PRIVACY POLICY

1. Introduction

As Libra, we aim to crate quality time for our users and connect our users all around the world with passion and fun. On our quest to provide a joyous and unforgettable experience to our users with our gamer focused, authentic and entertaining content, we collect and use some data from our users. Your privacy and security of your data is of utmost importance to Libra. Accordingly, we prepared this Privacy Policy (“Privacy Policy”) with the purpose to explain what kinds of data are collected and how they are collected while you are playing our games and mobile games, how these data are protected, how you can revoke your permission for the data to be collected and how you can contact us, within the framework of transparency principles.

2. Data Controller

Data controller is the natural or legal person who determines the purposes and means of processing personal data and who determines how and why the data processing activity is carried out. Under this Privacy Policy;

Data Controller: Libra Teknoloji Anonim Şirketi
Data Controller Address: Business İstanbul Merdivenköy, Merdivenköy Mah. Dikyol Sk. No: 10 Yumurtacı Abdi Bey Cad. 34732 Kadıköy Istanbul - Turkey

Should you have any questions or comments on this Privacy Policy you can contact us at [email protected]. In relation to your questions and demands for your data we advise you to contact us primarily in-game that way we can get back to you faster.

3. Scope of the Privacy Policy

This Privacy Policy is a part of Libra Terms of Service (shall be referred to as “Terms of Service” or “Agreement”). In the Privacy Policy the terms “Libra” and “us”, shall mean Libra Teknoloji Anonim Şirketi as the “Data Controller”.

The data processed by Libra in the course of its business including on Libra’s website, games, mobile games, social networking services, online or offline services it provides (including any and all current and future online and offline services provided by Libra shall be referred to as the (“Services”), is subject to this Privacy Policy.

BY CREATING AN ACCOUNT WITHIN THE SERVICES, USING OUR SERVICES OR OTHERWISE ACCESSING OUR SERVICES YOU GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS EXPLAINED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU MAY CHOOSE NOT TO DOWNLOAD / INSTALL / USE OUR SERVICES.

We may periodically update the Privacy Policy. When we make changes on the Privacy Policy, we will inform you by sending a notification through our Services. Your continued use of our Services after the changes shall mean that you accept the updates and changes and the updated Privacy Policy shall be effective.

4. Data We Collect and How We Collect It

As the users of Libra Services, when you interact with our Services, create an account in order to utilize our Services, or when you interact with us; your data may be collected and used by us, or automatically by third party service providers (Firebase Analytics, Fabric Analytics, Game Analytics, Adjust) and also passively by Advertisement networks.

Data About You That You Share with Us Directly:

When you create an account; in order for us to provide you with the Services and to fulfill our obligations under the Terms of Service;

Name and Surname

Username

Gender

E-mail address

User Password

Age or Birth Date

When you contact us; in order for us to fulfill our contractual obligations and in line with our legitimate interest;

E-mail address

Mail address
Other data which enables us to verify your identity and data which enables us to provide or improve the Services
Telephone number (only if made public and given to us by you, in accordance with its purpose)

Also, we may allow you to create a gamer profile which our other users can view. In order for us to perform our Services, your gamer profile may include the following data:

Profile Picture

Name and Surname

Username

Gender

Biographical data (age or age range)

Links to your profile on different social networks (such as Facebook, Twitter etc.)

We do not collect or store special categories of your personal data

Personal data relating to health, sexual life, biometric and genetic data, membership to associations, foundations or trade-unions, race, ethnic origin, convictions and security measures, political opinion, philosophical belief, religion, sect or other beliefs, clothing are deemed to be personal data of special nature, and we do not collect or store these data. Please do not send us or send/share over our Services any of your personal data of special nature.

Cookies and Other Automated Data Collection:

We, our service providers and our business partners use cookies and other similar technologies in order to collect and analyze certain technical data below in line with our legitimate interest through third party analytics and advertisement providers on the purpose of providing our Services to you.

IP address

The type of computer or mobile device you are using

Platform type (like Apple iOS or Android)

Operating system version

Mobile device identifiers such as MAC address, Apple Identifier for Advertising (IDFA) and/or Android Advertising ID (AAID)

Application performance and de-bugging data

Browser type and language

Referring pages and exit pages and URLs

The number of clicks on an application feature or a web page

The amount of time spent on an application feature or web page

Viewed pages and the order of these pages

Game state and the date and time of activity on our Services

In case you play the Libra games on a mobile device, we may collect the below data in line with our legitimate interests:

The name that you have associated with your device

Your country
Your geographical location data (with your permission and consent)
Your telephone number (only if made public and given to us by you, in accordance with its purpose)

If you choose or allow to connect your gamer profile with your profiles on social networks such as Facebook, your Facebook profile picture and Facebook account name will be visible to us and to other users. You can activate or deactivate these settings directly through our Services. Your interaction with these features is subject to the privacy policy of the companies who provide the relevant features, therefore if you choose to use such features please read the privacy policies of such companies.
While accessing data requiring your consent, in order to obtain your consent, your consent is requested via notifications special to the operating systems. Where you do not give your consent, we do not collect or store such data.

5. How and Why We Use the Data We Collect

We use the data we collect for the limited purposes below and in accordance with the legal grounds, in order to perform the Agreement we executed with you, for our legitimate interests, to protect you and Libra’s rights, to use your or Libra’s rights, to fulfill our legal obligations.

We process the data necessary for the purposes below and to perform our Agreement and our Services and to fulfill our legal obligations:

To create accounts, to allow you to use our Services and to manage the Services,
To verify and process the purchases you make in relation to our Services,
To provide and deliver the Services you request,
To send you notifications related to the Services,
To make the Services more suitable for our users,

In order to provide excellent Services to our users we, in our legitimate interest, collect and process the necessary data to:

Protect the safety and well-being of our users,
Manage our relationship with our users and to provide support to our users,
Measure and analyze the use of our Services,
Enhance and develop our Services and the user experience,
Detect and repair possible errors in our Services,
Provide software updates,
Provide the Services on mobile devices,
Protect the rights and properties of Libra in relation with our Services,
Conduct research in order to improve and provide our Services,
Operate, improve, personalize and optimize our Services and the user experiences, including their experience using analytics
Provide and manage advertisements to our users in order to be able to finance and keep providing our Services to our users in line with our legitimate interest.

We may process data for the purposes below based on your consent:

To provide location-based experiences by obtaining your consent before processing,
To send you push notifications related to our Services by primarily obtaining your consent.

You may at any time enable and/or disable the push notifications and geographical information at the device level through its settings.

6. Whom Do We Share Data With

Limited to the events below and for the purposes explained under the section 5 we may share your data with third parties or we may allow third parties to access certain data through our Services as explained below.

Data Shared with Your Friends and Other Libra Players

In some of Libra games, if you choose to play through a social networking channel or if you connect through a social network (i.e. Facebook), your friends playing the game who are on such social networks may view your name, picture, gamer profile and your in-game activities.

Additionally, in some Libra games other player may view your gamer profile (as described above) regardless of whether they are your social network friends or not; and they may view your in-game activities, may contact your within the Services and may send you friend or play requests through the relevant social network or through our Services.

Data Shared with Third Parties for Third Party Advertisements Including Behavioral Advertisement and Analytics

We provide advertisement supported services in order to be able to provide our services free of charge to our users. 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 to provide virtual currency or 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. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Libra

Under chapter “13. Third Party Service Providers” you may find a list of who these third party service providers are where it is explained how you may utilize your opt-out right. These service providers process your data in line with their own privacy policies, and we urge you to review the relevant privacy policies.

We do not actively share personal information that directly identifies you with third-party advertisers for their direct marketing purposes unless you give us your consent.

For the explained purposes, when you use our Services, third party service providers may collect, or we may share with them the below data:

Performance data (such as the number of clicks on an advertisement),
Certain technical data (IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID),
Unique identifiers such as your social network ID or Libra gamer ID, and/or,
Contextual data regarding your game (such as your level and session length)

In addition to serving you with relevant advertisements, the data collected may be used to:

Measure how effective advertisements are,
Offer you targeted advertising (both on and off our Services) in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or,
Undertake web analytics to analyze traffic and other player activity to improve your experience

Advertisers or ad networks may collect this data using cookies and other similar tracking technologies, and they may use a single tracking technology or multiple tracking technologies at the same time.

Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Libra or the social network through which you are playing Libra’s games.

Data Shared with Third Party Payments Processors

We may sell some virtual merchandise, virtual items, or benefits through our Services. When you play Libra games or connect to any of our Services through third party applications or platforms (such as Facebook, Apple, Google or Amazon), all the purchases you make shall be processed through third party applications such as Apple App Store and Google Play App Store and shall be subject to third party terms of service and privacy policies. During such payment processes Libra does not collect, store, or use any of your financial data. Libra does not collect your financial data for such purchases but may collect your non-financial data such as your name, approximate physical location, or the virtual items you have purchased. The data collected by Libra depends on the Libra game you are playing and the third party application.

Data Shared in order for us to Maintain Your Security, Our Security and to Fulfill our Legal Obligations

Your personal data may be shared with official authorities, law enforcement, state organs/institutions, third party legal consultants within the framework of good faith in order to enforce our Terms of Service and Privacy Policy, enforce the law, abide by the enforcement of the court decisions and subpoenas, answer your requests for the protection of your safety, collect our fees for our Services and to prevent fraud or perpetration.

7. Where Do We Keep Data and International Transfer of Data

Libra keeps a large portion of the data collected within the scope of this Privacy Policy as explained above and for the explained purposes and legal grounds at the local servers in Turkey and a portion of the data at the servers of our service providers (namely Firebase Realtime Database and Playfab Azure) located in United States of America and the European Union Region where a sufficient protection of your personal data is provided for hosting purposes. Accordingly, in the international transfer of your data we ensure that your data is lawfully transferred with high level security precautions as explained in the Privacy Policy. If you are accessing our Services outside of Turkey, European Union or United States of America, by opting to use our Services or otherwise opting to share data with us, you give consent to the transfer and processing of your data to Turkey, European Union or United States of America. Please do not forget that data protection laws may vary from country to country and may differ from the rules applicable to where your data is transferred to. You may share any and all your questions regarding the international transfer of your data using the communication channels indicated under the section “12. Contact Us”.

For our users accessing our Services from outside of Turkey, we would like to state that our Privacy Policy and Terms of Service and all possible disputes in relation to them are subject to the laws of Republic of Turkey.

8. For How Long Do We Keep Data and How We Protect It

We keep your data in line with the purposes explained under this Privacy Policy and to be able to realize the purposes, for as long as necessary to provide our Services to our users, to maintain our business operations in line with our legitimate interests, to protect and exercise our rights.

When data keeping purposes cease to exist and/or our necessity to keep data disappears for other legal reasons, we irrevocably delete the data from our systems or irrevocably anonymize it in a way that they can no longer be associated with our users.

Moreover, we keep data in relation to our Services or your account/gamer profile as long as your account is active. In case you delete your account, we delete the relevant data from our systems. However keep in mind that in such cases we may keep data necessary for us to perform our legal obligations, achieve our legitimate business interests, to exercise our rights or for dispute resolution purposes, for as long as necessary to achieve these purposes and legal reasons.

Security of your data is important to Libra. We take the necessary safety precautions to prevent unauthorized access to your data when we collect it. Your data is kept on safe servers in an encrypted way and in line with the industry standards. No electronic storage method or data transfer through the internet can be guaranteed to be 100% secure, however, Libra follows the industry standards for data security and takes all the reasonable physical and/or electronic measures. It should also be noted that data collected by third parties may not provide the same level of protection as Libra and Libra assumes no responsibility for the safety of the data collected by third parties.

9. Age Restrictions – Privacy of Children

The Services Libra provides are not directed towards children under 13 (under 16 for children located in the European Economic Area and under 14 for children located in South Korea) and we do not collect or demand data from anyone under 13. If you are under 13 please do not send us any of your data including your name, address, phone number, e-mail address. In case we realize that we collected data from a child under 13 without his parent’s/guardian’s consent, we delete such data as soon as possible. We may only process the data of children under 13 if there is a consent of his parent/guardian for the use of our Services. If you are a parent/guardian of a child under 13 please contact us through [email protected] and if you want your child to use our Services, provide us your consent. You may exercise your child’s rights in relation to his data and revoke your consent using the same channel.

10. California (USA) Notice

Pursuant to the California Consumer Privacy Act effective as of 1 January 2020 those who reside in California State in United States of America may use their additional rights with regards to their personal data. Such additional rights are as below;

Request information on the personal data we have collected of you during the last 12 months,
Request a list of the personal data we have collected of you during the last 12 months,
Demand the deletion of the personal data we have collected about you.

You may exercise such rights by contacting us at [email protected].

We do not sell personal data to third parties. Data we transfer to third parties is limited to solely as explained in this Privacy Policy.

11. Your Rights

Pursuant to the Article 11 of the Law on the Protection of Personal Data numbered 6698 (“Law”) you have the rights below as the data subject;

To learn whether your personal data have been processed or not,
To request information in relation to it if your personal data have been processed,
To learn the processing purposes of your data and to learn whether your data is used,
To know the third persons to whom your personal data is transferred at home or abroad,
To request the rectification of the incomplete or inaccurate data, if any,
To request the erasure or destruction of your personal data under the conditions set out under the Article 7 of the Law,
To request notification of the operations carried out as per the paragraphs (d) and (e) to third parties whom your personal data has been transferred to,
To object to the processing, exclusively by automatic means, of your personal data, which leads to an unfavorable consequence for the data subject,
To request compensation for the damages arising out of the unlawful processing of your personal data.

In cases where we process your personal data based on your consent, you always have the right to withdraw your consent. You may exercise the above listed rights by contacting us using the information provided under the section “12. Contact Us” of this Privacy Policy.

Libra, depending on the nature of your request, finalizes your requests as soon as possible within 30 days at the latest. However, if such requests necessitate additional expenditure, additional fees may be requested. Libra might accept your request or deny it with justification; and submits its response electronically or in writing. Upon acceptance of your request, the Company does what is necessary. In case your request is denied, or the answer was found inadequate or your request was not answered within the time limit you have the right to file a complaint to data authorities.

12. Contact Us

By Email: [email protected]
By Mail: Business İstanbul Merdivenköy, Merdivenköy Mah. Dikyol Sk. No: 10 Yumurtacı Abdi Bey Cad. 34732 Kadıköy İstanbul - Turkey

13. Our Third Party Service Providers

You may find below a list of the third parties we work with for the advertisement and analytics services under our Services, along with links to their privacy policies and links to their opt-out explanations. Libra is not responsible for the privacy policies of such third parties.

Analytics Services: