COMPACTIVE PRIVACY POLICY

Effective Date: May 14, 2024

This Compactive Game Studio Privacy Policy ("Policy") describes how Compactive Oyun Yazılım ve Pazarlama A.Ş. and our subsidiaries "Compactive," "we," "our," or "us"), collect, use, disclose, and otherwise process your personal information, as well as the rights and choices you have regarding such personal information.

You can review information about our privacy practices and your rights and choices below in the following sections:

1. Scope of Our Policy
2. Personal Information We Collect
3. Purposes of Use and Legal Bases for Processing of Personal Information
4. Disclosure and Sharing of Personal Information
5. Cookies, Analytics, and Personalization
6. Targeting and Advertising
7. Third-Party Links and Features
8. User Generated Content
9. Security of Your Information
10. Data Retention
11. International Transfers of Data
12. User Rights and Choices
13. Contact Details
14. Changes to this Policy
15. Additional Information for Users in Certain Jurisdictions

1. Scope of Our Policy

Except as otherwise noted below, this Policy applies to the personal information that Compactive collects and processes related to:

• Our "Services," which include (i) our mobile applications, games, websites, and other online services (and any feature thereof), including games published and developed by Compactive Game Studio, and other Compactive studios, (ii) contests, sweepstakes, promotions, events, research, and surveys that we sponsor or conduct, and (iii) other content, products and services that we make available to customers, purchasers, subscribers, players, and/or users (each, a "User").
• Individuals who subscribe to receive news, information, and marketing communications from us.
• Individuals who engage with us at conferences, expos, and other events in which we participate.
• Users and other individuals that communicate or engage with us related to our Services or our business, communicate with or about us or our content on third-party platforms and social media pages, or otherwise interact with us online or offline.

Not Covered by this Policy. This Policy does not apply to job applicants and candidates who apply for employment with us, or to employees and non-employee workers in the context of our working relationship with them. This Policy also does not apply to any third-party websites, services, products or mobile applications maintained by other companies, which are linked to from our Services.

Aggregate and Non-Identifiable Information. Notwithstanding anything else in this Policy, we may collect, use, share, disclose, and otherwise process aggregate, anonymous, and in some cases de-identified information related to our business and the Services for research, marketing, analytics, and other purposes. Where we use, disclose or process de-identified information, we will maintain and use this information in de-identified form and not to attempt to reidentify the information, except in accordance with applicable privacy laws.

2. Personal Information We Collect

Compactive collects personal information directly from Users, automatically related to the use of the Services, and in some cases, from third parties (e.g., social networks, platform providers, payment processors, and operators of certain third-party services that we use). The information we collect about Users varies depending upon the circumstances, such as the games or other Services used.

Information We Collect Directly From You. You can visit our websites and use certain of our games without registering. However, in certain circumstances (e.g., to create an account or use certain Services), you must provide us with certain personal information.

The personal information that we collect varies depending upon your use of our Services and our interactions with you. It includes:

• Registration and profile information: To access and use certain Services (e.g., to register a game, access subscription-based Services, create an account, or link certain accounts), we may require you to provide us with certain information including your name, username and password, as well as country of residence, email, and other contact information. If you decline to register and provide the mandatory information, you may not be able to use certain Services. We may also ask you or allow you to submit certain optional information, which may include your phone number, birthdate, location, preferences, a photo or avatar, and other profile information.
• Purchases and payments information: If you make a purchase or sign up for certain subscription-based Services, you are required to provide your payment information, including name, billing and shipping address and details, payment type, as well as credit card number or other payment account details (e.g., PayPal). We work with third parties like payment processors and fulfillment partners to process these payments. We do not collect, receive, process, or store credit card or debit card numbers, or other third-party payment account credentials (e.g., PayPal). Depending upon the Service, we may receive your username, name, email, payment type, product(s) or service(s) purchased, and other transaction details, and we may maintain records of your purchase and subscription history.
• Marketing, contests and promotions: You can sign up online or in-person (e.g., at tradeshows, conferences, and the like) to receive direct marketing communications from us, including emails about game launches, developments, and upcoming releases. If you agree to receive direct marketing communications from us, we will collect your email address, and we may also collect your name, preferences, and if relevant, information about your account and the Services and other games you use. We may also collect your name, age, email address, and other information in connection with contests, sweepstakes or other events or activities on our websites and social media channels.
• Your communications: When you email us, call us, chat with us, or otherwise send us communications regarding the Services, we collect and maintain a record of your contact details, communications, and our responses. We may also collect and maintain records of the in-game communications and information that you post in chat sessions, forums, and in other areas of the Services.
• Business partners and others: We may collect and receive personal information about current, former and prospective vendors, business partners, and others with whom we have a business relationship. Generally, this information may include name, company information, payment and contact details, and communications records. If you visit one of our offices, we may ask you to provide certain information for health, safety, or security purposes.

Information We Collect and Receive from Third Parties. We may collect and receive personal information about you from third parties, as explained below:

• Third-party Platforms: You may be able to access or connect with some of our Services through certain third-party platforms (e.g., Steam) and interact with us and others about the Services through forums and communities on third-party platforms (e.g., Discord, https://discord.com/privacy) (each, a "Third-Party Platform"). For example, you may be able to log in to or link to certain Services with a Third-Party Platform account, such as PlayStation™ Network (https://www.playstation.com/en-us/legal/privacy-policy/), Steam (https://store.steampowered.com/privacy_agreement/), Twitch (https://www.twitch.tv/p/en/legal/privacy-notice/), and Xbox Network (https://privacy.microsoft.com/en-us/privacystatement). You may be able to subscribe to certain Services, make game-related purchases, download applications, updates, and other Services, and earn rewards (subject to applicable program terms) from us through Third-Party Platforms. You may also be able to access certain games and other Services or interact with us and others about the Services through Third-Party Platforms, without logging in to our Services or registering with us. In each of these circumstances, we may receive certain personal information from these Third-Party Platforms, subject to their respective policies and terms—for example, if you play a game through a Third-Party Platform, we may receive your username, console identifiers (e.g., XUID and PUID), IP address, MAC address, and other identifiers and device information, and if you communicate about us or the Services through third-party forums, we may collect and receive personal information such as username, email address, public profile information, and information you post about us and our Services.

These Third-Party Platforms may also collect information about your login and activities related to the Service and enable you to interact, chat, and share game information with other users, subject to their respective policies and terms. Each of these Third-Party Platforms is operated and managed by a third party and subject to their respective terms and conditions and privacy policies.

Mobile Platforms. In addition, if you download our mobile apps or use our Services on your mobile device, we may receive personal information from the relevant app stores and platform providers, including your country/location, user ID. and other identifiers and device information. These third parties may also collect information from you as described above.

• Third-party tools: We may use third-party tools to help us manage and analyze our social media presence and report on comments, mentions, and other content that is posted about us and our Services on third-party social media sites and other public channels and forums. How your information may be shared and accessed from these third-party social media sites and other public channels and forums is subject to their respective privacy policies and terms.
• Vendors and providers: We may engage vendors and work with other partners to provide services to us or to Users on our behalf (such as payment processors, digital storefronts, cloud hosting, and service providers). In addition, we may receive personal information from ad networks, analytics providers, and others who we work with to deliver, improve, and measure our online advertising and marketing campaigns.

Information We Collect About Your Usage and Activities. We collect personal information about how you use the Services and interact with us and others, such as information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services (e.g., when you play our games). Such information includes:

• User IDs: we assign Users a unique user identifier, which we use to identify and link relevant information to your activities within the Services (e.g., in-game information such as statistics, scores, achievements, and subscription levels). Some of our games also may allow Users to play without creating an account and/or registering with us. In such cases, we may assign you a guest user ID so that we can keep track of your game play, scores, stats, purchasing data, and usage data for your current and future sessions. If you later decide to register or create an account with us, we may associate your guest user ID and the data from your guest session(s) with your account.
• Activities, stats, friends and preferences: we collect usage and preference details related to your use of the Services, such as language, in-game purchases, game-play statistics, scores, persona, characters, achievements, rankings, time spent playing, click paths, game profile, preferences, friends (including friend relationships through, for example, the creation of clans), and other data that you provide to us as part of your account.
• Other information: We also may automatically or indirectly collect information about you, your computer or mobile device (such as when you use our Services, read our emails, or interact with our social media channels). We (and our third-party providers) may record log files and use cookies, pixel tags, local shared objects, java script, and other mechanisms to collect this information about you. For more information, see Section 5. Cookies, Analytics, and Personalization. In addition, we may collect location information from your device if you grant us permission to do so, or derive your location based upon your IP address.

Children. Compactive does not knowingly request or collect personal information from children younger than 13 years of age. If you believe that we have collected personal information from a child under 13, please contact us as set forth in Section 13. Contact Details, and we will take action as necessary to securely delete such information.

3. Purposes of Use and Legal Bases of Processing for Personal Information

We use, disclose, and otherwise process the personal information we collect as described in this section. In this section, we also explain the legal bases for which we process personal information about Users, as required by the EU General Data Protection Regulation (the "GDPR") (and other relevant laws such as UK data protection laws and the Brazilian General Data Protection Law (the "LGPD")).

Legal Bases for Processing. Pursuant to the GDPR (and other relevant laws), in general, we process your personal information for the following legal bases:

• Performance of our contract with you: The personal information we collect may be used to perform our agreements with you, including our Terms of Service, Code of Conduct, and other terms and conditions applicable to the Services you use.
• To comply with a legal obligation to which Compactive is subject: The personal information we collect may be processed in order to comply with the law and our legal obligations.
• For our legitimate business interests: We may process personal information in furtherance of our legitimate business interests in protecting, maintaining, and improving the Services; developing new games, features, and services; marketing and promoting our Services (including by profiling and marketing to Users); protecting our legal rights and interests; in support of mergers, acquisitions, reorganizations, and other business transactions; and to generally operate and improve our business.
• With your consent: We may process personal information about you based on your consent, for example (where required by law) to send you marketing communications, surveys, news, updates, and other communications. In addition, where required by applicable law, Compactive will obtain your consent to this Policy and our collection, use, and disclosure of your personal information. You may be able to withdraw your consent at any time in accordance with applicable laws; please see Section 12. User Rights and Choices for information on how to withdraw your consent.

Purposes of Use and Processing. In general, we use, disclose, and process personal information for purposes described below. Where GDPR or other similar laws apply, we have also set forth the legal bases for such processing (see above for further explanation of our legal bases) in parentheses below:

• Providing our Services and related support: including to operate the Services; to administer contests, programs, and promotions; to communicate with Users about their access to and use of our Services; to respond to User inquiries; to fulfill User orders and requests; to process payments; to provide troubleshooting and other technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and/or for our legitimate business interests)
• Protecting the integrity of the Services: including to verify your identity (when you access or use our Services or interact with us in-person); to detect and prevent fraud, cheating and unauthorized activities; to facilitate software updates; to secure our systems and the Services; to prevent hacking, cheats, and spamming; to enforce our Terms of Service, Code of Conduct, and other applicable terms; and to protect the rights and safety of Users. (Legal basis: performance of our contract with you; to comply with a legal obligation; and/or for our legitimate business interests)
• Analyzing and improving the Services and our business: including to better understand how Users access and use our Services; to evaluate and improve the Services and our business operations; to develop new games, features, offerings, and services; to conduct surveys and other evaluations; and for other research and analytical purposes. (Legal basis: our legitimate business interests)
• Personalizing the Services: including to tailor content we send or display on our websites and other Services (e.g., for your geographic area); to offer personalized help and instructions; to tailor your gameplay experiences; and otherwise personalize your experiences with the Services. (Legal basis: our legitimate business interests; and/or to comply with a legal obligation)
• Advertising, marketing, and promotional purposes: including to send or display targeted marketing to Users and others who may be interested in our Services; to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes. (Legal basis: our legitimate business interests; and/or with your consent)
• Securing and protecting our business: including to protect and secure our business operations, assets, Services, network, and information and technology resources; to investigate, prevent, detect and take action regarding fraud, cheating, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct (Legal basis: our legitimate business interests; to comply with a legal obligation; and/or performance of our contract with you)
• Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect our rights or interests, including in the context of anticipated or actual litigation with Users or third parties. (Legal basis: our legitimate business interests; and/or to comply with a legal obligation; in Brazil, this also includes the exercise of rights in judicial, administrative, or arbitration proceedings in accordance with applicable laws)
• Auditing, reporting, corporate governance, and internal operations: including financial, tax, and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping, and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business. (Legal basis: our legitimate business interests; and/or to comply with a legal obligation)
• Complying with legal obligations: to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. (Legal basis: our legitimate business interests; and/or to comply with a legal obligation)

4. Disclosure and Sharing of Personal information

Compactive may disclose your personal information as described in this section and we will obtain your consent to do so when required by applicable law:

Vendors and Providers. We may engage vendors, agents, service providers, and affiliated entities to provide services to us or to Users on our behalf, such as support for the internal operations of our websites, online stores (including payment processors), products (such as our games), and services (e.g., forum operations and technical support processing), as well as related offline product support services, data storage, and other services. In providing their services, they may access, receive, maintain, or otherwise process personal information on our behalf. Our contracts with these service providers do not permit use of your personal information for their own marketing and other purposes.

Compactive Affiliates and Subsidiaries. Your personal information may be processed by Compactive affiliates and subsidiaries ("Affiliates") (see https://www.Compactive.com/legal_information) for purposes of (i) assisting us to market our Services and games, (ii) analytics, research, and demographic studies, and (iii) development and improvement of games, features, and other products and services by Compactive and Affiliates. Subject to applicable law, we may also share your personal information (e.g., contact information, usage data, and characteristics) with Affiliates so that they may contact you about their products and services.

Advertising and Analytics Services. We work with Affiliates and other companies that provide advertising, campaign measurement, online and mobile analytics, and related services to us (with your consent, where required by applicable laws) and to others. They may use the information that we provide or make available (e.g., online identifiers, browsing history, usage data, and other activity information and characteristics) to help us better reach individuals with relevant ads and to measure and improve our ad campaigns, or to better understand how individuals interact with our Services. In addition, these advertising and analytics companies may combine the information collected from us and our Services with information collected about you by them and from third-party sites, apps, and services, in order to make inferences about you and your interests, to better tailor advertising and content to you across multiple sites, apps, and services, and to collect associated metrics. For information about the rights and choices that you may have regarding the sharing of your personal information with advertising and analytics companies, see Section 12. User Rights and Choices.

Legally Required. We may also disclose your personal information if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes, including when we believe necessary or appropriate to disclose personal information to law enforcement, other governmental or regulatory authorities, or the courts (in any relevant jurisdiction worldwide). In addition, we may disclose the names of sweepstake and contest winners, in accordance with applicable law.

Security and Protection of Rights. We may also disclose your personal information where we believe doing so is necessary to protect the Services and our business operations; to prevent and detect fraud, unauthorized activities and access, and other misuse; to investigate, prevent, or take action regarding actual or suspected illegal activities or fraud, situations involving potential threats to the safety or legal rights of Compactive or any person or third party, or violations of our Terms of Service; to regularly exercise our rights in judicial, administrative, or arbitration proceedings (as applicable in Brazil); to respond to any claims against us; and to protect the rights, property, or personal safety of Compactive, our customers, or the public.

Corporate Transactions. Your personal information may be disclosed as part of any proposed or actual merger, sale, or transfer of Compactive assets, acquisition, bankruptcy, or similar event. We may also share certain personal information as necessary prior to the completion of such a transaction, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence, or as necessary to plan for the transfer.

With Consent. We may also disclose your personal information to any other affiliated or third parties where you have consented or requested that we do so.

5. Cookies, Analytics, and Personalization

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, gaming performance, and use of the Services. We may combine this "activity information" with other personal information we collect about you. Generally, we use this activity information to understand how our Services are used, track bugs and errors, provide and improve our Services, establish matchmaking, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes (see Section 12. User Rights and Choices for information about opting in or out of certain uses of your personal information).

Log Files. We collect certain activity information from log files. Log file information is automatically collected by our servers when you access our Services. We record certain information from these log files, including web requests, IP address, browser type and version, language information, referring and exiting URLs, links clicked, pages viewed, engagement data, and other similar information.

Cookies. These are small files with a unique identifier that are transferred to your browser through our websites. They allow us to remember Users who are logged in, to understand how Users navigate through and use our Services, and to display personalized content and targeted ads (including on third-party sites and applications).

Clear GIFs, Pixel Tags, and Web Beacons. These are tiny graphics with a unique identifier, similar in function to cookies, to understand how Users navigate through and use our Services and to personalize content. We also use these in our emails to let us know when they have been opened or forwarded, so we can gauge the effectiveness of our communications.

Anti-Cheat and Fraud Prevention. Providing a fair gameplay environment is important to us. We prohibit cheating, hacking, account stealing, and any other unauthorized or fraudulent activity when using our Services. In order to detect and prevent fraud and cheating, we may use anti-cheat and fraud prevention tools, applications, and other technologies. When you use our Services, such technologies may create a machine "fingerprint" or "hash" of your machine components, and collect information about you, including information about your browser, device, activities, game identifiers, and operating system. We may also monitor publicly-available information, third-party sites, and/or use anti-cheat technology within our Services.

Analytics Tools. We may use internal and third-party analytics tools to collect and aggregate activity data and other data across multiple channels.

Preferences. You can review or change your preferences for most cookies on our websites (other than those that are necessary to the proper functioning of our websites) by adjusting your cookie settings:

Cookie Settings

6. Targeting and Advertising

We work with third-party ad networks, channel partners, mobile ad networks, analytics and measurement services, and others ("third-party ad companies") to personalize content and display advertising within our Services (including our websites and our mobile and other games and apps), as well as to manage our advertising on third-party sites, mobile apps, and online services. We and these third-party ad companies may use cookies, pixel tags, and other tools (which we may refer to collectively as "targeting cookies") to collect activity information within our Services (as well as on third-party sites and services), as well as IP address, location information, device ID, cookie and advertising IDs, and other identifiers; we and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.

Preferences. We make available multiple ways for you to manage your preferences regarding targeting cookies, advertising, and personalization:

• Our websites: You can review or change your preferences for targeting cookies and tags on our websites by adjusting your cookie settings: Cookie Settings

• Mobile: Some of our mobile games and apps may include third-party advertising and personalization. You can opt out of targeted advertising in our mobile games through the in-app settings for that game and/or by adjusting your device privacy settings (please refer to your device settings for more information). This means that you will no longer get targeted ads in the app; however, you may still receive contextual or general ads.

• Industry ad choice programs: You can also control how participating third-party ad companies use the information that they collect about your visits to our websites and use of our mobile applications, and those of third parties, in order to display more relevant targeted advertising to you; for more information and to opt out of receiving targeted ads from participating third-party ad networks go to:

  • U.S. Users: https://aboutads.info/choices (Digital Advertising Alliance) (You can also download the DAA AppChoices tool in order to help control interest-based advertising on apps on your mobile device.)
  • EU Users: https://youronlinechoices.eu (European Interactive Digital Advertising Alliance)
  • Canada Users: https://youradchoices.ca/choices/ (Digital Advertising Alliance of Canada)

Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or "contextual" ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

Custom Lists and Matching. Subject to applicable law, we may share certain customer list information (such as your email address or other contact information, which in most cases is hashed when it is shared) with third parties so that we can better target ads and content to our Users, and others with similar interests, within their services and other third-party platforms and services. These third parties use the personal information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit to target ads for third parties. You may opt out of this as set forth in Section 12. User Rights and Choices.

7. Third-Party Links and Features

Our Services may contain links to third-party sites that are not owned or controlled by Compactive. We are not responsible for the collection and use of your information by these third-party sites. We recommend that you read the privacy notice of any website you visit before you submit any personal information.

In addition, our Services may include or incorporate social media and other third-party features (e.g., widgets, buttons, and plugins), which are operated by third parties, such as Facebook, Steam, Twitch, Twitter, Instagram, YouTube, and others. These features are hosted by the respective third-party operator even though they appear on our Services, and the third party may collect your IP address, URL, date and time stamp, browser details, and the like, subject to their own privacy policies.

8. User Generated Content

You may choose to disclose information (including personal information) about yourself in the course of contributing user-generated content to Services such as forums, chats, in-game messaging, sweepstakes, and contests. Information that you disclose in any of these forums is unencrypted public information, and may be accessed by members of the public, who are not subject to this Policy. In addition, when you enter certain public areas of our Services, your username and other public profile information may be viewable by others. You should have no expectation of privacy as to any information you post or display in our forums or games, or in your profile, or that you otherwise make available on or through our Services.

9. Security of Your Information

Compactive takes reasonable and appropriate administrative, technical, and physical measures to protect against possible breaches of our Services and the personal information we maintain. However, no website or Internet transmission is completely secure. Thus, Compactive cannot and does not guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, enabling multifactor authentication (where available), as well as logging out of your User account and closing your web browser when finished using the Services.

10. Data Retention

We will retain your personal information as long as necessary for purposes for which the personal information was collected and is used by us, as stated in this Policy. If you wish to cancel your account or request that we no longer use your personal information to provide the Services to you, please contact us as set forth in Section 13. Contact Details. However, if you withdraw consent or otherwise object to our collection, use, and disclosure of your personal information, you may not be able to use the Services. Further, to the extent permitted by applicable law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

11. International Transfers of Data

Compactive is headquartered in the United States, and has operations, entities, and service providers in the United States and throughout the world. As such, Compactive may collect your personal information from the United States, and we may transfer your personal information to, and process your personal information from, the United States and other jurisdictions where we and our Affiliates and service providers have operations. Some of these jurisdictions (including the United States) may not provide equivalent levels of data protection as compared to your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.

Users in the European Economic Area (EEA) and United Kingdom. Compactive will take steps to ensure that appropriate safeguards are in place to protect your personal information that we transfer to the United States or other jurisdictions that do not provide equivalent levels of data protection according to the European Commission, including by putting in place standard contractual clauses as approved by the European Commission (the form for the standard contractual clauses can be found at https://eurlex.europa.eu/eli/dec_impl/2021/914/oj).

Users in Brazil. If your personal information is subject to Brazilian laws, Compactive will ensure that appropriate safeguards are in place to protect your personal information, as required by the LGPD.

12. User Rights and Choices

Compactive gives Users several ways to access, amend, and exercise their choices and rights regarding their personal information.

Marketing Preferences. You may change your email preferences and opt out of marketing communications through the marketing preferences tab in your account profile(s).

• Marketing emails: You may opt out of marketing emails by using the unsubscribe option in each marketing email we send to you. Account holders may also opt out or change their preferences for marketing emails in the marketing preferences tab of their account profile(s). If you opt out of direct marketing communications, we may to the extent permitted by applicable law still send you non-promotional communications, such as those about your account or our ongoing business relationship.
• Custom lists and matching: If you maintain an account with us, you can opt out of being included in custom lists and matching campaigns by us by updating your marketing preferences in your account profile(s).

Cookies and Advertising. As noted in Section 5. Cookies, Analytics, and Personalization and Section 6. Targeting and Advertising, you can manage your preferences for cookies (including advertising cookies) on our websites and in our online games by adjusting your cookie preferences:

Cookie Settings

For our mobile games and apps that include third-party advertising, you may opt out of such targeted advertising through the in-app settings for that game and/or by adjusting your device privacy settings, as explained in Section 6. Targeting and Advertising.

Push Notifications. In some of our mobile Services, we may send push notifications from time-to-time in order to update you about the game, events, or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level.

Remove Content. If you wish to request removal of any User content you have posted, please contact us as set forth in Section 13. Contact Details.

Access, Correction, and Deletion. Registered Users may review and update their profile information and communications preferences directly within their account. If you would like us to delete your personal information, you may contact us to delete your account. Please contact us as set forth in Section 13. Contact Details, to exercise your rights or make a request regarding your personal information.

Submitting a Privacy Request. Privacy requests may be submitted by you (or an authorized agent with authority to act on your behalf) to us as set forth in Section 13. Contact Details. Please keep in mind that certain Services will not be available if you withdraw your consent, or otherwise delete or object to our processing of certain personal information. We will take steps to verify your request by matching the information provided in your request with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via email as set forth in Section 13. Contact Details) and verify their access to the User's registered email address. Authorized agents must provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

We will respond to your request in accordance with applicable law, and we will inform you if we do not intend to comply with your request.

Additional Information for Users in Certain Jurisdictions. Additional Information about the privacy rights under certain privacy laws, including the GDPR and UK data protection law and certain U.S. privacy laws, can be found in Section 15. Additional Information for Users in Certain Jurisdictions. Please review this section for more information.

13. Contact Details

If you have any questions, complaints, or comments regarding our Policy or practices, or would like to exercise your privacy rights, please submit a request via email info@compactive.tech.

Controller. The controller for your personal information is Compactive Oyun Yazılım ve Pazarlama A.Ş, Reşitpaşa Mh. Katar Cad. ITU Ari Teknokent No:4 34467, Sariyer Istanbul, Turkey. Further, each Compactive subsidiary company is a controller for the personal information that they process related to vendors, service providers, and others with whom they have a contractual or business relationship.

14. Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Services. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will provide you with appropriate notice.

15. Additional Information for Users in Certain Jurisdictions

This section includes additional information as required under the privacy laws of certain jurisdictions.

a. EEA (GDPR), UK and Brazil

Subject to the conditions set out in applicable law, Users in the European Union/European Economic Area, United Kingdom, and Brazil (as well as in other jurisdictions where similar rights apply) have the following rights regards our processing of their personal information:

• Right of access: to confirm whether we are processing your personal information and to receive a copy of that personal information (along with certain other details).
• Right to correction (rectification): to request that we correct any personal information we hold about you that is inaccurate or incomplete.
• Right to erasure: to request that we delete your personal information under certain circumstances, such as where we no longer need it or if you withdraw your consent (where applicable). (NOTE: If you request that we delete your personal information, we may do so by deleting your account(s) with us.) Brazilian Users may also request the anonymization, blocking, or erasure of unnecessary or excessive personal information, or personal information processed in violation of the LGPD.
• Right to restrict (block) processing: to request that we restrict the processing of your personal information under certain circumstances, such as where you contest its accuracy or object to our use or stated legal basis.
• Right to data portability: to receive a copy of personal information we have obtained from you in a structured, commonly used, and machine-readable format and to reuse it elsewhere or to ask us to transfer it to a third party of your choice, under certain circumstances.
• Right to object : to object to our processing of your personal information on the basis of our legitimate interests, in which case, we must stop such processing unless we have compelling legitimate grounds that override your interest or where we need to process it for the establishment, exercise, or defense of legal claims. Where we are relying on our legitimate interests (other than marketing), we believe that we have a compelling interest in such processing, but we will individually review each request and related circumstances.
• Right to object to marketing : to request that we stop processing your personal information for marketing purposes, on the basis of our legitimate interests. If you do so, we will stop such processing for our marketing purposes.
• Right not to be subject to automated decision-making: to not be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us.
• Right to withdraw your consent: where you have consented, to withdraw your consent to our processing of your personal information, without affecting the lawfulness of our processing prior to the withdrawal of your consent. Brazilian Users also have the right to be informed about the consequences of denying or withdrawing consent.
• Right to lodge a complaint: to lodge a complaint with a supervisory authority if you believe our processing of your personal information infringes the law.

Please note that some of these rights may be limited, such as where we have an overriding interest or legal obligation to continue to process the data. Please contact us using the information set out in Section 13. Contact Details as well as provided below, if you wish to exercise any of your rights or if you have any inquiries or complaints regarding the processing of your personal information by us.

Do We "Sell" or "Share" Personal Information? We may "sell" (as defined by the CCPA) Identifiers and Usage Data to third-party advertising networks, analytics providers, and social networks. We may "share" (as defined by the CCPA) Identifiers, Customer Records, Commercial Information, Geolocation Data, and Usage Data to third-party advertising networks, analytics providers, and social networks, as well as our Affiliates. We do not "sell" or "share" (as defined by the CCPA) sensitive personal information, nor do we "sell" or "share" any personal information about individuals who we know are under sixteen (16) years old.

Sources of Personal Information. In general, we may collect the categories of personal information identified in the table above from the following categories of sources, in addition to directly from consumers:

• Our Affiliates
• Third-party platforms
• Third-party sites and services
• Ad networks
• Analytics providers
• Social networks
• Internet service providers
• Operating systems and platforms
• Our vendors and service providers

Purposes for Collecting and Disclosing. As described in more detail in Section 3. Purposes of Use and Legal Bases of Processing for Personal Information, in general, we collect and otherwise process the above personal information in order to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:

• Providing our Services and related support
• Protecting the integrity of the Services
• Analyzing and improving the Services and our business
• Personalizing the Services
• Advertising, marketing, and promotional purposes
• Securing and protecting our business
• Defending our legal rights
• Auditing, reporting, corporate governance, and internal operations
• Complying with legal obligations

Retention. We will retain your personal information as long as necessary for purposes for which the personal information was collected and is used by us, as stated in this Policy. If you wish to cancel your account or request that we no longer use your personal information to provide the Services to you, please contact us as set forth in Section 13. Contact Details. However, if you withdraw consent or otherwise object to our collection, use, and disclosure of your personal information, you may not be able to use the Services. Further, to the extent permitted by applicable law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.

Sensitive Personal Information. We collect and use certain sensitive personal information which may vary depending on the circumstances. We may collect the following categories of sensitive personal information, as indicated in the chart above: identifiers; geolocation data; protected classifications; and paper and electronic records.

We may use or disclose these categories of sensitive personal information for the following purposes:

• To perform the services or provide the goods as reasonably expected by you;
• To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of sensitive personal information that is stored or transmitted;
• To resist malicious, deceptive, fraudulent, or illegal actions directed at Compactive and to prosecute those responsible for those actions;
• To ensure the physical safety of Users and other people;
• For short-term, transient uses;
• To perform services on behalf of Compactive, such as maintaining or servicing User accounts, verifying User information, and providing support to Users; and
• With respect to a service or device that is owned, manufactured, manufactured for, or controlled by Compactive, to verify or maintain the quality or safety, improve, upgrade, or enhance the service or device.

We do not sell your sensitive personal information to third parties, and we do not share your sensitive personal information for cross-context behavioral advertising purposes.

When We Share Information

As detailed below, we share your information with:

• vendors that perform support and other services for us

• Compactive group members

• advertising service providers and partners

• other third parties (e.g., for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, and other purposes with your permission)

• other users, such as when you participate in open communities or events, or information published on leaderboards

In the last 12 months, Compactive has sold and/or shared unique identifiers, IP address, as well as Internet/Electronic Activity and Profile Inferences with third-party advertising providers to enable us to provide personalized advertising to you and others like you. We do not sell or share personal information about persons that we know are under the age of 16 without their (or depending on age, their parent's) consent.

---Vendors

We use vendors to perform services on our behalf. These vendors provide business, professional or technical support to us, help us operate our business and Services, or administer activities in connection with our business and the Services.

---Advertising

We use Compactive and third-party advertising to support our Services, such as ad networks, data exchanges, traffic management service providers, social networks, and marketing analytics service providers. These providers use cookies and similar tracking technologies (see Cookies and Similar Technologies above) to collect information about your device and your Service use. This information, along with information that we share with them, enables us or our providers to recognize you or your device and to serve ads to you or your device and measure the effectiveness of those ads. This includes Identifiers / Contact Information, Internet / Electronic Activity, Device and Usage Data, and Profile Inferences.

We (and sometimes our providers) collect or share this information when you use our Services, click on a site or an ad, or launch one of our games or other mobile applications.  This information: (1) allows us to accurately and properly pay for ads placed on our behalf (e.g., an ad that led you to purchase or download one of our games) and get paid when you see an ad on our Services; (2) helps prevent you from repeatedly seeing the same ads; (3) helps select and display targeted ads or other content on your device (such as on a site or social networking service you are visiting or a mobile application you are using) that may be of particular interest to you; (4) helps with measuring and analyzing the effectiveness of our ads, popularity of content, and traffic on our Services; and (5) helps us improve our Services.

You can learn more about managing how we and our providers use your information in the Manage Your Account, Communications, and Data section; and, as applicable for the Service, by using our cookie preference tool, where available, or visiting the Cookie Policy posted on the Service.

---Third Parties

We share your information with third parties as described in this Privacy Policy, including as follows:

• Collaborative Relationships: When we offer services or promotions in collaboration with a third party who will receive your information for its own use, we will inform you of that at the time of collection and you may choose whether to participate in the offering. 

• Legal & Safety: We may share your information to protect the security of our Services, servers, network systems, databases, users and business and in connection with an investigation of fraud, intellectual property infringements, interference with our rights, property or users, or other activity that is illegal or may expose you or us to legal liability, including as required or requested by law enforcement or other government officials.  We also may share your information with third parties when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users, or others who may be harmed or may suffer loss or damage, or when we believe that it is necessary to protect our rights, investigate, or enforce our policies, terms, combat fraud, or comply with a judicial proceeding, court order, or legal process served on Compactive.  We also may share your information when we have reason to believe it is necessary to investigate or enforce our policies, terms, or other legal document or contract related to the Services or rights of a third-party.

• Sale or Transfer of Business or Assets: We may sell or purchase assets during the normal course of our business.  We may disclose information about you and transfer that information to another entity as part of a potential or actual acquisition or merger of Compactive or any of our assets. If we bring or are defending a reorganization, bankruptcy, or similar event, such information may be considered our asset and sold or transferred to third parties.

• As Disclosed to You: We may share your information as disclosed to you at the time of collection.

---Other Users

If you participate in open communities, such as online gaming sessions and social networking services, we automatically post certain information, such as your user name or ID and gameplay statistics, within the game, on social networking services, on our Services, or on specialized game sites.  If you participate in tournaments or other online game events, we must publicly post your information.

We publish gameplay boards and multiplayer match records that contain information based on your use of the Services, such as your user name or ID, when they are essential components of the Services that we offer you and others.  Like other gameplay statistic services, your game activity, leaderboards, and multiplayer match information may appear nested in the Services or third-party webpages.

Some third-party services also let you post information about your game activity to their sites to share with others. If you use these features, those third-party services' privacy policies and terms govern your actions on those sites and the information that those services collect.

We combine information collected through various Services and display it publicly, including on our Services, in our games, or in multiplayer game lobbies. For example, if you link your game platform account with us, we may display your in-game achievements along with your account name.

Public Postings

If you share personal information, post an image or video, or provide other content in public forums such as on a message board, chat room, comment field, or profile page, other people can view, collect, and use that information. If your user name or ID contains your name, your name will be publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may be able to identify you, use the information to send you messages, or copy any of the images, video, or content you have shared. There is no expectation of privacy or confidentiality on any of these public forums. Please do not share your personal information in public forums or in your user name or ID. You are responsible for any information or content you publicly post using our Services. 

Data Rights

Depending on your location, you may have certain rights over your personal information, including the right to:

• Request access to or a copy of your personal information

• Request deletion of your personal information

• Request correction or modification of your personal information

• Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes

• Withdraw consent, if processing is based on consent

• Opt-out of the sale or sharing of your personal information (including targeted advertising)

• Opt-in/out of financial incentives

• Limit the use and disclosure of your sensitive personal information

You can make a data rights request in relation to your personal information via email address below. We will respond to data requests within a month. We may take steps to verify your identity before we can respond to your request. To the extent these rights apply to you, they may be limited in some situations -- for example when we are under a legal requirement or have a compelling interest for processing your personal information, or when the personal information is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a privacy authority. A list of privacy authorities is available here. Alternatively, if you wish to make a data request or appeal a data request decision, please contact Compactive using the details provided in the Contact Us section.

To opt out, please send an email.

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you've authorized them to act on your behalf, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity.

---Email Unsubscribe

You can unsubscribe from marketing emails from Compactive or a specific label or division by using the unsubscribe link provided in the email. 

---Interest-Based Ads

On your mobile device, you may adjust your privacy and advertising settings to control whether you want to receive advertising based on your interests. To opt out from the use of your online activities for interest-based activities by participating providers, please visit the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance at http://www.aboutads.info/. For visitors from the UK, EU, EEA or Switzerland, visit Your Online Choices at http://www.youronlinechoices.eu/. 

Data Retention

We'll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.

We retain your information while your account is active, as needed to provide you Services, or to administer our Services. If you wish to delete your account or request that we no longer use your personal information to provide Services to you, contact us as identified in the Manage Your Account, Communications, and Data section. If your account is inactive, we will maintain your account for the length of time for which we reasonably expect you to reengage with our Services. After such period, we will delete personal information, including your email address and log-in credentials, and you may no longer be able to access your account. We may still retain some of your personal information in our files for a reasonable period of time to resolve disputes, enforce our terms and policies, administer our Services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Services, after which we will take steps to delete or archive your personal information.

Children's Privacy

Generally, we direct our Services to a general audience and we do not knowingly collect personal information from children under 13 years old (or older, if applicable law provides for different protections). We may direct certain Services to an audience of all ages---including children. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent's permission to collect personal information from children. If we become aware that a child has provided personal information without a parent's permission, we will promptly delete this information. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.

Data Security

We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no system can be 100% secure and we cannot guarantee our security measures.

International Transfers

We and our vendors and partners may process, transfer, and store information about you in connection with the Services in the United States and other countries that may not have privacy laws equivalent to the country where you reside. We take steps to apply appropriate safeguards when we transfer that information.

When your information is in another country, it may be accessed by the courts, law enforcement, and national security authorities pursuant to the laws of that country. If you reside in the UK, EU, EEA or Switzerland, we rely on Standard Contractual Clauses and/or other approved legal mechanisms to transfer personal information from the UK, EU, EEA or Switzerland to countries located outside of these locations (as applicable). To request a copy of such Standard Contractual Clauses, if applicable, please make a data request as provided under the Data Rights or Contact Us section. 

Other Compactive Terms, Third-Party Terms, and Links to Other Sites

Use of our services and products may be subject to other terms and disclosures provided by us, platform manufacturers, and other partners, including: (i) the terms that accompanied your purchase; (ii) terms applicable to online Services; (iii) other terms and disclosures made available to you by us or third parties.  We are not responsible for practices on third-party sites that may be linked to the Services.

---In-Game Transactions and Reseller / Store 

The third-party platform you use to access the Services, or the online reseller, governs in-game transactions.  We may process Compactive online store transactions directly or through our official online resellers. These transactions are subject to both Compactive's and the third-party platform or online store's privacy policy and terms (as applicable).  Please review the third-party's terms and privacy policy for more details on their policies.

---Third-Party Services 

If you connect to us through third-party services such as platform, mobile device, gaming, and social networking accounts, that third-party's terms and privacy policy govern your use of that service. We are not responsible for third-party services.

---Third-Party Sites 

Our Services may direct you to third-party sites. If we link to another site, it is not an endorsement, authorization, or representation of our affiliation with that third party. Please review the privacy policy of the other site before you submit any of your personal information to that site.

Contact Us

If you have questions about this Privacy Policy, please send an email to contact our Data Protection Officer. Please identify your location in your message. You may also have the right to complain to a privacy authority. You may also contact us by email at privacy@compactive.tech.

For purposes of privacy laws, the data controller of your personal information is Compactive Oyun Yazilim ve Pazarlama A.S. References in this Privacy Policy to Compactive should be interpreted as references to the applicable Compactive entity identified as the controller of personal information for the particular Services you are using.

Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to review these changes. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.