Informational translation. This is an informational translation of the Turkish KVKK Aydınlatma Metni. If the two texts differ, the Turkish text prevails.
This notice is provided under art. 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform, for users who play Machware Games titles, visitors of games.machware.com.tr and people who contact us through the forms on this site. More detail is available in our Privacy Policy and in each game's own privacy policy.
Data controller
Your personal data is processed by the following company as data controller:
- Company: Machware Teknoloji A.Ş.
- Address: Maslak Mah. Maslak 42 B Blok İç Kapı 542, Sarıyer/İstanbul
- MERSIS number: [TO BE COMPLETED]
- Registered e-mail (KEP): [TO BE COMPLETED]
- VERBIS registration: [TO BE COMPLETED]
- Email: support@machware.com.tr
Personal data processed
| Data subject group | Data category | Examples |
|---|---|---|
| Players | Transaction security and device data | Device model, operating system, language, app version, Firebase Installation ID, App Instance ID, Player ID or Support code, the anonymous player profile on the game server (installation ID, internal player number, nickname, country), server access logs with a shortened IP address |
| Players | Marketing and advertising data (only in games with ads) | Advertising ID (GAID; on iOS the IDFA only in games that ask for ATT permission, and only with it), ad interactions |
| Players | Usage and analytics data | Sessions, screens, in-game events, approximate location derived from IP |
| Players | Error logs | Crash logs and device state at the time of a crash |
| Players | Customer transaction data | Game progress, virtual item balances, purchase records (product, date, transaction number; no payment details), an optionally linked Google Play Games or Apple player ID |
| Website visitors | Transaction security data | IP address, server logs, browser information, spam protection signals |
| Website visitors | Marketing and analytics data (only with consent) | Google Analytics 4 cookies and visit data, cookie choice |
| Applicants (formal KVKK application: written, KEP, secure electronic/mobile signature or registered email) | Identity and contact data | Full name, signature, Turkish ID number (for foreign nationals, nationality and passport/ID number), address for notifications, email address |
| Applicants (data subject request form on the site) | Identity, contact and request data | Full name, email address, the right being exercised, message; optionally address and the game concerned |
| Applicants (data deletion form) | Contact and request data | Selected game and platform, Player ID or Support code, email address |
| Applicants (support form) | Contact and request data | Subject, message, email address; optionally the game concerned |
| Applicants (all channels) | Request and complaint data | Reference number, date, language, correspondence |
The games have no username-and-password accounts (games with online features keep an anonymous player profile tied to your installation); no name, email, phone number, precise location or special category of personal data (KVKK art. 6) is collected in the games.
Purposes of processing
- Running the games, saving game progress and delivering purchased content,
- Detecting and fixing crashes and bugs, carrying out information security processes,
- With your explicit consent, measuring game and website usage (analytics) and showing personalised ads,
- Showing non-personalised ads, capping ad frequency and preventing ad fraud,
- Receiving, answering and resolving support, data deletion and data subject requests,
- Meeting accounting, finance and tax obligations,
- Preventing spam and abuse on forms and remembering your cookie choice,
- Informing authorised persons, institutions and organisations, and keeping evidence in legal disputes.
Legal bases and method of collection
Your personal data is collected by automated and partly automated means through the game apps and the software development kits (SDKs) in them, the website, cookies and web forms, and is processed on the following KVKK art. 5 legal bases:
- art. 5(2)(c), directly related to the formation or performance of a contract: running the game, saving progress, delivering purchased content, answering support requests.
- art. 5(2)(ç), compliance with a legal obligation: answering data subject requests, accounting and tax records.
- art. 5(2)(a), expressly provided by law: keeping commercial books and records.
- art. 5(2)(e), establishing, exercising or protecting a right: keeping request and correspondence records as evidence.
- art. 5(2)(f), legitimate interest (provided it does not harm your fundamental rights and freedoms): crash reports and information security, to keep the games and the site stable and secure; spam protection, to protect the forms from abuse; non-personalised ads and ad fraud prevention, to be able to offer the games for free; storing your cookie choice, to respect the choice you made.
- art. 5(1), explicit consent: game and website analytics, personalised ads, and cases requiring an incidental transfer abroad. In the games, analytics and personalised ads are off by default; explicit consent is obtained separately in the permission screen shown when a game first starts (in the EU/EEA, UK and Switzerland, the Google consent screen) and in the website cookie banner, and can be withdrawn at any time in the game's Settings screen or through the site's Cookie preferences link. Until consent is given, games with ads show only non-personalised ads.
Transfers of personal data
Transfers within Türkiye
Your personal data may be transferred, on request, to legally authorised public institutions and organisations (e.g. courts, the Personal Data Protection Board, tax offices) and to our legal advisers, within KVKK art. 8 and the legal bases above.
Transfers abroad
Because our service providers' servers are abroad, data is transferred to the following recipient groups:
- Google LLC / Google Ireland Limited (Firebase, Google Analytics, AdMob, YouTube, Google Play): analytics, crash reports, ads, video and in-app purchases.
- Apple Inc. / Apple Distribution International Ltd. (App Store): game distribution and in-app purchases.
- Cloudflare, Inc. (Turnstile): form spam protection.
- Resend: delivering form requests and confirmation emails.
- Vercel Inc.: website hosting.
- Railway Corporation (Railway, United States (US East, Virginia)): the game server for games that use online features. Transfer tool: KVKK art. 9: the Board's standard contract (notified to the Board within 5 business days of signing). GDPR: the European Commission's Standard Contractual Clauses.
Under KVKK art. 9 as amended by Law No. 7499, transfers are made, provided one of the conditions of art. 5 or 6 exists, in this order: (1) on the basis of an adequacy decision of the Board for the destination country, sector or international organisation; (2) without an adequacy decision, with one of the appropriate safeguards, in particular the Board's standard contract (which is notified to the Board within 5 business days of signing), binding corporate rules or a written undertaking approved by the Board; (3) where none of these exist, in non-regular, exceptional cases, on one of the incidental transfer grounds in art. 9(6).
Retention period
Your personal data is kept for as long as the purpose requires and for the periods set by the applicable legislation; it is then deleted, destroyed or anonymised under KVKK art. 7 and the Regulation on the Deletion, Destruction or Anonymisation of Personal Data. Retention periods by category are listed in the "Retention periods" table of our Privacy Policy.
Your rights under KVKK art. 11
Under KVKK art. 11, by applying to the data controller 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 your personal data is transferred,
- request rectification if it is incomplete or inaccurate,
- request erasure or destruction under the conditions of KVKK art. 7,
- request that the actions under items 5 and 6 be notified to third parties to whom the data was transferred,
- object to a result against you arising from the analysis of the processed data exclusively through automated systems,
- claim compensation for damage arising from unlawful processing of your personal data.
How to apply
Under the Communiqué on the Procedures and Principles of Application to the Data Controller, you can send your request in Turkish (requests under the GDPR may also be sent in English) through these formal channels:
- a signed written application to Maslak Mah. Maslak 42 B Blok İç Kapı 542, Sarıyer/İstanbul,
- our KEP address ([TO BE COMPLETED]), or a secure electronic or mobile signature,
- an email to support@machware.com.tr from an email address you previously gave us and that is registered in our systems.
A formal application must include your full name, your signature (for written applications), your Turkish ID number (for citizens of Türkiye) or nationality and passport/ID number (for foreign nationals), an address for notifications, your email address and the subject of the request.
In addition, for convenience, you can use the form on the Data Subject Request page. The form asks for your full name, email address, the right being exercised and your message, and optionally your address and the game concerned. For form requests we may ask for additional information, or for one of the formal channels, to verify your identity.
For requests about game data, because there are no accounts, please also give the Player ID or, depending on the game, the Support code shown in the game so that we can find your data. We may ask for additional information to verify your identity.
We resolve your request free of charge within 30 days at the latest, depending on its nature. If the request involves an additional cost, a fee under the Board's tariff may be charged. If your request is rejected, you find the answer insufficient or we do not answer in time, you may complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu, www.kvkk.gov.tr) within 30 days of learning of our answer and in any case within 60 days of your request.
Age limit
Our games are designed for users aged 13 and over and are not directed at children under 13. In some EU countries the age of digital consent is as high as 16. Minors should obtain a parent's or guardian's approval before giving explicit consent.