DOPIVERSE PRIVACY POLICY

Last updated: September 17, 2023

DOPIVERSE PRIVACY POLICY

1. Introduction. 1

2. Summary of Key Points. 2

3. Definitions. 2

4. What data we collect about you. 3

6. How we use your personal data (for GDPR). 4

7. Legal Basis for Use of Your Personal Information. 6

8. We share information about you as follows or as otherwise described in this Privacy Policy: 7

A. Sharing Your Personal Data. 7

B. Service Providers. 8

C. Cookies. 8

D. Analytics. 9

9. Data Transfer and Security. 9

A. Data Transfer. 9

B. Data Security. 9

10. Data Retention: How long we keep your personal data. 10

11. Your rights. 10

12. Children’s Privacy and Parental Controls. 11

13. Privacy Policy Changes and Updates. 11

14. Further questions and how to make a complaint. 11

1.      Introduction

At Dopiverse, we extend a warm welcome to you! We strive to create a learning environment for children that is not only educational but also fun. Rest assured that we take the privacy of your children seriously and have measures in place to safeguard it.

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", “company” refer to Doping Bilişim Teknolojileri Anonim Sirketi, or our group companies, as appropriate.

Company Information:

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.

We are always looking to improve the information we provide to our users and contacts, so if you have any feedback on this privacy policy, please let us know at our email address: support@dopiverse.com. For any questions, or complaints, please see Section 15 (Further questions and how to make a complaint) below.

2.      Summary of Key Points

A.        Dopiverse is currently in the process of seeking certification under kidSAFE's FTC-approved COPPA Safe Harbor program. This involves undergoing an independent review to ensure that our product meets the required standards of online safety and privacy.

B.        Under COPPA (Children's Online Privacy Protection Act), Personal Information (PI) refers to individually identifiable information that pertains to a child who is under the age of 13. This includes the child's name, phone number, email address, or any other identifier that may allow someone to identify or contact the child. It may also include information about the child's activities, interests, location, and any other data that could be used to create a profile of the child. COPPA requires that websites and online services directed to children obtain parental consent before collecting, using, or disclosing a child's Personal Information. You can learn about COPPA by looking at this simple guide from the kidSAFE Seal Program: https://www.kidsafeseal.com/knowaboutcoppa.html

C.        We prioritize your privacy and do not exploit your Personal Information for financial gain. In fact, we do not knowingly collect any Personal Information that could be used to identify a profile of child users under age 13. We even encourage anonymity by allowing users to create a nickname instead of asking for their real name in the safe world of Dopiverse. However, in certain situations such as when you contact us, we may need to collect Personal Information. For more information about what data we may collect and when we collect Personal Information from you, please see Section 4 (What Data We Collect From You) below.

D.        We employ commercially reasonable physical, technical, and administrative security measures to ensure the confidentiality and protection of all information gathered through our services. For more information about security, please see Section 10 (B) (Data Security) below.

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

F.         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.

G.        Protecting the privacy of children (i.e., users under the age of 13 under COPPA), see the Section 13 (Children’s Privacy and Parental Controls) below for more information about your rights as a parent or legal guardian.

3.      Definitions

Prior to fulfilling our obligation to disclose information, we would like to clarify certain key concepts as follows:

What is Personal Data? Any information that helps to identify a natural person is considered personal data. This includes not only traditional identifiers surname, telephone number, and education information but also things like IP address, and device IDs.

What is Personal Information (PI)? PI is a more specific subset of personal data. It refers specifically to information that is related to a natural person who can be identified directly or indirectly, in particular by reference to an identifier such as age, name, address, phone number, e-mail address gender, and more. When Personal Information is protected by the Children's Online Privacy Protection Act (COPPA), personal data is subjected to the General Data Protection Regulation (GDPR).

What Is Data Collecting Activity? It refers to the process of gathering and storing information from various sources. In the context of digital technology, it typically involves collecting and storing data about users and their activities online. This data can include Personal Information such as name, address, and email, as well as other types of data such as browsing history, search queries, and location information. Data is collected for various reasons, including to improve companies’ products and services, personalize user experiences.

Who Is the Data Controller? The data controller is the entity or organization that determines the purposes and means of processing personal data. In other words, they are the ones responsible for deciding why and how personal data is collected, used, and shared. This can be an individual or a company that collects and processes personal data. The data controller is responsible for complying with relevant data protection laws and ensuring that the personal data is handled in a secure and lawful manner. In this sense, our company is a data controller.

4.      What data we collect about you

A.        Name and e-mail address: When you purchase Dopiverse through www.dopiverse.com, we will ask your name and e-mail address to send your account information to your e-mail address.

B.        Age: We will ask your age data before entering the game in order to customize our Service for you. Since this data cannot be identified, it is not considered Personal Information.

C.        Online Identifiers and Other Technical Data: We collect log and device data. We log data 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. We collect data 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.

D.        Usage/In-App Data: We collect data relating to your use of our Services, including which applications you use, 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. We also will ask you to choose a unique nickname and stay anonymous. You must not create a username that includes your real name or other Personal Information.

E.         Data 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. We do not collect any of your payment information.

F.         Subscription Data: We collect data 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.

G.        Data Collected by Cookies and Other Tracking Technologies: We use various technologies to collect data, 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 data 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 Section 9(C) (Cookies) below.

H.        Personal Information and Personal Data 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 data you include in your correspondence with us), including any updates to any of that data.

5.      How we use your personal information (For COPPA)

As previously mentioned, we do not collect any Personal Information that directly or indirectly identifies an individual. However, if you contact us and provide Personal Information, we may process it to fulfill our Services, receive and respond to customer service and support enquiries we receive from you.

6.      How we use your personal data (for GDPR)

We will collect, use and store the personal data listed above for the following purposes of processing your personal data and legal basis for data processing. Also, you can find the method of collecting your personal data below:

7.      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:

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

·         operate, maintain and improve our apps and our marketing optimization efforts;

·         understand the way in which our apps are used; and

·         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 12.

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

A.     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.

B.     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.

·         Amplitude, Inc.

·         Optimizely, Inc.

·         Adapty Tech 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.

C.     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.

D. 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

9.      Data Transfer and Security

A.     Data Transfer

The transfer of data across borders is a common occurrence in our global operations. We may transfer your Personal Information to other companies within Dopiverse or third-party entities located around the world, in accordance with the purposes outlined in our Privacy Policy. If you reside in a jurisdiction with data protection laws that differ from those in the United States, please note that your information may be transferred to a location that does not have similar data protection regulations. By using our services, you consent to the transfer of your information to the U.S. or any other country where Dopiverse or its affiliates maintain facilities, as well as the use and disclosure of your information as described in our Privacy Policy.

B.     Data Security

To ensure the safety of your Personal Information, we employ technical, physical, and organizational security measures that guard against unauthorized access, loss, and misuse. Our most infrastructure is built on our cloud provider’s services. We also conduct routine monitoring of our systems to detect and address potential security threats. However, as electronic communications and information processing technology are not entirely infallible, we cannot guarantee the complete safety and security of any data transmitted to us via the Internet or stored on our systems. Despite the implementation of our physical, technical, and organizational safeguards, there remains the possibility that Personal Information be accessed, altered, or destroyed by others. In the event of a security breach resulting in compromised Personal Information, we will comply with applicable laws by promptly notifying our users. Here some of security measures we take with respect to user data: Separate testing vs. production environments, Internal access control procedures (e.g., access limited to personnel with strict need-to-know and valid login credentials, password management procedures, etc.).

10. Data Retention: 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 support@dopiverse.com, 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 anonymize 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.

11. 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 support@dopiverse.com at any time. You have the following rights:

·         Right of access.

·         Right to update your information.

·         Right to delete your information.

·         Right to restrict use of your information.

·         Right to data portability.

·         Right to object.

We will consider all such requests and provide our response within a reasonable period (and in any event within 2 weeks 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.

12. Children’s Privacy and Parental Controls

If you provide us with your parent or guardian's email address when creating your Dopiverse account, we will share account-related information with them via email. This includes the option for them to review and update your account settings, as well as approve your account.

Additionally, if you and your parent or guardian would like to track your usage and improvement in Dopiverse, we can share statistics and usage information related to your Dopiverse account.

For parents or guardians who need to make changes to their child's account, please contact us at supports@dopiverse.com.

13. Privacy Policy Changes and Updates

We may periodically update this Privacy Policy, so it's important to check our website www.dopiverse.com and in Dopiverse app regularly. The date of the latest version is always displayed at the top of this page.

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 significant changes, we will provide you with a prominent notice on this website or in the app before the changes take effect. If any of these changes affect the data we've collected from you in a less protective way and if required by law, we will seek your parent's renewed consent (e.g. by adding a statement to our website’s homepage or sending you a push notification).

14. 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 support@dopiverse.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your Personal Information.