Maestro Game Studio Yazılım A.Ş. (“Maestro Game Studio“, “Maestro Games” ,“Company“, “we“, “our” or “us“) develops, publishes and operates hybrid casual games (the “Games”) for mobile applications (each, an “App“) for the Games to be played across multiple devices.
We also operate the website www.maestro.gs, its subdomains and its related features (“Site“, and together with the Games and App, collectively – the “Services“).
Specifically, it describes our policy regarding –
- Data Collection
- Data Uses
- Advertising Uses
- Storage and Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject to Rights
- Notice for California Residents
- How to contact us
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services.
- Data Collection
We collect four main categories of data (and to the extent it may enable the identification of a specific person, or is linked to such potentially identifying data, we will deem it as “Personal Data“):
1-Data automatically collected or generated: when someone visits, interacts with or uses our Services, including any email or text messages sent to them by us or via our Services, we may collect or generate technical data about them. We collect or generate such data either independently or with the help of third-party services (as detailed in Sections 4 and 6 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 6 below). Such data consists of connectivity, technical or aggregated usage data, such as IP address, unique advertising ID, non-identifying data regarding a device, operating system, App version, mobile carrier, locale and language settings, user activity on our Services, and in-App or Game events. We do not use such data to learn a person’s true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners to deliver interest-based or otherwise more effective advertisements and content, to optimize our ad management and our users’ viewing experience, and to improve the overall performance and your user experience of our Services. For more information about our advertising uses, please see Section 3 below.
2- Data received from you: you may provide us Personal Data voluntarily, such as when you contact us (through Facebook, Messenger, e-mail or any other channel, including any support services), when you post on our public forums or groups, when you provide us your email address (such as when you sign-up to receive email updates or gifts), when you place any purchases in any of our Games, when you interact with other users through the in-game chat or when you choose to connect your Facebook or Apple account to any of our Games.
3- Data received from Facebook and other channels: Once you connect the Game to your Facebook or Apple account, we will receive access to your public profile, including (to the extent you defined it as “public”), as applicable, your full name, (e-mail address provided to Facebook), gender, locale, time zone, and a list of your friends playing our Games. This will also allow us to present your and your friends’ public profile pictures inside such Games and to create your in-game friends list. In addition, we or our advertising partners may receive from Facebook and our other marketing channels general information concerning the performance of our advertising campaigns, such as the targeted age group or interests, and we or our partners may be able to link such general data to any other data in our possession (to learn more about our advertising practices, please read Section 3 below).
4- Transaction Data: In-Game purchases will typically be processed by the relevant platform provider (e.g. Apple, Google or Facebook), and we will not collect or store your financial data, e.g. your credit card numbers or bank account. We may still however receive your non-financial Personal Data related to the purchase, such as your name, billing address, e-mail address and the items purchased, in order to fulfil your purchase and for our accounting purposes.
2- Data Uses
Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is being processed, however, we generally use the following:
- “Performance of a contract” – We will use this basis for processing necessary to make the Game and support services, available to you, and to send you service communications.
- “Consent” – In limited cases we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us using the details given in section 11.
- “Legitimate interests” – We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Games and through other channels, improving our customer service and support operations, and protecting and securing our users, ourselves and our Services.
- “Compliance with a legal obligation” – In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body.
The purposes for which we use Personal Data are described in more detail below:
- To facilitate, operate, and provide our Services;
- To authenticate the identity of our players, and allow them access to additional features;
- To provide our users with customer care, assistance and technical support services;
- To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
- To manage and deliver advertisements more effectively, including contextual, behavioral and interests-based advertising based on in-Game progress and activity, based on your preferences or other data available to us or to our business partners, including for re-targeting purposes;
- To contact our users (via e-mail, push notifications or any other available channels) with general or personalized service-related messages (such as purchase confirmations or system maintenance notices); to contact our users with promotional messages (such as Game updates, bonuses, new features, VIP services, etc.); and to facilitate, sponsor and offer certain events and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
- To comply with any applicable laws and regulations.
3. Advertising Uses
Our Games include advertising for third party services and products. We and our advertising partners use certain data about you in order to improve our advertising practices and make the ads we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems.
Such data includes your device advertising identifiers (e.g. IDFA or Advertising ID), to the extent available, data related to your connected Facebook, Apple or Google Play profile (if any, such as your gender, region or country), and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis [Author1] (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described in Section 3 above).
The ads we or our advertising partners deliver may be shown within our Games, our Services, or through other channels, such as third party websites and applications.
How to adjust your preferences regarding interest-based advertising
If you wish to prevent the use of your device’s advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising ID or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings).
If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users).
Please note that if you reset your advertising ID or opt-out of interest based advertising, you may still see advertisements in our Games, or on any other channels, but those ads will not be targeted based on the above mentioned identifiers. For example, such ads may be instead based on context, such as your progress and actions in the Game, or your language preferences. Please note that such actions may result in a less enjoyable user experience.
4. Storage and Retention
Your Personal Data may be maintained, processed, accessed and stored by Maestro Game Studio and our authorized affiliates, Service Providers and business partners in and from the United States of America and other jurisdictions, as necessary for the proper delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, Maestro Game Studio has taken commercially reasonable steps to ensure that your Personal Data is treated by its affiliates and Service Providers in a secure and lawful manner, and in accordance with common industry practices, regardless of any lesser legal requirements that may apply in their jurisdiction. If we transfer Personal Data of users outside of Turkey, we make such transfers in accordance with Personal Data Protection Law of Turkish Republic No.6698 (“Personal Data Protection Law”). You can contact us using the details in section 12 to find out more about these safeguards.
We retain your Personal Data in order to maintain and expand our relationship, and to provide you with our Services. In other words, we will retain your Personal Data for as long as you remain our user and have not notified us otherwise. We will take commercially reasonable measures to delete your Personal Data if you delete your account. We may also retain your Personal Data for legal and accounting purposes (i.e., as required by laws applicable to record and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with the Personal Data Protection legislation in Turkey.
Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.
5. Data Sharing
We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates – but only in accordance with this Personal Data Protection legislation of Turkey:
- Compliance with Laws, Legal Orders and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
- Service Providers and Business Partners: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, marketing agencies and advertising services and tools, data and cyber security services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal, financial and compliance advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, in accordance with the respective provisions of the Personal Data Protection legislation of Turkey depending on each of their specific roles and purposes in facilitating and complementing our Services, and may use it for such purposes.
- Third Party Integrations: The Services allow you integrate with certain third-party services, such as in order to connect your Facebook or Apple account to a certain Game or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third-party services.
6. Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also notify you about new services, events and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
If you wish to receive such promotional communications, you can choose to subscribe. If you wish not to receive such promotional communications anymore, you may notify Maestro Game Studio at any time by emailing us at email@example.com or by following the “unsubscribe”, “stop” or “change e-mail preferences” instructions in the promotional communications you receive.
8. Data Security
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 6 above.
9. Data Subject Rights
In case we process Personal Data about you and if you are an EU resident or the resident of another jurisdiction that affords you with the below rights you:
- may learn whether or not your Personal Data is being processed,
- have the right to know what Personal Data we maintain about you.
- may learn the purpose of Personal Data processing and whether the Personal Data is used appropriately in line with such purposes,
- may, at any time, access, correct, request deletion, request restriction, destruction of our process of your Personal Data or object to the processing of your Personal Data, as set by applicable law.
Please note that if you ask us to delete or restrict how we use or process your Personal Data, subject to applicable law, we may not be able to provide you with all of our Services and customer support or the quality of the Services may be diminished.
- have the right to know the third parties to which your Personal Data is transferred domestically or abroad,
- have the right to request the transmission of your correction, deletion and destruction requests to third parties to whom your Personal Data has been transferred,
- may ask to transfer your Personal Data in accordance with your right to data portability.
- have the right to object to any consequence occurring against you by analyzing your processed data through automated systems.
- have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you.
- may request compensation in case you incur any damage due to the unlawful processing of Personal Data.may object to the occurrence of an adverse consequence by analyzing the processed data exclusively through automated systems, and
- have the right to lodge a complaint with the relevant data protection authority and have the right to claim damages in case of impairment because your personal data is processed in violation of the relevant legal legislation.
Rights of Turkish residents
If you are an user from Turkey you have certain rights in connection with your Personal Data and how we handle it based on the Law No. 6698 Personal Data Protection Law. Some of these rights may be subject to some exceptions or limitations.
According to the relevant legislation, you have the right to;
- learn whether or not your personal data is being processed,
- request information as to processing if it has been processed,
- learn the purpose of personal data processing and whether the personal data is used appropriately in line such purposes,
- know the third parties to which your personal data is transferred domestically or abroad,
- to request correction if “your personal data is incompletely or incorrectly processed,
- to request deletion or destruction of your personal data,
- to request the transmission of your correction, deletion and destruction requests to third parties to whom your personal data has been transferred,
- to object to any consequence occurred against you by analyzing your processed data through automated systems
- request compensation in case you incur any damage due to the unlawful processing of personal data.,
If you wish to exercise your rights under applicable law please contact us at firstname.lastname@example.org.
Please note that your request must:
- Provide sufficient information to allow us to reasonably verify you are the person about whom we processed Personal Data or an authorized representative.
- Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Therefore, when you make a request, please include your name, surname, signature (if your request is written), your identity number or passport number with nationality, residential and business address subject to the notification; electronic mail address, telephone, fax number subject, and subject of demand. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Your requests will be answered as soon as possible and within thirty (30) days at the latest.
Please note that the above mentioned rights are not absolute, and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.
If you wish to manage the information we receive about you from a third-party application or platform where you play our Games, such as Apple or Google, please follow the third-party application’s instructions for updating your information and changing your privacy settings.
You have the right to file complaints with a data protection supervisory authority. You can find details of your national supervisory authority via this link https://edpb.europa.eu/about-edpb/board/members_en. For the avoidance of doubt, the supervisory authority for Turkey is the Personal Data Protection Authority.
The Games and Services are available only to individuals who are the greater of sixteen (16) years of age or the age of legal majority in your jurisdiction. We reserve the right to request proof of age at any stage. We may block Users whom we suspect are under the applicable age. We do not knowingly collect Personal Data from minors and do not wish to do so. If we learn that a minor is using the Services or playing any of our Games, we may prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such minor.
If you believe that we might have any such data, please contact us at email@example.com .
11. Notice for California residents
If you reside in the state of California please visit “Privacy Notice for California Residents” section to learn more about the rights available to you.
12. Updates; How to Contact Us
Address: Maslak Mah. AOS 55. Sk. 42 Maslak B Blok Sitesi No: 4 İç Kapı No: 569 Sarıyer / İstanbul
MERSIS Number: 0610125903500001
13. Controlling Version
Last modified: August 2021
Processing Personal Data
We may have collected and discloses for a business purpose the following categories of Personal Data:
Sources of Personal Data
|Category of Personal Data Collected||Personal Data Collected||Categories of service providers to whom Personal Data was disclosed||Business Purpose for Collection|
|A. Identifiers||Name, username, email address, social media identifier, IP address, username, advertising ID, device an operating system information||·Advertising networks |
·Social media services
·Data analytics vendors
·Quality assurance vendors
·Cloud storage Providers ·Service providers
·App distribution platforms
|·Operate our business and game |
·Product development/improvement ·Customer service
·Detecting/Protecting against security event
·Internal analytics and reporting
·Game mechanics or functionality
·Facilitate players’ social interaction
·Maintaining and enhancing service, debugging
·Advertising and direct marketing
·Detecting/protecting against security events, preventing fraud and abuse of our policies
·Compliance purposes and meeting legal/regulatory requirements
|B. Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))||Name, image|
|D. Commercial Information||Transaction information, purchase history. This does not include any payment information, which is collected directly by the mobile app distribution platform.|
|E. Internet or Other Electronic Network Activity Information||Interaction with our App|
|F. Geolocation Data||Country, State, City|
- Directly from users
- Directly or indirectly by cookies or other tracking technologies
- Social networks
- Advertising networks
- Data Analytics Providers
In accordance with the CCPA, you have the right to request: (i) that we disclose what Personal Data we collect, use or disclose, (ii) the deletion of your Personal Data as collected or maintained by us; (iii) to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA – in accordance with the CCPA, using the methods we made available herein.
You can designate an authorized agent to make a request under the CCPA on your behalf, in accordance with the CCPA, using the methods we made available herein.
Selling Personal Data