Gizlilik Politikası / Privacy Policy 

AÇIK RIZA METNİ

1. KaZZu Sen De Kazan Oyun Yazılımı (“KaZZu Sen De Kazan Oyun”) tarafından, 6698 sayılı Kişisel Verilerin Korunması Kanunu (“KVKK”) kapsamında tarafıma sunulan Aydınlatma Metnini okudum ve anladım.

2. Kimlik (isim, soy isim ve doğum tarihi, medeni hali dahil olmak üzere), iletişim, konum, pazarlama, müşteri işlemi, mesleki deneyim bilgisi, işlem güvenliği bilgisi, sosyal medya hesap bilgileri, müşteri hobileri bilgilerimin: (i) firma ve ürünlere bağlılık süreçlerinin ve müşteri memnuniyetine yönelik aktivitelerin yürütülmesi ve bu kapsamda müşterilere sadakat programı çerçevesinde çeşitli avantajlar sağlanması ve bunlara ilişkin bilgilendirmede bulunulması amacıyla, (ii) ürün pazarlama süreçlerinin yürütülmesi kapsamında müşteri alışveriş alışkanlıkları ve eğilimleri analiz edilerek özelleştirilmiş pazarlama faaliyetlerinin planlanması ve bunlara ek müşteri kartı oluşturulması, satın alınan ürünler üzerinden müşteri segmentasyonu ve diğer müşteri ilişkileri yönetimi (CRM) analizlerinin yapılması ve icrasının yönetimi ve şirket içi raporlanması amacıyla, (iii) reklam/kampanya/promosyon süreçleri ve iletişim faaliyetlerinin yürütülmesi (promosyon ürün gönderilmesi, yarışmaların kazananlarına ürün gönderilmesi dahil) ve bu kapsamda elektronik ticari iletilerin (telefon, SMS, MMS, e-posta (maktu) veya diğer şekillerde) gönderiminin sağlanması amacıyla, kişisel verilerimin Oyun tarafından işlenmesini kabul ederim.

3. Yukarıda belirtilen amaçlarla uygulamanın kişisel verilerimi (özel nitelikli olan ve olmayan), açık rızama binaen yurt içinde veya yurt dışında; işbirliği yapılan ve/veya hizmet alınan şirketler ile satış, pazarlama, müşteri ilişkileri, hukuk, muhasebe ve benzeri alanlarda destek alınan danışmanlık firmaları ile Oyun’un faaliyetleri ile ilgili satış, pazarlama ve yazılım hususlarında destek veren üçüncü kişiler ile (SMS ve e-posta gönderimi, CRM (Müşteri İlişkileri Yönetimi), reklam ve halkla ilişkiler ve bulut bilişim, yedekleme, yazılım desteği veren firmalar ve benzeri) paylaşabileceğini ve/veya bu kişilere erişime açabileceğini kabul ederim.

KVKK (Personal Data Protection Law) Notice

1. GENERAL EXPLANATION REGARDING THE PROCESSING AND SECURITY OF YOUR PERSONAL DATA

• The Personal Data Protection Law No. 6698 was published in the Official Gazette dated 07.04.2016 and numbered 29677, entering into force. Prepared by taking into account international documents, comparative law practices, and the needs of our country, the Law aims to process and protect personal data in accordance with contemporary standards. In this context, the purpose of the Law is to regulate the conditions for processing personal data, to protect the fundamental rights and freedoms of individuals in the processing of personal data, and to set forth the obligations, procedures, and principles to be complied with by natural and legal persons processing personal data. 

• KaZZu Sen De Kazan is obliged to comply with the Personal Data Protection Law No. 6698, and all personal data processed within its operational processes fall within the scope of this law. 

• KaZZu Sen De Kazan acts in the capacity of data controller and takes the necessary measures regarding the protection of personal data. 

• First of all, we would like to state that in order to provide you with a better service, in all other cases where we need to inform you and obtain your explicit consent, we strictly obtain your explicit consent via the explicit consent information and approval text shared with you prior to processing your personal data. Before executing your payment, we kindly ask you to perform email verification "to ensure transaction security and in accordance with the principle decision made by the Personal Data Protection Board". The moment you complete the email verification via the link we sent you, your account will become active along with the information you shared; therefore, we inform you beforehand with this disclosure text and begin processing your personal data. 

• As will be seen in the "Data Category and Processed Personal Data" section of this disclosure text, we do not process your credit or debit card information used for payments. This information is processed and stored by institutions that ensure your payment is successfully executed and provide a secure payment system compatible with our website/application. No one, including us, can access the passwords you create to log into your account. Passwords you create are stored by being re-encrypted using specific algorithms. Due to the importance we attach to the security of your personal data and our legal responsibilities, we take cybersecurity measures by protecting our website/application with state-of-the-art security certificates and firewalls. 

• We request you to create an application account in order to log in to all digital platforms belonging to KaZZu Sen De Kazan; however, we do not request or process every personal data specified in Article 2 of this disclosure text during your account creation process. Aside from all these explanations, we would like to inform you pursuant to Article 10 of Law No. 6698 regarding which personal data of yours are processed, the purposes for which your processed personal data are processed, with whom they may be shared, the collection method and legal reason for your data, and your right to apply to the data controller ("application name or company name"). 

2. DATA CATEGORY AND PROCESSED PERSONAL DATA

• IDENTITY INFORMATION: Name and Surname, Turkish ID Number, Tax Identification Number, Year of Birth, Occupation Information. 

Special Explanations Regarding Identity Information: You are not obliged to share your Turkish ID Number with us. This information is generally arranged as an optional choice in our forms. When you share your Turkish ID Number with us, we use it for identity verification when you win an award and for security verification in the name of transaction security. However, in cases where we do not have an obligation to obtain explicit consent due to reasons set forth in the law, you may need to share your Turkish ID Number with us. 

Tax Identification Number is personal data processed only if corporate application account holders are taxpayers. It is not requested from our individual users, even if they have tax identification numbers. 

You are not obliged to share your birth year information with us. We process this shared information for statistical purposes and to provide a better user experience. 

You are not obliged to share your occupation information with us. We process this shared information for statistical purposes and to provide a better user experience. 

Competition, Survey, Electronic Message, Sweepstakes, Application, and Contact Form Data: We collect personal data that you provide when you fill out any form, give communication consent, respond to a research or survey, or participate in a competition (name, surname, email address, phone number, and for information-request processes, Turkish ID number and phone number). 

• CONTACT INFORMATION: Email Address, Phone Number, Billing Address. 

• USER TRANSACTION INFORMATION: Product and Service Purchase History Information, Billing Information, Request and Complaint Information. 

• FINANCIAL INFORMATION: Bank Account Number and IBAN Number. 

Special Explanations Regarding Financial Information: If you are a user who purchases corporate membership as a real person taxpayer (sole proprietor, self-employed professional), you carry out the service fee via wire transfer/EFT method. This situation requires us to process your bank account information. 

To make purchases in the application and play some of our games, you must have an account. To create an account, you will be required to provide us with basic registration information such as your name, a public display name, password, country of residence, and email address. If you wish to make a purchase, we may ask you to provide payment-related information (such as your credit card number and expiration date) to complete the transaction. In addition, many of our services require your date of birth to determine which features we can offer you and what settings apply to your account based on your age and location. 

We also collect information that you voluntarily provide to sign up for email alerts, use social features like forums or chats, sign up for early access to our games, use our developer tools (including to create and publish games and other content), enable two-factor authentication, register for or participate in our events, fill out surveys, or contact us through Player Support or customer service. 

If you choose to pay by invoice for a service or feature, we may receive data from our payment partners to enable us to send you an invoice, process your payment, and deliver what you purchased. 

• TRANSACTION SECURITY INFORMATION: IP Address, Log Records, User's Usage Record Breakdown Information on Websites/Application, Browsing History. 

Special Explanations Regarding Transaction Security Information: We process the IP information of anyone logging into the digital platform due to our legitimate interest in preventing unauthorized access and within the scope of cybersecurity measures. We may process browsing information on the website/application to provide a better user experience, ensure the use of purchased services, and detect unlawful acts committed on the platform. 

We design application services to embrace users of all ages everywhere in the world. This means we collect age information from users, and some of our services will provide a different experience based on what we know about a user's age and where they live. The following information is for parents and guardians to understand our privacy practices regarding children (under 13 or the digital age of consent in the user's region, whichever is higher). 

TO ENTER INTO THE AGREEMENT CREATED BY THESE TERMS, YOU MUST BE AN ADULT OF LEGAL AGE IN YOUR COUNTRY OF RESIDENCE. YOU ARE LEGALLY AND FINANCIALLY RESPONSIBLE FOR ALL ACTIONS USING OR ACCESSING OUR SOFTWARE, INCLUDING THE ACTIONS OF ANYONE YOU ALLOW TO ACCESS YOUR ACCOUNT. YOU CONFIRM THAT YOU ARE OF LEGAL AGE, THAT YOU UNDERSTAND AND ACCEPT THESE TERMS (INCLUDING DISPUTE RESOLUTION TERMS). IF YOU ARE NOT OF LEGAL AGE, YOUR PARENT OR LEGAL GUARDIAN MUST ACCEPT THESE TERMS. 

If you choose, or are provided with, a user identification code, password, or any other piece of information as part of our security procedures, you must treat such information as confidential (other than your user name) and you must not disclose it to any third party. You must notify us immediately of any unauthorized use of your user name or password or any other breach of security. You should use extra caution when accessing your account from a public or shared computer/phone/tablet so that others are not able to view or record your password or other personal data. You may only access the services through your own account. Users do not own their accounts and are prohibited from gifting or otherwise transferring accounts or access keys. 

• MARKETING INFORMATION AND COOKIES: Cookies, Survey Information. 

Special Explanations Regarding Marketing Information and Cookies: We collect and process marketing information containing personal data through cookies and surveys. Except for mandatory (essential) cookies, the consent for the use of all other cookies containing or not containing personal data (Functionality, Analytics, Marketing Cookies) is left entirely to your preference. You can find more detailed information about cookies in the relevant section. 

• LEGAL TRANSACTION INFORMATION: Contract Number, Notice and Warning Letter Information, Lawsuit File Information, Information Shared with Judicial, Administrative, Regulatory, and Supervisory Authorities. 

• VISUAL AND AUDIO RECORD INFORMATION: Call Center Voice Recordings. 

3. GENERAL PRINCIPLES IN PROCESSING PERSONAL DATA

• KaZZu Sen De Kazan acts in accordance with the general principles set forth by Law No. 6698 in the processing of personal data. Our general principles in processing personal data are as follows: 

1. Compliance with the law and rules of integrity, 

2. Being accurate and, when necessary, up-to-date, 

3. Being processed for specific, explicit, and legitimate purposes, 

4. Being relevant, limited, and proportionate to the purposes for which they are processed, 

5. Being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed, 

6. Ensuring access security to the website/application, 

7. Performing regulation, storage, and archiving operations regarding all records and documents, 

8. Managing request and complaint processes, 

9. Necessity of data transfer to third parties in order to fulfill obligations arising from legislation and contracts, 

10. Providing information to authorized persons, institutions, and organizations, 

11. Mandatory data sharing with business partners for the execution of business activities, 

12. Execution of management activities, 

13. Execution of advertising, campaign, marketing, and customized product/service presentation activities in the presence of your explicit consent, 

14. Execution of statistical studies. 

4. TRANSFER OF PERSONAL DATA

• Your collected personal data are shared only within the scope of the purposes explained in the first article of this disclosure text and the reasons requiring transfer under relevant legal regulations, in compliance with Articles 8 and 9 of the Personal Data Protection Law No. 6698, with supervisory and regulatory public institutions and organizations, judicial units, and natural or legal persons and business partners from whom the data controller receives services for its legitimate interests, provided that it does not harm the fundamental rights and freedoms of the data subject. Since obtaining explicit consent is a condition for sharing your personal data with third parties outside the reasons listed in the law, data transfer domestically or abroad is not carried out without obtaining an explicit consent approval text from you. 

• The application is obliged to keep records and transactions performed with and by its users for a certain period within the scope of legal regulations. If you request the deletion of your personal data, this request can be fulfilled until the end of the period determined by legal regulations; during this process, your personal data will not be processed except for obligations arising from legal regulations and will not be shared with third parties. 

• Security: We have appropriate administrative, technical, and physical safeguards to protect your personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, use, and other forms of unlawful processing. In some cases, your information is accessible when you log in to a feature we offer, and in these cases, you must keep your user credentials and password confidential and secure to protect your information. If we become aware of an unauthorized disclosure of your personal information, we will notify you as required by law and take necessary steps to help ensure the security of your information. 

• Great sensitivity is shown to the protection of children's personal data. Considering the practical difficulty of tracking children in the digital environment, such traffic must be carried out under the supervision of a parent/guardian, and in cases where explicit consent must be obtained regarding the processing of data, explicit consent must be given by the parent/guardian. 

5. LEGAL REASON FOR PERSONAL DATA COLLECTION

• Your personal data are acquired in any verbal, written, or electronic medium in line with the purposes stated above, for the purpose of offering the products and services we provide within the determined legal framework and enabling 3A TEKNOLOJİ HİZMETLERİ to fully and accurately fulfill its responsibilities arising from the contract and the law. Your personal data collected for this legal reason can also be processed and transferred for the purposes specified in this text within the scope of personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK Law. 

Personal data are used by the application for the following purposes: 

• Improving the services offered, developing new services, and providing information regarding them, 

• For users and candidate users with commercial electronic message consent; promotion and marketing of campaigns and services, 

• Resolving user issues and complaints, 

• Conducting statistical evaluations and market research, 

• Determining and implementing the company's commercial and business strategies, 

• Managing relations with users and business partners, 

• Monitoring accounting and payment transactions, 

• Legal processes and compliance with legislation, 

• Answering information requests from administrative and judicial authorities, 

• Planning in-house reporting and business development activities, 

• Performing financial control and reporting to carry out legal notifications, 

• Managing internal control and audit activities, 

• Ensuring information and transaction security and preventing misuse, 

• Making necessary arrangements to ensure that processed data are current and accurate, 

and to carry out activities related to all these listed processes. 

• Rights of the Personal Data Owner Enumerated in Article 11 of the KVKK Law:

As personal data owners, if you submit your requests regarding your rights to us via the methods regulated below in this Disclosure Text, we will finalize your request free of charge within thirty days at the latest, depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by us will be charged. In this context, personal data owners have the following rights: 

• Learning whether personal data are processed, 

• Requesting information if personal data have been processed, 

• Learning the purpose of processing personal data and whether they are used in accordance with their purpose, 

• Knowing the third parties to whom personal data are transferred domestically or abroad, 

• Requesting the correction of personal data in case of incomplete or incorrect processing and requesting the notification of the operation made within this scope to third parties to whom personal data have been transferred, 

• Requesting the deletion or destruction of personal data in the event that the reasons requiring their processing disappear, despite being processed in accordance with the KVKK Law and other relevant provisions of the law, and requesting the notification of the operation made within this scope to third parties to whom personal data have been transferred, 

• Objecting to the emergence of a result against the person by analyzing the processed data exclusively through automated systems, 

• Requesting compensation for the damage in case of suffering damage due to unlawful processing of personal data. 

• Pursuant to the 1st paragraph of Article 13 of the KVKK Law, you can submit your request regarding the exercise of your above-mentioned rights to us in writing or by other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application in writing in accordance with the KVKK Law. In this framework, the channels and procedures through which you will submit your application in writing within the scope of Article 11 of the KVKK Law are explained below. 

• To exercise your above-mentioned rights, you can submit your request containing the necessary information identifying your identity, other requested information, and explanations regarding the right you wish to exercise among the rights specified in Article 11 of the KVKK Law by filling out the form at (https://www.kazzusendekazan.com), hand-delivering a signed copy of the form along with identity-identifying documents to the address (Yalı mahallesi, Ortaç sokak, Numara 11 Kartal Istanbul), sending it via registered mail with return receipt requested, through a notary public, or by other methods specified in the KVKK Law, or by transmitting the relevant form to the email address (kazzusendekazan@gmail.com) with a secure electronic signature. 

The following features are disabled in a Limited Account:

• Communicating with other players using voice chat or unmoderated text chat, 

• Purchasing items with real money, 

• Earning rewards, 

• Recommendations based on past activity, 

• Marketing via email or push notifications, 

• Two-factor authentication via SMS. 

Explicit Consent Text

1. I have read and understood the Disclosure Text presented to me by KaZZu Sen De Kazan Game Software ("KaZZu Sen De Kazan Game") within the scope of the Personal Data Protection Law No. 6698 ("KVKK")[cite: 2].

2. I accept the processing of my identity (including name, surname, date of birth, marital status), contact, location, marketing, customer transaction, occupational experience information, transaction security information, social media account information, and customer hobby information by the Game for the following purposes: (i) execution of loyalty processes to the firm and products and activities aimed at customer satisfaction, and providing various advantages to customers within the framework of a loyalty program and informing them in this context, (ii) planning customized marketing activities by analyzing customer shopping habits and trends within the scope of executing product marketing processes, creating an additional customer card, performing customer segmentation and other customer relationship management (CRM) analyses over purchased products, managing their execution and internal corporate reporting, (iii) execution of advertising/campaign/promotion processes and communication activities (including sending promotional products, sending products to competition winners) and ensuring the shipment of commercial electronic messages (via phone, SMS, MMS, email (standard) or other forms) within this context[cite: 2].

3. I accept that for the purposes stated above, the application may share and/or grant access to my personal data (special categories of personal data and non-special categories) based on my explicit consent, domestically or abroad, with companies cooperated with and/or received services from, consultancy firms supported in areas such as sales, marketing, customer relations, law, accounting, and similar fields, and third parties supporting the Game in sales, marketing, and software matters related to its activities (firms providing SMS and email delivery, CRM (Customer Relationship Management), advertising and public relations, and cloud computing, backup, software support, and the like)[cite: 2].