Privacy

NOCTURNAL GAMES BİLİŞİM YAZILIM VE PAZARLAMA ANONİM ŞİRKETİ

Last updated: 26 November, 2022

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal data to provide and improve the Service.

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy is maintained by the Free Privacy Policy Generator. Interpretation and Definitions Interpretation The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions For the purposes of this Privacy Policy: You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to . Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority. Account means a unique account created for You to access our Service or parts of our Service. Website refers to , accessible from Service refers to the Website.

Country refers to: Turkey Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Personal Data is any information that relates to an identified or identifiable individual. Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses. Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). Collecting and Using Your Personal Data Types of Data Collected Personal Data While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You.

Personally identifiable information may include, but is not limited to: Usage Data Usage Data Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device. Tracking Technologies and Cookies We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. We use both session and persistent Cookies for the purposes set out below: Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website. Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website. Tracking and Performance Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them. Targeting and Advertising Cookies Type: Persistent Cookies Administered by: Third-Parties Purpose: These Cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest to You. These Cookies use information about your browsing history to group You with other users who have similar interests.

Based on that information, and with Our permission, third party advertisers can place Cookies to enable them to show adverts which We think will be relevant to your interests while You are on third party websites. For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy. Use of Your Personal Data The Company may use Personal Data for the following purposes: To provide and maintain our Service, including to monitor the usage of our Service. To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user. For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service. To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information. To manage Your requests: To attend and manage Your requests to Us. We may share your personal information in the following situations: With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to show advertisements to You to help support and maintain Our Service, to contact You, to advertise on third party websites to You after You visited our Service or for payment processing. For Business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.

Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. With Business partners: We may share Your information with Our business partners to offer You certain products, services or promotions. With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see You name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile. Retention of Your Personal Data The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods. Transfer of Your Personal Data Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data Business Transactions If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy. Law enforcement Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Other legal requirements The Company may disclose Your Personal Data in the good faith belief that such action is necessary to: Comply with a legal obligation Protect and defend the rights or property of the Company Prevent or investigate possible wrongdoing in connection with the Service Protect the personal safety of Users of the Service or the public Protect against legal liability Security of Your Personal Data The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure.

While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Detailed Information on the Processing of Your Personal Data Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose. Analytics We may use third-party Service providers to monitor and analyze the use of our Service.

Unity Analytics Unity Analytics is provided by Unity Technologies. For more information on what type of information Unity Analytics collects, please visit their Privacy Policy page: https://unity3d.com/legal/privacy-policy

Advertising We may use Service providers to show advertisements to You to help support and maintain Our Service.

Unity Ads Unity Ads is provided by Unity Technologies. You can opt-out from Unity Ads service by following the instructions as described by Unity Technologies on their Privacy Policy page: https://unity3d.com/legal/privacy-policy

For more information about Unity Technologies, please visit Unity Technologies Privacy Policy: https://unity3d.com/legal/privacy-policy

Children’s Privacy Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old. In some cases, this means We will be unable to provide certain functionality of the Service to these users. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies and Usage Data.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User, or collected automatically when using this Application. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for this Application to provide its services.

Users are responsible for any Personal Data of third parties obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

It require READ_PHONE_STATE permission.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: Advertising, Analytics and Interaction with external social networks and platforms.

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services:

● Advertising This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.

AdColony (Jirbo, Inc.) AdColony is an advertising service provided by Jirbo, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

AppLovin (AppLovin Corporation) AppLovin is an advertising service provided by AppLovin Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

Opt out – https://www.applovin.com/optout

Chartboost (Chartboost, Inc.) Chartboost is an advertising service provided by Chartboost Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

Fyber (SponsorPay GmbH) Fyber is an advertising service provided by Fyber GmbH.

Personal Data collected: Cookies and Usage Data.

Place of processing: Germany

Unity Ads (Unity Technologies ApS) Unity Ads is an advertising service provided by Unity Technologies ApS.

Personal Data collected: Cookies and Usage Data.

Place of processing: Denmark

Vungle (Vungle, Inc.) Vungle is an advertising service provided by Vungle, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

● Analytics The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

GameAnalytics (GameAnalytics ApS) GameAnalytics is an analytics service provided by GameAnalytics ApS.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

Unity Analytics (Unity Technologies ApS) Unity Analytics is an analytics service provided by Unity Technologies ApS.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: Denmark

● Interaction with external social networks and platforms This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.) The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

Additional information about Data collection and processing Legal action The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Application or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System logs and maintenance For operation and maintenance purposes, this Application and any third party services may collect files that record interaction with this Application (System logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Application and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Information about this privacy policy The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda’s servers.

Definitions and legal references Personal Data (or Data) Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data Information collected automatically from this Application (or third party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject The legal or natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor) The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner) The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application The hardware or software tool by which the Personal Data of the User is collected.

Cookies Small piece of data stored in the User’s device.

Legal information Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to this Application.

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Cookies and Usage Data.

It require READ_PHONE_STATE permission.

Mode and place of processing the Data

Methods of processing

Place

Retention time

The use of the collected Data

The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data Personal Data is collected for the following purposes and using the following services:

AdColony (Jirbo, Inc.) AdColony is an advertising service provided by Jirbo, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

AppLovin (AppLovin Corporation) AppLovin is an advertising service provided by AppLovin Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

Opt out – https://www.applovin.com/optout

Chartboost (Chartboost, Inc.) Chartboost is an advertising service provided by Chartboost Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

Fyber (SponsorPay GmbH) Fyber is an advertising service provided by Fyber GmbH.

Personal Data collected: Cookies and Usage Data.

Place of processing: Germany

Unity Ads (Unity Technologies ApS) Unity Ads is an advertising service provided by Unity Technologies ApS.

Personal Data collected: Cookies and Usage Data.

Place of processing: Denmark

Vungle (Vungle, Inc.) Vungle is an advertising service provided by Vungle, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

● Analytics The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

GameAnalytics (GameAnalytics ApS) GameAnalytics is an analytics service provided by GameAnalytics ApS.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

Unity Analytics (Unity Technologies ApS) Unity Analytics is an analytics service provided by Unity Technologies ApS.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: Denmark

Facebook Like button and social widgets (Facebook, Inc.) The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: US

This Application does not support “Do Not Track” requests. To determine whether any of the third party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Information about this privacy policy The Data Controller is responsible for this privacy policy, prepared starting from the modules provided by Iubenda and hosted on Iubenda’s servers.

User The individual using this Application, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.

Data Subject The legal or natural person to whom the Personal Data refers.

This Application The hardware or software tool by which the Personal Data of the User is collected.

Cookies Small piece of data stored in the User’s device.

Tenjin is an analytics service provided by TENJIN. Below information is taken from Tenjin’s website. For the most recent information please check their website.

Tenjin :

LAST UPDATED: October 28, 2022

Tenjin, Inc. is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. The first section of this document describes our practices in connection with information that we collect from our customers and potential customers through the websites operated by us from which you are accessing this Privacy Policy (the “Websites”), and from users of the Websites (whether or not such users are our customers). The Websites include tenjin.io, tenjin.com, blog.tenjin.io, blog.tenjin.com, docs.tenjin.io, docs.tenjin.com, track.tenjin.io, and track.tenjin.com. The second section describes the information we collect in the course of providing services to our customers (the “Services”). If you are a Tenjin employee or contractor and want to learn how Tenjin uses your personal information, you can find that information in the “Tenjin Notice of Data Privacy for Employees” posted in Confluence.

European Union’s General Data Protection Regulation (the “GDPR”) and the United Kingdom’s Data Protection Act (the “UKDPA”)

Tenjin provides tools and services to mobile app developers so that they can track and analyze certain End User actions in the context of mobile marketing. Tenjin does not collect any data directly (except from the companies and people that sign up for Tenjin or request marketing info, which is described in the Website Privacy Policy below). With regard to Tenjin’s Services, under the EU’s General Data Protection Regulation (the “GDPR”) and the UK’s Data Protection Act (the “UKDPA”), Tenjin is a data processor. As a data processor, Tenjin processes, and may store, information sent by Tenjin customers from their mobile apps. Tenjin’s customers may send information about the End Users of their apps, and the users’ devices, to Tenjin for processing and storage. The mobile app developers must receive your consent in order for Tenjin to process, and perhaps store, your data. Tenjin recognizes your right of access under Section 15 of GDPR and Section 45 of UKDPA. If you are a user of a Tenjin customer’s mobile app, and you wish to exercise your right of access, you must contact the owner or operator of the mobile app (the data collector).

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (the “CCPA”) became law on January 1st, 2020 but enforcement begins six (6) months from the date the California Attorney General issues final regulations (which shall be no later than July 1st, 2020). With regard to Tenjin’s Services, under CCPA, Tenjin is a service provider. As a service provider, Tenjin processes, and may store, information sent by Tenjin customers from their mobile apps. Tenjin’s customers may send information about the End Users of their apps, and the users’ devices, to Tenjin for processing and storage. Tenjin customers must comply with the opt-out requirements under CCPA (Cal. Civ. Code § 1798.120(a)) and take into account any exceptions or other requirements mandated by law. As a service provider, Tenjin relies on CCPA’s business purpose exemption under Cal. Civ. Code § 1798.140(t)(2)(C) and as a service provider, Tenjin does not have any direct obligations to the End Users to obtain consent, provide opt-outs, or delete data. If you are a user of a Tenjin customer’s mobile app and you wish to opt-out or exercise another right under CCPA, you must contact the app publisher (the business).

The above applies to both Section 1 and Section 2 below.

SECTION 1: WEBSITE PRIVACY POLICY

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable person. We collect Personal Information, such as name, organization name and email address, from our customers and potential customers when they provide it to us through the Services (such as by creating an Account), through the Website, or via email sent to a Tenjin email address.

How We May Use Personal Information

We may use Personal Information:

To respond to your inquiries and fulfill your requests.
To send administrative information to you, such as information regarding our services and changes to our terms, conditions and policies.
To provide you with customer service.
To send you marketing communications that we believe may be of interest to you.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

To our affiliated and third-party service providers and consultants who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services.
To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
As we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as browser and device information; information collected through cookies, pixel tags and other technologies; and aggregated information.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

Using cookies: Cookies are pieces of information stored directly on the device that you are using to access the Websites. Cookies allow us to collect information such as browser type, time spent on the Websites, pages visited and other anonymous traffic data. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Websites. Some third-party services providers that we engage (including third-party advertisers) may also place their own Cookies on your hard drive. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.
Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Websites to, among other things, track the actions of users (including email recipients), measure the success of our marketing campaigns and compile statistics about use of the Websites.
Using a third-party analytics provider: We use Google Analytics and Hubspot for our Website analytics. These providers use cookies and similar technologies to analyze how users use the Websites, compile statistical reports on Website activity, and provide other services related to the Websites. They may also collect information about Website visitors’ use of other websites. For more information about Google Analytics, including how to opt out, please go to: https://tools.google.com/dlpage/gaoptout. For more information on Hubspot’s privacy practices, please go to: https://legal.hubspot.com/privacy-policy.
IP Address: Your IP Address is a number that is automatically assigned to your computer by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Websites, along with the time of the visit and the page(s) visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Websites.
By aggregating information: Aggregated Personal Information does not personally identify you (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Websites link. The inclusion of a link on the Websites does not imply endorsement of the linked site or service by us or by our affiliates.

SECURITY

We take reasonable administrative, physical and electronic measures designed to protect Personal Information and Other Information from unauthorized access, use or disclosure. Data collected from your device is encrypted using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.

CROSS-BORDER TRANSFER

The Websites are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Websites you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

MODIFYING INFORMATION

Customers can access and modify their billing address by emailing privacy@tenjin.io. If customers want to delete their own Customer Data or their Account from the Services, customers can contact us at privacy@tenjin.io with a request. We will delete the Customer Data but some information may remain in archived/backup copies for our records or as otherwise required by law. If a customer ceases subscribing to the Services, please email privacy@tenjin.io and we’ll automatically delete the customer’s Account and take steps to delete that customer’s Customer Data from the Services.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Websites. Your use of the Websites following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at privacy@tenjin.io.

SECTION 2: SERVICES PRIVACY POLICY

CUSTOMER DATA

Our customers are advertisers. On behalf of a customer, we receive data about its advertising campaign on a particular advertising network directly from that network. “Customer Data” means advertising campaign data or information made available to Tenjin or the Tenjin Platform by or on behalf of a customer or any Authorized User, or via a customer’s use of the Tenjin Platform. We format and otherwise process the Customer Data, to help our customer understand and analyze the effectiveness of and costs associated with its advertising campaigns across various advertising networks.

HOW WE COLLECT CUSTOMER DATA

We collect Customer Data through Tenjin’s software development kit (“Tenjin SDK”) that customers have a license to use. We may also collect Customer Data from our customers’ third party mobile marketing partners, to the extent that the customer has authorized us to do so.

HOW WE USE CUSTOMER DATA

We use Customer Data to provide the Services to the relevant customer. We may also use it to improve the Services and develop new products and services.

We do not share Customer Data with any customer other than the customer to which it relates, unless we have received the prior express written consent of the customer to do otherwise. Without consent, we may disclose Customer Data:

To our affiliated and third-party service providers; and To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

In addition, we may use or disclose Customer Data as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Unless prohibited by applicable law or advertising network terms, we may aggregate Customer Data such that it is not reasonably identifiable with or to the customer to which it relates, or the customer’s end users (“Aggregate Data”). We may share Aggregate Data with third parties for industry research and analysis, demographic profiling and other similar purposes.

HOW WE COLLECT AND PROCESS END USER DATA FOR CUSTOMERS

Customers may send information about individuals using their app (“End Users”) to Tenjin for processing and storage. This information may include Vendor ID (if available), IP address, Apple Search attribution (if enabled), Bundle ID, SDK Version, App Version, OS Version, Device Type, Device Model, Device Locale, Device Country, OS Platform, Limit Ad Tracking setting, and Advertising ID. Advertising IDs are user-specific, unique character strings that can be reset by the user and are used to track an End User’s device for advertising purposes. Examples include Google Ad ID and IDFA.

Tenjin customers must abide by all applicable laws and obtain all applicable consents before sending End User data to Tenjin. If you feel that your data has been collected by a Tenjin customer without your consent, please contact the Tenjin customer directly. If you would like to access, modify or delete your data collected by a Tenjin customer, please contact the Tenjin customer directly.

Tenjin also recognizes the Right to Erasure under Article 17 of GDPR. For erasure requests, since Tenjin is a data processor, please contact the Tenjin customer directly with your deletion request.

HOW WE PROCESS AND SECURE DATA

Tenjin is a SaaS company whose solutions are built on the AWS platform. Data is processed by Tenjin in secure locations operated by Amazon (AWS) in the United States.

Tenjin uses appropriate and reasonable measures to protect data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, while taking into account any inherent risks and the nature of the data. Additional details on AWS security certifications and procedures can be found here: https://d1.awsstatic.com/whitepapers/Security/AWS_Security_Whitepaper.pdf.

QUESTIONS

Please contact us at privacy@tenjin.io if you have any questions about our Privacy Policy or Tenjin’s compliance with GDPR or CCPA. Please email privacy@tenjin.io if you would like to contact Tenjin’s Data Protection Officer (DPO), or EU representative under GDPR Article 27.

For further questions please check TENJIN website: https://tenjin.com/privacy & https://tenjin.com/disclosure

This privacy policy relates solely to this Application.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

You can contact us by email: ceyhun@nocturnal.games