Last Update: April 26, 2023
Netra Games (“Tolga Guzelhan”, “we”, “us” or “our”) is the developer of interactive entertainment. This Privacy Policy discloses the data practices for the products, services and websites provided by Netra Games referenced herein (“Services”). Please read this Privacy Policy carefully and keep in mind that our practices and the data we collect may vary depending on how you use the Services. The Services are also subject to any other terms and policies contained within our Services. This Privacy Policy supplements the privacy statements provided with your software product and from your platform manufacturer.
This Privacy Policy does not apply to personal information collected from job applicants. Please see our job applicant privacy policy available here.
Notice When Collecting Personal Information: Please refer to the Categories of Information Collected and How We Use Personal Information and Our Legal Basis sections for an overview of what information we collect and why, and Data for information on how to exercise your privacy rights, including opting out of having your personal information sold or shared. See the Rights section.
The type of information we collect depends on how you use the Services. Generally we collect the following information:
Identifiers / Contact Information: Name, username, gamertag, postal and email address, phone number, unique IDs, mobile device ID, platform ID, game service ID, advertising ID (IDFA, Android ID) and IP address
Protected Characteristics: Age and gender
Business Information: Purchase and usage history and preferences, including game information
Billing Information: Payment information (credit/debit card information) and shipping address
Internet Activity / Electronic Activity: web / application browsing and gaming information in relation to the Services and information about your online interaction(s) with the Services or our advertisements and details of the games and platforms you use and other information in relation to installed applications
Device and Usage Data: Device type, software and hardware details, language settings, browser type and version, operating system, and information about how users use and interact with the Services (e.g. content viewed, pages visited, clicks, scrolls)
Profile Inferences: Inferences drawn from your information and web activity to help create a personalized profile so that we can identify goods and services that may be of interest to you
Audio/Visual Information: Account photos, images and avatars, audio information via chat features and functionality, and gameplay recordings and video footage (such as when you participate in playtesting)
Sensitive Information: Precise location information (if you allow the Services to collect your location), account credentials (username and password), and the content of communications through chat features and functions.
We use the information we collect within Netra Games games and applications in accordance with various legal bases as follows:
We also use your information as permitted by law.
We use the information we collect for our business purposes, including to:
We use the information we collect for business purposes, including to:
– Legal Grounds for Processing Personal Data
If you are based in a location that requires us to establish legal grounds, we process your information on the following grounds:
How we obtain information depends on how you use the Services. For example, we collect the following information:
-Information You Provide
You provide information to us when you use the Services, for example when you:
Depending on the service or your activity, your name, email address, phone number, photo, postal address/zip code, payment or purchase information, age, gender, password, platform ID, software products played, survey data, geographic location and the information you play on. We collect information such as systems or platforms. We combine this information across the devices you use.
-Game Play Information
When you use the Services, we automatically receive information about your gaming. Gaming information includes your platform ID or gaming service ID, gaming achievements, game scores and performance, IP address, MAC address or other device IDs, other platform/device information, and other information and statistics regarding your use of the Services. We collect game play information even if you do not register for the Services. We may combine game play information with other information we have about you. We may also use internal and third-party anti-cheat technologies to detect and prevent fraud within our Services.
-Platform, Gaming and Social Networking Information
We collect information when you access our services through a third-party platform account, such as a gaming platform account, gaming network service account, or social networking service account. Third-party platforms provide us with information about you when you access our services in this way. For example, based on your use of or activity on a third-party platform, we receive your username, friends list or account information that is necessary to provide the Services or a purchased in-game item. The third party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, statements or actions of any third-party platforms.
-Cookies and Similar Technologies
To improve and maintain the functionality of our services; We may use cookies, pixel tags, web beacons, Flash cookies, Internet log files, software development kits and similar tracking technologies to improve security and fraud prevention and to provide you with targeted advertising. Our system may not respond to Do Not Track requests or headers from some or all browsers. The Manage Your Account, Communications and Data section provides additional information about our use of cookies and similar technologies and your ability to manage cookies. You may also use the cookie preference tool when available or visit the Cookie Policy posted on the Service for more information.
-Information from Third Parties
We receive information from third parties to update the information we have collected about you. We may receive information, including demographic information and information about your interests, from public databases, platform manufacturers, analytics providers, game developers and other business partners and the Netra Games involved in providing the Services to you. We may collect publicly available information, including from social media, to protect our users, employees, facilities and Services and to assist with investigations. We also receive information from others who use our Services. This may include information about you if you are mentioned in comments on the Services or if someone sends us a direct message.
As detailed below, we share your information with:
Netra Games has sold and/or shared unique identifiers, IP address, as well as Internet Activity/Electronic Activity and Profile Inferences with third party advertising providers in the last 12 months so that we can provide personalized advertisements to you and others like you. We do not sell or share personal information about people we know are under the age of 16 without their (or their parents’, depending on age) consent.
–Vendors
We use vendors to perform services on our behalf. These vendors provide us with business, professional or technical support, assist us in operating our business and Services, or manage activities in connection with our business and Services.
-Advertising
We use Netra Games advertising and third-party advertising such as advertising networks, data exchanges, traffic management service providers, social networks and marketing analysis service providers to support our services. These providers use cookies and similar tracking technologies (see Cookies and Similar Technologies above) to collect information about your device and use of the Service. This information, together with the information we share with them, allows us or our providers to recognize you or your device and deliver advertisements to you or your device and measure the effectiveness of those advertisements. This includes Identifiers / Contact Information, Internet Activity / Electronic Activity, Device and Usage Data and Profiling Inferences.
We (and sometimes our providers) collect or share this information when you use our services, click on a site or ad, or launch one of our games or other mobile applications. This information: (1) allows us to accurately and appropriately pay for advertisements placed on our behalf (for example, an advertisement that causes you to purchase or download one of our games) and to receive payment when you see an advertisement on our Services; (2) helps prevent you from seeing the same ads repeatedly; (3) helps select and display targeted ads or other content that may be of particular interest to you on your device (for example, on a site or social networking service you visit or a mobile application you use); (4) helps measure and analyze the effectiveness of our advertising, the 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 vendors use your information in the Manage Your Account, Communications and Data section, as well as by using our cookie preference tool when available or by visiting the Cookie Policy posted on the Service, as applicable to 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 that will receive your information for its own use, we will notify you at the time of collection and you will be able to choose whether or not to participate in the offering
Legal and Security: We may disclose your information to protect the security of our Services, servers, network systems, databases, users, and business, including as required or requested by law enforcement or other public officials, and to protect against fraud, intellectual property violations, or damage to our rights, property, or users. We may share it in connection with an investigation into interference or other activity that is unlawful or could subject you or us to legal liability. We also may disclose information when we have reason to believe that disclosing information is necessary to address potential or actual injury or interference with our rights, property, operations, users, or anyone else who may be harmed or subjected to loss or damage, or to protect our rights, conduct investigations, enforce our policies, terms and conditions. We may share your information with third parties when we believe it is necessary to combat fraud or comply with a judicial proceeding, court order or legal process served on Netra Games. We may also share your information when we have reason to believe it is necessary to conduct an investigation or enforce our policies, terms, or other legal documents or agreements that relate to the Services or the rights of a third party.
Sale or Transfer of Business or Assets: We may sell or purchase assets in the normal course of our business. We may disclose information about you and transfer that information to another organization as part of a potential or actual acquisition or merger of Netra Games or any of our assets. In the event that we initiate or defend a reorganization, bankruptcy, or similar event, such information may be considered our property and may be sold or transferred to third parties.
As Explained to You: We may share your information as described 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 publish certain information, such as your username or ID and gaming statistics, within the game, on social networking services, on our Services or on customized gaming sites. If you participate in tournaments or other online gaming events, we are required to publish your information publicly.
We publish game boards and multiplayer match recordings when they are essential components of the Services we provide to you and others, which contain information such as your username or ID based on your use of the Services. Like other gaming statistics services, your gaming activity, leaderboards, and multiplayer match information may appear embedded within the Services or on third-party web pages.
Some third-party services also allow you to post information about your gaming activity to their sites to share with others. If you use these features, the privacy policies and terms of those third-party services govern your actions on those sites and the information those services collect.
We aggregate information collected through various Services and display it publicly, including by displaying it on our Services, in our games, or in multiplayer game lobbies. For example, if you link your gaming platform account to us, we may display your in-game achievements along with your account name.
If you share personal information, post an image or video, or provide other content in a public forum such as a message board, chat room, comment area, or profile page, others may view, collect, and use that information. If your username or ID includes your name, your name will be publicly available on leaderboards and elsewhere as described in this Privacy Policy. Users of such public forums may identify you and use this information to send you messages or copy images, videos or content you share. There is no expectation of privacy or confidentiality in any of these public forums. Please do not share personal information in public forums or your username or ID. You are responsible for any information or content that you post publicly using our services.
Depending on your location, you may have certain rights over your personal information, including the following rights:
You can make a data rights request regarding your personal information here. We will respond to data requests within one month. In order to respond to your request, we may implement measures to verify your identity. If these rights apply to you, they may be limited in some cases; For example, where we are under a legal obligation or have a compelling interest to process your personal information or where the personal information is protected by trade secret. If you have unresolved concerns, you may also have the right to lodge a complaint with a privacy authority, where applicable. A list of privacy authorities is available here. Instead, if you wish to make a data request or object to a data request decision, please contact Netra Games using the information provided in the Contact Us section.
To opt out, please click Do Not Sell or Share My Personal Information in our site footer (and is available there) and follow the instructions on that page. To more broadly opt out of online personalized advertising, please see the opt-out options set out in the Manage Your Account, Communications and Data section. We will not discriminate against you for exercising any of these rights.
You may authorize someone to make a privacy right request on your behalf (an authorized representative). Authorized representatives will need to prove that you have given them permission to act on your behalf, or they must prove that they have power of attorney under applicable probate law. We reserve 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.
We provide a variety of options for you to manage your Service account, the communications you receive from us, and how we use your information. These include, through the settings in your Service account; email unsubscribe and delete tools; opting out of interest-based advertising.
You can find more information on how to manage your brand-specific account and communications here.
-Service Accounts
You can manage our use of your personal information and the communications you receive from us through the account, communications and privacy settings in your Services account.
-Unsubscribing from Email
You can unsubscribe from marketing emails from Netra Games or a specific brand or division by using the unsubscribe link provided in the email.
-Interest Based Ads
You can adjust your privacy and advertising settings on your mobile device to control whether you want to receive advertising based on your interests. You can opt out of having your online activities used for interest-based activities by participating providers.
We will retain your information for the period necessary to provide you with the Services, comply with our legal obligations and/or exercise, defend or establish our rights.
While your account is active, we retain your information as necessary to provide you with the Services or administer our Services. If you would like to delete your account or request that we no longer use your personal information to provide you with Services, contact us as provided in the Manage Your Account, Communications, and Data section. If your account is inactive, we will retain your account for as long as we reasonably expect you to reconnect to our Services. After this time, we will delete personal information, including your email address and login information, 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 restrictions on the security, integrity and operation of our Services, and thereafter delete or archive your personal information. We will take precautions.
Generally, we direct our Services to a general audience and do not knowingly collect personal information from children under 13 (or older children if applicable law provides different protections). We may direct some Services to audiences of all ages, including children. For these Services, we may restrict the collection of personal information from anyone on the Services, restrict the collection of personal information from children on the Services as well as impose an age restriction that permits children to use the Services, or obtain a parent’s consent to collect personal information from children. If we discover that a child has provided personal information without parental consent, we will delete that information immediately. We encourage parents to teach their children to never give out their real name, address, or phone number without permission when using the Internet.
We comply with generally accepted industry standards and take appropriate safeguards to help protect the security, integrity and confidentiality of the information we collect about you. These security measures are designed to protect the information under our control against accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure or access. However, no system can be 100% secure and we cannot guarantee our security measures.
We and our suppliers and business partners may process, transfer to, 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 in which you reside. We take precautions to implement appropriate safeguards when transferring this information.
When your information is in another country, courts, law enforcement and national security officials may access it in accordance with that country’s laws. If you are located 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 outside those locations (as applicable). To request a copy of those Standard Contractual Clauses, if applicable, please make a data request as set out in the Data Rights or Contact Us section.
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 accompanying your purchase; (ii) terms applicable to the online Services; (ii) any other terms and disclosures provided to you by us or third parties. We are not responsible for the practices of third-party sites that may link to the Services.
– In-Game Business Transactions and Reseller/Shop
The third-party platform or online reseller you use to access the Services regulates in-game commercial transactions. We may process Netra Games online store business transactions directly or through our official online resellers. These business transactions are subject to the privacy policy and terms of both Netra Games and the third party platform or online store (as applicable). For more details about the third party’s policies, please review its terms and privacy policy.
– 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, this is not an endorsement, authorization or representation of our relationship with that third party. Please review the privacy policy of that other site before providing any personal information to that site.
If you have any questions about this Privacy Policy, please use https://www.netragames.com to contact our Data Protection Officer. You can also contact us or our Data Protection Officer by post at the addresses below. Please include your location in your message. You may also have the right to lodge a complaint with a privacy authority. You can also contact us by email at info@netragames.com
Yeni Mahalle 313. Sokak. No:20 Altınordu/ORDU
For the purposes of privacy laws, Netra Games is the data controller of your personal information. Depending on the services, our brands and divisions, both together with Netra Games Interactive and on their own, may be considered data controllers. Data controller and representative information and contact information are stated here. References to Netra Games in this Privacy Policy should be interpreted as references to the applicable Netra Games entity designated as the controller of personal information for the particular Services you use.
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 notify you and provide you with additional options regarding such change, as appropriate. As permitted by applicable law, your continued use of the Services constitutes your acceptance of these changes.
