Effective Date: November 22, 2021
As Grand-Attic Publishing Limited (“Grand-Attic” or “we”, “us”) we are a technology and entertainment company that designs, develops, and publishes mobile games. This Policy governs and details the main principles that Grand-Attic applies to the data we collect and process to develop, publish and monetize websites, mobile games, and applications (collectively the “Services”).
Your privacy and the security of your personal data is, and will always be, enormously important to us.Where this Policy refers to "personal data" it is referring to any information that relates to an identified or identifiable living individual.
This Policy applies to websites, mobile applications, forums, and every kind of blog of Grand-Attic and any other online or offline services provided by Grand-Attic. It also applies to our marketing and advertising activities on all platforms and other services that we may provide to you from time to time.
Under this Policy, your personal data shall be processed in order to provide the Services once you download our mobile application, access and/or play our games, or interact with our websites or other Services. If you have any other concerns about providing data to us or it being used as described in this Policy you should not use our games or other Services.
2. Why We Collect Personal Data
When you install our mobile games and use our Services, we can or our partners can collect and process some of your data for different legitimate purposes. You will find below explanations regarding the reasons why we may collect data and the legal bases Grand-Attic relies on in each case.
We and/our partners may collect data:
- To provide you with the Services you asked for;
- To run analytics and understand how users interact with our Services in order to continuously improve it either directly or through third-party partners; and
- Legal basis for third-party analytics - In the countries where collecting users’ consent may be required by applicable laws and regulations, Grand-Attic only shares personal data collected through Grand-Attic apps with third-party partners that provide Grand-Attic with analytics services.
- Legal basis for first-party analytics – Legitimate interest. Grand-Attic collects user data for the purpose of its own internal analytics tools. Data is used for the sole purpose of Grand-Attic analytics tool and is not shared with any third parties. This data processing is based on the legitimate interest of Grand-Attic.
- To serve advertising tailored to the preference and interests of our users and allow Grand-Attic to continue to provide free services and products.
- Legal basis –In the countries where collecting users’ consent may be required by applicable laws and regulations, Grand-Attic only processes or shares personal data collected through Grand-Attic apps for personalized advertising purposes once you express your consent through the pop-up notice included in one of our apps and/or mobile game.
For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “settings” page in our various applications. Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests. 3. What Personal Data Does Grand-Attic Collect From Mobile Games and Services
For all the purposes listed above the data that Grand-Attic collect is limited to:
- Your IP address;
- Your Mobile Advertising ID (which are technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings);
- Technical information about the device you use and your connection (user agent, type of connection, timestamp);
- Location information without direct and identified address; and
- Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks).
4. With Who May Your Personal Data To Be Shared
We may share any information we receive with service providers. The types of service providers (processors) to whom we entrust personal data include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. Grand-Attic has executed appropriate contracts with the service providers that prohibit them from using or sharing personal data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Marketing Partners. Through our Services, Grand-Attic may allow third-party advertising partners to set tracking tools (e.g., Cookies) to collect the following information within our Services:
- performance data (like the number of clicks on an advertisement);
- certain technical information (for example, IP addresses, non-persistent device identifiers such as Advertising ID and de-identified persistent device identifiers such as a hashed Android ID);
- your social network ID;
- other contextual data about your gameplay (for example, your level and session length); and
- pseudonymous data, not directly identifying information (e.g., OS name and versions, device models, timestamp).
These advertising partners may use this information (and similar information collected from other websites) to measure how effective ads are for delivering targeted advertisements to you about our games within their networks. This practice is commonly referred to as “interest-based or targeted advertising.” We may allow access to other data collected by the Services to facilitate the transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you.
Business Partners. Grand-Attic may share personal data with our Business Partners including but not limited to analytic companies and affiliates for our and our affiliates’ internal business purposes or to provide you with the Services that you have requested.
Grand-Attic does not share your personal data with third parties without your prior consent in the countries where collecting users’ consent may be required by applicable laws and regulations. When you consent to the collection of data for advertising and analytics purposes, we may share the data listed above with the following categories of recipients:
- Marketing Partners: that allow us to monetize the ad inventory of our apps and provide users with free products and services.
Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:
- Facebook -https://www.facebook.com/about/privacy
- AdColony - https://www.adcolony.com/privacy-policy/
- Applovin - https://www.applovin.com/privacy/
- Chartboost - https://answers.chartboost.com/en-us/articles/200780269
- Fyber - https://www.fyber.com/privacy-policy/
- Google AdMob - https://policies.google.com/privacy
- InMobi - https://www.inmobi.com/privacy-policy/
- IronSource - https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
- Mintegral - https://www.mintegral.com/en/privacy/
- Ogury - https://ogury.com/privacy-policy/
- Pangle - https://www.pangleglobal.com/privacy
- Snap - https://snap.com/en-US/privacy/privacy-center
- Tapjoy - https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy
- TikTok - https://www.tiktok.com/legal/privacy-policy-us?lang=en
- Unity Ads - https://unity3d.com/legal/privacy-policy
- Vungle - https://vungle.com/privacy/
- Business Partners and Analytic Companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:
- Authorities: only to the extent we are obliged to by applicable laws and regulations.
You can set your web browser to warn you about attempts to place Cookies on your computer or limit the type of Cookies you allow. Please be advised that if you disable Cookies, you may lose some of the features and functionality of our Services because the Cookies are necessary to track and enhance your game activities.
6. Your Rights
You have certain rights in connection with your personal data and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.
Those rights include:
- Access to personal data: You have the right to access your personal data that Grand-Attic is using.
- Correction or deletion of personal data: You have the right to ask Grand-Attic to correct or complete your personal data if it is wrong or incomplete. You may also have the right to ask Grand-Attic to delete your personal data when certain conditions apply.
- Restriction on processing of personal data: You may have the right to ask Grand-Attic to restrict the use of your personal data, when certain conditions apply.
- Object to processing of personal data: You may have the right to object to the use of your personal data by Grand-Attic, when certain conditions apply.
- Portability of personal data: You may have the right to receive your personal data in a structured and commonly used format so you can use this data with another company when certain conditions apply.
You must be over 13 years old to play our games and use our Services. We do not collect personal data from anyone under 13 years old person knowingly and willfully. However, if the Services are used by such person in contradiction to this Policy, we may collect personal data from such person. If you believe that we might have any information from or about a child under 13 years old (or under 16 years old in certain jurisdictions in the European Union countries and/or districts), please Contact Us.
8. International Transfer
All personal data collected or stored by Grand-Attic or its business partners may be stored anywhere in the world, including, but not limited to, in the Republic of Turkey, the United States, the European Union, in the cloud, on our servers, and on the servers of our service providers. When we transfer your personal data internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your personal is transferred to or stored, used or processed in may be different from the privacy laws applicable to the place where you are resident.
By providing your personal data to us, you consent to the storage of your personal data in the above-mentioned locations.
If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data to Turkey and the United States and to processing of your data globally.
By choosing to visit our website, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Policy will be governed by the laws of Republic of Turkey and the adjudication of any disputes arising in connection with Grand-Attic or the Website will be in accordance with the terms of Terms of Service.
The personal data that you provide to Grand-Attic is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such data such as firewalls and data encryption. However, no server, computer or communications network or system or data transmission over the internet can be guaranteed to be 100% secure. As a result, while Grand-Attic strives to protect your personal data, Grand-Attic cannot ensure or warrant the security of any personal data you transmit to Grand-Attic or through the Services.
By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security privacy, and administrative issues related to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you.
We retain your data for as long as your account is active or as needed to provide you the Service.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
12. Contact Us