Privacy Policy

Wodo PRIVACY POLICY

1. Introduction

We, as Wodo Teknoloji A.Ş. (Wodo), which is a technology company that designs and develops games, help third-party development companies to integrate to our system and publish them on our platform. With this Privacy Policy, we intend to explain our online and offline information practices, the kinds of information we may collect, how we intend to use, process, store, protect, disclose, and share that information, and how you can opt-out of a use or correct or change such information.

This Privacy Policy applies to websites, mobile applications, forums, and every kind of blogs of Wodo and any other online or offline services provided by Wodo. It also applies to our marketing and advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our games and websites and other services collectively as our “Services”.

By using our website, accessing and/or playing our games, or interacting with our platform or other Services; or somehow communicating with Wodo, Wodo may collect information about you in accordance with the nature of the information and transaction within the current technical possibilities. You accept, acknowledge, and promise that your personal information and data might be used in limited manner by Wodo and/or through Wodo to the extent that it is limited to the format and purposes set forth in this Privacy Policy. If you have any other concerns about providing data to us or it being used as described in this Privacy Policy, you should not use our games or other Services.

Every type of information related to an identified or identifiable natural person constitutes personal data. Processing your personal data signifies all types of transactions performed on the data such as obtaining, recording, storing, preserving, altering, re-arranging, disclosing, transferring, acquiring, making accessible, alignment and preventing access.

Please note that Wodo is not responsible for the actions of Platforms (defined below), the content of their sites, the use of information you provide to them or any services they may offer.

Wodo reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

2. The Identity of the Data Controller ,

The data controller is Wodo Teknoloji A.Ş.

3. How We Collect Your Personal Data

We may collect personal data automatically whenever you download or use or Services to your device, whenever you send us your feedback or convey your information or support requests directly to Wodo, Apple App Store and Google Play App Store (Referred to as “Platforms” together) platforms and the business partners or other third-party companies who have obtained your consent or have another legal right to share such personal with us (including advertising platforms and partners and data aggregators who have obtained). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use your personal data as described in this Privacy Policy.

3.1. Personal data that is collected directly from you while you are using Services:

By downloading, accessing and/or playing our games or using our other Services, you consent to the collection of your personal data by Wodo. When you use Services via Platforms, Wodo may collect certain personal data from you and/or your device. Most of this data comes directly from you or your devices, such as your unique device ID (persistent/non-persistent), your device operating system, version, model, CPU, amount of RAM and disk space, hardware type, Identifier For Advertising (IDFA for IOS devices and GAID for Android devices), advertising ID, the version of your operating system ("OS"), your device name, game center ID, and your location based on your Internet Protocol ("IP"). We use this data to provide our games and Services to you, to provide better service to you, to make suggestions, to improve its services, to improve and update our Services, to facilitate the use of Services at the works related to your interest and preferences, including for the purposes of optimization, customizing and in-game offers and verifying purchases, within the framework of legal legislation. We may also use it for the other purposes set out in this Privacy Policy.

Payments for in-app purchases are being carried out by the Platforms. Wodo does not collect personal data such as your name, surname, credit card number and e-mail address that you share with the Platforms for the payment. Wodo does not have access to your credit card or bank account data. However, Platforms may share non-financial payment information for the items your purchase is being shared with us to fulfill your order.

If you choose not to create a Wodo profile, the personal data that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including:

  • The type of device(s) you are using to play our games or access our Services, identifiers such as IP address, device identifiers, ad identifiers, a Wodo player ID, and the country or region that you are playing in; and

  • how you play our games and interact with our websites (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).

  • Your profile photo, your first and last name, your game username (your username and score can be viewed by other users in our games that include a scoreboard feature).

Providing and optimizing our Services

We use your personal data to enable us to provide our websites, advertising, and other services to you and to optimize all of them so that we can make them the best they can be for you and all our players. This will include the use and analysis of aggregated data to make sure that our websites work properly on all devices and are as enjoyable as they can be for all our players.

Customer Services

We use your personal data, including contact information (e-mail) that you provide directly to us in communications, to provide you with technical support through our customer service channels when you need it or contact us anyhow. Your contact information will be processed for the purposes of fulfilling your requests, communicating with you, as part of customer service or sending you updates about our games and Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.

User Reviews/Comments

From time to time, you may share your comments about our games and provide certain information that may include personal data. All personal data collected from your participation in such reviews is provided by you voluntarily. We may use such personal data to solve issues you encountered, to fulfill your requests, to improve our products, websites and/or Services and in any manner consistent with the policies provided herein.

Analytics and Research

We use analytics tools, which may include third-party analytics tools, to collect information about how you play our games or use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes.

Promotions and Competitions

From time to time we may run promotions or competitions during which we may collect certain personal data from you, such as your name, address, postcode, email address or other information or content submitted in order for you to claim a prize. Those competitions will have their own specific terms and conditions, but we will use personal data that you provide in relation to that competition for the purposes of running the competition.

Chat

Some of our Services include chat functionality. Users of our chat service(s) can send messages to other players. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history (although please note that after the relevant period of time which is determined by us, your in-game chat messages will no longer be accessible). We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason.

Cheating, Crime and Fraud Prevention

We may use personal data that we hold to prevent cheating, crime, or fraud. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention, such as the police.

We may use your data as required or permitted by any applicable law.

Visiting Wodo Owned Websites

When you visit our website https://wodo.io or https://wodo.network (“Website or Websites”), we collect and process the below-mentioned personal data about you: Any information provided to us when filling out the job application form on our Website, or when you upload a CV and provide additional links.

3.2. Personal Data Collected from Third Parties

As mentioned above, most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising, or other Services. However, when you allow third-party companies to access to your personal data (e.g., downloading our mobile applications through Platforms), we also collect information from such Platforms.

Installation of our Mobile Applications via App Store and Google Store

When you install or purchase items related to our mobile apps (such as those you can purchase/download via Platforms), Wodo does not have access to your credit card or bank account data. However, Platforms stated above may share non-financial payment information with us related to your purchases, like the items purchased to fulfill your order. The personal data received from the Platforms will depend on privacy settings on relevant Platform applications.

Purposes for Processing of Your Personal Data

We collect and use your personal data for the following purposes:

  • to enable us to provide our games, to ensure that your purchases are activated in the games, and to provide you with player support if you need it;

  • to enable us to optimize our games for you and for the device that you are using, as well as to deliver customized in game events, offers and promotions;

  • For the other purposes as set out in this Privacy Policy, including for marketing and advertising purposes;

  • to operate, improve and optimize our games and other Services;

  • to personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience;

  • to provide access to certain areas, functionalities and features of our Services;

  • to notify you about in-game updates, new products, or promotional offers;

  • 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 our social media accounts;

  • to respond to your comments and inquiries and provide customer support services;

  • to prevent potentially prohibited or illegal activities and protect of our players;

  • 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 compliance with our terms of service or where necessary to defend, exercise or establish our legal rights

  • to contact you as a part of our recruitment processes; and

  • as otherwise expressly set out in this Privacy Policy or as required by law.

The legal grounds that Wodo relies upon while processing your personal data are the following:

  • Explicit consent and/or your request

  • In cases where it is necessary to disclose such information in accordance with applicable laws or regulations or a court judgment or administrative order issued

  • Being necessary for the establishment and execution of an agreement

  • Being necessary for Wodo to fulfill its legal obligations as a data controller

  • Being necessary for the establishment, exercise, and protection of any right

  • Without prejudice to your fundamental rights and freedoms, being compulsory for Wodo's statutory interests

In data processing activities where your personal data is processed based on explicit consent, you have the right to withdraw your consent at any time.

Wodo’s statutory interest in processing your device and usage data is to provide better service to you, to make suggestions, to improve its services, to improve and update our Services, to facilitate the use of Services at the works related to your interest and preferences, within the framework of legal legislation.

Wodo undertakes to keep your data and any confidential information strictly private and confidential, without prejudice to the contents hereof, to regard it as an obligation to keep confidentiality, to take all measures and act in due diligence to prevent all or any part of your information from entering into the public domain or be subject to unauthorized use, or to take measures to prevent the confidential information from disclosure to any third party. If despite all necessary data security measures taken by Wodo, the confidential information is damaged because of attacks on the system or captured by third parties, Wodo shall have no responsibility with that respect.

Wodo shall not be responsible for damages caused by the use of information that you disclose in comments or messages given by third parties in public areas. If you share your name, password, etc. used by you when creating the membership record with third parties, the Wodo shall not be responsible for any damages that may arise from the information shared with third parties.

The Transfer of Your Personal Data

In case a public institution is authorized to request personal data by the law, your personal data can be transferred to such an authorized public institution in accordance with the applicable personal data protection legislation. Requests from judicial authorities will also be fulfilled in accordance with the applicable legislation.

Your personal data may be transferred to our business partners and service providers only if it is required to provide Services with you. The types of Service Providers (data processors) to whom we entrust include companies that provide:

(i) provision IT and related services;

(ii) provision of information and services you have requested;

(iii) customer service activities;

(iv) analytics and search engine activities that assist us in the improvement and optimization of the Services; and

(v) any supporting activities in connection with our Services. Wodo 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.

We may access, preserve, and disclose your personal data, other account information and content if we believe doing so is required or appropriate (e.g. required by Law and similar disclosures):

(i) to comply with law enforcement or national security requests and legal processes, 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 Wodo Games’ policies or contracts;

(v) to collect amounts owed to Wodo Games;

(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 unauthorized activities.

International Transfer

All personal data collected via or by Wodo may be stored anywhere in the world, including, but not limited to, in Turkey, the United States, the European Union, in the cloud, on our servers and on the servers of our affiliates or the servers of our service providers. When we transfer your personal data internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used or processed may be different from the privacy laws applicable to the place where you are resident.

By providing information to Wodo, you consent to the storage of your personal data in these 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 are agreeing to the transfer of your information to Turkey and the United States and to the processing of your data globally.

By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Turkey.

Marketing

We and our third-party partners may use personal data collected about you to send you marketing communications about our mobile applications and related Services based on your interests. For example, we may serve ads within our Services or place ads on third-party websites and apps.

We may use the information that we hold about you to promote Wodo’s Services in several ways. This might include:

  • advertising within third-party websites and apps;

  • offering you customized promotions for our services in the game you play;

  • offering you in-game advertisements and special offers regarding the Wodo services and games.

Information used for Marketing

We use information about you to try to make sure you only see marketing from us that might be of interest to you. This includes using information that we may have about you, such as:

  • ad identifiers and other non-personal data collected from your device;

  • the games you play and information about how you interact with our games and Services;

  • country or region;

  • and other information that we might acquire 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.

Marketing Partners

When we market our games in media published by other companies, we use various third-party marketing partners to assist us on our behalf, and we may share data that we have collected about you with such third parties for these purposes.

Our marketing partners may help us to serve ads to you by combining this information with data that they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested to see an advert for Wodo’s games or Services, they will serve you with a Wodo ad while you are using other websites and services.

If you would prefer that your personal data is not processed to receive interest-based ads, you can submit an opt-out request by contacting us via info@wodo.io. You should note that if you opt-out of receiving interest-based or targeted advertising, you will still see advertising and you may see advertising for Wodo products, but that advertising will not be targeted using your personal data.

This Privacy Policy does not apply to the collection of your data by our marketing partners. We recommend that you review our partners’ privacy policies for more information.

Cookies Used by the Third Parties

Service providers acting on our behalf may use cookies or similar technologies to automatically collect information through the Services. Cookies are small text files placed in users’ computer browsers to store their preferences. Cookies belonging to such service providers may be set on your device when using our website or Services. Cookies relating to the website will be used by service providers for the purposes set forth below:

  • Operationally Necessary: We may use cookies, web beacons or other similar technologies that are necessary to the operation of our sites, services, applications and tools. This includes technologies that allow you access to our sites, services, applications and tools and that are required to identify irregular site behaviour, prevent fraudulent activity and improve security.

  • Performance Related: We may use cookies, web beacons or other similar technologies to assess the performance of our websites, applications, services and tools, including as part of our analytic practices to help us understand how our visitors use our websites.

  • Functionality Related: We may use cookies, web beacons or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications or tools. This may include identifying you when you sign in to our sites or keeping track of your specified preferences, interests or past items viewed so that we may enhance the presentation of content on our sites.

  • Advertising or Targeting-related: We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third-party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that have been delivered to you, such as whether you have clicked on an advertisement.

Opting Out of Cookie Tracking: You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash Cookies operate differently than browser cookies, and cookie management tools available in a web browser may not remove flash cookies.

Please be advised that if you disable cookies, you may lose some of the features and functionality of our Services because the cookies are necessary to track and enhance your activities.

Ad identifiers, Software Development Kits and Similar Technologies

To provide our games, websites and interest-based advertising, we use ad identifiers, software development kits and similar technologies. This section describes our use of these technologies.

Ad identifiers and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third-party advertising partners to:

  • recognize you and your device;

  • provide interest-based advertising to you;

  • allow our Services to interact with a third-party social network or platform (where you have chosen to allow such interaction);

  • enable us and third parties to provide you with more customized services, for example, to provide our Services in the correct language.

Work of Ad Identifiers and Similar Technologies

Ad identifiers are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising, which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use Websites and applications.

Options of Opt-out from Interest-based Advertising

  • Opting out of interest-based advertising at a device level: You can choose to prevent your device's ad identifier from being used for interest-based advertising, or you can reset your device's ad identifier, by changing the settings of your device. 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 advertising: To update your advertising preferences with Wodo, you will need to log in to your account on Wodo Website and update your settings there.

10. Your Rights Regarding the Protection of Your Personal Data

You have certain rights in connection with your personal data and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.

Those rights include:

  • Access to personal data: You have the right to access your personal data that Wodo Games is using.

  • Correction or deletion of personal data: You have the right to ask Wodo Games to correct or complete your personal data if it is wrong or incomplete. You may also have the right to ask Wodo Games to delete your personal data, when certain conditions apply. Such requests should be sent to info@wodo.io

  • Account deactivation: Should you wish to completely deactivate your account include disassociating your Wodo account from our current and future mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items will be lost and we may not be able to restore them in the future.

  • Restriction on processing of personal data: You may have the right to ask Wodo Games to restrict the use of your personal data, when certain conditions apply.

  • Object to processing of personal data: You may have the right to object to the use of your personal data by Wodo Games, when 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 you can use this data with another company, when certain conditions apply.

  • Right to opt-out (California, USA): California residents have the right to opt out of the sale of personal data, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. If you opt out of the ‘sale’ of your data, we will not sell your data, including to our advertising partners, but you may still see ads in the game and some of our partners may deliver ads to you, based on information they hold on you.

  • Rights under GDPR: The GDPR is a regulation intended to strengthen and unify data protection for all individuals within the EU. It aims to protect the fundamental right to privacy and the protection of personal data. Wodo Games is committed to data protection and has taken steps to align with the GDPR. You can exercise your rights to review or request the permanent deletion of your personal data by submitting a request to our support team at info@wodo.io. Please make sure to choose “Account Information” as the topic and “Privacy” as a sub-topic. If you do not want to permanently delete your account, you may deactivate your account instead, and activate it again at any time. Please be advised that by deleting your personal data, all game progress and any related asset will no longer be restorable. If you have any questions or comments in regards to privacy matters please send us a message at info@wodo.io.

There are other ways in which you can control the personal data that we collect about you. For instance, you could disconnect your Wodo account or other social network accounts from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone.

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

If you believe we have misused your data or violated any data protection regulations, you may file a complaint with a Data Protection Authority, for example, the Authority of your place of residence.

You can submit all your claims, deletion requests and questions with respect to such rights to info@wodo.io. Your requests will be answered as soon as possible and within thirty days at the latest.

There are other ways in which you can control the personal data that we collect about you. For instance, you could disconnect your Wodo account or other social network accounts from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings in your phone.

11. Children’s Privacy

Most of Wodo Services and games are not intended for children under the age of 18 and Wodo does not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use Wodo Services.

You must be over 18 years old to play our games and use our Services. We do not collect personal data from anyone under 18 years old person knowingly and willfully. However if the Services are used by such person in contradiction to this Privacy Policy, we may collect personal data from such person. If you believe that we might have any information from or about a child under 18 years old, please contact us.

12.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

  • Consent: 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.

In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you play our game we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease playing our games and stop using our Services.

13. Data Retention

Wodo retains the personal information collected as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

14. Security

The personal data that you provide to Wodo is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such data such as firewalls and data encryption. However, no server, computer or communications network or system or data transmission over the internet can be guaranteed to be 100% secure. As a result, while Wodo strives to protect your personal data, Wodo cannot ensure or warrant the security of any personal data you transmit to Wodo or through the Services.

By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security privacy, and administrative issues related to your use of the Services. 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.

15. Changes to Our Privacy Policy and Practices

Revision to the Privacy Policy

We may revise this Privacy Policy at our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.

Posting of Revised Privacy Policy

If there are any material changes to this Privacy Policy, Wodo will notify you by email or as otherwise required by applicable law. We will post adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information

Additionally, before we use personal information for any new purpose not originally authorized by you, we will endeavour to provide information regarding the new purpose and give you the opportunity to opt-out. When consent of the individual for the processing of personal information is otherwise required by law or contract, Wodo will endeavour to comply with the law or contract.

16. Contact Info of Data Controller

If you have any questions about the privacy practices or this Privacy Policy, please contact Wodo’s data protection officer by email at info@wodo.io.

Wodo

Last updated