Privacy Policy
Orange Wolf Privacy Policy
Last updated: December 31, 2023
INTRO
Orange Wolf Dijital Oyun Teknolojileri Anonim Şirketi (“Orange Wolf” or “we”, “us”, “our”) is a technology company that designs and develops mobile games. With this Privacy Policy, we aim to explain how and why we gather, store, share, and use your personal data in a manner consistent with the laws of the countries where we do business. When this Policy refers to “personal data” in this Policy, we mean any information that can be used to identify, relate to, characterize, or reasonably be linked, either directly or indirectly, with a specific natural person or household, as well as any other information that falls under the definition of “personal data” or “personally identifiable information.” This privacy policy covers all of the following: websites, mobile applications, blogs, forums, offline services, our advertising and promotional activities across all platforms, and any other services we might occasionally offer to you (collectively, the “Services”). Employees, job candidates, and other personnel of Orange Wolf are not covered by this privacy policy. Orange Wolf oversees the management of the information we possess pertaining to you in relation to your utilization of the Services. In essence, we decide and bear the responsibility for the utilization of your personal data. According to this Privacy Policy, your personal data will be handled to facilitate the provision of the Services following your download of our mobile applications, engagement with our games, or interaction with our Services. Should you have any reservations about furnishing us with data or its utilization as outlined in this Privacy Policy, you can reach out to us and exercise the rights detailed in the Security section of this Privacy Policy.
HOW WE COLLECT YOUR PERSONAL DATA
We might gather personal information either directly from you or through third-party entities with whom you have granted consent or who possess legal authorization to share such data with us (including advertising platforms, partners, and data aggregators). This information may encompass details about your attributes, interests, other games and services you engage with, as well as demographic and general location information. The utilization of your personal data will align with the provisions outlined in this Privacy Policy.
Personal Data Collected Directly from You
Orange Wolf processes your personal data with the purpose of delivering the Services when you download, access, and/or engage with our games or utilize our other Services. The majority of this data is obtained directly from you, and we collect the following information in connection with our Services:
- Contact Information: This includes details like your country or region and username.
- User Generated Content: Encompassing files, documents, videos, images, data, or information you opt to upload or transmit through your interactions with us or your utilization of the Services.
- Profile and Gameplay Information: This comprises your screen name, avatar or profile picture; in-game scores, achievements, and purchases; your participation in competitions, as well as your membership and involvement in teams on the Services.
- Survey Information: This involves the feedback and ratings you provide regarding our Services. Inferences: Information derived from your usage of the Services, presenting predictions about your interests and preferences.
- Parental Information: If you activate parental control settings in the Services, this may include the parent’s email address and PIN.
- We utilize this data to furnish our games and Services to you, which includes optimizing our Services, tailoring in-game offers, and validating purchases. Additionally, we may employ it for other purposes outlined in this Privacy Policy.
Information We Collect Automatically
Depending on your interaction with specific Services we offer, we may collect and process various types of information, including: Analytics Data: This involves details about your usage and interactions with our games, advertising, and other Services. Examples include information on when and how you use our Services, the device you use for access, and technical diagnostics such as battery life, loading time, latency, framerate, or crash logs pertaining to the performance of our Services on your device. Device Data: This includes your unique device ID (persistent/non-persistent), Identifier For Advertisers (IDFA), Identifier for Vendor (IDFV), and game center ID. Location Data: This encompasses your location based on your Internet Protocol (“IP”). Commercial Information: Such as details about products and services purchased, obtained, or considered, as well as other histories or tendencies related to purchasing or consumption. We and our third-party providers may utilize technologies like cookies (small data files stored on an individual’s computer), web beacons, pixels, embedded scripts, location-identifying technologies, and logging technologies (collectively referred to as “cookies”) to deliver our website services. For more detailed information, please refer to the Cookies section of this Privacy Policy.
Personal Data Collected from Third Parties
As previously stated, the majority of the data we get about you is provided by you when you use our services or play our games. On the other hand, we also obtain information from third parties that you authorize to access your personal data (for example, by installing our mobile applications through the App Store or Google Store and connecting your Facebook account to mobile applications).
- Social Media: We may receive information about individuals that they allow the social network to share with third parties when you interact with our Services through different social media networks. Examples of these interactions include when someone “Likes” us on Facebook, follows us, or shares our content on Google, Facebook, Twitter, or other social networks. Depending on a user’s privacy choices on the social network, we may obtain information about them that includes their name, profile image, and friend list. Before sharing information or connecting to other services, users should always check and, if needed, modify their privacy settings on third-party websites, social media networks, and services. We use this information for the purpose of running, maintaining, and offering you the features and functionalities of the Services. We also use it for direct communication, such as sending you emails about goods and services that could be of interest to you.
- Service Providers: Orange Wolf does not have access to your credit card or bank account information when you install or purchase things related to our mobile apps (such as those available through the App Store or Google Play). However, the previously mentioned third-party payment processors may share non-financial information about your purchases with us, such as the items purchased to fulfill your order. Personal data obtained from third-party firms will be subject to the privacy settings of the relevant third-party applications.
- Authentication Services: Certain aspects of our Services offer you the option to log in using a third-party social network or authentication service, such as Facebook. These services serve to authenticate your identity and provide you with the opportunity to share specific personal data with us. This may include details like your name, email address, user ID associated with the third-party, profile picture, and the names and avatars of your Facebook friends who are already engaged with our games. The extent of data we receive is contingent upon the policies of the third party and your privacy settings on that particular third-party site. Where applicable, you’ll also have the ability to view which of your friends are participating in the same game, monitor their progress, and allow them to see your advancements. Additionally, various functionalities within our games and other Services, such as inviting friends to play, may be accessible. It’s important to note that, during the initial association of your Facebook account with your Orange Wolf profile, you have the choice to withhold access to your email address through the Facebook dialog box. Logging in with Facebook does not grant us permission to post anything to your page without your explicit consent, and we do not receive information about your Facebook friends who do not engage with our games. If you prefer not to have your Facebook friends view your progress within our games, you can prevent this by disconnecting from Facebook within our games and adjusting your app permissions from within your Facebook settings. Opting not to create an Orange Wolf profile by linking your Facebook account means that the personal data we collect during your gameplay will be associated with a random identifier rather than direct identifying information. However, we will still collect device-level identifiers and other information associated with those identifiers, as previously described. We recommend that you read Facebook’s Privacy Policy and review your privacy settings from time to time to ensure that you understand fully how your Facebook data is shared.
- Other Sources: We may also collect personal data about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide you with the features and functionality of our Services.
- Other Sources: Additionally, we may acquire personal data about individuals from sources other than direct interactions, such as publicly available sources, third-party data providers, brand partnerships, or through transactions like mergers and acquisitions. This information is employed to ensure the operation, maintenance, and provision of features and functionality within our Services.
PURPOSES FOR PROCESSING OF YOUR PERSONAL DATA
We collect and utilize your personal data for the following purposes:
- Personalization and Game Support:
- To personalize your in-game profile.
- Provision of our games, including social elements such as team play and competitions.
- Activation of purchases within the games.
- Providing player support when needed.
- Optimization and Customization:
- Optimization of games for your device and personalized in-game events, offers, and promotions.
- Organizational Management:
- Managing our organization and day-to-day operations.
- Identity Verification:
- Verifying your identity and entitlement to products or services when you contact us or access our Services.
- Surveys and User Feedback:
- Requesting your participation in surveys about our organization, partner organizations, and Services.
- Safety and Security:
- Maintaining the safety, security, and integrity of our property, Services, technology assets, and business.
- Operational Improvement:
- Operating, improving, and optimizing our other games and services.
- User Experience Enhancement:
- Personalizing our Services, understanding user preferences to enhance user experience, and improving overall enjoyment.
- Access and Communication:
- Providing access to specific areas, functionalities, and features of our Services.
- Communicating with you regarding Services-related information, including confirmations, technical notices, updates, security alerts, and support messages.
- Social Interaction:
- Enabling players to communicate with each other in games or on our social media accounts.
- Customer Support and Inquiry Response:
- Responding to your comments, inquiries, and providing customer support services.
- Prevention and Protection:
- Preventing potentially prohibited or illegal activities, including cheating or fraud, and protecting our players.
- Interest Measurement:
- Measuring interest in our Services.
- Quality Control and Compliance:
- Ensuring internal quality control.
- Complying with laws, contractual obligations, and legal requirements.
- Activation and verification of parental control settings.
- Legal Compliance and Rights Protection:
- Enabling compliance with applicable laws.
- Prevention of fraud.
- Ensuring compliance with our Terms of Service.
- Defending, exercising, or establishing our legal rights.
- Customer Service and Research:
- Providing support through customer service channels.
- Conducting internal research and analytics.
- Academic Purposes:
- Providing data for University or Research Centers to contribute their researches on the game development field.
- Other Purposes:
- As expressly set out in this Privacy Policy or as required or permitted by law.
DISCLOSURE OF YOUR PERSONAL DATA
We may share, transmit, disclose, grant access to, make available, and provide personal data with and to the following third parties for the purposes outlined in this Privacy Policy, including providing the Services, complying with legal obligations, and protecting our rights and property.
- Other Users: If you engage in our online communities or make purchases on our Services, we may disclose your public profile information to other community members. This may include your screen name, profile picture or avatar, in-game scores and achievements, and any other information you choose to provide or make public.
- Contests, Sweepstakes, and Survey Providers: Personal data may be shared with third parties assisting in delivering contests, sweepstakes, or surveys and processing responses.
- Business Partners: We may share personal data or information collected through the Services with select marketing partners for advertising and other relevant purposes.
- Academic Partners: We may share personal data or information collected through the Services with select academic partners for contributing researches and other relevant purposes..
- Service Providers: Your personal data may be shared with service providers for various activities such as IT services, provision of requested information, customer service, analytics, search engine activities, and supporting activities related to our Services. Contracts with service providers prohibit the unauthorized use or sharing of personal data.
- Disclosures to Protect Rights: We may access, preserve, and disclose personal data if deemed necessary to comply with legal requests, respond to your requests, protect rights, property, or safety, enforce policies or contracts, collect amounts owed, prevent harm or loss, or in connection with investigations or prosecutions.
- Ad Networks and Advertising Partners: Collaboration with third-party ad networks and advertising partners involves the collection of information for targeted advertising and related services. See the Third-Party Data Collection and Online Advertising section for more details.
- With Your Consent: Personal data may be disclosed to certain third parties or publicly with your consent or direction. For instance, testimonials may be posted on our sites or service-related publications with your consent.
- Sale of Assets and Change of Control: In the event of a sale of Orange Wolf’s assets, corporate restructuring, or change in control, any third party acquiring Orange Wolf’s assets will have the right to use the personal information provided in accordance with this Privacy Policy.
- Legal Obligations and Rights: We may disclose personal data to third parties, including legal advisors and law enforcement, under the following circumstances:
In connection with the establishment, exercise, or defense of legal claims.
- To comply with laws or respond to lawful requests and legal processes.
- To protect our rights and property, as well as the rights and property of others. This includes the enforcement of our agreements and policies.
- To detect, suppress, or prevent fraud.
- To protect the health and safety of ourselves and others.
- As otherwise required by applicable law.
These disclosures are made in accordance with legal obligations and are aimed at ensuring compliance with the law, protecting individual and collective rights, preventing fraud, maintaining health and safety standards, and with the purpose of enhancing and delivering our Services.
THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING
We engage in interest-based advertising and collaborate with third-party advertising companies to deliver targeted advertisements based on your browsing history. We authorize third-party online advertising networks, social media companies, and other third-party services to gather information about your usage of our online services over time. This data is used to display ads on our Services, other websites or services you may use, and across various devices you utilize. Our advertising partners may enhance ad targeting by combining your personal data with information they have collected about you from other sources. They gather this data when you use their services or visit third-party websites. Our partners use this information to make assumptions about your preferences and serve you advertisements tailored to your interests, including ads for Orange Wolf’ Services when you use other websites and services. To facilitate these processes, we utilize ad identifiers and similar technologies, allowing our third-party advertising partners and us to:
- Recognize you and your device.
- Provide interest-based advertising.
- Enable interactions between our Services and third-party social networks or platforms, if you have granted permission for such interaction.
- Enable the provision of more customized services, such as delivering our Services in the correct language.
The information used for interest-based advertising is typically collected through tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, and similar tools. These technologies identify the device you are using and collect various details, such as click stream information, browser type, visit time and date, AdID, precise location data, and more. We may share a common account identifier, like a hashed email address or user ID, with our third-party advertising partners to recognize you across different devices. This information is utilized by our third-party partners and us to enhance the relevance of online advertisements, providing advertising-related services such as reporting, attribution, analytics, and market research. Additionally, we may use services from third parties, like social media platforms, to deliver targeted ads. This may involve providing a hashed version of your email address or other information to the platform provider. Our website currently employs strictly necessary, functional, analytical/performance, and advertising/targeting cookies. Please refer to the Cookies section of this Privacy Policy for more detailed information.
COOKIES
Our website utilizes the following types of cookies, similar to most online services:
- Strictly Necessary Cookies: Essential for the proper functioning of our website.
- Functional Cookies: Enable the website to remember information that alters its behavior or appearance, such as preferred language or region. The legal basis for using functionality cookies is our legitimate interests in maintaining our website.
- Analytical/Performance Cookies: Allow recognition and counting of visitors, aiding in the improvement of website functionality and understanding visitor movement.
- Advertising/Targeting Cookies: Operate during your visit to our website, particularly in the presence of videos linked to third-party streaming platforms. They track visitors’ online activity on our website to display more relevant advertisements.
It’s important to note that when playing our games, unless you opt-out of interest-based advertising (as explained in this section), your personal data may be used by our marketing partners to collect and utilize information about you. This is done to enhance advertising, targeting, and measurement systems, as described in their respective privacy policies. You have the option to configure your web browser to notify you about attempts to place cookies on your computer or restrict the types of cookies allowed. However, please be aware that cookies used by our website operate differently than browser cookies, and standard cookie management tools in web browsers may not effectively remove them. Disabling cookies may result in the loss of certain features and functionality on our website, as cookies are essential for tracking and enhancing user activities. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at https://www.privacyrights.info/.
CONTROL OVER YOUR INFORMATION
You have several options to control the personal data collected by our Services:
- Delete or Reset Services:
- Delete our games from your mobile device.
- Reset your mobile advertising identifier.
- Control Device Information Access:
- Manage the Services’ access to your device information through your device’s “Settings” app.
- Withdraw permission for the Services to access your network devices, location data, and integration with other applications.
- Modify or Delete Information:
- Contact us using the methods described in the Contact Us section for assistance with reviewing, modifying, or deleting your information. Note that modification or deletion may not be possible in all circumstances.
- Push Notifications:
- Opt-out of push notifications for game updates, high scores, and other notices by adjusting the settings on your mobile device.
- Online Advertising:
- If you don’t want your personal data used for interest-based ads, submit an opt-out request by contacting us via info@orangewolfgames.com. Opting out doesn’t eliminate advertising but ensures it won’t be targeted based on your personal data.
- Opting out at a Device Level:
- Prevent your device’s ad identifier from being used for interest-based advertising or reset the identifier by adjusting your device’s settings under “privacy” or “ads.”
- Opting out of Facebook Advertising:
- Update advertising preferences on Facebook by logging into your account and adjusting settings. Disconnect your Facebook or other social network account from our games if desired.
- Cookies:
- Refer to the Cookies section of this Privacy Policy for detailed information on controlling your cookie settings.
These options provide you with control over the personal data collected and used by our Services, allowing you to tailor your experience to your preferences.
YOUR RIGHTS
As a user of our Services, you may have certain rights regarding your personal data and its handling. It’s important to note that exercising these rights, especially in cases like deletion requests, may impact our ability to process personal data, potentially affecting our ability to provide products and services or engage with you in the same manner. To inquire about or exercise these rights, you can contact us at info@orangewolfgames.com. If you are a user in the EU, you may have rights under the EU General Data Protection Regulation (GDPR). If you are a user in Virginia, you may have rights under the Virginia Consumer Data Protection Act. If you are a user in Brazil, you may have rights under the Lei Geral de Proteção de Dados Pessoais. Users in other countries may also have rights under local regulations. These rights are designed to empower you with control over your personal data and its processing. Feel free to reach out to us for more information or assistance in exercising these rights. As a user, you have specific rights concerning your personal data, including:
- Access to Personal Data: You have the right to access the personal data that Orange Wolf utilizes.
- Correction or Deletion of Personal Data: You can request Orange Wolf to correct or complete your personal data if it is inaccurate or incomplete. Additionally, under certain conditions, you may ask for the deletion of your personal data.
- Account Deactivation: If you choose to deactivate your account, you can disassociate your Facebook account from our mobile games and remove our games from your mobile devices. Note that complete deactivation will result in the loss of game progress and unspent virtual items, which may not be recoverable in the future.
- Restriction on Processing Personal Data: You may have the right to request Orange Wolf to limit the use of your personal data under certain conditions.
- Object to Processing of Personal Data: You have the right to object to the processing of your personal data by Orange Wolf under certain conditions.
- Portability of Personal Data: Under specific conditions, you may have the right to receive your personal data in a structured and commonly used format, allowing you to use this data with another company.
- Right to Opt Out of:
- Targeted Advertising: You can direct us not to process your personal data for providing targeted advertising.
- Certain Types of Profiling: You may direct us not to process your personal data for specific types of profiling activities.
To exercise the right to opt-out, contact us through the methods described in the Contact Us section. Refer to the Control Over Your Information section of this Privacy Policy for detailed information.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising these opt-out rights. However, note that limitations on processing personal data (e.g., deletion requests) may affect our ability to provide products and services or engage with you.
- Right to Appeal: If we decline action on a request related to your rights, you may have the right to appeal our decision.
- Right to Withdraw Consent: In circumstances where we require your consent, you have the right to withdraw it. Withdrawal does not affect the lawfulness of our data processing before your withdrawal.
- Verification and Declining Requests: We may need to verify your identity and California residency in certain cases. This may involve authenticating your account or matching provided information with our records. We may decline requests, particularly if identity cannot be verified or information is not located in our systems. Reasons for declining will be provided.
For European, UK, and Swiss Residents:
- You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner’s Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner For California Residents: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes.
Authorized Agents:
- In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice, where we can verify the authorized agent’s authority to act on your behalf.
To exercise these rights, contact us through the methods outlined in this CA Notice.
For requests related to knowing, deleting, or correcting personal data, we require the following for verification:
- Power of Attorney:
- A power of attorney valid under the laws of California from you or your authorized agent; or
- Sufficient Evidence:
- Evidence showing that you have:
- Provided the authorized agent signed permission to act on your behalf; and
- Verified your identity directly with us as per the instructions in this CA Notice; or
- Directly confirmed with us that you granted the authorized agent permission to submit the request on your behalf.
- Evidence showing that you have:
For Virginia Residents:
- You have the right to know if your personal data is sold or shared and the right to opt-out of such activities, particularly for targeted advertising.
- To Opt Out:
- Contact us through the methods outlined in the Contact Us section.
- Refer to the Control Over Your Information section of this Privacy Policy for detailed information.
CHILDREN
We do not intend to or knowingly collect personal data from children. We use the term “children” to refer to someone who is (a) under 13 years old or, if older (b) between 13 and 17 years old but under the age at which they can give valid consent to the processing of their personal data under applicable local or regional laws. In general, we do not intentionally or knowingly collect any personal data from children. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If you believe that we might have any information from or about children, please Contact Us.
INTERNATIONAL TRANSFER
All personal data collected or stored by Orange Wolf may be stored in various locations worldwide, including, but not limited to, the Republic of Turkey, the United States, and the European Union. When we transfer your personal data internationally, we will take reasonable steps to ensure its secure, lawful, and consistent treatment, as described here. It’s important to note that privacy laws differ across jurisdictions, and the laws applicable to where your personal data is transferred, stored, used, or processed may not offer the same level of protection as the laws in your resident country. For international transfers of personal data outside of Europe, we rely on appropriate or suitable safeguards recognized under applicable law. This includes adequacy decisions and adherence to standard contractual clauses. If you are using our Services from the European Union or other regions with laws governing data collection and use, please be aware that providing your personal data to us implies your consent for processing it in the locations mentioned above. By choosing to visit the Services or providing information to us, you agree that any privacy-related dispute or disputes concerning the terms outlined in this Privacy Policy will be subject to the laws of the Republic of Turkey. Adjudication of disputes related to our Services will be under the terms specified in the Orange Wolf Terms of Service.
SECURITY
The personal data you share with Orange Wolf is stored on servers located in secure facilities. These servers are safeguarded by protocols and procedures, including firewalls and data encryption, designed to maintain industry-standard security for such data. It’s crucial to note that, despite these measures, no server, computer system, communication network, or data transmission over the internet can be guaranteed to be 100% secure. While Orange Wolf is committed to safeguarding your personal data, we cannot ensure or warrant the absolute security of any personal data you transmit to us or through the Services. By utilizing the Services or providing personal data to us, you acknowledge and agree that we may communicate with you electronically concerning security, privacy, and administrative matters related to your use of the Services. In the event of a security system breach, we will make efforts to notify you electronically, either by posting a notice on the Services or sending an email to you.
LEGAL BASES (FOR EEA, SWISS AND UK USERS)
If you are an individual in the European Economic Area (EEA), Switzerland, or the United Kingdom, we collect and process your personal data only when we have legal bases for doing so under applicable EU, Swiss, or UK laws. The legal bases on that we rely are as follows:
- Contractual Necessity: We use your data to provide you with the Services you have requested and agreed upon, such as our games, customer services, chat functionality, and third-party social network connectivity.
- Legal Obligation: We process data to comply with legal obligations, such as maintaining records related to tax or responding to valid legal requests for certain data.
- Legitimate Interests: We use data for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services. This includes marketing, advertising, analytics, research, and optimization of our games and other Services.
- Consent: We rely on your consent for the collection of data stored on your device by our advertising partners and us. This includes device information, ad identifiers, IP address, country, and region. You provide this consent when installing our game, and you can withdraw it by uninstalling our games.
In this Privacy Policy, we have outlined how you can opt-out of certain types of processing. If processing is based on your consent, you can withdraw that consent at any time as described in this Privacy Policy. However, please note that if you continue to use our Services, we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you prefer that we do not collect any personal data about you, you should discontinue using our Services.
THIRD-PARTY WEBSITES
Our Services may contain links to third-party websites, plug-ins, and applications. This Privacy Policy applies only to our Services and does not govern the personal data practices of third-party websites and online services. We are not responsible for the privacy practices of other third parties. If you visit third-party websites, we recommend reviewing their respective Privacy Policies to understand their personal data practices.
RETENTION
We retain your data for the duration of your active account or as required to deliver the Services to you. If you request the removal of your personal data, we will retain the necessary information for our legitimate business interests, including compliance with legal obligations, resolution of disputes, and enforcement of agreements.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to update this Privacy Policy periodically, and any changes will be reflected on this page. The date at the beginning of the Privacy Policy will indicate the last update. In the case of significant modifications, we will notify individuals through email to their registered email address, prominent postings on our Services, or other suitable communication channels. The effectiveness of any new policy will begin on the date of publication.
CONTACT US
For detailed information collected under this Privacy Policy, you may contact us here: info@orangewolfgames.com. Address: Çifte Havuzlar Mah. Eski Londra Asfaltı Cad. Kuluçka Mrk. A1 Blok No: 151/1c İç kapı no: B34 Esenler/İstanbul/Türkiye