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PRIVACY POLICY — SULTAN SIEGE

DATA CONTROLLER

Ahsen Kılıç (Türkiye), contact: [email protected]

1. STORED ON YOUR DEVICE

Sultan Siege (the "Game") keeps a local game profile on your device: your player name, chosen avatar, progress (trophies, level, cards, Gold and Gems), decks, settings, the date and version of the texts you accepted, and the store transaction identifiers processed so that a purchase is not delivered twice. This profile stays on your device; the data of your online account is also kept on the server (see section 2).

2. SENT TO THE SERVER (only after you accept these texts)

Before you accept, the Game does not connect to any server. After you accept, the following is sent to our game server (Nakama) for online features and kept there:

  • device identifier: the app identifier provided by the operating system or, if that is unavailable, a random identifier generated on your device; used to recognise your account,
  • your player name: filtered on the server and may be shown to other players,
  • your game progress: trophies, cards, Gold and Gems balance, Battle Pass, quests and cosmetics; your trophy count and player name are visible to other players on the trophy leaderboard,
  • your acceptance record: the accepted text versions, date and app version,
  • friends data: your invite code, friends you added, whether you are online or in battle, and your app version (visible to your friends),
  • match data: your matchmaking request, your moves during a match and your match results,
  • purchase records: the transaction identifier provided by the store, the product purchased, the store and the date; used to verify your purchase, to avoid delivering it twice and to process refunds,
  • Hearth data (only if you join or found a Hearth): your Hearth membership and role, your card requests and donations, the name and settings of a Hearth you found, and the messages you write in Hearth chat (filtered on the server and shown to Hearth members),
  • age declaration and community rules: before you first use Hearth features you enter your birth year; the server does not store your birth year, only whether you are 13 or older and the version of the community rules you accepted,
  • reports: if you report another player, the reason you chose, the player you reported and, if the report was made from Hearth chat, a copy of the message concerned,
  • Sign in with Apple (only if you use it, iOS): the anonymous user identifier provided by Apple is linked to your account; the refresh token issued by Apple is also stored so that the Apple link can be revoked when you delete your account. We do not request your email or name from Apple. If you delete your account, the Apple link is also revoked with Apple.

When you connect, your IP address and connection details reach our server; they are kept in connection logs for a limited time for security and debugging and are deleted regularly.

The server is hosted in Germany (Hetzner Online GmbH). The connection between the Game and the server is encrypted and goes directly to our server. DNS for our domain is provided by Cloudflare, Inc. Encrypted connections to our website (sultansiege.site) are terminated by Cloudflare and forwarded to the website; during this, your IP address and the request data sent by your browser are processed on Cloudflare's servers. Cloudflare processes this data only on our behalf, for transmission and security.

3. ANALYTICS

This version of the Game does not collect analytics data: no data is sent to any analytics or measurement service (including GameAnalytics), and no analytics identifier is written to your device or sent. If analytics is added in the future, this text will be updated and your consent will be requested again.

4. PURCHASES AND ADS

Payments are taken by the App Store or Google Play; we have no access to your card details. The records we keep to verify your purchase are listed in section 2.

This version of the Game shows no ads: it contains no ad SDK, does not access the advertising identifier (IDFA / Google advertising ID) and does not request App Tracking Transparency (ATT) permission. We do not track you across apps or websites. If ads are added in the future, this text will be updated and your consent will be requested again.

5. WHAT WE DO NOT ASK FOR, AND EMAIL CORRESPONDENCE

In the Game we do not ask for your email, phone number, real name, location, contacts, photos or microphone data. We use your birth year only for the age check and do not store it. If you email us for support or deletion, we use your address and message only to answer your request. Support emails are kept on our own server (Germany): incoming and outgoing messages are deleted automatically 90 days after they are received or sent, and spam after 30 days; they may remain in encrypted backups for up to 14 more days. We do not access the advertising identifier (see section 4) and do not collect analytics or usage data (see section 3).

6. RETENTION AND DELETION

Your server account is kept until you delete it. The account deletion option on the Settings > Account screen deletes your server account and the data linked to it: your account ID, player name, game progress, friends list, Hearth membership and your Hearth chat messages, your trophy leaderboard record and your Apple link. Your invite code is locked without any personal data so that it cannot be given to someone else, and your identity is removed from match history. If you no longer have access to the app, you can send a deletion request to [email protected]; details: https://sultansiege.site/en/delete-account/

After your account is deleted, the following records are kept under an internal identifier that is no longer linked to any player profile:

  • purchase records (store transaction identifier, product, date): for refunds and disputes, and so that the same purchase is not delivered twice,
  • report (moderation) records: to fight abuse and to review appeals. These records keep the reason for the report and, for reports made from Hearth chat, a copy of the reported message together with the sender's player name at that time (including that of a deleted account). Reports that have been decided are deleted 180 days after the decision; undecided reports are deleted at the latest 1 year after they were created.

Deleted data leaves our encrypted backups within 14 days at the latest. Hearth chat messages older than 30 days are deleted. Deleting the app deletes the profile on your device.

7. LEGAL BASES, TRANSFERS AND YOUR RIGHTS

This section is the information notice under Article 10 of KVKK and Article 13 of the GDPR. We process your data on these legal bases:

  • to provide the Game and its online features, that is, to enter into and perform our contract with you (KVKK Art. 5/2-c, GDPR Art. 6(1)(b)),
  • for our legitimate interest in security, fighting cheating and abuse, and moderation (KVKK Art. 5/2-f, GDPR Art. 6(1)(f)),
  • to comply with legal obligations we are subject to (KVKK Art. 5/2-ç, GDPR Art. 6(1)(c)).

Your data is processed only on our behalf, and only for the purposes in this text, by these service providers:

  • Hetzner Online GmbH (Germany): hosting of the game server and support email,
  • Cloudflare, Inc. (USA): DNS for our domain, delivery of our website and storage of encrypted backups (R2).

Apple (Sign in with Apple and the App Store) and Google (Google Play) process data for payments and sign-in under their own privacy policies, as independent controllers.

Because the server is in Germany, your data is transferred outside Türkiye; through Cloudflare it may also be transferred to the USA. You can write to us for information on the safeguards for these transfers.

Under Article 11 of KVKK and the GDPR you have the right to: learn whether your data is processed and request information about it; learn the purpose of processing and whether data is used for that purpose; know the third parties to whom your data is transferred; ask for incomplete or incorrect data to be corrected, for your data to be deleted or destroyed, and for these actions to be notified to those it was transferred to; ask for processing to be restricted; receive your data in a portable format; object to processing based on legitimate interest and to an outcome against you that results solely from automated analysis; and claim compensation if you suffer damage because of unlawful processing.

Send your requests to [email protected]; we reply within 30 days at the latest. If you are not satisfied with our reply, you can complain to the Turkish Personal Data Protection Board (KVKK Kurulu) or, if you live in the European Union, to the data protection authority of your country.

8. CHILDREN

The Game does not knowingly collect additional personal data from children; it asks for nothing beyond what is listed above. Based on the age declaration, players under 13 are not shown Hearth chat and cannot found a Hearth. The age rating is shown on the Game's store page.

9. CHANGES

If this policy changes, the Game will inform you and ask you to accept the new version before continuing.