Privacy Notice (KVKK)

Türkçe

Version: AYD-1 · Effective date: [TO BE FILLED]

DRAFT — this line will be removed after the lawyer's review.

English translation of the Turkish text (AYDINLATMA_TR). [LAWYER: which language version prevails]

This text informs you under Article 10 of Law No. 6698 on the Protection of Personal Data (KVKK) of the Republic of Türkiye. It is not a consent form; you are not asked to "consent" to any processing of personal data in order to play the game.

IN SHORT

  • Your game account is currently kept only on this device. When you connect to the game, your player name, IP address and in-game data are processed on our game server in France.
  • We do not collect e-mail address, phone number, real name, date of birth, location, contacts, camera, microphone, advertising ID or device ID.
  • We use no advertising or analytics software (SDK); we do not build profiles; we do not sell your data. We use Sentry for crash and error reports; the reports are not linked to you.
  • You can delete your account with SETTINGS › PRIVACY / ACCOUNT › DELETE ACCOUNT or on our web page.

1. DATA CONTROLLER

Developer and data controller of Alfa Wolf Game: [TO BE FILLED: full name]

Address: [TO BE FILLED: address for notices]

E-mail: [email protected]

Registered e-mail (KEP, if any): [TO BE FILLED]

2. WHICH DATA WE PROCESS, FOR WHAT PURPOSE AND ON WHAT LEGAL GROUND

The legal grounds are the sub-paragraphs of Article 5(2) of the KVKK: (c) the formation or performance of a contract, (ç) a legal obligation, (e) the establishment, exercise or protection of a right, (f) our legitimate interest, provided it does not harm your fundamental rights and freedoms.

  • Account: your player name, an irreversible digest of your password (the password itself is not stored), creation time

Why: To create the account, sign you in and identify you in the game · Legal ground: (c) · Where: On your device; your player name also goes to the game server

  • Connection: your IP address and port, a random session key created anew for each session

Why: To connect to the server; to bring you back to the same match if your connection drops · Legal ground: (c) · Where: Game server (France); the session key is kept in memory only and never written to logs

  • In-game data: rank, level, team, your movements and results in matches, the room name and room password you create, your look and weapon choices, your preset radio messages

Why: To run the match and show it to other players · Legal ground: (c) · Where: Game server and the players in the same room

  • Server logs: your player name, rank and level, connection and match events, error logs

Why: Security of the service, prevention of cheating and abuse, fixing bugs · Legal ground: (f) · Where: Game server (France)

  • Crash and error reports: the error message and stack trace, game version, device model, operating system version, technical device details, the warning lines before the error. Before sending, player and room names, chat text, e-mail and IP addresses, passwords and session keys are removed; there is no user, account or device identifier, no screenshot and no location

Why: Fixing bugs and crashes · Legal ground: (f) · Where: Sentry (EU data region, Germany)

  • Game profile: your Gold, GP and Cash balances, items, missions, badges, statistics, play time; the device's boot ID and a random installation number to count rental item durations correctly

Why: To keep your progress and the game economy; to prevent cheating with the device clock · Legal ground: (c), (f) · Where: On your device

  • Your settings: controls, graphics, sound, button layout

Why: To remember your settings · Legal ground: (c) · Where: On your device

  • Privacy records: which text version was shown to you, which version of the Terms of Use you accepted, time, your deletion requests

Why: To prove that we met our obligations · Legal ground: (ç), (e) · Where: On your device (on the server once online accounts arrive)

  • Requests and support correspondence: the name, contact details and request you give when writing to us

Why: To answer your request · Legal ground: (ç), (e) · Where: E-mail / post

In addition, when purchases open: the Google Play order number, product, amount, date and refund status; the purpose is to verify the purchase, add Cash to your account, handle refunds and disputes and keep tax records; legal grounds (c) and (ç). Google processes card and payment details; we do not see them. [TO BE FILLED: this paragraph and the version will be updated before purchases open]

3. HOW WE COLLECT DATA

Electronically and by automatic means, through the registration form, your use of the game and the connection the app makes with the game server; for requests and support, through the messages you send us.

4. WHO WE TRANSFER IT TO

  • Our hosting provider OVH SAS (France): runs the game server; processes your data only on our behalf and on our instructions (data processor).
  • Our error-reporting provider Functional Software, Inc. (Sentry): stores the crash and error reports in its EU data region (Germany) only on our behalf (data processor).
  • Other players in the same room and on the server: your player name, rank, level, team and in-match movements are visible by the nature of the game.
  • Google: distributes the game through Google Play; when purchases open, Google processes the payments. [LAWYER: the nature of the transfers to Google]
  • Public authorities and courts empowered by law: when there is a legal obligation and only to the extent requested.
  • [TO BE FILLED: e-mail service provider; accountant when purchases open]

5. TRANSFER ABROAD

Our game server is currently in France (OVH SAS, Roubaix). When you connect to the game, your player name, IP address, session key, in-game data and server logs are processed there; this is a transfer abroad within the meaning of Article 9 of the KVKK. The transfer is made under the standard contract (controller to processor) announced by the Personal Data Protection Board; the contract is notified to the Authority within five working days of signature. [TO BE FILLED: the contract's signature date and the date of notification to the Authority — this text must not be published before they are completed]

We plan to move the server to Türkiye later; this text will be updated when it moves.

Crash and error reports are stored in Sentry's EU data region (Germany); the transfer is made under the data processing agreement with Sentry and the standard contract announced by the Board. The data processing agreement with Sentry (DPA, version 5.1.0) was signed on 10.11.2026. [TO BE FILLED: date the standard contract was notified to the Authority]

If your Android device's automatic backup is on, the game's files on the device (your account record, game profile, settings) may be backed up by Google to your own Google account. We cannot see this backup; you can manage it in your device's Google backup settings.

6. HOW LONG WE KEEP IT

  • Data on your device: until you delete your account, or the app or its data.
  • Session key: for the duration of the connection; at most a few minutes if your connection drops (to bring you back to the match).
  • Server logs: at most 14 days; then deleted automatically. [TO BE FILLED: to be verified on the server]
  • Crash and error reports (Sentry): at most 90 days; then deleted automatically.
  • Privacy records: as long as the account exists; when the account is deleted, the records of that account are deleted too; only the number and date of the deletion request and a shortened form of your name (e.g. "A*t") stay on the device.
  • Request correspondence: [TO BE FILLED: period]
  • Purchase records (when purchases open): for the period required by tax and commercial law. [TO BE FILLED: accountant]

When the period ends, or on a deletion request, we delete, destroy or anonymize your data.

7. CHILDREN

Alfa Wolf Game is not designed for children under 16. [TO BE FILLED: age limit — 16 or 18, owner's decision and the Google Play target audience choice] If you are under 18, you must get your parent's or guardian's permission before making a purchase.

8. YOUR RIGHTS (KVKK ART. 11)

By applying to us you can learn whether your personal data is processed and, if so, request information about it; learn the purpose of the processing and whether the data is used in line with that purpose, and the third parties in Türkiye or abroad to whom it is transferred; ask for it to be corrected if it is incomplete or wrong, deleted or destroyed under Article 7 of the KVKK, and for these actions to be notified to the third parties it was transferred to; object to a result against you that arises solely from analysis by automated systems; and claim compensation if you suffer damage because of unlawful processing.

9. HOW TO APPLY

  • In writing by post: [TO BE FILLED: address]
  • By e-mail: [email protected] [LAWYER: the status of this channel under Art. 5 of the Communiqué, as there is no e-mail registered in the system]
  • By registered e-mail (KEP, if any): [TO BE FILLED]

In your application, write your player name and your request; never write your password. The application form is on our website: alfawolfgame.com/kvkk [TO BE FILLED: address]; you do not have to use the form. Applications are made in Turkish and are answered free of charge within 30 days at the latest (if the action requires a separate cost, the fee in the Board's tariff may be charged). The answer is given in writing or electronically. If you do not find the answer sufficient, you can complain to the Personal Data Protection Board.

10. CHANGES

If this text changes, the new version is shown in the game; the version number and date are at the top of the text.