Last updated: January 24, 2023

DOPIVERSE PRIVACY POLICY

A. This Privacy Policy explains how information about you is collected, used and disclosed by Doping Bilisim Teknolojileri Anonim Sirketi when you use our website and mobile application (“Dopiverse”) (together the “Services”). All references in this policy to "Dopiverse", "our", "us" or "we" refer to Doping Bilişim Teknolojileri Anonim Sirketi, or our group companies, as appropriate.

B. Our registered Tax ID number is 3101275788 in Turkey and our registered office is located at Cifte Havuzlar Mah. Londra Asfalti Cad. Kulucka Mrk. B2 Blok No: 205 Yildiz Teknik Universitesi Teknopark Esenler, Istanbul, Turkey.

C. We may change this Privacy Policy from time to time. If we make changes, we will notify you by publishing the date we made any change at the top of the policy and, depending on the specific changes, we may provide you with additional notice or require a renewed consent (e.g. by adding a statement to our website’s homepage or sending you a push notification).

D. This policy applies to users of our apps and people who contact our customer support function.

E. By visiting or otherwise using our Services, you are agreeing to the practices set out in this Policy to the extent permitted by data protection legislations.

F. Please note that our Services are not directed at children under the age of 13 (each a "Child" together "Children") and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at [email protected] and request us to cease processing data about your Child.

G. We are always looking to improve the information we provide to our customers and contacts, so if you have any feedback on this privacy policy, please let us know using our contact details in section 7.

1. What personal information we collect about you

- Log Information: We log information about your use of our Services, including the type of browser you use, access times and numbers, pages viewed, and the page you visited before navigating to our Services.

- Device Information: We collect information about the device you use to access our Services, including information about the device model, information regarding operating system, device language, country and city information, which typically our third-party service providers derive from your device’s IP address.

- Usage/In-App Information: We collect information relating to your use of our Services, including which applications you use and your username, user ID, country, city, ratings, likes, effects on/off, music on/off, power up bar position on/off movements, scores, achievements, and interactions with other players.

- Information when you subscribe to our Services: Payment processors you use, such as Apple Pay and Google Pay, will process all purchases, and you will be subject to their terms and conditions and privacy policy. Your billing information, transaction details, and purchase history may be retained and used by the payment processors to resolve subsequent billing disputes and inquiries.

- Subscription information: We collect information about the purchase history and subscription details (this does NOT include payment method details or banking information which is collected and processed by a third-party), such as subscription type, subscription starting and ending times, payment processor information (Google or Apple), user ID.

- Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your mobile device. Cookies are small data files stored on your computer’s hard drive or in device memory that help us to improve our Services and your experience and see which areas and features of our Services are popular. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies, please see “Cookies” in section 4.

- Information when you contact our customer support function: We collect your e-mail address, your first name, your surname and certain data about your device, including your mobile phone network and operator, and generated device identifier information (as well as any other information you include in your correspondence with us), including any updates to any of that information.

2. How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

- To provide, maintain and improve our current Services;

- To develop new Services;

- To provide and deliver the products and services you request and send you related information;

- To respond to your comments, questions and requests and provide customer service and support;

- To send you technical notices, updates, security alerts and support and administrative messages;

- To process and deliver contest entries and rewards;

- To monitor, analyse, and compile statistics, trends, usage and activities in connection with our Services;

- To recognize you when you return to our app, to store information about your use of our app;

- In order to restrict access to harmful, infringing or illegal movements of users;

- To link or combine with information we get from others to help understand your needs and provide you with better service; and

- To comply with any procedures, laws and regulations which apply to us, and to establish, exercise or defend our legal rights;

- To receive and respond to customer support enquiries we receive from you.

3. Legal Basis for Use of Your Personal Information

We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

a. our use of your personal information is necessary to perform our obligations under any contract with you (for example, to comply with the terms of service of our apps); or

b. where a does not apply, our use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

i. run, grow and develop our business (as well as the businesses of our group companies) including funding our business;

ii. operate, maintain and improve our apps and our marketing optimization efforts;

iii. understand the way in which our apps are used; and

iv. for internal group administrative purposes.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 7.

4. We share information about you as follows or as otherwise described in this Privacy Policy:

Sharing Your Personal Data

- With any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries;

- With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;

- With other users (for example, in connection with your interactions in the App)

- In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;

- If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Dopiverse or others;

- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and

- With your consent or at your direction.

We also may share aggregated information or de-identified information, which cannot reasonably be used to identify you.

We may allow third parties to provide analytics services in connection with our Services. These entities may use cookies, web beacons and other tracing technologies to collect information about your use of our Services, including your location, device model, operating system information, and usage information. This information may be used by Dopiverse and others to, among other things, analyse and track data, determine the popularity of certain content, deliver content targeted to your interests and better understand your activity on our Services.

Our Services may also integrate third party Application Program Interfaces (APIs), which allow others to collect and process information about you, including your geo-location information, to provide you with content.

Third-party analytics technologies are integrated into our Services, so if you do not want to be subject to these technologies, do not use or access our Services.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. The following is a list of our major service providers:

AppsFlyer (AppsFlyer Inc.)

Google Analytics for Firebase (Google Inc.)

Google Analytics (Google Inc.)

Crashlytics (Google Inc.)

Amazon.com, Inc.

Where we provide links to third party websites that are not affiliated with Dopiverse such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those services.

Cookies

Our Services uses “cookies” in order to provide a better user experience. These cookies are stored for record keeping and may also track information. You can choose to set your browser to refuse cookies, however, be aware that some elements of the website may not function correctly without them.

Technologies That Dopiverse or Third Parties Use

Local Shared Objects (LSOs), which are also known as “Flash Cookies,” are used to:

Identify devices so we can prevent and respond to fraud or other illegal activity.

Store App preferences so we can present the App experience you want. These preferences let us know things like whether you want music/effects on or off or whether you want to power up bar position on or off.

Store Dopiverse assets (files) on your device so you can have faster load times.

If you do not want Flash Cookies stored on your device, you can adjust the settings of your Flash player to block Flash Cookies storage using the tools contained in the “Website Storage Settings Panel.” You can also control Flash Cookies by going to the “Global Storage Settings Panel“ and following the instructions, which may include instructions that explain, for example, how to delete existing Flash Cookies (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without you being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time.

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Services.

Browser Cookies are used by Dopiverse primarily to:

Identify specific users and track whether they are logged in (Authentication).

Customize site content and remember site preferences.

There are several ways to manage browser cookies on your device. Most major browsers offer choices for whether and how you receive future cookies and for deleting cookies already on your device. Which browser cookies are on your device will depend on which browser you use to access Services. Here are links to information from some of the larger browsers about how you can control your browser cookies: Chrome, Firefox, Safari, Internet Explorer.

In addition, there are several browser plugins available to web users who want to be better informed about and have more control over cookies and similar technologies. Two popular ones are Ghostery and Abine.

Beacons, Pixel Tags, and Clear Gifs are all terms for similar technology that often works in the same way. These small strings of (software) code track events such as when a user visits a page or opens an email. They are used by Dopiverse to measure the effectiveness of App performance. In many instances, beacons, pixel tags, and clear gifs work in conjunction with cookies to function properly, so declining cookies will impair their functioning.

Analytics

Dopiverse analyzes traffic and other end user activity to improve the user experience. Dopiverse and its service providers and business partners may use web server log files and tracking technologies to collect and analyze certain types of technical information, such as cookies, user ID, country information, device type, and usage information, including time spent on particular pages or number of clicks. These cookies help us to understand the effectiveness of our Services.

Our analytics partners use browser cookies to generate statistics about users to Services, such as the views, clicks, or times of peak traffic. Our analytics partners, include, without limitation, the following third parties. Please follow the links below for further information concerning the privacy policies and opt-out choices offered by these third parties.

AppsFlyer: https://www.appsflyer.com/legal/services-privacy-policy/ ; https://www.appsflyer.com/legal/opt-out/

Google Analytics: https://support.google.com/analytics/answer/6004245?hl=en ; https://tools.google.com/dlpage/gaoptout

Google Analytics for Firebase: https://policies.google.com/privacy

Crashlytics: https://policies.google.com/privacy

5. How long we keep your personal data

We will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.

You may request that we update, correct, or delete information about you at any time by emailing us at [email protected], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

Most device browsers are set to accept cookies by default. If you prefer, you can usually choose to set your device browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of certain features of our Services.

With your consent, we may send push notifications or alerts to your mobile device to provide App-related information, service updates, and other related messages. You can deactivate these notifications by changing your notification settings on your device.

In some circumstances you can ask us to delete your data: see "Your Rights" below for further information.

In some circumstances we may 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 data indefinitely without further notice to you.

6. Your rights

- You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at [email protected] at any time. You have the following rights:

(a) Right of access.

(b) Right to update your information.

(d) Right to restrict use of your information.

(e) Right to data portability.

(f) Right to object.

- We will consider all such requests and provide our response within a reasonable period (and in any event up to 14 business days after receiving your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

7. Further questions and how to make a complaint

If you have any questions or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact [email protected] We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.