Effective Date: 03/08/2021
Applicable To The Following Mobile Application:
Zest Game Studio
Mobile App listed above, which shall hereinafter be referred to as “Mobile App.”
(“Data Controller”) and you, as the user of this Mobile App. Hereinafter, the parties will individually
be referred to as “Party” and collectively as “Parties.”
4.DATA CONTROLLER: Data Controller is the publisher, owner, and operator of the Mobile App
and is the Party responsible for the collection of information described herein. Data Controller
shall be referred to either by Data Controller’s name or “Data Controller,” as listed above. If Data
Controller or Data Controller’s property shall be referred to through first-person pronouns, it shall
be through the use of the following: us, we, our, ours, etc.
be referred to herein as either you, the user, or if any second-person pronouns are required and
applicable, such pronouns as ‘your”, “yours”, etc.
6.GOODS: “Goods” means any goods that we make available for sale on the Mobile App.
7.PERSONAL DATA: “Personal DATA” means personal data and information that we obtain from
you in connection with your use of the Mobile App that is capable of identifying you in any
2. GENERAL INFORMATION
Data that we receive about you, as well as your rights in relation to that Personal Data, when you
visit our Mobile App or purchase our Goods.
sources other than the use of our Mobile App. The Mobile App may link out to other websites or
websites or applications.
We are committed to the protection of your privacy while you use our Mobile App.
By continuing to use our Mobile App, you acknowledge that you have had the chance to review
also consent to the use of your information and the method of disclosure as described in this
immediately cease your use of our Mobile App.
Data Controller may be contacted as follows:
The location where the data processing activities take place is Ankara, Turkey.
5. MODIFICATIONS AND REVISIONS
any manner. If we do so, however, we will notify you and obtain your consent to the change in
impact the information collected on or after the date of the change. It is also your responsibility to
periodically check this page for any such modification, revision or amendment.
6. THE PERSONAL DATA WE RECEIVE FROM YOU
Depending on how you use our Mobile App, you will be subject to different types of Personal Data
collected and different manners of collection:
a) Unregistered users: If you are a passive user of the Mobile App and do not register for any
purchases or other service, you may still be subject to certain passive data collection (“Passive
Data Collection”). Such Passive Data Collection may include through cookies, as described below,
IP address information, location information, and certain browser data, such as history and/or
b) All users: The Passive Data Collection that applies to Unregistered users shall also apply to all
other users and/or visitors of our Mobile App.
c) Sales & Billing Information: In order to purchase any of the goods on the Mobile App, you will be
asked to provide certain credit information, billing address information, and possibly additional
specific information so that you may be properly charged for your purchases. This payment and
billing information will not be stored and will be used exclusively to assist with your one-time
d) Combined or Aggregated Information: We may combine or aggregate some of your Personal
Data in order to better serve you and to better enhance and update our Mobile App for your and
other consumers’ use.
We may also share such aggregated information with others.
THE PERSONAL DATA WE RECEIVE AUTOMATICALLY
Cookies: We may collect information from you through automatic tracking systems (such as
information about your browsing preferences) as well as through information that you volunteer to
us (such as information that you provide during a registration process or at other times while using
the Mobile App, as described above).
are small strings of text used to store some information that may concern the user, his or her
preferences or the device they are using to access the internet (such as a computer, tablet, or
mobile phone). Cookies are mainly used to adapt the operation of the site to your expectations,
offering a more personalized browsing experience and memorizing the choices you made
A cookie consists of a reduced set of data transferred to your browser from a web server and it
can only be read by the server that made the transfer. This is not executable code and does not
Cookies do not record or store any Personal Data. If you want, you can prevent the use of
cookies, but then you may not be able to use our Mobile App as we intend. To proceed without
changing the options related to cookies, simply continue to use our Mobile App.
Technical cookies: Technical cookies, which can also sometimes be called HTML cookies, are
used for navigation and to facilitate your access to and use of the site. They are necessary for the
transmission of communications on the network or to supply services requested by you. The use
of technical cookies allows the safe and efficient use of the site.
You can manage or request the general deactivation or cancelation of cookies through your
browser. If you do this though, please be advised this action might slow down or prevent access
to some parts of the site.
Cookies may also be retransmitted by an analytics or statistics provider to collect aggregated
information on the number of users and how they visit the Mobile App. These are also considered
technical cookies when they operate as described.
Temporary session cookies are deleted automatically at the end of the browsing session – these
are mostly used to identify you and ensure that you don’t have to log in each time – whereas
permanent cookies remain active longer than just one particular session.
Third-party cookies: We may also utilize third-party cookies, which are cookies sent by a third-
party to your computer. Permanent cookies are often third-party cookies. The majority of third-
party cookies consist of tracking cookies used to identify online behavior, understand interests
and then customize advertising for users.
Third-party analytical cookies may also be installed. They are sent from the domains of the
aforementioned third parties external to the site. Third-party analytical cookies are used to detect
information on user behavior on our Mobile App. This place anonymously, in order to monitor the
performance and improve the usability of the site. Third-party profiling cookies are used to create
profiles relating to users, in order to propose advertising in line with the choices expressed by the
Profiling cookies: We may also use profiling cookies, which are those that create profiles related to
the user and are used in order to send advertising to the user’s browser.
When these types of cookies are used, we will receive your explicit consent.
Support in configuring your browser: You can manage cookies through the settings of your
browser on your device. However, deleting cookies from your browser may remove the
preferences you have set for this Mobile App.
For further information and support, you can also visit the specific help page of the web browser
you are using:
– Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies
– Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
– Safari: http://www.apple.com/legal/privacy/
– Chrome: https://support.google.com/accounts/answer/61416?hl=en
– Opera: http://www.opera.com/help/tutorials/security/cookies/
Log Data: Like all websites and mobile applications, this Mobile App also makes use of log files
that store automatic information collected during user visits. The different types of log data could
be as follows:
– internet protocol (IP) address;
– type of browser and device parameters used to connect to the Mobile App;
– name of the Internet Service Provider (ISP);
– date and time of visit;
– web page of origin of the user (referral) and exit;
– possibly the number of clicks.
The aforementioned information is processed in an automated form and collected in an exclusively
aggregated manner in order to verify the correct functioning of the site, and for security reasons.
This information will be processed according to the legitimate interests of the Data Controller.
For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may
also possibly include Personal Data such as IP address, which could be used, in accordance with
applicable laws, in order to block attempts at damage to the Mobile App or damage to other
users, or in the case of harmful activities or crime. Such data are never used for the identification
or profiling of the user, but only for the protection of the Mobile App and our users. Such
information will be treated according to the legitimate interests of the Data Controller.
8. THIRD PARTIES
We may utilize third-party service providers (“Third-Party Service Providers”), from time to time or
all the time, to help us with our Mobile App, and to help serve you.
We may provide some of your Personal Data to Third-Party Service Providers in order to help us
track usage data, such as referral websites, dates and times of page requests, etc. We use this
information to understand patterns of usage of, and to improve, the Mobile App.
We may use Third-Party Service Providers to host the Mobile App. In this instance, the Third-Party
Service Provider will have access to your Personal Data.
Some of our Third-Party Service Providers may be located outside of the United States and may
not be subject to U.S. privacy laws. The countries or regions in which our Third-Party Service
Providers may be located include:
We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our
Your Personal Data will not be sold or otherwise transferred to other third parties without your
a third party or to third parties in order to protect the rights, property or safety, of us, our
customers or third parties, or as otherwise required by law.
We will not knowingly share your Personal Data with any third parties other than in accordance
If your Personal Data might be provided to a third party in a manner that is other than as explained
share that information.
In general, you may request that we do not share your Personal Data with third parties. Please
contact us via email, if so. Please be advised that you may lose access to certain services that we
rely on third-party providers for.
9. HOW PERSONAL DATA IS STORED
We use secure physical and digital systems to store your Personal Data when appropriate. We
ensure that your Personal Data is protected against unauthorized access, disclosure, or
Please note, however, that no system involving the transmission of information via the internet, or
the electronic storage of data, is completely secure. However, we take the protection and storage
of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.
Personal Data is stored throughout your relationship with us. We delete your Personal Data upon
request for cancelation of your account or other general request for the deletion of data.
In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but
in no event later than two weeks, and we will follow all applicable laws regarding such breach.
10. PURPOSES OF PROCESSING OF PERSONAL DATA
We primarily use your Personal Data to help us provide a better experience for you on our Mobile
App and to provide you the services and/or information you may have requested, such as use of
our Mobile App.
Information that does not identify you personally, but that may assist in providing us broad
overviews of our customer base, will be used for market research or marketing efforts. Such
information may include, but is not limited to, interests based on your cookies.
Personal Data that may be considering identifying may be used for the following:
a) Improving your personal user experience
b) Fulfilling your purchases
c) Providing customer service to you
11. DISCLOSURE OF PERSONAL DATA
Although our policy is to maintain the privacy of your Personal Data as described herein, we may
disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole
and exclusive discretion. Such cases may include, but are not limited to:
a) To satisfy any local, state, or Federal laws or regulations
b) To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas,
court orders, or writs from law enforcement or other governmental or legal bodies
d) As may be necessary for the operation of our Mobile App
e) To generally cooperate with any lawful investigation about our users
f) If we suspect any fraudulent activity on our Mobile App or if we have noticed any activity which
may violate our terms or other applicable rules
12. OPTING OUT OF TRANSMITTALS FROM US
From time to time, we may send you informational or marketing communications related to our
Mobile App such as announcements or other information. If you wish to opt-out of such
communications, you may contact the following email: firstname.lastname@example.org. You may also
click the opt-out link which will be provided at the bottom of any and all such communications.
Please be advised that even though you may opt-out of such communications, you may still
receive information from us that is specifically about your use of our Mobile App or about your
account with us.
By providing any Personal Data to us, or by using our Mobile App in any manner, you have
created a commercial relationship with us. As such, you agree that any email sent from us or third-
party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is
13. MODIFYING, DELETING, AND ACCESSING YOUR INFORMATION
If you wish to modify or delete any information we may have about you, or you wish to simply
access any information we have about you, you may reach out to us at the following email
14. ACCEPTANCE OF RISK
By continuing to our Mobile App in any manner, use the Product, you manifest your continuing
information or data via the internet is not always completely secure, no matter what steps are
taken. You acknowledge, agree and accept that we do not guarantee or warrant the security of
any information that you provide to us, and that you transmit such information at your own risk.
15. YOUR RIGHTS
You have many rights in relation to your Personal Data. Specifically, your rights are as follows:
– the right to be informed about the processing of your Personal Dat
– the right to have access to your Personal Data
– the right to update and/or correct your Personal Data
– the right to portability of your Personal Data
– the right to oppose or limit the processing of your Personal Data
– the right to request that we stop processing and delete your Personal Data
– the right to block any Personal Data processing in violation of any applicable law
– the right to launch a complaint with the Federal Trade Commission (FTC) in the United States or
applicable data protection authority in another jurisdiction
Such rights can all be exercised by contacting us at the relevant contact information listed in this
16. CONTACT INFORMATION: