KVKK Information Notice

1. Data controller

As Adil Onur Karahan Şahıs Şirketi (the “Company”), the confidentiality and security of your personal data are among our top priorities. Our Company processes your personal data in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”) and the secondary legislation. Personal data means any information that renders your identity identified or identifiable.

This notice has been prepared to inform you about your personal data processed when you benefit, as a member or a guest, from the services (the “Platform Services”) offered on the Race Of Words mobile application and website (the “Platform”) owned by our Company.

2. Which personal data do we process?

• Your user account information: your username, membership e-mail address, your telephone number if you enter it during registration, your password (stored in an irreversible form), your profile photo, your guest account identifier, and, if you register through an institution, information on the institution to which you are affiliated.
• Your Platform usage information: your level, experience points, coins, trophies, league and ranking information, your match and level history, your achievements, your friend list and friend requests, your clan memberships, the nicknames and scores you use in live quiz rooms, and your in-game preferences.
• Your purchase information: app store transaction number, product purchased, amount and date. Your card details are not transmitted to the Company; payment is collected by Google Play or the App Store.
• Your transaction security information: your IP address and the country/region information derived from it, device model, operating system and app version, language setting, session key, Platform access logs, your sign-in method (e-mail, Google, Apple or guest) and e-mail verification records.
• Your marketing information: your advertising identifier and advertising interaction information (through Google AdMob).
• Your request and legal transaction information: your applications, requests and complaints, and information contained in correspondence with authorised persons, institutions and organisations.
• Institution membership information (only for users who join through an institution): the institution you belong to, your grade/level, in-institution coins, level and experience points, and raffle participation and winner information.

3. Legal grounds, purposes and methods of collection for processing your personal data

Your personal data is collected by automated means in electronic form through the Platform, through the Google / Apple authentication services and the app stores, through the e-mail channel if you contact us by e-mail, and in physical form if it is submitted by application form, official notification or post, or served by legal authorities. The purposes and legal grounds of processing are set out below.

3.1. Membership, account creation and provision of the Platform Services

Your personal data processed in this category: your user account information, Platform usage information and transaction security information.

• Establishment and performance of the membership agreement,
• Creation, management and closure of member and guest accounts,
• Verification of the e-mail address,
• Saving game progress; provision of matchmaking, duel, league, ranking, friend and clan features,
• Provision of content appropriate to language and region, and sending of app notifications.

Legal grounds: Being necessary for the establishment and performance of the membership agreement between you and us (KVKK Art. 5/2-c).

3.2. Carrying out purchases

Your personal data processed in this category: your user account information and purchase information.

• Verification of in-app purchases and crediting of virtual items to your account,
• Carrying out finance and accounting processes.

Legal grounds: Being necessary for the performance of the agreement; being mandatory for our Company to fulfil its legal obligation (KVKK Art. 5/2-c, ç).

3.3. Improving the Platform experience

Your personal data processed in this category: your Platform usage information, transaction security information and request information.

• Improving game balance, level difficulty and user experience,
• Detecting and fixing errors,
• Evaluating requests, complaints and suggestions.

Legal grounds: Being necessary for the performance of the agreement; the legitimate interest of our Company, provided that it does not harm your fundamental rights and freedoms (KVKK Art. 5/2-c, f).

3.4. Information security and prevention of abuse

Your personal data processed in this category: your user account information, Platform usage information and transaction security information.

• Carrying out information security processes,
• Detecting and preventing cheating, fraud and suspicious transactions,
• Reviewing content and behaviour contrary to the community rules.

Legal grounds: Being mandatory for our Company to fulfil its legal obligation; the legitimate interest of our Company (KVKK Art. 5/2-ç, f).

3.5. Carrying out legal affairs

Your personal data processed in this category: your user account information, purchase information, transaction security information, and request and legal transaction information.

• Carrying out legal and litigation affairs; reviewing and responding to data subject applications,
• Providing information to authorised persons, institutions and organisations,
• Fulfilling obligations arising from the legislation to which we are subject, in particular Laws No. 6563, 6102, 213, 5237, 5651 and 6502.

Legal grounds: Being expressly provided for by law; fulfilment of a legal obligation; the establishment, exercise or protection of a right (KVKK Art. 5/2-a, ç, e).

3.6. Advertising activities

Your personal data processed in this category: your marketing information and transaction security information.

• Displaying advertisements and rewarded advertisements within the app,
• Offering personalised advertisements based on your interests.

Legal grounds: The legitimate interest of our Company in offering the Platform free of charge (KVKK Art. 5/2-f) and the acceptance of personalised advertising you give by downloading and using the Platform. Advertising data is transferred to Google’s servers abroad in accordance with Article 9 of the KVKK. You may turn off personalised advertising at any time in your device settings; non-personalised advertisements are then shown.

3.7. Institution membership

This section also applies if you join the Platform through a school, company or other institution (the “Institution”). Institution-mode features are shown only to members of that Institution.

Personal data processed in this category: your user account information, institution membership information and Platform usage information.

• Running in-institution leagues, rankings and events,
• Allowing Institution officials to view, in the institution management panel, your username, e-mail address, grade, in-institution coins, level and experience points, your numbers of wins/losses/draws and your registration date; to adjust your in-institution coin balance; and to delete your account,
• Handling your participation in raffles organised by the Institution and determining the winners.

Legal grounds: performance of the contract relating to the institution membership service; legitimate interests of the Company and the Institution (KVKK Art. 5(2)(c), (f)).

4. To whom and for what purposes is your personal data transferred?

Our Company shares your personal data in accordance with the “need to know” and “need to use” principles, ensuring data minimisation and taking the necessary technical and organisational measures. Your personal data may be shared, limited to the above purposes and in accordance with Articles 8 and 9 of the KVKK, with the following recipient groups:

By the nature of the game, your username, profile photo, level, league and ranking information and clan membership may be viewed by other players on the Platform.

5. How does the Company protect your personal data?

As data controller, the Company takes the necessary technical and organisational measures to protect the confidentiality and integrity of information:

• Data transmission between the Platform and the servers is encrypted with SSL/TLS.
• Passwords are stored in an irreversible form; card details are not held by the Company.
• Access to personal data is restricted by authorisation, and access logs are kept.
• Regular checks for security vulnerabilities are carried out, and data is backed up regularly.
• Data processing policies are updated at regular intervals.

6. Your rights regarding the protection of your personal data

Pursuant to Article 11 of the KVKK, by applying to our Company you have the right:

• to learn whether your personal data is being processed,
• to request information about the processing if your personal data has been processed,
• to learn the purpose of the processing of your personal data and whether it is used in accordance with that purpose,
• to know the third parties to whom your personal data is transferred within Turkey or abroad,
• to request the rectification of your personal data if it is incomplete or inaccurately processed, and to request that this operation be notified to the third parties to whom your personal data has been transferred,
• to request the erasure or destruction of your personal data where the reasons requiring its processing no longer exist, even though it has been processed in accordance with the Law, and to request that this operation be notified to the third parties to whom your personal data has been transferred,
• to object to a result arising to your detriment by means of the analysis of the processed data exclusively through automated systems,
• to claim compensation for damages if you suffer loss due to the unlawful processing of your personal data.

as set out above.

7. Contact for your rights and requests

You may submit your requests by a petition in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, or by means of the Data Subject Application Form on our Policies page, through the following channels:

We kindly ask you to write “Kişisel Verilerin Korunması Kanunu İlgili Kişi Talebi” (Personal Data Protection Law – Data Subject Request) in the subject line of the application envelope or e-mail.

*For applications made in person, only the front side of the document identifying you must be presented (in such a way that the blood type and religion fields are not visible).

Your requests will be concluded free of charge within 30 (thirty) days at the latest. If the operation requires an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

8. About this information notice

The Company may update this notice in line with changes in the legislation and on the Platform. The current version is published on the Platform.