to optimize our games for you and for the device that you are
using, as well as to deliver customized in-game events, offers and
promotions; l To
verify your identity and entitlement to products or Services when you contact
us or access our Services; l To
help maintain the safety, security and integrity of our property and
Services, technology assets and business; l To
respond to your comments and inquiries and provide customer support services. |
Contract Performance Legal Basis |
|
l Contact
information l User
generated content l Profile
and gameplay information (including Rjoy Games ID
defined to user) l Survey
information l Device
information l Analytics
information l Commercial
information l Information
that may be received from social media network providers (strictly limited to
your privacy settings with the social network provider) |
l To
manage our organization and its day-to-day operations; l To
request your participation in our surveys about our organization,
organizations we partner with, and the Services; l To
develop new games and other Services; l To
enable players to communicate with each other in games or on our social media
accounts; l To
measure interest in our Services; l To
conduct internal research and analytics; l To
personalize your in-game profile; l To
personalize our Services, understand our users and their preferences to
enhance user experience and enjoyment using our Services and improve our
users' experience; l To
ensure internal quality control. |
Legitimate Interest Legal Basis—namely, to operate
and optimize our business; improve our Services; administer communities of
users; develop new Services; manage our relationships with users; and ensure
the security and integrity of our platforms and systems. |
|
l Contact
information l User
generated content l Profile
and gameplay information l Parental
information l Other
information required to address your concern submitted through customer
service channels |
l To
communicate with you regarding Services-related information, including
confirmations, technical notices, updates, security alerts and support and
administrative messages; l To
provide support through our customer service channels when requested. |
l If
we are contractually required to provide such communications or support,
Contract Performance Legal Basis. l If
applicable laws require us to provide such communications or support, Legal
Obligations Legal Basis. l Otherwise,
Legitimate Interest Legal Basis—namely, to manage our relationship with you. |
|
l Contact
information l User
generated content l Profile
and gameplay information l Survey
information l Device
information l Analytics
information l Commercial
information l Parental
information |
l To
enable us to comply with laws that apply to us, to prevent fraud, to ensure
compliance with our Terms of Service or, where necessary, to defend, exercise
or establish our legal rights, including our rights under our Terms of
Service; l To
comply with contractual and legal obligations and requirements; l To
activate, verify and give effect to parental control settings; |
l If
we are contractually required to process your personal data for these
purposes, Contract Performance Legal Basis. l If
applicable laws require us to process your personal data for these purposes,
Legal Obligations Legal Basis. l Otherwise,
Legitimate Interest Legal Basis—namely, to enable us to comply with laws,
prevent fraud, enforce contracts and defend, exercise or establish our legal
rights. |
|
All related information for the transaction |
l To
evaluate and enter into a reorganization, restructuring, merger, acquisition,
or whole or partial sale or transfer of our business or assets
("Business Transaction") l To
engage in the marketing activities described in this Privacy Policy. |
Legitimate Interest Legal Basis—namely, to engage
in a transaction that our management team considers to be advantageous to our
business interests. But we will seek your consent if we wish to use your
personal data for any new purpose incompatible with those set forth in our
Privacy Statements, and if you provide such consent, the Consent Legal Basis
applies. |
|
l Analytics
information l Device
information l Commercial
information l Inferences |
To use or disclose personal data for cross-context
behavioral advertising, targeted advertising, or interest-based. |
We obtain consent before using tracking
technologies other than essential technologies on your device and rely on the
Consent Legal Basis to process your personal data to customize our
advertising to you or deliver cross-context behavioral advertising, targeted
advertising or interest-based advertising to you. |
Your personal data is transferred
abroad in accordance with Article 9 of the DPL.
In Türkiye, you have the following
rights, subject to the conditions under the DPL:
·
Right to learn whether your personal data are
processed or not; and
·
Right to request information regarding your
data, if your personal data are processed; and
·
Right to learn the purpose of processing of
your personal data, and whether your personal data are used for the intended
purposes or not; and
·
Right to learn the identity of third parties to
whom your personal data are transferred in Türkiye or abroad; and
·
Right to request completion or correction of
your data, if your personal data are processed incompletely or inaccurately,
and
·
Right to request deletion or destruction of
your personal data; and
·
If your personal data are corrected, deleted or
destroyed, to request notification of these transactions to third parties to
whom your personal data are transferred; and
·
Right to raise objections against any
consequences that may arise in disfavor of you as a result of analysis of the
processed data solely and exclusively through automatic systems; and
·
Right to claim indemnification of your damages
and losses, if any, incurred due to illegal or unlawful processing of your
personal data
To submit a request to exercise your
privacy rights, you can contact us by any method described in the Contact Us
section below. In your request, please describe what rights you are exercising
and how you would like us to assist. We may need to request specific
information from you to help us verify your identity and that you have the
right to request what your
are requesting. These are security measures to ensure that we do not disclose
personal data to any person who has no right to receive it, or otherwise
process the data in unauthorized ways. We may also contact you to ask for
further information about your request to clarify the scope of your request and
speed up our response. The requests in your application will be resolved as
soon as possible according to the nature of your request and within thirty days
at the latest.
If you have any questions about our
privacy practices, personal data processing activities, or would like to
exercise your rights under privacy laws, you may contact our privacy team
here: cointalesvip@rjoy.com.
From time to time, we may revise
this Supplemental Türkiye Privacy Statement. When we do so, the changes will be
posted and the revised document will be available online and the "last updated"
date above revised.