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PRIVACY POLICY

 

Effective Date: December 11, 2022

 

  1. Introduction

 

As Lost CTRL Dijital Eglence ve Teknoloji A.S. (“Lost CTRL” or “we”, “us”) we design, develop, and publish mobile games we’re passionate about. In accordance with the laws of the nations in which we conduct business, we attempt to clearly explain how and why we collect, retain, disclose, and utilize your personal data in this Privacy Policy. Any information that relates to a named, identifiable, and living individual is referred to as “personal data” in this Policy.

 

This privacy policy is applicable to all Lost CTRL websites, mobile applications, forums, blogs of every sort, and any other online or offline services that Lost CTRL offers. It also applies to all marketing and advertising campaigns we run across all platforms, as well as any additional services we might occasionally offer you. Our games, websites, marketing and advertising activities, and other services are collectively referred to as “Services” in this policy.

 

Once you download our mobile application, access and/or play our games, or interact with our websites or other Services, your personal data will be handled in accordance with this privacy policy in order to deliver the Services. You shouldn’t use our games or other services if you have any additional worries about supplying information to us or about it being handled as specified in this Privacy Policy. This policy is meant to comply with international laws, including those in North America, Europe, Turkey, the Asia-Pacific region, and other nations.



  1. Gathering of Your Personal Information

 

We may get personal information directly from you or from other third parties that have your consent or another legal basis to share it with us (including advertising platforms and partners and data aggregators who have obtained). This may include details about you, other games and services you use, demographic data, and information about your geographical region. Your personal information will be used in accordance with this privacy policy.



2.1 Personal Information Obtained Directly from You

 

By downloading, accessing, and/or playing our games or using our other Services, you authorize Lost CTRL to process your personal data in order to deliver the Services. The majority of this information is provided by you or your device directly, including your unique device ID (persistent or non-persistent), your device’s operating system, version, model, CPU, amount of RAM and disk space, hardware type, Identifier For Advertising (IDFA), advertising ID, the version of your operating system (“OS”), your device name, game center ID, and your location determined by your Internet Protocol address (“IP”). We use this information to deliver our games and Services to you, including for optimization, in-game offer customization, and purchase verification. We might also use it for the additional reasons listed in this policy.

 

The following sorts of information may be collected and processed by us depending on which of our Services you use:

 

Information about how and when you play our games or visit our website(s), what device you use to access our games and Services, or information about profile visits; your interactions with us on our social media channels are just a few examples of the information we may collect about how you use and interact with our games, advertising, and other Services.

 

The personal information we get about you when you play our games will remain anonymous if you decide not to create a Lost CTRL profile by linking your Facebook account, but we will still gather device-level identifiers and data related to those identifiers, such as:

 

identifiers like your IP address, device identifiers, ad identifiers, a Lost CTRL-player ID, the country or region you are playing in, and the type of device(s) you use to play our games or access our Services, as well as information about how you use our websites and play our games (such as level start, level end, session start, booster use, spending, rewards, your progress through the games, session time and duration, number of attempts at each level and purchases made).



Delivering and Improving Our Services

We utilize your personal information to make it possible for us to offer you access to our websites, advertising, and other Services and to optimize them all for both you and the rest of our players. In order to ensure that our websites function effectively on all platforms and are as pleasurable as possible for all of our players, this will include the use and analysis of aggregated data.



Client Services

We utilize your personal information, including information you directly give us in communications, to assist you when you need it through our customer service channels. We may also use it to get in touch with you, such as when providing customer support or updating you on our services and games. To administer your account and connection with us, as well as to enhance your usage of our Services, we will use your data.



Reviews

You might occasionally remark on our games and add details, possibly including personal information. You freely provide us with all personal information we acquire from your involvement in these reviews. We may use such personal data in ways that are compliant with the guidelines set forth in this document in order to improve our services, websites, and/or products.



Research and Analytics

To learn more about how you use our services or play our games, we use analytics tools, some of which may come from third parties. These tools might make use of cookies or other tracking mechanisms. Your information might be used by us for research or surveys.

 

Prevention of Fraud, Crime, and Cheating

To stop fraud, theft, and other crimes, we may use the personal information we have on file. Your information could also need to be given to law enforcement officials, fraud prevention organizations, and other groups engaged in crime and fraud prevention.



Uses for Legal Purposes

As needed or permitted by any applicable law, we may use your data.

 

Visiting Our Website

When you visit our website, lostctrl.com, (“Website”), we gather and use the personal information listed below about you.

 

Any information you give us when you contact us using our website.

 

2.2 Personal Information Obtained from Outside Sources

 

As was already noted, the majority of the data we gather about you comes from you when you use our games, websites, advertisements, or other services. However, we also collect information from third parties that you permit to access your personal information (such as when you download our mobile applications through the App Store or Google Store or when you link your Facebook account to mobile applications).



Facebook Account Connection

We will obtain some of your Facebook account information when you check in to your Lost CTRL profile using your Facebook login credentials. Your basic Facebook account information will be immediately linked to your Lost CTRL profile if you decide to play our games online. We specifically obtain your name, Facebook ID, and profile picture. By doing this, you will be able to log in with your account from several devices and sync your progress between them. You can utilize other features we make accessible in our games and other Services, like asking others to play, as well as view which of your friends are currently using the same game and their progress through it (and they can see you and your progress).

 

Along with the names and avatars of your Facebook friends who have previously downloaded our games, we will also gather the email address linked to your Facebook account. When you first link your Facebook account to your Lost CTRL profile, you have the option of denying us access to your email address in the Facebook dialog box.

 

By logging in with Facebook, you don’t allow us to post anything on your page without your consent and from learning which of your Facebook friends don’t play our game. You can prevent this by disabling Facebook while playing our game and changing your app permissions in your Facebook settings if you don’t want your Facebook friends to be able to see you and your game progress.

 

To make sure you completely understand how your Facebook data is shared, we advise you to read Facebook’s Privacy Policy (https://www.facebook.com/privacy/explanation) and periodically review your privacy settings.



Installing Our Games through the Google Play Store and the App Store

The information associated with your credit card or bank account is not accessible to Lost CTRL when you install or buy products associated with our mobile apps (such as those you can buy or download via the App Store or Google Store). However, the aforementioned third-party payment processors could divulge to us non-financial information about your purchases, such as the goods bought to complete your order. The privacy options on pertinent third-party applications will determine the personal data that is obtained from the third-party businesses.




  1. Reasons for Processing Your Personal Information

 

We gather and utilize your personal information for the following reasons:

 

to help us deliver our games, make sure your purchases are fulfilled in them, and offer you player assistance if you need it; to help us adapt our games for you and your device and to present in-game events, deals, and promotions that are appropriate for you;

To operate, enhance, and optimize our games and other Services; for the additional reasons detailed in this Privacy Policy, such as marketing and advertising;

 

to offer access to specific regions, capabilities, and features of our services; to personalize our services, comprehend our users and their preferences to better user experience and satisfaction with our services;

to give you relevant information, such as confirmations, technical notices, updates, security alerts, support and administrative messages; to advise you about in-game updates, new items, or promotional offers;

to allow players to engage with one another in-game or through our social media accounts; to answer your questions and comments; and to offer customer assistance;

 

to measure interest in our Services, to ensure internal quality control, to enable us to comply with laws that apply to us, to prevent fraud, to ensure adherence to our terms of service, or when necessary to defend, exercise, or establish our legal rights, including those under our Terms of Service (https://www.lostctrl.com/terms-conditions/). This includes when it becomes necessary to enforce our Terms of Service.

to get in touch with you as part of our hiring procedures; as otherwise clearly stated in this privacy statement; or as otherwise required by law.




  1. Marketing

 

Based on your interests, we and our third-party partners send you marketing communications about our mobile applications and associated Services using the personal information we’ve gathered about you. For instance, we might display advertisements on third party websites and apps or within our own Services.

 

We might employ the data we have on you in a variety of ways to advertise Lost CTRL’s services. This could incorporate:

 

advertising on third-party websites and applications; providing you with personalized promotions for our services in the game you play; and providing you with in-game promotions and discounts for the services and games of Lost CTRL.



4.1 What data do we use in marketing?

 

We aim to ensure that you only see marketing from us that might be of interest to you by using information about you. Utilizing data that we may already have about you, such as:

 

The games you play and information about how you interact with our games and Services, your country or region, and other information that we might obtain from our third-party marketing partners or other third parties who have obtained your consent or have another legal right to share that information with us, ad identifiers and other non-personal data collected from your device.



4.2 Marketing Partners

 

We may share information we have gathered about you with such third parties for these purposes when we employ various third-party marketing partners to assist us on our behalf when marketing our games in media produced by other businesses.

 

By combining this information with data they have already gathered about you, our marketing partners may be able to assist us in serving adverts to you. When you use their services, as well as those of other companies’ websites and services, they get this information. This information is used by our partners to guess what sorts of advertisements you would want to see. While you are using other websites and services, they may show you an advertisement for Lost CTRL if they think you would find it interesting to view one.

 

You can send us an opt-out request by emailing if you would rather your personal information not be used to provide interest-based advertisements. You should be aware that even if you choose not to receive targeted or interest-based advertising, you may still see advertisements for Lost CTRL products. However, these ads won’t be based on the information you personally provide.

 

Your personal information will be used for our marketing partners to collect and use information about you to improve advertising, targeting, and measurement systems in accordance with their privacy policies if you accept this privacy policy, download or continue playing our games, and unless you opt out of interest-based advertising as described in this section.

 

Your data will not be subject to this Privacy Policy if it is collected by one of our marketing partners. For further details, we advise you to consult the privacy policies of our partners.




4.3 Third-Party Use of Cookies

 

Cookies and other similar technologies may be used by service providers working on our behalf to automatically gather data through the Services. Cookies are tiny text files that are installed in users’ web browsers to store preferences. When using our website or services, cookies from these service providers may be placed on your device. Service providers will utilize cookies related to the Website for the following purposes:

 

Operationally Necessary Cookies may be used to maintain the Website’s functionality.

The effectiveness of our website may be evaluated using performance-related cookies, including as a part of research into how users interact with our websites.

When accessing or using our website, functionality-related cookies may be utilized to provide functionality.

You can limit the kinds of cookies you allow or have your web browser notify you when someone tries to put one on your machine. Flash Cookies function differently than browser cookies, and flash cookies might not be erasable with cookie management tools found in web browsers.



Please be aware that as cookies are required to track and improve your activities, if you disable them, you might lose access to some of the features and functionality of our Services.



  1. Advertising IDs, SDKs and similar technologies

 

To deliver games, websites and interest-based advertising, we use advertising IDs, SDKs and similar technologies. This section describes our use of these technologies.

 

We use advertising ID and similar technologies to provide our services to you and to collect data from your device. These technologies enable us and our third-party advertising partners:



To recognize you and your device;

provides you with interest-based advertisements;

allow our Services to interact with third-party social networks or platforms (if you have chosen to allow such interaction);

allows us and third parties to provide you with more personalized services, such as providing our Services in the appropriate language.

 

5.1 How do advertising identifiers and similar technologies work?

 

Advertising IDs are non-permanent, non-personal identifiers, such as your Android advertising ID and/or Apple advertising ID, that are uniquely associated with your device. Similar technologies include pixel tracking in advertising. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and apps.



5.2 How to opt out of interest-based advertising on your device and on Facebook, or you can reset the advertising ID on your device by changing your device settings. Settings vary from device to device but you will usually find the ad identifier settings under “privacy” or “ads” in your device’s settings.

 

Opting out of Facebook advertising:

To update your advertising preferences with Facebook, you will need to log in to your account on Facebook and update your settings there.





  1. Your Rights

 

You have certain rights over your personal data and how we process it. You may exercise these rights at any time by contacting us using one of the methods described in the Contact Us section below.

 

These rights include:



Accessing personal data:

You have the right to access your personal data that Lost CTRL uses.

Edit or delete personal data:

You have the right to request that Lost CTRL correct or complete your personal data if it is inaccurate or incomplete by sending an email to . You may also have the right to request that Lost CTRL delete your personal data, where certain conditions apply, by sending an email to .

Deactivate the account:

If you want to deactivate your account completely, unlink your Facebook account from our mobile games and remove our games from your mobile device. Please note that if you deactivate your account completely, all your progress in our games and any unused virtual items will be lost and we will not be able to restore them in the future. future.

Restrictions on processing personal data:

You may have the right to request that Lost CTRL restrict the use of your personal data, where certain conditions apply.

Objection to the processing of personal data:

You may have the right to object to Lost CTRL’s use of your personal data, where certain conditions apply. Portability of personal data:

You may have the right to receive your personal data in a structured and commonly used format so that you may use it with another company, where certain conditions apply.

Right of withdrawal (California, USA):

California residents have the right to opt-out of the sale of personal data, determined in a way that may include transferring the data to third parties to personalize advertising for you. If you refuse to “sell” your data, we won’t sell your data, including to our advertising partners, but you may still see ads in the game and some partners. Our site may serve ads to you, subject to the information they allow them to retain.

There are other ways to control the personal data we collect about you. For example, you can disconnect your Facebook or other social network account from our game or remove our game from your mobile device. You can also reset your mobile advertising ID or limit ad tracking entirely using your phone settings.

 

From time to time, we may send you push notifications through our mobile applications with game updates, high scores and other notifications that may be of interest to you. You can opt out of receiving these types of communications at any time by changing the settings on your mobile device.



  1. Children

 

You must be over 13 years old to play the game and use our Services. We do not knowingly and knowingly collect personal data from anyone under the age of 13. However, if the Service used by the person violates this Privacy Policy, we may collect personal data from that person. If you believe that we may have any information from or about a child under the age of 13 (or under the age of 16 in certain jurisdictions of European Union countries and/or counties), please contact us.




  1. Disclosure of your personal data

 

We may share your information as described in this Privacy Policy (to provide the Services with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) as part of our services described in this privacy policy. .

 

Service providers. We may share your personal data with our service providers. The types of service providers (data processors) we work with include companies that provide (i) IT and related services; (ii) provide the information and services you request; (iii) customer service activities; (iv) search engine and analytics activities that help us improve and optimize the Services; and (v) any support activities related to our Services. Lost CTRL has executed appropriate contracts with the service providers that prohibit them from using or sharing personal data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

Disclosures to Protect Rights of Us, You or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your personal data, other account information and content if we believe doing so is required or appropriate:

(i) to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) to respond to your requests; (iii) to protect yours, ours or others’ rights, property or safety; (iv) to enforce Lost CTRL’ policies or contracts; (v) to collect amounts owed to Lost CTRL; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes (e.g., to detect unauthorized activity on the Services). In such cases, server log data containing IP addresses may be shared with law enforcement bodies, so they may identify users in connection with their investigation of the unauthorized activities. Sell ​​assets and change control. If there is a sale of Lost CTRL assets or a corporate reorganization or after a change of control in the share structure of Lost CTRL or in preparation for any of these events. Any third party to whom a lost CTRL transfers or sells a lost CTRL asset will have the right to continue to use the personal and other information you provide to us in the manner set forth in the Rights Policy. this privacy.




  1. International transfer

 

All personal data collected or stored by Lost CTRL may be stored anywhere in the world, including but not limited to the Republic of Turkey, the United States of America, the European Union, the cloud, on our servers and on the servers of our service providers. When we transfer your personal data internationally, we will take reasonable steps to ensure that it is processed securely, legally and in the manner described herein. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to places where your personal information is transferred or stored, used or otherwise processed may differ. with the privacy laws that apply to your place of residence.

 

By providing us with your personal data, you consent to the storage of your personal data in the aforementioned locations. If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that you consent to the transfer of your personal data to Turkey. United States and the United States and the processing of your data globally.

 

By choosing to visit the Website, use the Services, or provide information to us, you agree that any dispute regarding privacy or the terms of this Privacy Policy will be governed by the laws of the Republic of Turkey and the arbitration of any dispute arising in connection with Lost CTRL or the Website will be subject to the Terms of Use.




  1. Security

 

Personal data you provide to Lost CTRL is stored on servers located in secure facilities and uses industry standard security for such data, including firewalls and data encryption for assurance purposes. protected by protocols and procedures designed to maintain However, no server, computer, communications network or system, or data transmission over the Internet is guaranteed to be 100% secure. Therefore, while Lost CTRL strives to protect your personal information, we cannot ensure or warrant the security of any personal information you transmit to Lost CTRL or through the Service.

 

By using the Service or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues related to your use of the Service. You agree to If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you.



  1. Legal Bases (for European Economic Area users)

 

If you are an individual in the European Economic Area (EEA), we collect and process personal data about you only where we have legal bases for doing so under applicable EU laws. The legal bases which we rely upon are the following:



Contractual Necessity.This covers data used by us in order to provide you with Services that you have requested – and that we have agreed – to provide to you, such as our games, customer services, chat functionality and third-party social network connectivity;

Legal Obligation.This covers data used by us to comply with a legal obligation, such as to maintain records relating to tax or to respond to a valid legal request for certain data;

Legitimate Interests.This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as marketing, advertising, analytics, research and optimization of our games and other Services; and

This is used as a legal basis in the following contexts:

the collection of data stored on your device by us and our advertising partners, including device information, ad identifiers, IP address, country and region. You consent to this collection when you agree to install our game and you can withdraw your consent to this by uninstalling our games.

This Privacy Policy explains how you can object to certain types of processing we carry out, and where processing is based on your consent, that you can withdraw that consent at any time in the manner described in this Privacy Policy. I’m explaining. Nevertheless, if you play our games, we collect and process some personal information about you, as described separately in this Privacy Policy. If you do not want us to collect your information, please stop playing our games and using our services.





  1. Retaining Information

 

We keep your information for as long as your account is open or as long as it’s necessary to give you the Service.

 

Please take note that even if you request that we delete your personal information, we may still need to keep it in order to pursue our legitimate business interests, such as meeting our legal requirements, resolving legal disputes, and upholding our agreements.



  1. Updates to this Privacy Statement

 

Periodically, we might amend our privacy statement. When we do, we’ll post the revised privacy statement here. Any new policy will go into effect the day after we post it.



  1. Get in Touch

 

To interact with us and/or exercise your rights as described in this privacy statement, please get in touch with us at: