KVKK Aydinlatma Metni (Personal Data Protection Notice)
This notice is provided in accordance with the Turkish Personal Data Protection Law No. 6698 (KVKK) and is intended primarily for users resident in Turkey. If you are located in the European Economic Area, the United Kingdom, or any other jurisdiction governed by the EU General Data Protection Regulation (GDPR), please refer to our Privacy Policy, which contains the disclosures required by GDPR Articles 13-14 in addition to the information below.
1. Data Controller
PointArt Games is operated by an independent developer based in the Republic of Türkiye and acts as the data controller for the personal data processed through this platform. The primary contact channel for all data-controller requests and legal notices is [email protected].
2. Categories of Personal Data
- Identity data: Username, display name.
- Contact data: Email address.
- Transaction data: Game sessions, scores, progress.
- Technical data: IP address, browser information, session data.
- Visit attribution data: URL campaign parameters (utm_source, utm_medium, utm_campaign), the HTTP Referer your browser sends, and the URL of the first page you visited. Processed only to measure the effectiveness of marketing channels, on the legitimate-interest basis (Art. 5/2-f); does not include IP address or cookie identifiers.
- Legal data: Consent records, disclaimer acceptance logs.
3. Methods of Data Collection
Your personal data is collected through the registration forms you complete on the platform, the credentials you provide when logging in, the session and score data automatically generated while you play the game, and server logs (IP address, browser information, session data, etc.). Collection takes place wholly or partially through automated means in electronic form, in accordance with Art. 10 of KVKK.
4. Purposes of Processing
Your personal data is processed for: providing the gaming service, user authentication, game progress management, platform security, and legal compliance. Additionally, only if you explicitly opt in during registration, your data may be used to send commercial electronic messages informing you about updates to our games and other projects from the same developer. Marketing-purpose processing continues only for as long as your opt-in remains active.
5. Legal Basis
Processing is based on: explicit consent (Art. 5/1), contractual necessity (Art. 5/2-c), legitimate interests (Art. 5/2-f), and legal obligation (Art. 5/2-e).
6. Data Transfer
Your personal data is currently stored on servers located within the borders of Turkey and is not transferred to third parties, except as required by legal obligations. If a future change of infrastructure provider results in personal data being transferred abroad, you will be separately informed in accordance with Art. 9 of KVKK and, where required, your explicit consent will be requested.
7. Commercial Electronic Communication
In accordance with Law No. 6563 on the Regulation of Electronic Commerce (ETK), marketing-purpose commercial electronic messages may only be sent to you on the basis of the explicit opt-in you provide either (a) during registration via the optional checkbox, or (b) through an in-product notification prompt shown inside the logged-in dashboard. In-product notifications are not themselves commercial electronic messages — they are delivered as part of the service you are already using, and no email is sent before consent is obtained. This opt-in is strictly optional; if it is not granted, you will only receive system emails directly related to your account security and the use of the service (e.g. email verification).
You may withdraw your consent at any time, free of charge and without having to provide any reason. To do so, use the "unsubscribe" link included at the bottom of every marketing email, or reply to [email protected] with the word "UNSUBSCRIBE" in the subject line. Once your withdrawal is received, marketing communications to you will be stopped within the period stipulated by ETK.
8. Data Retention
Account, game and technical data is retained until you request deletion. To request deletion, contact us at the email below. Visit attribution data (UTM, referrer, landing page) is retained for at most 12 months from the date of the visit and is then deleted.
9. Your Rights Under KVKK (Art. 11)
You have the right to:
- Learn whether your personal data is processed.
- Request information about processing.
- Learn the purpose of processing and whether data is used accordingly.
- Know domestic or foreign third parties to whom data is transferred.
- Request rectification of incomplete or inaccurate data.
- Request deletion or destruction of data under Art. 7.
- Object to automated decisions that produce adverse effects.
- Claim compensation for damages caused by unlawful processing.
10. Governing Law and Jurisdiction
This Notice and any dispute arising out of or in connection with our personal data processing activities under KVKK shall be governed by the laws of the Republic of Türkiye, in particular by Law No. 6698 (KVKK). The İzmir Courts and Enforcement Offices (İzmir Mahkemeleri ve İcra Müdürlükleri), Republic of Türkiye, shall have exclusive jurisdiction over any such dispute. This clause does not affect your right to lodge a complaint with the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu) under KVKK Art. 14, which remains fully available to you.
11. Application Method and Contact
To exercise the rights listed above, you may submit your request through one of the following channels, in accordance with the Turkish "Communiqué on the Procedures and Principles of Application to the Data Controller":
- By sending a written request to [email protected] from the email address previously registered in the system,
- By submitting an application signed with a secure electronic signature or mobile signature,
- By submitting an application from a Registered Electronic Mail (KEP) address.
Your application must clearly state your identity information, the subject of your request, and your contact details. Your application will be answered within the period stipulated by KVKK.