Paint Twist Privacy Policy and Information Notice

Effective date: [EFFECTIVE DATE]

This notice explains how we process your personal data when you play the Paint Twist game (the "Game"). It is also our information notice under Article 10 of the Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"). Additional information for the European Economic Area and the United Kingdom (GDPR), the United States and children is set out in separate sections below.

1. Data controller

Elif Şen · Zekeriyaköy Mah. Yediveren Sok. İsmail Zengin Apt. No: 30 Daire: 13, Sarıyer, Istanbul, Türkiye · Privacy and data requests: privacy@nunogames.com

2. In short

3. What data we process

DataExampleSource
Player identifierThe random Player ID the Game creates when it is first openedThe Game
Device informationLanguage, screen size, game version and region (from your phone's region setting: Türkiye / EU / other). We do not collect your device model or iOS version; advertising partners may (section 5).Your device
Connection informationIP address: our server keeps it only in memory, briefly, to prevent abuse (rate limiting); it is never written to disk or to the database and is not used to determine your country.The connection
Game dataLevels you played, number of moves, times, boosters you used, rewards, league points, session lengths, your test groupThe Game
Age groupAge group calculated from your birth month and year (under 13 / 13 and over). Your date of birth itself stays only on your device.You
Purchase informationProduct, price, date, Apple transaction number. We do not see your card details.Apple
Ad informationWhich ad was shown, whether it was watched, the reward earned; if you gave permission, your advertising identifier (IDFA)The Game and advertising partners
Error logsTechnical information when the Game crashes or reports an errorThe Game and Apple
Notification permissionIf you allowed notifications, reminders (e.g. "your lives are full") are scheduled on your phone itself. We do not collect a notification token; our server does not send you notifications.Your device
Parent's emailOnly the email of the parent who sets up Parental Control (for PIN verification and reset)The parent
Support correspondenceYour email address and message when you write to usYou

4. Why we process data and on what legal basis

PurposeLegal basis (KVKK / GDPR)
Running the Game, giving you your progress and what you bought, running the league and eventsFormation and performance of a contract (KVKK Art. 5/2-c · GDPR Art. 6/1-b)
Improving the Game: adjusting level difficulty, finding bugs, game statistics and A/B testsLegitimate interest (KVKK Art. 5/2-f · GDPR Art. 6/1-f)
Selecting in-game offers based on your play styleLegitimate interest (KVKK Art. 5/2-f · GDPR Art. 6/1-f). You always have the right to object (section 9). [LAWYER: whether explicit consent is required for Türkiye]
Showing personalized ads and measuring adsExplicit consent (KVKK Art. 5/1 · GDPR Art. 6/1-a) and, on iPhone, Apple's tracking permission
Showing non-personalized adsLegitimate interest (KVKK Art. 5/2-f · GDPR Art. 6/1-f); in the EEA and the UK, consent as required by local rules
Protecting children (Kids mode, Parental Control)Legal obligation and legitimate interest (KVKK Art. 5/2-ç, f · GDPR Art. 6/1-c, f)
Preventing cheating and misuse, securityLegitimate interest (KVKK Art. 5/2-f · GDPR Art. 6/1-f)
Keeping purchase records, legal obligationsLegal obligation (KVKK Art. 5/2-ç · GDPR Art. 6/1-c)
Answering support requestsPerformance of a contract and legitimate interest

Automated decisions and adapting to how you play. The Game adjusts some things automatically based on how you play:

The Game never secretly changes the board or the move limit, and never makes the game harder for a particular player. These adjustments do not produce legal or similarly significant effects for you. You can still object to them (section 9).

5. Who we share data with

We do not sell your data. We share it only with the following partners, and only as much as necessary:

List of advertising partners and links to their privacy policies: [LINK].

Our contracts with service providers require them to process data only on our behalf and to protect it.

Other services: Ads or links in the Game may take you to other apps and websites (for example the App Store). Those services are subject to their own terms and privacy policies; we are not responsible for their practices.

6. Transfers abroad

Our own server is in Türkiye. Some of our partners process data on servers abroad:

7. How long we keep data

DataPeriod
Game data linked to a Player IDAt most 13 months; then deleted or anonymized so that it cannot be linked to anyone
Anonymous statisticsIndefinitely (cannot be linked to anyone)
Purchase recordsFor the statutory retention periods ([LAWYER: e.g. 10 years])
Parent's emailUntil Parental Control is turned off
Support correspondence2 years after the request is closed
Error logs90 days

8. Personalized ads and your permissions

9. Your rights and how to use them

Under KVKK Art. 11, you have the right to:

If you are covered by the GDPR, in addition:

How to apply: Write to privacy@nunogames.com and include your Player ID from Settings > Terms & Privacy. Because the Game has no accounts, we find you by this number. You can write in Turkish or English; we reply free of charge within 30 days at the latest. We may ask for additional information to verify your identity. You can also submit KVKK requests in writing or by registered electronic mail (KEP) in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller (Veri Sorumlusuna Başvuru Usul ve Esasları Hakkında Tebliğ). Your right to complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu) in Türkiye remains unaffected.

Deleting your data: Because the Game has no accounts, you request deletion by writing to privacy@nunogames.com with your Player ID.

10. Children

11. Players in the United States

12. Security

We take technical and organizational measures to protect your data, such as encrypted connections, access restrictions and regular backups. No system is completely secure. If a data breach occurs, we will notify the Turkish Board within the period it requires (72 hours) and the people affected without delay; for players in the EEA and the UK we also follow the rules that apply there.

13. Changes

We may update this notice. If there is an important change, we will let you know in the Game. The current version is always available in Settings > Terms & Privacy.

14. Contact

Elif Şen · Zekeriyaköy Mah. Yediveren Sok. İsmail Zengin Apt. No: 30 Daire: 13, Sarıyer, Istanbul, Türkiye · privacy@nunogames.com