Supplemental EEA+ Privacy Statement
Last updated: April 17, 2025
We are Catchy Yazılım Limited Şirketi (“Company”). This Supplemental EEA+ Privacy Statement (“Statement”) applies only to individuals located in the European Economic Area (EEA), United Kingdom (UK), and Switzerland (collectively, “EEA+”). It supplements our Catchy Yazılım Privacy Policy and describes how we process your personal data when you use or interact with our website, online advertisements, and mobile games (collectively, our “Services”). If there is any inconsistency between the Catchy Yazılım Privacy Policy and this Statement, this Statement controls for EEA+ residents.
If you are in the EEA, the EU General Data Protection Regulation applies. If you are in the UK, the UK GDPR applies. References to the “GDPR” below include both regimes. If you are in Switzerland, the Swiss Federal Data Protection Act applies, and references to the GDPR should be interpreted analogously.
1. Data Controller
Data Controller:
Catchy Yazılım Limited Şirketi
Üniversiteler Mahallesi, İhsan Doğramacı Blv.
ARGE ve Eğitim Merkezi No: 13
06800 Çankaya / Ankara / Türkiye
2. Data Protection Officer
You may contact our Data Protection Officer at [email protected].
3. Personal Data Collected & Sources
See Section 2 of the Catchy Yazılım Privacy Policy. We also use cookies as described in our Cookie Policy.
4. Purposes of Processing & Lawful Bases
We process personal data for the purposes listed below, relying on the indicated GDPR legal bases:
| Purpose | Legal Basis |
|---|---|
| Personalize your in‑game profile, provide games (including social/team features), activate purchases, and provide player support. | Contract Performance (if you have a contract or we’re preparing one) or, otherwise, Legitimate Interest (to optimize, personalize, and secure Services, and for quality control). |
| Optimize games and deliver customized in‑game events, offers, and promotions. | Contract Performance or, otherwise, Legitimate Interest (to improve user experience and ensure Service security). |
| Verify identity and entitlement when you contact or access our Services. | Contract Performance or, otherwise, Legitimate Interest (to prevent fraud and enforce Terms). |
| Maintain safety, security, and integrity of our Services and technology. | Legitimate Interest (to protect our platforms and users). |
| Manage organization and operations, conduct surveys, develop new games/Services, enable player communications, measure interest, and perform analytics. | Legitimate Interest (to operate and improve our business and Services). |
| Communicate confirmations, technical notices, updates, security alerts, support and administrative messages. | Contract Performance (if contractually required), Legal Obligation(if required by law), or, otherwise, Legitimate Interest (to manage our relationship with you). |
| Comply with laws, prevent fraud, enforce our Terms, and defend legal rights. | Contract Performance (if contractual), Legal Obligation (where mandated), or Legitimate Interest (to enforce legal rights). |
| Activate, verify, and enforce parental control settings. | Contract Performance, Legal Obligation, or Legitimate Interest (to comply with regulations and protect minors). |
| Evaluate and enter into reorganizations, mergers, acquisitions, or asset sales (“Business Transaction”). | Legitimate Interest (to pursue business efficiency); if new, incompatible purpose arises, we’ll seek Consent. |
| Serve and measure targeted advertising (via non‑essential cookies and identifiers). | Consent (you may withdraw at any time via our website/app settings or by emailing us). We disclose identifiers (IDFA/Google Ad ID), IP addresses, Service usage, timestamps, and inferred interests to our AdTech Providers. |
| Provide essential website functionality (via essential cookies). | Contract Performance (if you’re a user) or Legitimate Interest (to deliver a functioning Service). |
You may withdraw consent at any time for processing based on consent (future effect only) via our in‑Service consent settings or by emailing [email protected].
5. Legitimate Interests
Where we rely on Legitimate Interest, those interests include optimizing and personalizing our Services, securing our platforms, conducting quality control, operating and improving our business, and defending our legal rights. You may request further details of our balancing test by contacting our DPO.
6. Recipients of Personal Data
We may share your data with:
- Other Users: your public profile, scores, achievements when you participate in online communities.
- Contest/Sweepstakes/Survey Providers: to run promotions.
- Service Providers: IT, customer support, analytics, and other vendors under contract.
- Legal & Safety: law enforcement, legal advisors, or to protect rights under court orders or investigations.
- AdTech Providers: with your consent for targeted advertising (see Cookie Policy).
- With Your Consent: e.g., testimonials.
- Business Transaction Parties: potential acquirers or their advisors.
7. International Data Transfers
Personal data may be transferred to processors and AdTech Providers in Türkiye, the United States, Israel, the EU, and the UK. We use EU and UK Standard Contractual Clauses or equivalent safeguards. You may request copies by contacting our DPO. The UK, EU, and Israel are recognized as providing an adequate level of protection.
8. Data Retention
We retain personal data only as long as necessary for its collection purposes, legal compliance, defending legal rights, or fulfilling court/authority requests. When no longer required, we delete or anonymize it.
9. Your Rights
Under the GDPR (and Swiss FDPA), you have the right to:
- Access confirmation of processing and copies of your personal data.
- Rectify inaccurate data.
- Erase data when no longer needed or unlawfully processed.
- Restrict processing for certain purposes.
- Object to processing based on Legitimate Interest or for direct marketing.
- Data Portability of data you provided.
- Withdraw Consent without affecting prior processing.
- Lodge Complaint with a supervisory authority (EEA/UK).
- Post‑mortem Instructions (in some jurisdictions).
Supervisory authority contacts:
- EEA: https://edpb.europa.eu/about-edpb/about-edpb/members_en
- UK ICO: https://ico.org.uk/global/contact-us/
- Switzerland FDPIC: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
Submit requests to [email protected] or in writing to our address above. We will verify your identity before responding.
10. Provision of Data
You are not legally required to provide personal data, but without it, we cannot provide our Services.
11. Updates
We may revise this Statement. Updates will appear here with a new “Last updated” date.