PRIVACY POLICY.
LAST UPDATED: JULY 2, 2026
1. Introduction
Welcome to TWIMH Games. We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, process, use, store, and share your personal data when you use our mobile games, websites, customer support, forums, social media channels, or other services we offer (collectively referred to as the "Services").
By accessing, downloading, or using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms outlined here, please do not use our Services.
2. Data Controller
For the purpose of data protection laws, including the Turkish Personal Data Protection Law No. 6698 ("KVKK"), the General Data Protection Regulation ("GDPR"), and other local privacy regulations, the data controller is:
TWIMH Yazılım Teknolojileri Anonim Şirketi
Email: support@twimhgames.com
Registered Address: Elazığ, Turkey
3. Data We Collect
We collect different categories of information depending on how you interact with our Services. The types of personal data we collect include:
A. Automatically Collected Data
- IP address and coarse location (country/city level).
- Device ID, Advertising ID (IDFA for iOS, GAID for Android).
- Device properties (brand, model, screen resolution, OS version, language, connection type).
- Usage data (time spent in-game, features used, levels completed, gameplay preferences).
- Crash reports and application performance logs.
B. Data You Provide to Us
- Your name, username, or email address (when contacting customer support).
- Communications sent to our customer support or legal teams.
- Information submitted in connection with surveys, contests, or sweepstakes.
- Job applicant data (CV, experience, contact details).
Note on Financial Information: All in-app purchases are handled securely through third-party platforms (Apple App Store or Google Play Store). We do not collect or store your payment details, credit card numbers, or billing addresses.
5. How We Collect Data
We gather data in three main ways:
- Directly from you: When you submit support queries, send emails, or apply for a position.
- Automatically within our games: When you play, our applications automatically record metrics using SDKs and APIs built into the games.
- From Third-Party Partners: Including app store distributors (Apple/Google), analytics providers (such as Google Analytics/Firebase), and mobile advertising partners.
6. Purpose & Legal Bases of Processing
We process personal data based on several legal grounds under the GDPR and KVKK:
Performance of a Contract
To deliver game services, store game progress, process support cases, and allow you to make in-app purchases.
Legitimate Interests
To improve our Services, analyze player behavior, prevent fraud/cheating, optimize performance, and display customized advertising.
Legal Obligation & Right Protection
To meet corporate compliance, satisfy statutory responsibilities under Turkish law (such as tax compliance), and defend against legal claims.
7. Interest-Based Advertising
We show third-party advertisements in our free-to-play games to support game development. These ad partners collect device identifiers (such as IDFA and GAID) and usage logs to serve interest-based, personalized ads.
You can opt out of interest-based advertising on mobile devices by adjusting your privacy settings:
- iOS Devices: Go to Settings > Privacy & Security > Tracking, and toggle off permissions for the app, or choose to turn off "Allow Apps to Request to Track".
- Android Devices: Go to Settings > Privacy > Ads, and select "Opt out of Ads Personalization" or "Reset Advertising ID".
8. Data Sharing & International Transfers
We do not sell your personal data. We may share information with trusted third-party service providers who assist us in operating our business, such as:
- Cloud infrastructure and database providers (e.g., AWS, Google Cloud).
- Analytics tools (e.g., Google Analytics, Firebase, GameAnalytics).
- Mobile advertising networks and mediation platforms (to show in-game ads).
- Legal authorities if required by law or to protect rights and safety.
International Data Transfers: Because our servers and subprocessors operate globally, your information may be transferred outside of Turkey or the EEA. We ensure that appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) and satisfying KVKK conditions for cross-border data transfer.
9. Data Retention & Security
We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy or to comply with applicable laws. For example, technical logs may be deleted or anonymized within a short period, while customer support histories are kept as required for legal protection.
We implement industry-standard physical, technical, and administrative security measures to prevent unauthorized access, alteration, disclosure, or destruction of your data. While we strive to protect your information, no online storage or transmission is 100% secure, and we cannot guarantee absolute security.
10. Your Legal Rights
You hold several legal rights concerning your personal data. The exercise of these rights depends on your geographic location.
A. Rights under Turkish KVKK (Article 11)
Turkish citizens have the right to:
- Learn whether personal data is processed, and request information if processed.
- Request correction of incomplete or inaccurate data.
- Request deletion or destruction of data under lawful conditions.
- Object to analysis carried out solely through automated systems leading to unfavorable results.
- Claim indemnification for damages due to unlawful processing.
B. Rights under GDPR (EEA/UK Players)
European residents have the right to:
- Access, rectify, or request erasure of your data.
- Request restriction or object to the processing of your data.
- Request data portability.
- Withdraw consent at any time (where processing is based on consent).
- File a complaint with a local data protection supervisory authority.
To exercise any of these rights, please contact us at support@twimhgames.com. We will respond to your requests in accordance with applicable statutory timelines.
11. United States Privacy Rights
Under US state laws (including California's CCPA/CPRA, Virginia's VCDPA, and others), residents have specific rights regarding their personal information:
- Right to Know & Access: Request details on the categories of personal data collected, shared, or sold.
- Right to Delete: Request deletion of your collected personal information.
- Right to Correct: Request modification of inaccurate personal information.
- Right to Opt-Out: Opt-out of the "sale" or "sharing" of personal data for targeted behavioral advertising. You can do this via device tracking settings.
- Right to Non-discrimination: We will not discriminate against you for exercising your privacy rights.
If you wish to submit a state-specific privacy request, please email us at support@twimhgames.com.
12. Children's Privacy
Our Services are not intended for or directed to children. We do not knowingly collect or solicit personal data from anyone under the age of 13 (or under 16 in certain European jurisdictions) without verified parental consent.
If we discover that we have inadvertently collected personal data from a child under the minimum legal age, we will take immediate steps to delete that data as quickly as possible. If you believe we have data from a child, please notify us at support@twimhgames.com.
13. Contact Information
If you have any questions, concerns, or requests regarding this Privacy Policy or your data, you can reach our team at:
TWIMH Yazılım Teknolojileri Anonim Şirketi
Contact & Support Email: support@twimhgames.com
Registered Address: Elazığ, Turkey