Please note that Peak is not responsible for the actions of Third Parties, the content of their sites, the use of information you provide to them or any services they may offer.
3. Types of Personal Information We Collect and How We Use It
The types of personal information we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with Peak and the requirements of applicable law. Some of the ways that Peak may collect personal information include:
- you may provide personal information directly to Peak through interacting with the Services, participating in Services feedback, questionnaires, surveys, or contests or participating in forums discussions, and requesting services or information; and
- as you navigate the Services, certain passive information may also be collected about your visit, including through technologies as described below.
Primary goals in collecting information are to provide and improve our Services, to administer your use of the Services and to enable you to enjoy and easily navigate our Services. We endeavor to collect only that information that is relevant for the purposes of processing. Below are the ways we collect personal information and how we use it.
3.1 Types of Personal Information We Collect
Peak collects personal information regarding its current, prospective, and former customers, users, visitors, and guests (collectively “Individuals”).
3.1.1 Information Collected Directly from You:
Communications with Us. We may collect personal information from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us.
Communications with Other Users. You may send non-public messages or invitations to other players, made directly through our Services or through a third-party service, like Facebook. If so, we will collect whatever information you choose to send to the other users, and if you connect your third-party service’s account, we may collect information about the friends and contacts you are connected to through the third-party service. You are responsible for ensuring your sharing of this personal information with us is compliant with applicable laws. In some countries, this may require you to get permission from the people you invite before you share their information. We may also get personal information about you from other users. We process this personal information to help you and your contacts connect through our Services. If you want to remove personal information stored by us, follow any instructions in the Services or see Online Privacy Choices below.
User Reviews. From time to time, you may share your comments about our games and provide certain information that may include personal information. All information collected from your participation in such reviews is provided by you voluntarily. We may use such information to improve our products, Sites and/or Services and in any manner consistent with the policies provided herein.
Fan Pages, Forums, and Posting on the Site. Peak may offer publicly accessible fan pages, blogs, private messages or community forums. You should be aware that when you disclose information about yourself on Peak’s fan pages, blogs, private messages, and community forums, the Site will collect the information you provide in such submissions, including any personal information. We may keep such content on our servers to use it to protect the safety and well-being of our players; to protect our rights and property in connection with our Services; to conduct research; to operate, improve, personalize, and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this. If you choose to submit content to any public area of the Site, such content will be considered public.
Registration for Contests. Occasionally, Peak may run contests. We ask those who enter the contests to provide contact information (e.g., an e-mail address). If you participate in a contest, your contact information may be used to reach you about the contest and for other promotional, marketing and business purposes. All contest entry forms will provide a way for participants to opt out of any communications that are not related to awarding prizes.
A note on sensitive personal information. While we typically do not request sensitive or special categories of personal information you may choose to provide this information to us. The meaning of sensitive or special categories of personal information changes from region to region but could include information about your health or, in certain places, types of financial or precise location information. For some Services, we may also ask you to voluntarily provide information about any accessibility requirements you may have to better understand the needs of players and to improve the accessibility of our Services.
3.1.2 Information Collected from Third Parties when Installing and Playing the Games
If you play any of the games or use any of the Services on connected third-party applications or connect the Services to any third-party applications, like Apple, Google, Amazon and/or from Social Networking Sites (“SNS”) such as Facebook, Peak may receive certain information about you from the provider of the third-party application. The information received depends on the third-party application, your privacy settings and, if applicable, your friends' privacy settings on that third-party application.
When you connect with the Services through an SNS, the information that Peak collects may include your first and last name, your SNS user identification number and/or user name, location, sex, the login e-mail you provided to that third-party application when you registered with the SNS, language of your application, time zone and the SNS user identification numbers for your friends who are also connected to the Services.
We may sell Virtual Items or Merchandise through our Services. When you make purchases through the Services, we process your payments through a third-party application, including the Apple App Store, Google Play App Store, and Amazon App Store (together with any similar applications, “App Stores”) and SNS such as Facebook. The third-party application may collect certain financial information from you to process a payment on behalf of Peak, including your name, email address, address and other billing information. App Stores do not share this information they collect from you with us. Peak does not have access to your credit card or bank account data. However, third-party payment processors may share non-financial information with us related to your purchases, like the items purchased to fulfill your order.
You can manage the information Peak receives about you from a third-party application on which you play our games, like Facebook. You will need to follow the instructions from that third-party application for changing your privacy settings. You also can manage some aspects of information collection and use by visiting the settings page of your mobile device and reviewing the permissions of each application.
3.1.3 Automated Information Collection
When you use any of the Services, games or applications on a mobile platform, Peak may collect and record certain information 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”), the version of your operating system ("OS"), your device name, Game Center ID, and your location based on your Internet Protocol ("IP") address. This information is useful to Peak for troubleshooting and helps Peak understand usage trends.
We, our service providers, and our business partners use these cookies and other similar technologies within our games to collect and analyze certain kinds of technical information, such as your IP address, cookie identifiers, mobile advertising identifiers, your mobile device’s identifiers like your IDFA, Game Center ID, the type of mobile device you are using, your device's OS, version, model, hardware type and other device identifiers that are automatically assigned to your device, language, hardware type, operating system, Internet service provider, and other actions taken through use of the Services such as preferences. We may also collect the approximate physical location of your device. This data collection will be made clear by the operating systems that you are using the Services on.
In some cases, we will connect this information with your social network ID, Device ID, Game Center ID or IDFA.
We use “Google Analytics” to collect information about your use of the Services. Google Analytics collects information such as how often users access the services, what pages they access when they do so and what other sites, they used prior to using the services. We use the information we get from Google Analytics only to improve the services. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit https://www.google.com/policies/privacy/partners/ and the Google Analytics Opt-Out browser add-on page.
3.1.4 Social Media Widgets
3.2 How We Use Your Information
Our primary goals of using the information that we collect and store are to provide a better gaming experience, provide the Services to you, improve the Services, protect you and others, contact you, conduct marketing and research activities, create reports for internal use, for business continuity reasons and to comply with legal rights and obligations. We store information on servers located in the United States and in the European Union via Amazon Web Services and may store information on servers, cloud technologies and equipment in other countries.
The main reason we process your personal information is to provide you with Services and to improve your gaming experience, but there are other reasons as well. We collect, store, use and process personal information for a variety of business purposes, including:
- to operate, improve and optimize our games and other Services;
- to create game accounts and allow users to play our games;
- 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 that may be of interest to you;
- to notify you about rewards, surveys, contests or other promotional activities or events sponsored or managed by us or our business partners;
- to tailor and deliver advertising and marketing and promotional information to you;
- 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 our players;
- to measure interest in our Services;
- to send related information, including confirmations, technical notices, updates, and security alerts and support and administrative messages;
- to comply with our legal obligations, to resolve any disputes we may have with you or other players and to enforce our agreements with third parties;
- to conduct research;
- to ensure internal quality control; and
- to verify Individual identity.
Our legal grounds for collecting and using the information described above depends on what the information is, the context in which we collect it and applicable privacy laws. Those grounds are as follows:
- Establish and perform our contract with you (i.e., our Terms of Services);
- For our or our partners’ legitimate interests;
- Consent (where applicable);
- Compliance with a legal obligation;
- Protect your vital interests or those of another person (for example, another player); and
- While we typically do not collect sensitive or special category personal information, where we do this, it will be on the ground of consent or other applicable lawful basis.
If you have questions, need further information about the legal grounds for processing your personal information, or want to withdraw your consent please see the Contact Information section below.
4. How We May Disclose Your Information
We may share your information with third parties or allow third parties to collect this information from our Services in the following circumstances.
- Service Providers. We may share any information we receive with Service Providers. The types of service providers to whom we entrust personal information include Service Providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; (iv) customer service activities; (v) analytics; and (vi) in connection with the provision of the Services. As required by applicable data protection laws, Peak has executed appropriate contracts with the Service Providers that prohibit them from using or sharing personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners and Affiliates. Peak may share personal information with our business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with the Services that you have requested. Peak may also provide personal information to business partners with whom we may jointly offer products or Services. In such cases, our business partner’s name will appear, along with Peak. As required by applicable data protection law, Peak requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of personal information they maintain on our behalf and not to use it for any purpose other than the purpose for which Peak provided it.
- Displaying to Friends and Other Users. Our Services allow you to interact with other players. If you play our games through a social network or register through a social network (for example, Facebook Connect), your social network friends will see your name, profile photo and descriptions of your game activity. Similarly, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity, communicate with you within our Services if you use the chat feature of our games and view your game profile, which may include your name or a “game name” and your profile photo. In certain cases, your profile photo can reveal your social network ID or player ID, and access to a social network ID or player ID may allow others to view the public information associated with your related social network profile or the game account. Also, the content you post may be displayed in the chat feature of the Games. We are not responsible for privacy practices of the other users who will view and use the posted information.
- Third-Party Advertising Including Interest-Based Advertising. We use advertising to enable us to offer some of our games, game features, and other Services for free. These advertisements may include, without limitation, banner ads on game boards or Services themselves, as full-screen ads between moves or games, or through an “offer wall” in which third-party advertisers offer to provide virtual currency or other in-game items to players in exchange for watching an advertisement or for completing a task, such as signing up for an account with one of the advertisers, completing a survey, or finishing a particular game level. Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Peak.
We may share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services. We do not directly share personal information that identifies you with third-party advertisers for their advertising purposes unless you give us your consent, where legally required. To enable advertisers, ad networks, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:
- performance data (like the number of clicks on an advertisement);
- certain technical information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
- a unique identifier, such as your social network ID or Peak player ID; and/or
- other contextual data about your game play (like your level and session length).
In addition to serving you with relevant ads, the information collected may be used to:
- measure how effective ads are;
- offer you targeted advertising (both on and off our Services) in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as interest-based advertising or behavioral advertising); and/or
- undertake web analytics to analyze traffic and other player activity to improve your experience.
Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Peak or the social network through which you are playing Peak’s games.
- Security, Safety, and Compliance with Law. We may access, preserve, and disclose your personal information, other account information and content if we believe doing so is required or appropriate: (i) to satisfy any applicable legal obligations; (ii) when we have a good faith belief that we have to disclose personal information in response to lawful requests by public authorities, including for national security, law enforcement or legal process, such as a court order or subpoena; (iii) to respond to your requests; (iv) to protect your, our or others’ rights, property or safety; (v) to enforce Peak' policies or contracts; (vi) to collect amounts owed to Peak; (vii) 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 (viii) 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 the unauthorized activities.
5. Online Privacy Choices
Your privacy rights are explained below. These rights apply to information about you, and their scope and applicability can vary across different regions. For example, they could extend to your household or a legal entity or could be exercised by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times.
5.1 Accessing, Updating and Deleting Personal Information Held by Peak
Subject to certain exemptions, you and/or your legal representative have the right to:
- Request a copy of your personal information (known as ‘accessing your data’).
- Delete your information. When you ask us to delete your personal information, please remember that there may be lawful limitations on this right. For example, we will keep certain payment records or customer service records where we need to, including for legal or accounting purposes. We’ll also keep information in order to exercise, protect, defend, or establish our rights or the rights of third parties.
- Correct or update your personal information where it is inaccurate. To review and update personal information associated with your Peak player profile in certain games, visit the “settings” page in that game.
- Opt-out of marketing communications we send you by following the instructions in Opting Out of Promotional Communications below.
- Where applicable, withdraw your consent at any time directly in the Service or by contacting us. Withdrawing your consent will not affect the processing already undertaken before your withdrawal. Also, it will not affect processing of your personal information under other lawful grounds.
- Object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
- Ask that you are not subject to automated decision-making that has a legal effect or any other significant effect on you.
- Complain to a data protection authority. A list of privacy authorities is available here. In certain regions, you also have the right to request compensation if you suffer damage due to unlawful processing of your Personal Data.
For California residents, please also review our California Notice for additional rights. For Nevada residents, please see section 6.2 below.
To review and update personal information associated with your Peak player profile in our games, when otherwise permitted by applicable law, you and/or your legal representative can open a support ticket within the Games or, alternatively, send an e-mail to [email protected] to request access to, or rectification or erasure of personal information held about you by Peak. Please ensure that you and/or your legal representative include your full name, user identifier and a detailed description of your data request. Such requests will be processed in line with applicable laws.
Although Peak makes good faith efforts to provide Individuals with access to their personal information, there may be circumstances in which Peak is unable to provide access, including but not limited to when the information contains legal privilege, would compromise others’ privacy or other legitimate rights, when the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or when it is commercially proprietary. If Peak determines that access should be restricted in any particular instance, we will provide you and/or your legal representative with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Peak will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.
For deletion requests, we will take reasonable measures to delete your personal information from our records. If you have sent content through or posted content on the Service, we may not be able to delete it. We will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We’ll also keep information in order to exercise, defend, or establish our rights.
If you are located in the Republic of Turkey, you have the rights listed under Article 11 of the 6698 No. Law on Protection of Personal Data. Contact Us for your queries and requests.
5.2 Managing Personal Information We Receive from Third-Party Applications / Platforms And From Your Mobile Device
To manage the information Peak receives about you from a third-party application or platform where you play our games, like Facebook, Apple, Google, or Amazon, you will need to follow the third-party application’s instructions for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here .
You also can manage many aspects of information collection and use from your mobile device by visiting the “settings” page of your mobile device or web browser and reviewing the access permissions of each Peak game / application.
5.3 Opting Out of Promotional Communications
Push Notifications. Peak 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.
5.4 Opting Out of Third-Party Interest-Based Advertising
The online advertising industry provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these and also learn more about targeted advertising and consumer choice and privacy at Network Advertising Initiative Consumer Opt-Out Page or Your Online Choices and Digital Advertising Alliance Opt-Out Page for U.S.-based advertising . Please note that these opt out tools are provided by third parties, and Peak does not operate or control these tools or the choices that advertisers and others provide through these tools. These third-party opt-outs are browser and device-specific and will not apply to your use of Peak’s Services through other browsers or devices.
If you do not want to receive personalized in-application advertisements from third parties on your mobile device, you may exercise that choice by visiting your mobile device’s “settings” menu and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”). Certain apps, such as the Digital Advertising Alliance’s “AppChoices” app can help you exercise your behavioral advertising choices and are available from some platform providers (such as Apple or Google). Like the opt out tools mentioned above, these opt out tools are provided by third parties, and Peak does not operate or control these tools or the choices that advertisers and others provide through these tools.
To be clear, whether you are using our opt out or an online industry opt out, these opt outs must be performed on each device that you wish to have opted out. Please note that you may still receive third-party advertisements in the Services after using these opt-out tools, but the advertising you see may be less relevant to your interests.
6. Region-Specific Notices
If you are a California resident, you may be able to exercise additional rights granted by California law in relation to the personal information about you that we have collected (subject to certain limitations). For additional information concerning these rights, please review our California Notice .
Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. If you are a Nevada resident, you may exercise this right by submitting such a request to us at [email protected] .
7. International Transfers
All personal information collected via or by Peak 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 information internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner we describe here. For example, in European Countries, this may include transferring personal information to countries deemed safe by the European Commission, implementing the European Commission’s Standard Contractual Clauses or using another approved mechanism for transfers of personal information between our business partners and service providers (where applicable).
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 Peak, you acknowledge the storage of your personal information in these locations.
8. Data Retention
We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.
9. Children’s Privacy
Our Services are not marketed to, or intended for, children. For these purposes, we use the term "children" to refer to someone who is: (a) under 13 years old or, if older, (b) between 13 and 18 years old but under the age at which they can give valid consent to processing of their personal information under applicable data privacy laws. Peak strives to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our Services. Peak does not knowingly collect Personally Identifiable Information from children. If you are a parent or legal guardian of a child who uses our games, please contact us at [email protected]. We will delete your child’s personal information if we are able to identify your child unless you provide us with your verifiable consent for your child to continue to use our games.
11. Contact Information
For purposes of data protection laws, Peak Oyun Yazilim ve Pazarlama AS is the “data controller” of your personal information.