Turkish Data Protection (KVKK) Notice
Pursuant to Article 10 of the Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform, Lanista Danışmanlık Anonim Şirketi (the “Company”) informs users of its websites, mobile applications, games and related services (the “Services”), its business partners and persons who contact it about the processing of their personal data.
This notice is the Türkiye supplement to our Privacy Policy. It is a translation of the Turkish original, which prevails in case of any inconsistency.
1. Data controller
Lanista Danışmanlık Anonim Şirketi
Address: 15 Temmuz Mah. Bahar Cad. No: 61, Bağcılar, İstanbul, Türkiye
MERSİS No: 0608178021000001 · Trade Registry No: 1068521 (Istanbul Trade Registry Office)
Tax Office / No: Güneşli / 6081780210 · Share capital: TRY 250,000
Email: hey@lanista.vc
2. Categories of personal data processed
| Category | Examples |
|---|---|
| Identity | Name (in support requests), username / display name |
| Contact | Email address |
| Transaction security | IP address, device and install identifiers (e.g. IDFV), logs, crash and error reports |
| Marketing | Advertising identifiers (IDFA / Google Advertising ID — only with your permission), campaign and install-source information, ad interactions |
| Customer transaction | In-game progress and events, in-app purchase transaction information (product, amount, date, transaction ID), support requests |
| Device / technical | Device model, operating system, language, time zone, approximate location derived from IP (country / region) |
No special categories of personal data are processed. Payment card details are processed by Apple or Google and are not transferred to the Company.
3. Purposes of processing
- Providing and operating the Services and saving your game progress;
- Delivering and recording in-app purchases;
- Responding to requests and complaints and providing customer support;
- Analysing and improving the Services and fixing bugs and crashes;
- Showing ads in free products and measuring ad and campaign performance;
- Ensuring information security and preventing fraud, cheating and abuse;
- Fulfilling legal obligations and providing information to competent authorities;
- Establishing, exercising and defending legal rights.
4. Method of collection and legal grounds
Personal data is collected by automated means through software development kits (SDKs) integrated into our apps and games, server logs and app stores, and partly by non-automated means through email and support channels. It is processed on the following legal grounds under Article 5 of KVKK:
- Processing is directly related to the conclusion or performance of a contract (Art. 5(2)(c)) — providing the Services, delivering purchases, support;
- Compliance with a legal obligation of the data controller (Art. 5(2)(ç)) — tax, commercial and other legislation;
- Establishment, exercise or protection of a right (Art. 5(2)(e));
- Legitimate interests of the data controller, provided that your fundamental rights and freedoms are not harmed (Art. 5(2)(f)) — analytics, security, anti-cheat, non-personalised ads;
- Your explicit consent (Art. 5(1)) — personalised ads, cross-app tracking and, where required, marketing attribution. You may withdraw consent at any time via your device or in-app settings.
5. Transfers of personal data
Within Türkiye: personal data may be transferred, limited to the purposes above, to our service providers, business partners, legal and financial advisers and competent public authorities in accordance with Article 8 of KVKK.
Abroad: the servers of our cloud hosting, analytics, crash reporting, ad network, mediation and mobile measurement providers may be located abroad, mainly in the European Union and the United States; the app stores (Apple, Google) are also established abroad. Such transfers are carried out in accordance with Article 9 of KVKK: on the basis of an adequacy decision where one exists; otherwise with appropriate safeguards such as the standard contracts published by the Personal Data Protection Board, notified to the Authority within the prescribed period; and, in incidental cases where these are not possible, on one of the grounds listed in Article 9(6), including your explicit consent.
6. Retention periods
Personal data is retained for as long as required for the purpose of processing and for the periods set out in applicable legislation: gameplay, analytics and advertising data for up to 24 months after your last activity; support correspondence for up to 3 years; transaction and accounting records generally for 10 years under tax and commercial law; website server logs for up to 12 months. After that, data is deleted, destroyed or anonymised.
7. Your rights under Article 11 of KVKK
By applying to the Company, you have the right to:
- learn whether your personal data is processed;
- request information if it has been processed;
- learn the purpose of processing and whether it is used in line with that purpose;
- know the third parties in Türkiye or abroad to whom it is transferred;
- request correction if it is incomplete or inaccurate;
- request its deletion or destruction under the conditions of Article 7 of KVKK;
- request that operations under (e) and (f) be notified to third parties to whom the data was transferred;
- object to a result to your detriment arising from analysis exclusively by automated systems; and
- claim compensation for damages arising from unlawful processing.
8. How to apply
In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, you may submit your request, including information identifying you and the subject of your request:
- in writing with a wet signature, in person or via a notary, to our address above;
- signed with a secure electronic signature or mobile signature, to hey@lanista.vc;
- via registered electronic mail (KEP); or
- from the email address you previously provided to us and that is registered in our systems, to hey@lanista.vc (subject: “KVKK Request”, stating your player ID).
Your request will be concluded free of charge as soon as possible and within thirty (30) days at the latest; if the process requires an additional cost, the fee set by the Personal Data Protection Board may be charged. If your request is rejected, the response is insufficient or no response is given in time, you may file a complaint with the Personal Data Protection Board under Article 14 of KVKK.