We are Bigger Oyun Yazilim ve Pazarlama A.S, (referred to as Bigger Games, we, us and our in this Privacy Policy), a company incorporated in Turkey with company tax number tax 1680978598 and whose registered office address is Esentepe Mah. Büyükdere Cad. Apa Giz Plaza No:191 Sisli/Istanbul.
The information set out in this Privacy Policy is provided to individuals whose personal data we process (you or your) as data controller, in compliance with our obligations under the Data Protection Act 2018, the UK GDPR (as defined in the as defined in the Data Protection, Privacy and Electronic Communications Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations SI 2019/419) and the EU GDPR (Regulation 2016/679) (together the GDPR).
Data controller details
1
How we collect your information
2
Information we collect, purpose and legal basis for processing
2
Sharing your information
5
International transfers
5
Retention of personal data
6
Your rights in respect of your personal data
6
Automatic decision making
7
Use by minors
7
Security
8
Changes to this Privacy Policy
8
1.1. We are the data controller in relation to the processing of the personal information that you provide to us. Our contact details are as follows:
1.1.1 Address: Esentepe Mah. Büyükdere Cad. Apa Giz Plaza No:191 Sisli/Istanbul.
1.1.2 Email address: info@biggergames.com (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).
2.1. Generally, the information we hold about you comes from the way that you engage with us, for example by doing any of the following:
2.1.1 through engaging with us via our website or applications and/or by accessing one of our games (together the Site);
2.1.2 providing us with information in the course of subscribing with us or any newsletters we may operate from time to time (if you are an artist, client or visitor of our Site);
2.1.3 contacting us offline, for example by telephone, SMS, email or by post; and
2.1.4 interacting with us using social media.
2.2. We may also collect data from third-party companies who have obtained your consent or have another legal right to share such personal data with us (including advertising platforms, partners and data aggregators who have obtained it).
3.1. We have set out below the types that we may collect, use, store and transfer about you, together with the purpose and legal grounds for processing.
3.2. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4.1. Please note that personal information we are holding about you may be shared with and processed by:
4.1.1. any member of our group, which includes without limitation our subsidiaries, our ultimate holding company and its subsidiaries;
4.1.2. our service providers and agents (including their subcontractors) or third parties which process information on our behalf (e.g. internet service and data storage and security platform providers, analytics and search engine providers that assist us in the improvement and optimisation of the services; our bank, payment processing providers and those organisations we engage to help us send communications to you) e.g. AWS, Google and Firebase, so that they may help us to provide you with the applications, products, services and information you have requested;
4.1.3. application stores such as the Apple App or Google Play Store, for example where you make in-app purchases through one our games;
4.1.4. with your consent, third-party ad networks and advertising partners to deliver advertising and personalised content on our Site and within our games (as further detailed above and within our Cookie Policy [include hyperlink]);
4.1.5. regulators, fraud prevention agencies or other third parties for the purposes of monitoring and/or enforcing our compliance with any legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
4.1.6. any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
4.1.7. other parties and/or their professional advisers involved in a matter where required as part of the conduct of the services;
4.1.8. our own professional advisers and auditors for the purpose of seeking professional advice or to meet our audit responsibilities; and
4.1.9. another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets (provided that adequate protections and safeguards are in place).
4.2. Please note that we may include links within our site to third party social media providers such as Facebook and Twitter, but we will not share your information with such providers without your consent.
4.3. If you follow a link from our Site to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites.
We will not transfer personal data relating to you to a country which is outside the UK and EEA unless:
5.1. the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;
5.2. appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the approved Standard Model Clauses for transfers of personal data outside the UK); or
5.3. one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary):
5.3.1. the transfer is necessary to perform, or to form, a contract to which we are a party:
5.3.1.1. with you; or
5.3.1.2. with a third party where the contract is in your interests;
5.3.2. the transfer is necessary for the establishment, exercise or defence of legal claims;
5.3.3. you have provided your explicit consent to the transfer; or
5.3.4. the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.
6.1. We have systems in place to periodically review and delete data that is no longer being used by us for the purposes set out in this Privacy Policy. Unless we are required or permitted by law to hold on to your data for a specific retention period, we will only hold your personal information within our systems as long as you have an account with us or for a period of [12] months since your last interaction with us (whichever is longer).
6.2. Where we no longer need your personal information, we will dispose of it in a secure manner.
6.3. In some circumstances you can ask us to delete your data: see your legal rights at paragraph 7 below for further information.
6.4. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
7.1. You have certain rights under existing data protection laws, including the right to (upon written request) access a copy of your personal data that we are processing. In accordance with the Data Protection Act 2018 and the GDPR:
7.1.1. you will have the following rights:
7.1.1.1. right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs); and
7.1.1.2. right to access: right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete; and
7.1.2. in certain circumstances, you will also have the following rights:
7.1.2.1. right to erasure/“right to be forgotten”: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems where the personal data is no longer necessary in relation to the purpose for which it was collected (however, this will not apply in certain circumstances e.g. if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
7.1.2.2. right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it for example where the personal information we are holding is inaccurate;
7.1.2.3. right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
7.1.2.4. right to object: the right to object to our use of your personal information, including where we use it for our legitimate interests or for marketing/profiling purposes.
7.2. If you have subscribed to marketing communications from us, you have the right to unsubscribe from such communications at any time by following the link in the footer of the last email you received from one of our brands or by sending your request with detailed instructions to us (see contact details above).
7.3. Please note that if you withdraw your consent to the use of your personal information for purposes set out in our Privacy Policy, we may not be able to provide you with access to all or certain parts of our site.
7.4. If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk.
We do not make decisions based solely on automated data processing, including profiling.
9.1. We do not intend to or knowingly collect personal data from children. We use the term "children" to refer to someone who is (a) under 13 years old or, if older (b) between 13 and 17 years old but under the age at which they can give valid consent to the processing of their personal data under applicable local or regional laws.
9.2. When you access and use our services or games, we may ask you to confirm your age to us or your age may otherwise become known to us. If we discover that you are a minor or do not meet an age threshold that we apply, we may take steps to suspend, limit, or terminate your access to the Site or the services where we believe that to be necessary due to applicable regulatory or platform requirements.
9.3. If a child has provided personal data to us, we encourage the child's parent or guardian to contact us at: info@biggergames.com to request that we remove the personal data from our systems.
10.1. We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:
10.1.1. where appropriate, data is encrypted when transiting on our system or stored on our databases;
10.1.2. we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and
10.1.3. we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.
10.2. However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection. It is important that all details of any username, password and/or other identification information created to access our servers are kept confidential by you and should not be disclosed to or shared with anyone.
We may amend this Privacy Policy from time to time, for example to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always update this Privacy Policy on our site, so please try to read it when you visit the site (the “last updated” reference tells you when we last updated our Privacy Policy).