PONCHIQS GAMES – PRIVACY POLICY

ENTRANCE

This Ponchiqs Games – Privacy Policy (“Privacy Policy”) is prepared by Unihornverse Limited (“Ponchiqs”), operating with Company No: 2143282 at Territory of The British Virgin Islands to ensure that the personal data of our visitors/player is processed in compliance with the relevant legislation, international agreements to which our country is a party regarding human rights, and the General Data Protection Regulation (“GDPR”), and to enable the relevant data subjects to effectively exercise their rights.

All personal data shared with Ponchiqs will be processed in compliance with the law, in connection with our activities and service purposes, and in a proportionate manner.       

1) DEFINITIONS

The terms personal data, sensitive personal data, and data processing used in this Privacy Policy are used in accordance with the definitions provided in the GDPR. The concept of “personal data”, as envisaged in the GDPR, refers to any kind of information relating to an identified or identifiable natural person; while the concept of “processing of personal data” encompasses all kinds of operations carried out on data, whether fully or partially automated, or non-automated, provided that they are part of any data recording system, including obtaining, recording, storing, preserving, altering, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of data.

2) PRINCIPLES OF PROCESSING PERSONAL DATA

In accordance with GDPR, personal data belonging to the data subject will be processed by the data controller, Ponchiqs, within the scope of the purposes specified below, in compliance with the principles of legality and fairness, accuracy, being up-to-date when necessary, being specific, explicit, and legitimate purposes, being related to the purpose for which they are processed, being limited and proportionate, and being retained in accordance with the rules prescribed by the relevant legislation or for the period necessary for the purpose of processing.

3) PROCESSED PERSONAL

Ponchiqs processes your;

• Identity Information (Name, Surname, Birthdate, Age, Gender),
• Contact Information (E-Mail Adress, Phone Number),
• Social Media Account Information (Information Declared to the Relevant Social Media Platform if Associated with a Social Media Platform),
• Transaction Security Information (IP Address, Geographical Location, Network Status Information, Other Traffic Data, Password, Verification Code),
• Profile Information (Username, Nickname, Avatar),
• Chat Information (In Game-Chat Records), Game Information (In-Game Experience Points, Game Progress, Level, Score, User Statistics, Bugs, Errors, Crashes, Diagnostics, Registration/Login Time, Game Version, Stack Trace, Crash Reports, Abnormal Process Data, Usage Patterns),
• Device Information (ID, Device Name, Device Type/Model, MAC Address, IMEI Data, CPU Data, Graphics Card Model, OS Version&Language, Time Zone, Screen DPI, Device Resolution, Memory Data) for the purposes specified below, provided that it meets the explicit consent of the data subject or any of the legal grounds.

4) PURPOSES OF PROCESSING PERSONAL DATA

Ponchiqs processes your personal data for the following purposes:

• Execution of Information Security Processes
• Conducting Audit/Ethics Activities
• Execution of Access Authorizations
• Conducting Activities in Compliance with Legislation
• Execution of Commitment Processes for Company/Product/Services
• Follow-up and Execution of Legal Affairs
• Conducting Communication Activities
• Execution/Audit of Business Activities
• Receiving and Evaluating Suggestions for Improving Business Processes
• Carrying out Business Continuity Ensuring Activities
• Execution of Goods/Service After-Sales Support Services
• Execution of Goods/Service Sales Processes
• Execution of Goods/Service Production and Operation Processes
• Execution of Customer Relationship Management Processes
• Carrying out Activities for Customer Satisfaction
• Organization and Event Management
• Conducting Marketing Analysis Studies
• Execution of Advertising/Campaign /Promotion Processes
• Execution of Risk Management Processes
• Carrying out Storage and Archive Activities
• Execution of Contract Processes
• Carrying out Sponsorship Activities
• Conducting Strategic Planning Activities
• Tracking of Requests/Complaints
• Execution of Marketing Processes of Products/Services
• Ensuring the Security of Data Controller Operations
• Providing Information to Authorized Persons, Institutions and Organizations
• Conducting Management Activities
• Carrying Out Identification and/or Verification Process
• Carrying out Finance and Accounting Affairs
• Execution of Security and Verification Process
• Ensuring Platform Security and Integrity
• Providing Country (Region Leaderboard Rankings or Other Similar Features of Functionality
• Carrying Out Account Creation Process
• Carrying Out Communication Services (In case of the chat service (voice or text) has been enabled)
• Carrying Out Prize Sending Process (In case of any prize has won by user)
• Providing Personalized Game-Related Feedback Services
• Developing General Experiences Regarding Products/Services
• Ensuring the Security and Integrity of the Platform
• Detection and Analysis of Illegal Practices
• Keeping a Transaction History Record
• Conducting Access Management, Operation, Provision or Management Processes for Service Usage
• Creating and Tracking Website Visitor Records (Logs)
• Carrying Out Login and Log Out Process to the Platform

 

Ponchiqs reserves the right to amend this Privacy Policy at any time in case of changes in the purposes of personal data processing.

5) TRANSFER OF YOUR PERSONAL DATA

Ponchiqs acts in accordance with the regulations prescribed in the GDPR regarding the transfer of personal data. Except for exceptional circumstances specified in the legislation or listed below, your personal data is not transferred to other natural or legal persons by us without the explicit consent of data subject.

In exceptional cases as envisaged by the GDPR and other relevant legislation, utmost care is taken to ensure compliance with the form and limitations prescribed by the legislation during the transfer of personal data to authorized administrative or judicial institutions or private organizations

Your personal data may be transferred to: 

• Authorized public institutions and organizations and legally authorized private individuals for the purpose of fulfilling legal obligations,

 

 

6) METHOD&LEGAL BASIS FOR the COLLECTION of PERSONAL DATA/SENSITIVE PERSONAL DATA

Your personal data may be obtained through Ponchiqs’s website, tracking cookies created by third parties, site usage measurement systems, forms available in the game via automated methods.

The legal bases for the processing of your personal data by Ponchiqs are exceptions to explicit consent as stated in GDPR. Your personal data is collected by Ponchiqs for the purposes specified in Articles 4 and 5 of this Privacy Policy.

7) TECHNICAL MEASURES TAKEN WITHIN THE SCOPE OF DATA PROTECTION

Necessary technical and administrative measures are taken by Ponchiqs in accordance with GDPR, prevention of unlawful processing and access and destruction of personal data in accordance with the law;

• Preparation of personal data processing inventory,
• Organisation of institutional policies,
• Preparation of confidentiality undertakings,
• Conducting periodic and random audits within the organization,
• Risk analyses,
• Adding provisions in accordance with the GDPR to the employment contract,
• Training and awareness activities,
• Network security and application security are ensured,
• Closed system network is used for personal data transfers through the network,
• Key management is implemented,
• Security measures are taken within the scope of procurement, development and maintenance of information technology systems,
• Security of personal data stored in the cloud is ensured,
• There are disciplinary regulations that include data security provisions for employees,
• An authorisation matrix has been created for employees ,
• Access logs are kept regularly,
• Data masking measures are applied when necessary,
• Confidentiality undertakings are made,
• Authorisations of employees who change their duties or leave their jobs are removed,
• Up-to-date anti-virus systems are used,
• Firewalls are used,
• Extra security measures are taken for personal data transferred via paper and the relevant document is sent in confidential document format,
• Personal data security policies and procedures have been determined,
• Personal data security problems are reported quickly,
• Personal data security is monitored,
• Necessary security measures are taken for entry and exit to physical environments containing personal data,
• Physical environments containing personal data are secured against external risks,
• Security of environments containing personal data is ensured,
• Personal data is minimised as much as possible,
• Personal data is backed up and the security of backed up personal data is also ensured,
• User account management and authorisation control system is implemented and monitored,
• Log records are kept without user intervention,
• Intrusion detection and prevention systems are used,
• Cyber security measures have been taken and their implementation is constantly monitored,
• Encryption is performed,
• Data loss prevention software is used,

8) INFORMATION ON INDIVIDUALS UNDER THE AGE OF 18

As Ponchiqs, we do not provide services to individuals under the age of 18, and we do not process, collect or store any data about these individuals to the best of our knowledge. As a parent or legal guardian, we kindly request that you do not allow your children under 18 to share data with us. Our website, games, and all our other services are intended for people over the age of 18.

If the personal data of a child under the age of 18 is disclosed to us, as a parent, you consent to the processing of the child’s personal data within the scope of this Policy and agree to be bound by the terms of this Policy. You can check our Terms of Service for more information.

If you become aware that the data of a child under 18, of whom you are the parent or legal guardian, is being processed in any way, we suggest you contact our Data Protection Officer and notify us of the situation. We will immediately close the account used by the child and delete/destroy all personal data in accordance with the applicable laws.

9) RIGHTS OF THE DATA

The data subject has the right to apply to Ponchiqs, acting as the data controller, to learn whether their personal data is being processed, request information if their personal data has been processed, learn the purpose of processing their personal data and whether they are used for the intended purpose, be informed about third parties to whom their personal data is transferred domestically or abroad, request the correction of their personal data if it is incomplete or inaccurately processed, request the deletion or destruction of their personal data within the framework of the conditions specified in GDPR, request the notification of the actions taken pursuant to the GDPR to third parties to whom their personal data is transferred, object to the occurrence of a result against themselves by means of exclusively automated systems analyzing their data, and request the remedy of damages in case of suffering damages due to the unlawful processing of personal data.

According to the GDPR in applications to be made by you, it is mandatory to include the following information: name, surname, signature if the application is in writing, electronic signature or mobile signature if electronic, Identification Number, residence or workplace address for notification purposes, if any, the electronic mail address for notification purposes, telephone number, and information regarding the subject of the request.

The data subject is obliged to clearly specify the requested matter in the application containing the explanation regarding the relevant right for the use of the aforementioned rights, and to attach the relevant information and documents to the application.

The aforementioned applications can be made to Ponchiqs in the following ways: 

• Personally, by hand, in writing, to the address of Ponchiqs,
• Through notaries, by sending the request to the address of Ponchiqs,
• By using the email address [email protected] previously notified and registered in the system of Ponchiqs.

10) MISCELLANEOUS      

This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

Ponchiqs may revise this Policy from time to time without any prior Policy. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

This Policy and any action related thereto will be governed by the laws of Switzerland without regard to its conflict of law’s provisions. Any dispute arising out of or in connection with this Policy, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by Arbitration Rules of the Swiss Arbitration Center for the time being in force, which rules are deemed to be incorporated by reference in this clause. The language of the arbitration shall be English.