Privacy Policy
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1. Scope |
1.1 This Privacy Policy is intended to be incorporated into the Terms of Service (the “Terms of Services”) and it describes how Hakubuya Games Studio and its subsidiaries, parent companies, joint ventures and other corporate entities under common ownership and/or any of their agents, consultants, employees, officers and directors (collectively, as “Hakubuya Games”) in order to collect, use, process the personal information (“Personal Information”) of the persons downloading, using and accessing the below defined services (“ User”) conferred rights related thereto. In this Privacy Policy services provided by Hakubuya Games refer to the games, websites, marketing and advertising activities and other services collectively as the ("Services").
1.2 This Privacy Policy applies to all of the Services, whether accessed on the https://hakubuya-games.github.io website, mobile devices, PCs, social media platforms, several integration programs or on other platforms and alike. It also applies to the marketing and advertising activities on all platforms and other services that Hakubuya Games may provide or any of the marketing and advertising activities that through third party analytics and ad-network services, social media platforms and similar platforms and systems from time to time.
1.3 The user hereby grants and undertakes the collection and processing of his/her Personal Information under the terms and scope of this Privacy Policy.
1.4 By using and downloading the Services, User hereby explicitly agree and accept this Privacy Policy. If User is not willing to agree and accept this Privacy Policy, the User is obliged to cease the use of the Services and delete the Services from his/her equipment.
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2. Types of the Collected Personal Information and How We Collect It |
2.1 Personal Information regarding the current, prospective, and former clients, customers, users, visitors, and guests may be collected. The types of Personal Information Hakubuya Games may collect may vary upon the Service that User gets or relationship between Hakubuya Games and User.
2.2 By downloading, accessing and/or playing (if applicable) the games or using the Services, User consents to the collection of information about User by Hakubuya Games. The types of Personal Information Hakubuya Games may collect (directly from User or from Third-parties) and the privacy practices varies on the nature of the relationship that User have and the requirements of applicable law. Please find below which type of Personal Information we collect and the ways of collection.
· Information Directly Collected from User
Some games or parts of Hakubuya Games’s Services may use a more traditional registration or account set-up process that User directly provides information:
Ø User first and last name, email address, player/user name, password, age or birthday, sex and other information that helps Hakubuya Games to make sure it’s the User itself that is accessing the account or helps Hakubuya Games to improve its services
Hakubuya Games may also require from User to create player profile, in such cases, User profile may include below mentioned information:
Ø User first and last name, email address, User identification number and/or user name, User profile picture or his/her URL, player ID, location, sex, age-range, the login e-mail, detail about the games User plays, mobile phone number (if provided by User), locale, language of User application, time zone numbers for User friends who are also connected to the Services.
· Information User Generates Using Hakubuya Games Services
Information that User provides Hakubuya Games with when User fills in forms, and/or questions or complete surveys when using any of the Services, when User creates an account with Hakubuya Games or if User invites his/her friends to use the games and Services; (such as gender, name, date of birth place, nickname, nationality); the content of messages sent using the chat and messaging systems; posted photos, drawings, or other user-generated content; public posts or comments on other players’ profiles or gameboards.
Please note that, Hakubuya Games is entitled to access such record, and/or store archives of these communications, photos, drawings, and other contents generated by User in order to satisfy legal compliance and provide the safety of other users/players generated content on Hakubuya Games servers to make use of them to protect the safety and well-being of Hakubuya Games’s players as well as to conduct researches in order to improve, personalize, and optimize Hakubuya Games’s Services and games.
· Information collected when User make any purchases
In case of any purchase in-game virtual currency or items in a Services, third-party payment processor may collect the billing and financial information such as User’s postal address, e-mail address, and financial information.
In case of obtaining Services on connected third-party applications or platforms (like Facebook, Apple, Google, or Amazon), any purchases that User make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, Hakubuya Games does not receive any financial information, but may receive non-financial information related to the purchases, like User’s name, approximate physical location, and the items purchased.
Please note that the information that Hakubuya Games collects receives depends on Services that User is provided with.
· Information About User That Hakubuya Games Get Connected from Third-Party Applications, Including Social Networks
If User gets any Services of Hakubuya Games on connected third-party applications or connect Hakubuya Games Services to any third-party applications, including social networks like Facebook, Hakubuya Games may receive certain information about User from the provider of the third-party application. The information Hakubuya Games receives depends on the Service, the third-party application, privacy settings. In such case Hakubuya Games may collect below information;
Ø User first and last name, email address, User identification number and/or user name, User profile picture or his/her URL, player ID, location, sex, age-range, the login e-mail, user identification number (like Facebook ID number), which may be linked to publicly-available information like name and profile photo; friends’ user ID numbers and other public data; detail about the games User plays, mobile phone number (if provided by User), locale, language of User application, time zone numbers for User friends who are also connected to the Services; User personal comments which may include Personal Information; Personal Information to be published on the fan pages, forums, sites or to be provided via contest; information about User’s activities on or through the connected third-party application;
· Cookies and Other Automated Information Collection
Hakubuya Games collects information about User’s devices by using cookies and other similar technologies (e.g., beacons, pixel tags, clear gifs, and device identifiers) to recognize User and/or User device(s) on, off, and across different Services and devices. User always have option to opt out from such use and control it where needed.
Ø Protocol (IP) address, cookie identifiers, mobile advertising identifiers, User mobile device’s identifiers like User Identifier For Advertising , Advertising ID, Game Center ID, the type of computer or mobile device User is using, User device's operating system, version, model, hardware type and other device identifiers that are automatically assigned to User computer or device when User access the Internet, browser type and language, hardware type, operating system, internet service provider, pages that User visit before and after using the Services, the date and time of User visit, the amount of time User spend on each page, information about the links User click and pages User view within the Services and other actions taken through use of the Services such as preferences; information Hakubuya Games collect via cookies and widgets that allows Hakubuya Games to collect data, such as User device's model, operating system and screen size, IP, game center IP, preferences and other information about how User use the Services;
Ø domain names;
Ø performance and game contextual data like User games session activity;
Ø aggregated and/or de-identified information that is not intended to specifically identify a user; and
Ø technical information such as device identifier,
Ø details about how User uses and interacts with the Services (for example, information about how and when User play the games or visit the websites(s),
Ø information that User provides Hakubuya Games when User fills in forms, and/or questions or complete surveys when using any of the Services, when User creates an account with Hakubuya Games or if User invites his/her friends to use the games and Services; (such as gender, name, date of birth place, nickname, nationality etc. )
Ø User interactions with Hakubuya Games on the social media channels;
Ø the name User have associated with its device; country; telephone number (if User provides it); specific geolocation (with User’s permission); mobile contacts; and/or information about the Hakubuya Games games and other third-party apps on User’s device. (if Hakubuya Games Services obtained via mobile device)
· Other Sources
Ø information that Hakubuya Games collects about User from the other group companies or other third party companies who have obtained User’s consent or have another legal right to share such information with Hakubuya Games (including publishing partners, platforms, advertising platforms and partners and data aggregators who have obtained). This may include attributes about User and User interests, as well as other games and services that User uses, demographic and general location information.
· California “Do Not Sell My Info.”
Hakubuya Games does not sell any Personal Information or any data related to its users.
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3. Purpose |
3.1 The primary goal of processing the Personal Information is to provide a better gaming experience, improve the Services, and conduct marketing and research activities and create reports for internal use. The Personal Information may be stored anywhere in the world including but not limited to Turkey either physically or electronically.
3.2 Personal Information may be collected and processed for below mentioned purposes;
Ø the managing the account and relationship with Hakubuya Games and improving the experience during the use of the Services;
Ø research, surveying, and engaging with User, for example by sending communications (including by email);
Ø to enable users/players to interact and communicate with each other;
Ø marketing and promotion of Services, to create reports, analysis or similar services for use by Hakubuya Games;
Ø business intelligence, preventing cheating, crime or fraud;
Ø to deliver advertising and marketing and promotional information to User;
Ø to notify User about products and services or upcoming special offers/events that may be interest of User;
Ø to operate, improve and optimize the Services; to create game accounts and allow users to play the games; to personalize the Services, understand the users and their preferences to enhance user experience and enjoyment using the Services;
Ø to send related information, including confirmations, technical notices, updates, and security alerts and support and administrative messages; to enable players to communicate with each other in games or on the social media accounts;
Ø to prevent potentially prohibited or illegal activities and protect of the players; to ensure internal quality control;
Ø to provide technical support and respond to player inquiries;
Ø to provide services via mobile devices; for third party payment requirements;
Ø for serving cookies, pixel tags, analytics information and interest-based or targeted advertising;
Ø To comply with Hakubuya Games’s legal obligations, resolve any dispute that Hakubuya Games may come across and to protect the rights of Hakubuya Games.
The User accepts, acknowledges, and promises that his / her Personal Information might be used in limited manner by the Hakubuya Games to the extent that it is limited to the format and purposes set forth in this Privacy Policy.
3.3 In case that Services includes additional links and references to third party sites, services, and other domains. Such third-party providers can use advertising identifiers, cookies, web beacons, and other tracking technologies (including location tracking in location-based games) to collect or receive information about User. Statements of Hakubuya Games under this Privacy Policy do not apply to the features, technologies, or practices of such third parties. User acknowledges that Hakubuya Games is not liable for the compliance of such third parties to protection of the Personal Information. Hakubuya Games shall under no case held liable for the content of such sites and services.
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4. Using and Sharing Personal Information |
4.1 The Personal Information shared by the User shall in no case be used for the interest of other third Parties either directly or indirectly and shall be disclosed except as provided below. Please note that Hakubuya Games may share Users Personal Information to provide the Services with Third-party Service Providers; to comply with legal obligations; to protect and defend its rights and property or with User’s consent.
· Service Providers
We may share the information we receive from the User with Service Providers. The types of Service Providers (processors) to whom we entrust Personal Information include Service Providers for: (i) provision of IT and related services; (ii) provision of information and services User have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services. Hakubuya Games may also share information with platform partners for SDK Advertising and S2K Tag Advertising with AdColony, Inc., Admob, Inc. , AppLovin Limited, Chartboost, Inc., Pubnative GmbH, Inmobi Pte. Ltd., ironSource Mobile Ltd. Mopub Inc. Tapjoy, Inc. Unity Ads Vungle, Inc., Facebook Analytics for Apps (Facebook, Inc.), Google Analytics for Firebase (Google Inc.), Google Analytics (Google Inc.), Amazon Web Services (AWS) and Adjust GmbH. In order to provide safety to User’s Personal Information, Hakubuya Games takes reasonable precautions information (as required by applicable data protection laws) while sharing such information with such Service Providers.
· Displaying to Friends and Other Users
Hakubuya Games Services encourages it players to interact with each other if User plays the games or access the Services. If through a social network or register through a social network (i.e Facebook), User’s social network friends who also plays Hakubuya Games games or access Services will see User’s name, photo, player profile.
In addition, in Services offered by Hakubuya Games, other players, regardless of whether they are User’s social network friends, will be able to see User’s player profile; view descriptions of User’s in-game activity; communicate with User within the Services; and send User’s game requests or friend requests through Hakubuya Games games, Services or the related social network.
· Marketing - Interest-based or Targeted Advertising and Third-party Marketing.
In some occasions Hakubuya Games may use advertising tools and mechanisms in order to offer several features and Services gratis. These advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Mostly such offerings are hosted by third party wall providers and not held by Hakubuya Games itself. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party providers. Hakubuya Games does not actively shares Personal information with such third-party offer wall providers.
In order to carry out such advertising tools Hakubuya Games may share or such third-party provider may directly collect below Personal Information within Services:
Ø performance data (like the number of clicks on an advertisement);
Ø certain technical information (for example, IP addresses, non-persistent device identifiers such as Advertising ID and de-identified persistent device identifiers such as a hashed Android ID);
Ø User’s social network ID;
Ø other contextual data about User’s game play (for example, level and session length); and
Ø pseudonymous data, not directly identifying information (e.g., OS name and versions, device models, time stamp).
Ø In addition to serving Users with relevant ads, the information collected may be used to:
Ø calculate the effectiveness of the ads
Ø offer User targeted advertising (both on and off the Services) in order to personalize User experience by showing advertisements for products and services that are more likely to appeal by User (a practice known as interest-based advertising or behavioral advertising); and/or
Ø undertake web analytics to analyze traffic and other player activity to improve User’s experience.
· Disclosures to Protect Hakubuya Games or Others (i.e as Required by Law and Similar Disclosures).
Personal Information may be used accessed, preserve, and disclosed if Hakubuya Games believe doing so is required or appropriate:
Ø To satisfy and comply with applicable laws or regulations
Ø To fulfil to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
Ø To prevent illegal activities such as committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions which are carried out via using Services.
Ø Occurrence of emergency that poses a threat to the health and/or safety of the User, another person, or the public generally.
· Merger, Sale, or Other Asset Transfers.
If Hakubuya Games engages in a merger, acquisition, financing, due diligence, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, then User’s Personal Information may be disclosed or transferred as part of such a transaction as permitted by law and/or contract to the successor organization or competent body. In such case, Hakubuya Games will show its best efforts, to procure that the manners of such successors are compliant with this Privacy Policy.
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5. Transfer Abroad |
Services provided by Hakubuya Games is global by nature and Personal Information can therefore be transferred to anywhere in the world. Since different countries may have different data protection laws than User’s residential country, Hakubuya Games takes steps to ensure adequate safeguards are in place to protect Personal Information as explained in this Privacy Policy. Since each country has its own jurisdiction, the privacy laws applicable to the places where Personal Information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where User is resident. Hakubuya Games undertakes to comply with its legal obligations under the applicable law where such Personal Information is transferred and where User is located and ensure that Personal Information is subject to suitable safeguards or transferred to secure territories.
As part of the Services and games Hakubuya Games may transfer several Personal Information abroad to its business partners and service providers from time to time for the legitimate business purposes.
Hakubuya Games store Personal Information about Users and visitors to the sites on servers located in the Amazon Servers, and Hakubuya Games may also store this Personal Information on servers and equipment in other countries and may change such location from time to time. Personal information collected in the European Countries may be transferred to, and stored at, a destination outside of the European Countries. The data we hold may also be processed by employees operating outside of the European Countries who work for us, or one of its business partners or service providers. This staff may be engaged in, among other things, (i) the processing of transactions and User’s payment details, or (ii) the provision of support services. If Hakubuya Games transfers User’s Personal Information internationally, Hakubuya Games will take reasonable steps to ensure that Personal Information is treated securely, lawfully, and in accordance with this Policy.
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6. User Rights and Shine the Light |
6.1 User have certain rights in connection with Personal Information and how Hakubuya Games handle it. User can exercise these rights at any time by contacting us. In that vein, regardless of where User is located (applicable for European Union and Switzerland as well) User is entitled and have right to:
· access and require information regarding the types of personal information of Users is processed and to ask detailed information,
· learn the purpose of Personal Information processing and whether such Personal Information are used for such purpose,
· know the parties to which such Personal Information is transferred within the country or abroad,
· ask the correction of Personal Information in order to be true actual and updated,
· demand the deletion of User’s Personal Information,
· object to the processing of Personal Information about himself/herself, which is processed on the grounds of legitimate interests,
· opt-out of marketing communications,
· demand from Hakubuya Games to inform other third parties regarding the correction, deletion destruction of such Personal Information,
· object the results against to User which occurred through analysis of such Personal Information via exclusively automatic systems,
· to withdraw its consent at any time, in case of processing Personal Information with User’s request,
· demand compensation in case of any damages due to the processing of Personal Information in violation of applicable law,
· request a restriction of the processing of User Personal Information, such as when User is disputing the accuracy of User data held by Hakubuya Games.
6.2 To exercise User rights to access or deletion, please submit a request through contact details stated below. Hakubuya Games shall finalize the requests of the User in reasonable time in accordance with the applicable data protection laws and manner and yet no later than 30 (thirty) days. If the use of right by the User requires additional cost, then Hakubuya Games may be entitled to demand such costs from User.
6.3 For the use of rights conferred to User, User may also be required to take additional steps, such as deletion of Services or, suspension of User’ Accounts or the connection with several application or social network. For the use of the rights by User, Hakubuya Games may demand from the User the verification of its identity.
6.4 Accessing and Deleting Personal Information Held by Hakubuya Games
User can request a copy of or deletion of its game account data by contacting us. To review and update personal information associated with User profile in certain games, visit the “settings” page in that game.
For deletion requests, Foo will take reasonable measures to delete Personal Information from Hakubuya Games’s records. Hakubuya Games will keep certain records (e.g., personal information relating to payments or customer service matters) for legitimate purposes.
6.5 Managing Personal Information Hakubuya Games Receives from Third-Party Applications / Platforms And From User’s Mobile Device
To manage the information Hakubuya Games receives from third-party applications or platforms and from User’s mobile device, User can use the tools and settings provided by the third-party application and its own mobile device.
In order to manage the information that Hakubuya Games collects from third party applications, User has to follow the instructions of such third parties to update and changes the privacy settings
User can manage many aspects of the collection and use from its mobile device by visiting the “settings” page of its mobile device or web browser. Such procedures may vary depending on the device and the browser.
If Hakubuya Games receives Personal Information from a third-party application / platform or User’s mobile device, that information is stored and used by Hakubuya Games in accordance with this Privacy Policy.
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7. Opt Out |
7.1 Opting out Hakubuya Games Notifications
· User may opt out in any time in accordance with his/her sole discretion, clicking on the opt out link provided in all marketing mailings, by turning off notifications from mobile device or SNS settings or by sending an e-mail to hakubuya34@gmail.com without incurring any costs.
· If User wants to stop receiving promotional e-mails from Hakubuya Games, User may click on the “unsubscribe” link at the bottom of any promotional email from Hakubuya Games or may visit Email Settings page.
· Please note that if User opt ins or out of receiving marketing communications from Hakubuya Games, Hakubuya Games may still communicate with User from time to time that Hakubuya Games needs provide User with information about the Service that User using, if Hakubuya Games needs to request information from User with respect to a transaction initiated by User, or for other legitimate non-marketing reasons.
· If User wants to stop receiving push notifications, which are messages an app sends User via mobile device even when the app is not on, User can turn of push notifications by visiting his/her mobile device’s “Settings”. Many of the Services also offers the ability to turn off push notifications in the “Settings” section of related Services
7.2 Opting Out of Third-Party Behavioral Advertising
For the notification by personalized advertising from third-party partners, User can opt in or opt out of third-party customized advertising through the device Settings and other third-party opt-in or opt-out tools. If User does not want to receive tailored in-application advertisements from third parties that relate to his/her interests on his/her mobile device, User may adjust the ad tracking settings on his/her device (such as turning on Limit Ad Tracking). User can also reset the “Advertising Identifier” (such as an IDFA) from User’s mobile device’s settings which will prevent continued use of existing behavioral data tied to User’s previous “Advertising Identifier”. Further, depending on the platform provider (such as Apple or Google), User may be able to download apps that offer to provide User with control regarding the collection and use of cross-app data for tailored advertising. All the opt-in or opt-out tools described in this provision are provided by third parties, not by Hakubuya Games. Hakubuya Games does not control or operate these tools or the choices that advertisers and others provide through these tools.
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8. Protection and Retention of Personal Information |
8.1 In order to help ensure a secure and safe experience, Hakubuya Games is continuously developing and implementing administrative, technical and physical security measures to protect the Personal Information from unauthorized access or against loss, misuse or alteration. The Personal Information that User provide to Hakubuya Games is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such information, such as firewalls and data encryption.
8.2 If User has an account registered directly with Hakubuya Games, the credentials of such account is protected by the password created by the User itself. The protection of the password is on the shoulders of the User and user itself is liable for the unauthorized use of such password. User must not share such password and credentials and must keep its social network account information, including its social network account password, secure as well.
8.3 Hakubuya Games retains Personal Information if the account is active or as needed to provide User the Service. Hakubuya Games will take reasonable measures to delete Personal Information if User deletes its account. However, User acknowledges that Hakubuya Games may retain some information even after if User closes, have deleted, its account as necessary for legitimate business interests, such as to comply with legal obligations, resolve disputes.
8.4 The Personal Information is protected by protocols and procedures designed to ensure industry-standard security of such information, such as firewalls and data encryption. Yet Hakubuya Games cannot ensure or warrant the security of any information that User transmit to Hakubuya Games or through the Services.
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9. Policies with respect to Children |
Most of Hakubuya Games Services and games are not intended for children under the age of 13 and Hakubuya Games does not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use Hakubuya Games Services. Children are not permitted to use these Services, and Hakubuya Games does not collect any personal information from Children on purpose.
If the User is under 13 (or under 16 at some European Union Countries and territories) Hakubuya Games kindly ask from User not to send any data about oneself, including name, address, telephone number, or email address. If Hakubuya Games learns that personal data about a child under age 13 have been collected, such data will be deleted as quickly as possible.
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10. Revisions and Updates |
This Privacy Policy may be revised, amended, or promulgated upon the sole discretion of the Hakubuya Games. The latest version shall apply in each case. In order to be effective, Hakubuya Games does not need to notify User and such amendments shall become effective as of the publication date. Continuing the use of the Services shall be deemed as an acceptance to such revised terms.
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11. Contact |
If User have any questions and demands about the privacy practices or this Privacy Policy, User should contact Hakubuya Games’s data protection officer by email at hakubuya34@gmail.com. Hakubuya Games will be at User’s disposal in a timely and urgent manner.