1. Purpose
Fugo Bilişim Teknolojileri ve Yazilim Ticaret Anonim Şirketi ('Fugo,' 'we,' 'us') is the data controller responsible for processing your Personal Data. Should you have any questions regarding the processing of your Personal Data, please contact our Data Protection Officer (DPO) at privacy@fugo.com.tr. This Privacy Policy is part of the Fugo Terms of Service ("Terms of Service"). This Privacy Policy explains our online and offline practices regarding the data, the types of the data that we collect, our intention to use, store, protect, disclose, and share this data, how you can waive your consent for this data, and how you can exercise your data subject rights.
2. Extent
Fugo's websites (each referred to as the "Site"), mobile applications, forums, blogs, and other online or offline services it offers (as well as all services currently, online or offline ("Services") and the Personal Data processed in the workflow are subject to this Privacy Policy.
If you do not agree with this Privacy Policy, we recommend that you do not install or use Services.
Fugo does not share Personal Data with third parties for their own purposes. We may share data with service providers who process data on our behalf, such as for data storage, fraud detection, and security. Any such service provider must be approved by Apple where applicable, and we contractually require them to restrict further sharing of the data and to use it only as instructed by us for the specified purposes. Additionally, Apple receives data related to gameplay activities.
Fugo is not responsible for the actions of third parties, the content of websites, the data you provide to such third parties or the use of services provided by third parties.
3. Apple Arcade
This section describes the privacy practices specific to our titles available on Apple Arcade. These include: Words of Wonders: Search+ (“Games”).
All collected data is stored locally on your device or in private Apple iCloud containers. Your information is not shared with any third parties. We do not use third-party analytics, advertising, or tracking tools in our Games for Apple Arcade.
For Arcade titles no data is sent off your device except for iCloud and Game Center services. You can learn more about Game Center and privacy by going to www.apple.com/legal/privacy/data/en/game-center. You can learn more about iCloud privacy by going to www.apple.com/legal/privacy.
3.1. Information We Collect
We collect limited information about you in our Games for Apple Arcade. This includes all data that is sent off of your device to our servers, as well as data collected for short-term transient use. We are required to obtain your permission to collect any data generated by you, including information that relates to you as an identified or identifiable individual or that is linked or linkable to you by us. The information we collect includes:
3.1.1. Game Profile Information
Your Game Profile tracks your progress locally on your device in the Game for Apple Arcade, including unlocked features, levels played, achievements earned, the last time you played, and the boosters used. This profile may be stored on Apple’s servers to enable seamless gameplay across your supported devices.
3.1.2. Gameplay and Performance Data
Games collect aggregated, non-personal gameplay data on your device locally to help analyze trends, and optimize the game experience. This includes loading times, fps rates, in-game interactions, and crash reports.
3.1.3. Customer Support Data
If you contact us for support, we collect the personal information you provide in your request, including your email (if applicable), issue details, and troubleshooting logs. We use this data to respond to your inquiries, provide support, and improve our Games for Apple Arcade. Non-personal issue reports may be shared with our development team to enhance gameplay and fix potential issues. The personal data collected will be deleted once the issue is solved.
3.2. How We Use the Information We Collect
We use the information we collect for the purposes outlined below. Where we collect personal information, we may use your personal information only for the purposes we state when obtaining your permission.
3.2.1. Game Functionality & Progress Tracking
Ensuring your progress, unlocked content, and settings are maintained and accessible across Apple devices.
3.2.2. Game Performance & Experience Improvement
Identifying gameplay issues, improving performance, enhancing game features, and ensuring a smooth gaming experience based on locally stored performance and gameplay data.
3.2.3. Customer Support & Troubleshooting
Providing assistance with technical issues and fixing any problem users may encounter.
4. Types of Personal Data We Collect and How We Utilize Them
Fugo collects Personal Data in a variety of ways, including:
You may provide your Personal Data to Fugo directly by interacting with Services, during events such as service feedback, surveys or contests, or by requesting Services.
Some data can be collected passively through cookies and similar technologies described below through browsing Services.
Our main aim in collecting your data is to provide and improve our Services, manage your use of our Services, and enable you to use our Services with pleasure and ease. We endeavor to collect only data relevant to the purposes of the Processing. We explain below in what ways we collect your Personal Data and how we use it.
4.1. Types of Personal Data We Collect
Fugo collects Personal Data about its current, prospective and former customers, users, employees, job candidates and visitors of Sites (collectively referred as "Parties").
4.1.1. Data We Collect from Third Parties While Downloading and Playing Games
From mobile platform providers (iOS) during playing our games or when you use our Services via mobile platform, we collect and save some data. The data we collect and record depends on the data sharing policy of the mobile platform, the permission you have given to this platform and your privacy settings.
Data collected by Fugo includes your game profile information and customer support data. The game profile information may include data such as your current level, unlocked features, daily progress, the preferred language in the application and the time zone.
Fugo can collect data including your operating system ("OS") version and game center Identifier if you use our Services, games or apps on a mobile platform. This data is beneficial for resolving issues with our Services and helps us understand your user trends.
Fugo does not collect, store, or use your payment information, including your address, credit card number, telephone number, and e-mail address that you share with third parties during the payment process. Fugo does not have access to your data about credit card or bank account.
You can manage the Personal Data we collect from third-party applications. For the management of your Personal Data you need to follow the instructions to change your privacy settings in the application you used. You can also manage the collection and use of data by visiting the "settings" page of your mobile device and editing the permissions you have granted for each "application".
If you access or connect to our Services through a third-party application, you may also need to read the application's terms of service and privacy policies.
4.1.2. Direct Collection of Data
If you use Services or create an account for our games, provide feedback, request services or data, or contact us directly, we may ask you to provide all or some of the following data:
Creating Account: if you create an account to use our services, we may ask you for Personal Data such as your name, email address, and profile data.
Contacting Us: if you request data about our Services, request customer support or technical support, or contact us, we may collect Personal Data from you, such as your e-mail address, telephone number, or postal address.
User comments: When sharing your comments about our games, you may share some data, which may include your Personal Data. All data obtained from your participation in these comments are the data you provide voluntarily. We may use this data in any way in accordance with the policies contained herein to improve our products, sites and/or Services.
Fan Pages, Forums, and Site Posts: Fugo may offer publicly accessible fan pages, blogs, private messages, or community forums. You should be aware that if you disclose data about yourself on Fugo's fan pages, blogs, private messages, or community forums, the relevant sites will collect this data, including Personal Data. If you choose to provide content anywhere on the Site that is available to the public, that content will be deemed "public" and will not be subject to privacy safeguards.
Contest Applications: Fugo may hold competitions from time to time. We ask contest participants to provide their contact data (e.g., participant's e-mail address). If you participate in a contest, we may use the data collected from you to contact you about the contest or for promotional, or other commercial purposes. All contest entry forms give participants the option to opt out of all communications that are not related to the prize.
4.1.3. Data Offered Through Services
You agree that we are free to use the ideas, inventions, concepts, techniques, know-how, and other data contained in the content of your communication through Services for purposes such as developing, producing, and/or marketing Services. Fugo, (a) you give your consent to do so; (b) will not disclose your name or name about the materials or other data you submit, except where we have notified you in advance that materials or other data you submit about a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required by law to do so. Will not otherwise disclose that the data was submitted by you.
4.2. How We Process Your Data
We aim to process the data we collect and store mainly to improve your gaming experience, to provide Services, to improve Services, to contact you, and research activities and to generate reports to be used within Fugo. We store data on Apple servers located in the United States in private containers. We may also store your data on servers, cloud technologies and equipment located in other countries.
We may collect, store, use and process Personal Data for a variety of business purposes, including:
Providing Requested Services or Data
We may use the data about you that we collect through Services to provide Services to you, including but not limited to the following:
Fugo may use your data to inform you about offers, products, and Services that may be of interest to you, such as new games, content, or Services. Fugo may use materials such as in-game offers, push notifications, or e-mail to:
With the opt-out link provided in the correspondence from the relevant notification materials, you can choose to turn off the notifications from the options section from the mobile device, or by sending an e-mail to privacy@fugo.com.tr, without incurring any cost.
Sending Push Notifications
Fugo may occasionally send you push notifications via Fugo's mobile apps for game updates and notifications about high scores and services that you may find important. You can opt out of receiving such communications at any time by turning off such communications in the settings section on your device.
Usage of Anonymized and Aggregated Data
Personal Data and other data about you; demographic and local data, data about the computer or device you use to access our Services, we may use to create anonymous and aggregated data that cannot be identified, and to perform other analysis. Anonymized and aggregated data is used for a variety of functions, including measuring visitors' interest in various parts and features of Services and their use of those parts and features. Anonymized or aggregated data is not Personal Data and we may use it in a variety of ways, including for research, internal analysis and analytical purposes, or other purposes permitted by law. We may share this data within Fugo and with Third Parties for our or their purposes by anonymizing or aggregating this data in a manner designed to prevent you from being identified by anyone.
Providing Services via Mobile Devices
From time to time, we may offer Services that are specifically designed to be compatible with and used on mobile devices. When you use these Services, we may collect certain data sent from your mobile device, such as device identifier, user settings, location data, mobile service provider and your device's operating system. For mobile versions of our games, users may need to log in with their Account. In these cases, data about mobile versions of our Games may be associated with Accounts.
4.3. Third Party Websites, Social Media Platforms and Software Development Kits
Our Site may contain links to other websites, and other websites may also reference or link to our Site or other Services. These other domains and websites are not controlled by us, and we do not endorse, review, or endorse the privacy practices or content of other websites or apps, and also we are not responsible for them. We encourage our users to read the privacy policies of every website and application they interact with. Visiting these other websites or applications is at your own risk.
Fugo Services may host public blogs, community forums, or private messaging. Our Site and other Services may contain links to various social media platforms and interactive features (such as items). If you are already using these platforms, their cookies may be placed on your computer when you use our Site or other Services. Others may view and use Personal Data that you voluntarily disclose and transmit on a public blog, chat room, social media platform or online, or share in an open forum, without restriction. When you interact with a social media platform, we cannot prevent the use of your data in this way, and when you use these services, you assume that the risk that the Personal Data you share will be used by third parties for many purposes.
5. How We May Disclose Your Data
Third-Party Websites, and Software Development Kits
We may share your data as stated in this Privacy Policy (with our Third-Party service providers to provide our Services; to protect and defend our rights and property) or with your consent to comply with legal obligations.
Service Providers: We may share the data with service providers that we obtained. The types of service providers (processors) with which we share Personal Data include:
Fugo has signed appropriate contracts with service providers in order to perform the contractual services of the Personal Data, to provide Services in accordance with the applicable law, and not to use or share the Personal Data other than necessary.
Business partners: Fugo may share Personal Data with its business partners or affiliated companies for its or its affiliates' commercial purposes or to provide you with Services that are requested. Also, Fugo may share Personal Data with business partners with whom it offers products or Services. In such cases, the name of our business partner will be displayed next to Fugo. Fugo requires its affiliates and business partners to agree in writing to keep the Personal Data they hold on behalf of Fugo confidential and secure and not to use it for purposes other than the purpose for which Fugo has provided this data to them.
Protected Posts (e.g., disclosures required by law and similar Disclosures).
We may access, store or share your Personal Data, other data, and content related to your account, only if to ensure that we access, store, or disclose your Personal Data, other data and content related to your Accounts:
Moreover, server logs may be reviewed for security purposes from time to time. (e.g., determine whether unauthorized activities have been performed on Services). In this situation, data containing IP addresses in server logs of unauthorized activities may be shared with law enforcement so that they can identify users in connection.
Merger, Sale, and Other Asset Transfer: If we are the subject of a merger, acquisition, financial due diligence, restructuring, bankruptcy, appointment of a trustee, sale of company assets or transfer of services to another service provider, your data may also be sold or transferred as part of that transaction as permitted by law and/or contract. In this case, Fugo will endeavor to direct the transferee to use Personal Data in a manner consistent with the Privacy Policy in effect at the time such Personal Data was collected.
6. International Transfer
Your Personal Data will be transferred to Fugo for storage and processing in Turkey, the United States, or any other country in the cloud, on our servers, on the servers of our affiliates, or on the servers of our service providers. We rely on your consent or Article 49 of the GDPR for transfers of data collected from Data Subjects in the EEA and the UK.
Personal Data collected from Quebec will also be transferred outside of Canada to Fugo for storage and processing in Turkey, the United States, or any other country in the cloud, on our servers, on the servers of our affiliates, or on the servers of our service providers.
While such data is outside of your country of residence, it is subject to the laws of the country in which it is held and may be subject to disclosure to the governments, courts, law enforcement, or regulatory agencies of such other country, pursuant to the laws of such country.
We will protect all Personal Data we obtain in accordance with this Privacy Policy and take reasonable steps to ensure that it is treated lawfully.
Emails Communications
You can choose to opt out of Fugo newsletters and special offers at any time by clicking the unsubscribe link at the bottom of the email to avoid receiving further emails. After receiving such a request, we will process it within a reasonable time. We remind you that you will continue to receive emails in connection with transactions about the requested products and Services.
Mobile Devices
Sometimes, Fugo may send push notifications about game updates, high scores, and other topics you may be interested in via its mobile apps. You can always opt-out of receiving such communications (opt-out) by changing the settings on your mobile device. Also, Fugo may collect location data if you use its mobile applications. You can prevent this data from being collected by changing the settings on your mobile device.
7. U.S. State Privacy Rights
Certain states (i.e., California, Colorado, Connecticut, Virginia, Utah) provide specific rights to their residents as listed below. While we will attempt to respond to a request from any U.S. resident, we reserve the right to deny requests if allowed under applicable law.
Your Right to Know
Certain states provide the right to request our disclosure of any of the following:
You can do this through something called a "Verified Consumer Request." The process of submitting a Verified Consumer Request is described below in the section "How to Exercise Your Rights."
Your Right to Request Correction of Inaccurate Personal Data
Certain states provide you the right to request correction of inaccurate Personal Data maintained by us. We may request documentation from you to determine the accuracy of the data. If you provide us with documentation either upon our request or through your own initiative, that documentation will only be used for the purpose of correcting your Personal Data and complying with our record-keeping requirements.
As an alternative to correction, we may delete the inaccurate data if it does not negatively impact you or if you consent to this deletion. We reserve the right to deny a request for correction if allowed under applicable law or if we determine that the contested data is more likely than not accurate based on the totality of circumstances. You can submit a correction request through a Verified Consumer Request. That process is described below in the section "How to Exercise Your Rights."
Your Right to Request Deletion of Your Personal Data
Certain states provide the right to request that we delete any of your Personal Data, subject to certain exceptions. You can do this through a Verified Consumer Request. That process is described below in the section "How to Exercise Your Rights."
There may be scenarios where we deny your deletion request. If that occurs, we will explain why we could not delete all or some of your Personal Data.
Please note that if you request the deletion of your Personal Data, you will lose access to your in-game progress, in-game currencies, and any data that personalizes your experience to enhance gameplay. This may affect your ability to continue where you left off and may result in a more generic game experience.
How to Exercise Your Rights
You may exercise your rights by submitting a Verified Consumer Request to know data (and to receive your Personal Data in a portable format), to correct data, or to delete your data.
The response to a request to know will provide all Personal Data collected and maintained about you for the 12 months preceding the date of your request in a portable format, unless your request covers a more extended period, to the extent allowed under the law. Please note that we may deny requests made more than twice in a 12-month period. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request. We will only use the Personal Data provided in your Verified Consumer Request to verify the identity or authority of the requestor.
You can submit a Verified Consumer Request by emailing privacy@fugo.com.tr. Your request will be verified using the data you provide as described on the web form. If you submit your Verified Consumer Request by phone or email, you will be asked to provide the same data requested on the web form for verification purposes.
If you submit a request that is not through one of these designated methods or is deficient in some manner unrelated to verification, we will provide you with data on how to correctly submit the request or remedy any deficiencies.
Once we receive your Verified Consumer Request, we will confirm receipt of the request within 10 business days and describe our verification process. If we are able to verify your identity, we will respond to your request within 45 calendar days. Requests for deletion will require a separate confirmation that you want your data deleted.
Using an Authorized Agent to Submit a Request
California: Only you, or a natural person or a business entity registered with the Secretary of State to conduct business in California that you have authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data to opt-out of sale or sharing, or to limit the use or disclosure of your sensitive Personal Data. If you use an authorized agent, you may provide a power of attorney executed pursuant to California Probate Code sections 4000 to 4465. If a power of attorney that meets those provisions is not submitted, you will be required to provide the authorized agent signed permission to submit a request to verify your identity directly by submitting a verified consumer request according to the procedures in the section "How to Exercise Your Rights," and directly confirm with us that you provided the authorized agent permission to submit the request. To submit authorized agent documentation, contact us at privacy@fugo.com.tr.
Other States: If you use an authorized agent, you may provide a power of attorney executed pursuant to applicable state law. If a power of attorney is not submitted, you will be required to provide the authorized agent signed permission to submit a request to verify your identity directly by submitting a verified consumer request according to the procedures in the section "How to Exercise Your Rights," and directly confirm with us that you provided the authorized agent permission to submit the request by emailing us at privacy@fugo.com.tr or calling [+90 212 229 1759].
8. Your Data Protection and Privacy Rights and Choices in the European Economic Area and the United Kingdom
If you are in the UK or within the EEA, or if you use our service from one of these countries, you have the following rights, which you can exercise at any time:
You can exercise your rights by creating a support request within our games or email to privacy@fugo.com.tr. We kindly ask you to write your full name, user identifier and e-mail address associated with your Account and explain your request for data in detail. These requests will be handled in accordance with applicable law.
9. Retention Periods
The period of time for which we retain data depends on the purposes for which we collect or use that data. We will delete or de-identify data when it is no longer needed to fulfill the purposes listed for each category above unless a longer retention period is required to comply with applicable laws. There may be technical or operational reasons where we are unable to fully delete or de-identify your data. Where this is the case, we will take reasonable measures to prevent further processing of your data. For our Apple Arcade games, since only iCloud containers are used, the data retention period is determined by Apple's policy.
10. Data Security
The Personal Data you provide to us is stored on servers located in secure facilities and is protected within the framework of protocols and procedures designed to ensure the security of such data in accordance with industry standards, such as firewalls and data encryption. However, no server, computer, communication network or system, or data transmission over the Internet can be guaranteed to be 100% secure. Therefore, as Fugo, although we take all kinds of technical measures to protect user data and make great efforts to ensure data security, we cannot absolutely guarantee the security of the data you transmit to us or that you share through Services.
When you use Services or provide Confidential Data to us, you agree that we may communicate with you electronically regarding security, privacy, and governance matters relating to your use of Services. If we become aware that a security system has been breached, we may notify you electronically by posting a notice on Services, emailing you, or sending a push notification.
11. Children’s Privacy
At Fugo, we acknowledge the necessity of enhancing privacy protections for the personal information we collect from children on our websites and applications. "Children" are defined as individuals whom we identify as being below the legal age to consent to the collection and processing of their personal information. The term “children” refers to individuals under 13 years of age. Our services do not allow children under 13 to make their Personal Data publicly available. We have strict measures in place to prevent public posting of any Personal Data by children on our platforms.
In our efforts to protect the privacy of children when intending to collect their personal information, we undertake additional measures, including:
If you are a parent or guardian and believe that your child under the age of 13 has provided us with Personal Data without your consent, you have the right to contact us to request the review, modification, or deletion of this data. You can make such requests by emailing us at privacy@fugo.com.tr.
Upon receiving a request related to a child’s Personal Data, we will take steps to verify the identity of the requesting parent or guardian to ensure that they have the authority to make the request. Upon verification of your identity and relationship to the child, we will promptly remove the child’s Personal Data from our databases, except in cases where you certify that your child will continue to use our services under your consent and supervision.
New Scheme for Usage of Personal Data
In addition to the above, we will endeavor to notify you of the new purpose and give you the opportunity to opt out before we use Personal Data for new purposes that you did not originally authorize. In other cases where the law or a contract requires the consent of the Person for the Processing of Confidential Data, Fugo will endeavor to comply with the law or contract.
12. Contact for More Information
If you have any questions or comments about this notice, the ways in which we collect and use your data, your choices, and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:
13. Changes to This Privacy Policy
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes, we will post the updated Policy on the website and update the effective date. Please periodically review this Policy when you use our platform.