PRIVACY POLICY

LAST UPDATE: AUGUST 15th, 2024

This PRIVACY POLICY is the entire personal data protection policy (hereinafter “Privacy Policy”) for the product or service provided by Nebula Games.

We appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it.

Before accessing or using the application, please ensure that you have read and understood our Privacy Policy. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately.

If you have any queries about this Privacy Policy or data protection in general, please contact:  support@nblgames.com 

Please note that this Privacy Policy has been prepared in line with Quiz Crush ’s  Terms of Use available at here^[a]   and Nebula Games does not intend for the Game to be used by persons who are prohibited from using the Platform as per its Terms of Use.  Please refer to the Terms of Use for the definition of any capitalized term if not defined herein.

1. GENERAL INFORMATION

1. This Privacy Policy was drawn up by Nebula Games Yazılım Teknolojileri Sanayi ve Ticaret A.S.  a company registered at Zühtüpaşa Mah. Şefikbey Sk. No: 7a Kadıköy / Istanbul, Turkey (hereinafter “Nebula Games”, “we,” “us” or “our”) who is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share and protect data that identifies or is associated with you (“personal data”) in relation to our mobile game application Quiz Crush (as well as any other media form, website, web application, media channel, mobile website, linked, or otherwise connected thereto) including the services offered on such website (hereinafter collectively the “Platform” or “Game”), and your choices about the collection and use of your information.
2. By accessing and/or using Nebula Games’ game (Quiz Crush), applications, website or other services within our games such as chats or in-app purchases (the “Services”) you consent to the collection, transfer, operation, storage, disclosure and other uses of your information as described in this Privacy Policy.

1. This Privacy Policy will enter into force on the date stated above. If this document is updated, we will notify you of the revised versions through our regular channels. For more information regarding updates please see the section titled “Updates to the Privacy Policy” below.
2. Please note that this Privacy Policy was prepared in line with the applicable laws of the Republic of Turkiye relating to data privacy. Recognizing the global nature of the Internet, throughout the Privacy Policy, reference has been made to other jurisdictions and regulations that may be applicable to some users. However, we hereby expressly state that any such reference was made for ease of understanding of users and those persons who choose to access the Site from other locations do so on their own initiative and does not mean or imply that Nebula Games is subject to the laws and regulations of said jurisdiction.
3. Hereinafter, any person who is registered to the Platform shall be referred to as “User”. Nebula Games hereby acknowledges its Data Controller status in terms of Users of the Platform.
4. The only necessary data for registration is a display name which does not in and of itself necessitate the inclusion of any personal information. However, the display name may (if you so desire and choose to disclose) include your real name, surname or other personal information. Also, you may choose to provide more personal information such as a user photo (in case you choose to upload your own photo), messages (it may include your personal information), and any other data you may choose to provide will be a subject to this Privacy Policy.
5. Nebula Games’ mobile application Quiz Crush is a trivia game that a User can play with other Users whether randomly or up to User’s choice via the Internet. This Privacy Policy applies to all the products and services provided on the Platform to Members and Users by Nebula Games as the Data Controller. However, this Policy is not applicable to any information collected offline or via channels other than the Platform.
6. In terms of the collection of personal data, we would like to stress that we do not knowingly solicit data from children under 13 years of age. As stated in our Terms of Use, by using the Game, you represent that you are at least 13. For persons between the ages of 13 and 18 who want to register for the Game, we may require personal parental consent or confirmation for registration depending on your jurisdiction. Also, please note that certain content of Nebula Games’ mobile game Quiz Crush may be restricted or unavailable to Users below the age of 18 due to applicable laws regarding the provision of certain content to minors. If we learn that personal data from users who are under 13 years of age (or under 18 depending on the jurisdiction) has been collected due to their misrepresentation during membership registration, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 13 (or under 18 depending on the jurisdiction), please contact us at  support@nblgames.com

1. WHAT IS PERSONAL DATA?

1. “Personal Data” used throughout this Privacy Policy means in short personally identifiable information of Users that is collected through the Nebula Games’ mobile game application Quiz Crush and through the online by Nebula Games from User and maintained by Nebula Games in an accessible form, and by definition may include personal identifiers such as a first and last name, a physical address, an e-mail address, a telephone number, a Social Security number, or any other identifier that permits the physical or online contacting of the User, and any other information concerning the User collected by Nebula Games from User and maintained in personally identifiable form in combination with any identifier described in this paragraph.
2. This section is intended to provide you with a definition of personal data. Please see Section 4.2. titled “What Data Do We Use?” and Section 12 titled “Notice For California Residents; Categories of Personal Data Processed” for details regarding the data actually processed by Nebula Games as a Data Processor.

2. ON WHAT BASIS DO WE COLLECT OR USE PERSONAL DATA?

1. Data protection laws require that we meet certain conditions before we are allowed to use your personal data in the manner described in this Privacy Policy. To use your personal data, we will rely on one of the following conditions, depending on the activities we are carrying out:

1. You have given us consent;
2. Processing is necessary for our legitimate business interests or those of a third party: provided this does not override any interests or rights that you have as an individual.
3. Processing is necessary in order to enter into or perform a contract with you.
4. Processing is necessary for compliance with our legal obligations.
5. Processing is necessary for legal claims.
6. Processing is necessary for substantial public interest.

2. Below you will find detailed information on the basis that we collect and use your personal data. If we look to use your personal data for any other purpose not covered in this Privacy Policy, we will let you know about any proposed new purposes before using your personal data in this way.
3. Consent

1. We ask that you provide affirmative and informed consent to the use of some of your personal data as described in this Privacy Policy when you access and register to the Game and participate in the Services. Please discontinue using the Services if you do not have such consent. If we are relying solely on your consent to process your personal data, you may withdraw your consent to our processing of your personal data at any time; however, withdrawing consent may result in your inability to continue using some or all of the services in the Platform. Please note that the withdrawal of your previous consent will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.
2. Please note that any personal information disclosed at your discretion without our demand for such disclosure, for example if you decide to use your name and surname in forming your display name during registration or if you decide to upload a picture of yourself as a profile picture, is processed based on your consent.
3. We do not collect personal data for the purpose of sale of such information in a way that specifically identifies the individual (i.e., we don’t sell User information).
4. We may provide you with marketing information about our services or products where you have indicated your consent for us to do so (to the extent that we are required to collect consent under data protection laws). We may contact you by mail or email, phone and electronic notifications (where you have agreed to those methods of communication) to provide you with the information on your requested service or product. We may also provide you with information, special offers, research, promotions, and similar products and services. Where you have indicated your consent to us doing so, we may also pass your details to our group companies for marketing purposes. You may change your marketing preferences at any time from your account settings.  
5. We will also provide you with access to, or transfer your personal data at your written request, provided that we aren’t legally restricted from doing so or otherwise prevented from doing it due to circumstances beyond our reasonable control. Please relate your request for access to or transfer of personal data to support@nblgames.com

4. Legitimate Interest

1. Sometimes our collection and use of your personal data may not depend on your informed consent but our legitimate interests. It is in our legitimate interests to collect your personal data as it provides us with information that we need to provide our Services to you and to make our Platform available.
2. This requires us to carry out a balancing test of our interests in using your personal data (for example, in order to provide you with access to the Platform, against the interests you have as a person and the rights you have under Delaware Online Privacy and Protection Act and other applicable Data protection law (for example, to not have your personal data sold to third party marketing companies without your knowledge). The outcome of this balancing test will determine whether we may use your personal data in the ways described in this Privacy Policy. We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.
3. Our legitimate interests are: managing our business and relationship with you; understanding and responding to inquiries and Member and User feedback; understanding how our Users use the Platform; identifying what our Users want and developing our relationship with you; improving our Platform and offerings; managing our supply chain; developing relationships with business partners; sharing data in connection with acquisitions and transfers of our business.

5. Contractual Performance

1. Please note that when you become a User of the Platform you enter into a contractual relationship with Nebula Games via the Terms of Use which you accept by use of our Game. This contractual relationship necessitates the processing, use, and storage of your personal data for the purpose of fulfilling our contractual obligations and/or facilitating our contractual rights. Therefore, at this stage, the contractual relationship itself becomes the legal basis of our processing of your personal data.
2. In short, we are permitted to hold and process some of your personal data because it is necessary to do so in order to provide You with access to, and to enable you to make use of, the Platform. Without this personal data, we could not provide you with access to the Game.

6. Legal Obligations and Legal Claims

1. We are permitted to process your personal data where it is necessary for compliance with our legal obligations. We are also permitted to process your personal data where it is necessary to establish, pursue or defend a legal claim.
2. We may disclose your personal data to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Game, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose personal data when we believe in good faith that such disclosure is required by and in accordance with the law.
3. Please note that we may, upon request by another User or at our discretion, report User Content (as defined in the Terms of Use) as well as any information we have on such User to law enforcement officials in any relevant jurisdiction for criminal prosecution if we believe that User Content is in violation of applicable laws, the Terms of Use or the best interest of any children.

7. Substantial Public Interest

1. We are permitted to process your personal data where it is necessary for reasons of substantial public interest, on the basis of data protection laws.
2. Please note that we may, upon request by another User or at our discretion, report User Content as well as any information we have on such User to law enforcement officials in any relevant jurisdiction for criminal prosecution if we believe that User Content is in violation of applicable laws, the Terms of Use or the best interest of any children.

3. USE OF COLLECTED DATA

1. We use your personal data to help us provide and support (the Services on) our Platform. This section provides you with details of what personal data we use and why we use it.
2. What Data Do We Use?

1. We collect information directly from you and in some instances from third party service providers whom you authorize to share your information with Nebula Games.
2. Depending on whether you are a User or visitor, personal data collected from you will differ. If you only visit the Platform without becoming a User you are categorized as a visitor. The only personal data collected from visitor’s are explained in the article 4.2.3.4 below.
3. Naturally, we collect more personal data from you when you register to the Game as a User. As a User you provide more personal data including:

1. contact information such as your username (if you sign up using a third-party service provider), display name you choose for use of the Game (in case it contains your personally identifiable information);
2. user picture or “avatar” (in case it contains your personally identifiable information);
3. details of your correspondence with us;
4. technical information which we collect from you when you visit the Platform such as your Internet Protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system, platform and traffic data, cookies data, weblogs and other communication data and details of the resources that you access;
5. when you interact with us and other users, including messaging and chatting with other users, we collect every comment, communication and chat between you and other users in the Game;
6. when you ask for assistance from Nebula Games’ customer support, the contact information you provide will be collected, as well as information about your gameplay or activity on the Game, your user ID number, and the correspondence and any information contained within;
7. location data which you may choose to share with the Platform during your use and We may also determine location by using other data from your mobile device, such as precise location information from GPS, information about wireless networks or cell towers near your mobile device, or your IP address, to provide special features of our Services, to deliver ads that relate to your interests, and/or improve and customize the Services, for example, with more relevant content and suggestions for users;
8. when you make a purchase in the Services, We may collect the billing and financial information necessary to process the charges; and/or do so on behalf of the relevant payment service providers. Purchases of third party services are subject to the policies applicable to the third parties; and
9. any other information you provide to us in order to personalize and optimize your experience with the Platform.

4. For more detail on the personal data we process, please see Article 12 titled “Notice for California Residents; Categories of Personal Data Processed” below.
5. When you use your account information with third party service providers, we will receive certain profile information about you from your service provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, email address, and profile picture as well as other information you choose to make public on such service provider platform. We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on our Game. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policies to understand how they collect, use and share your personal data, and how you can set your privacy preferences on their sites and apps. As of the entry into force of this Privacy Policy, our Platform offers you the ability to register, log in with, or connect your Facebook, Google, or Apple account.
6. For registering as a User on our Game, only the provision of a display name is mandatory: if relevant data is not provided, then you will not be able to create an account. Alternatively, you may log in using third-party service providers as explained above. As of the entry into force of this Privacy Policy, our Platform does not require the provision of any other identifier information solely for membership purposes.

3. You are able to view and update much of the information collected about you through your account settings. Please note that if you sign in using a third-party service provider, we cannot allow you to change your email address information and username provided by the service provider. You shall be entitled to collect all of your personal data stored on the Platform upon request via the sections provided on the applications or via e-mail to us at  support@nblgames.com

1. We automatically collect certain information when you visit, use or navigate the Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Platform and other technical information which may lead to your identification. This information is primarily needed to maintain the security and operation of our Game and for our internal analytics and reporting purposes. Please refer to the section titled “Cookie Policy” and the sub-section titled “Service Providers Processing Data on Our Behalf” for more information on automatically collected personal data.
2. As a User, please remember that if you use the Platform to share personal data of persons who are not User themselves (e.g. photographs, documents containing personal data such as receipts, video, etc.), you represent that you have read and understood the Terms of Use and agree to be bound by the conditions thereto. In these instances, you further represent that the individuals to whom this data relates have been informed of and have consented to such use and disclosure.
3. When this product/service was designed, the possibility that it would be used to process special categories of personal data or data regarding criminal convictions and offenses was not taken into account. In fact, our Terms of Use specifically state that Users shall not use the Platform for any purpose or in any manner involving transmitting protected health information using Nebula Games unless you have received prior written consent to such use from Nebula Games.
4. Our Platform is intended for the use of persons above the age of 13 only. We do not knowingly collect personal information from children or minors without parental consent. If Nebula Games is made aware that a child has provided us with personal information without parental consent, we will endeavor to delete that information from our databases. If you have questions about personal information that may have been submitted by a child, please email us at support@nblgames.com

4. Why Do We Use Your Data?

1. Service provision: we use the information to carry out and administer the Game.
2. Communication: The main reason for processing your personal information for communication purposes is sending emails, newsletters, and other messages to keep you informed of Nebula Games. You may opt out of receiving any, or all, of any communications which are of a non-primary function (e.g. marketing) from us by following the unsubscribe link. However, please note that we may use your email address to send you emails about legal and administrative issues related to your User status (such as changes in Terms of Use or Privacy Policy, deletion or deactivation of your account, etc.) which we may be legally obliged to inform you about, which are not classified as marketing communications. We also use the personal data to deal with inquiries and complaints made by you relating to the Game and to address your questions, issues, and concerns;
3. Platform monitoring: to check the Platform and our other technology services are being used appropriately and to optimize their functionality for the purpose of administering and improving our Services.
4. Game optimization: improve, test, and monitor the effectiveness of our Game and diagnose or fix technology problems;
5. Managing suppliers: we use information to manage third-party suppliers who deliver services to us;
6. Statistics: monitor metrics such as total number of visitors, traffic, demographic patterns, and patterns in our test results (on an anonymized and aggregated basis) regarding the Game;
7. Development: develop and test new products and features.

5. If we plan to use your personal data in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled “Updates to the Privacy Policy”.

4. TRACKING WITHIN THE GAME

1.  We allow advertising on our free Services so we can continue to offer those Services for free. Our advertising partners may collect advertising identifiers [such as the Apple Identifier for Advertising (IDFA) or the Google Advertising ID (AAID)] to enable and optimize their advertising, to deliver tailor ads related to your interests (“Interest-Based Advertising” or “IBA”), and to improve and measure the effectiveness of ad campaigns. These identifiers are non-permanent, non-personal, device identifiers. Third parties, such as Facebook and our advertising partners, may collect information about your online activities over time and across different web sites and may use that information to provide advertisements on other websites about goods and services likely to be of interest to you.

1. In Android operating systems, you may opt out of IBA. To do this, open the “Google Settings app” from your app drawer, tap on “Ads”, and select “Opt-out of Interest-based ads” (https://developer.android.com/google/play-services/id.html) Please note that this will block your phone from receiving tailored ad recommendations across your device.
2. In iOS operating systems, you may opt out of IBA by clicking on “Settings”, select “Privacy”, then “Advertising” and toggle “Limit Ad Tracking” to “ON” (https://support.apple.com/en-us/HT202074)

2. As explained above, We may collect precise or approximate location information. In addition, we allow advertising on our free Services so we can continue to offer those Services for free. When you activated the Game or Services, you gave your consent that our advertising partners may collect precise or approximate location information from your mobile device and may use this information in order to provide you location and interest-based advertising. Your mobile device may allow you to opt out of the collection of precise location data by us and by our advertising partners, as further described below.

1. In order to disable the collection of precise location data on iOS, you may turn Location Services off for the Quiz Crush via the menu "Settings" > "Privacy" > "Location Services". Then select the Quiz Crush application and set the "Share My Location" status to "Never". Please see additional information from Apple here: https://support.apple.com/en-us/HT203033
2. Android (6.0 / Marshmallow and higher) - In order to disable the collection of precise location data on Android, you may turn Location off for the Quiz Crush game via the menu "Settings" > "Apps" > “Quiz Crush”> "Permissions" > "Location". Then turn off the "Location" button.

5. WHERE WE STORE YOUR DATA

1. Platform is hosted, stored and processed by Nebula Games leveraging data centers which are located in Turkiye. ^[b]Processing of the information collected about you is only undertaken for the purposes described in this Privacy Policy.
2. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In particular, this means that your personal data will only be transferred where the recipient is bound by contractual clauses requiring the confidentiality and protection of personal data.
3. Our Game is accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Game from outside the USA. This means that where you choose to show or send your data on our Game, it could be accessed from anywhere around the world and therefore a transfer of your data outside of the USA may be deemed to have occurred. You consent to such transfer of your data for and by way of this purpose.

6. DISCLOSURE OF YOUR PERSONAL DATA

1. We do not sell, lease, rent or give away the information collected about you without your permission. We only disclose your information as described below. If we disclose your information, we require those we share it with to comply with adequate privacy and confidentiality requirements and security standards.
2. We may disclose your personal data to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose personal data when we believe in good faith that such disclosure is required by and in accordance with the law. In certain instances, it may be necessary for Nebula Games to disclose the information that we’ve collected about you to government officials or otherwise as required by applicable law. No personal data will be disclosed to any law enforcement agency or governmental agency except in response to:

1. A subpoena, warrant or other process issued by a court of competent jurisdiction;
2. A legal process having the same consequence as a court-issued request for information, in that if Nebula Games were to refuse to provide such information, it would be in breach of local law, and it or its officers, executives or employees would be subject to liability for failing to honor such legal process; or
3. Where such disclosure is necessary for Nebula Games to enforce its legal rights pursuant to the laws of the jurisdiction from which such information was gathered.
4. Where such disclosure is necessary for Nebula Games to protect the rights and interests of other Users.
5. Specifically, we may, upon request by another User or at our discretion, report User Content (as defined in the Terms of Use) as well as any information we have on such User to law enforcement officials in any relevant jurisdiction for criminal prosecution if we believe that User Content is in violation of applicable laws, the Terms of Use or the best interest of any children.

3. We may also disclose your personal data, subject to appropriate confidentiality protections, in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.
4. The Game may contain links to third party websites such as advertisements. When you click on a link to any other website or location, you will go to another site, and another entity may collect personal or anonymous data from you. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that this Privacy Policy does not apply to these outside websites or content, or to any collection of your personal data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.
5. Service Providers Processing Data on Our Behalf

1. We may use contractors and service providers to process the information collected about you on our behalf for the purposes described in this Privacy Policy. We contractually require service providers to keep information secure and confidential and we do not allow our data processors to disclose your information to others without our authorization, or to use it for their own purposes. However, if you have an independent relationship with these service providers their privacy statements will apply. Please also see Article 6 above for information on where we store your data as it may contain information on service providers.
2. Google Analytics (Google LLC.): This third-party service enables Nebula Games to monitor and analyze the traffic. Google Analytics is a web analysis service provided by Google LLC. Google utilizes the information collected to track and examine the use of the Site to prepare reports that may be used for optimization of the Site. Information collected for this purpose is cookies and usage data. Place of processing of Google LLC is the US. Please check the Google privacy policy at https://policies.google.com/privacy?hl=en for more information. Opt-out option is also available as a browser add-on at: https://support.google.com/analytics/answer/181881?hl=en
3. Google Ads (Google LLC.): This third-party service enables Nebula Games to display advertisements on the Game. Please note that the information collected for the purposes of targeted advertising is determined by the service provider. Therefore, we refer you to the privacy policies of our service provider available at https://support.google.com/adspolicy/.
4. Apple Inc.: As stated above, our Game offers you the ability to register and login using your Apple account or connect your Apple account afterward. When you use your Apple account to register and login to our Platform, we will receive certain profile information about you from this service provider. The profile information we receive will depend on the policies of the service provider, but at the date of the entry into force of this Privacy Policy includes at the minimum your email address, the name you have provided for the email address and your profile picture. Therefore, we recommend that you review the privacy policy of your service provider available at apple.com/legal/privacy/data/ 
5. Google LLC.: As stated above, our Platform offers you the ability to register and login using your Google account or connect your Google account afterwards. When you use your Google account to register and login to our Platform, we will receive certain profile information about you from this service provider. The profile information we receive will depend on the policies of the service provider, but at the date of the entry into force of this Privacy Policy includes at the minimum your email address, the name you have provided for the email address and your profile picture. Therefore, we recommend that you review the privacy policy of your service provider available at https://policies.google.com/privacy.
6. Facebook (Meta Platforms, Inc.): As stated above, our Platform offers you the ability to register and login using your Facebook account or connect your Facebook account afterwards. When you register using a Facebook account or you link your Facebook account with Quiz Crush, we collect your name, email address, location and age information, as well as information about your friends and other Personal Information. This information is collected by Facebook and is provided to us under the terms of Facebook’s privacy policy. You can control the information that we receive from Facebook using the privacy settings in your Facebook account. Therefore, we recommend that you review the privacy policy of your service provider available at https://www.facebook.com/privacy/policy 

7. RETENTION OF YOUR PERSONAL DATA

1. We will retain your personal data for as long as needed to fulfill the purpose for which we collected it and for a reasonable period thereafter in order to comply with audit, contractual, or legal requirements, or where we have a legitimate interest in doing so. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
2. You may delete data collected based solely on your consent at any time using your account settings. Data not collected based solely on your consent will be retained as long as your User account is active. If your account is terminated due to your violation of this Privacy Policy or the Terms of Use, we will retain certain information about you in order to ensure that you do not re-register to the Platform. Upon the deletion or termination of your account due to your choice, we will retain certain your personal data (e.g. payment information) for 60 months (5 years) in order to comply with local laws and our internal audit purposes. ^[c]
3. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
4. We may retain aggregated or de-identified data indefinitely or to the extent allowed by applicable law. We may retain personal data preserved in automatically generated computer backup or archival copies generated in the ordinary course of our information technology systems procedures.
5. All retained personal data will remain subject to the terms of this Privacy Policy. Please note that if you request that your personal data be removed from our databases, it may not be possible to completely delete all of your personal data due to technological or legal constraints, though we will use reasonable efforts to do so.
6. No purpose in this notice will require us to keep your personal information for longer than twelve (12) months past the termination of the member’s account, unless as necessary to comply with our legal obligations, resolve disputes, prevent and detect fraud, and enforce our agreements.

8. MANAGING YOUR QUIZ CRUSH USER STATUS AND ACCOUNT

1. Display name: Nebula Games Members are required to assign themselves a display name that uniquely identifies you on Nebula Games Your display name may contain personal data such as your real name, surname or other identifier. You can change your Nebula Games display name at any time. However, please beware that if you change your display name, your old display name becomes available for anyone else to claim. Please note that references to your User profile under the old display name may remain the same when you change your display name for future use.  Please note that when you login using your Google, Facebook or Apple account, the name you have used for your Google, Facebook or Apple cccount will be displayed in Nebula Games and cannot be changed via Nebula Games but is subject to Google’s or Apple’s options regarding any such changes.
2. Profile Picture: You have the option to upload a profile picture under the “Profile” tab on the Game. Depending on the picture that you use, the profile picture may contain personal and/or sensitive personal data. Please be advised that your profile picture shall be visible to other Users of the Game when you match them for a game round or contact them.
3. Deleting Your Account: Deleting your account will stop you from playing the Game, permanently delete all the data you have uploaded to the Platform, including any specific Nebula Games content and profile information. However, please be aware that due to your interactions with other Users on the Platform, some information, like messages you sent to other Users, may still be visible after you delete your account. Also, upon the deletion of your account due to your choice, we will retain certain personal data such as payment information for 60 months (5 years) in order to comply with local laws and our internal audit purposes. Once you delete your account, there is no going back. Please be certain. We will be sorry to lose you.

9.  SECURITY POLICY^[d]

1. The security of your personal data is important to us. We use commercially reasonable efforts to store and maintain your personal data in a secure environment. We also take technical, contractual, administrative, and physical security steps designed to protect any and all personal data you provide. We have implemented procedures designed to limit the dissemination of your personal data to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you in this Privacy Policy.
2. Please note that you are also responsible for helping to protect the security of your personal data. For instance, never give out the credentials you use in connection with accessing the Platform so that other people will not have access to your personal data. Furthermore, you are responsible for maintaining the security of any personal computing device on which you play the Game.
3. We are not liable for disclosure of data due to errors in transmission, unauthorized access or acts by third parties, or omissions or acts beyond our reasonable control. Although we employ commercially reasonable measures of security, we also cannot guarantee that your personal data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards by persons or systems with malicious intent.
4. In the event we become aware of a security breach that could result in your personal data being disclosed in a manner that is not authorized under this Privacy Policy, we will notify you via notification (or other communication channel you have provided to us) to try to alert you as appropriate.
5. We have implemented the following security measures to protect its product or service:

1. The (database) servers can be accessed only via Nebula Games’ trusted network locations.
2. Procedures are in place to ensure only authorized personnel have access to the personal data. A non-disclosure and confidentiality agreement ensures this still applies when a member of staff leaves the company.
3. All mobile carriers (such as laptops, USB sticks and portable HDs) of Nebula Games are password protected.
4. Our web servers and database servers are firewall-protected.  
5. All data within Nebula Games will be stored as securely as possible.
6. Encryption will be used when possible.
7. All data will be transmitted with the highest possible form of encryption that is supported.
8. We ask for confirmation mail while registering.
9. We prevent two different users from logging using the same browser.
10. We keep our content on AWS S3 subject to private access.
11. We use PostgreSQL database and here we control all access with Row Level Security policies so that only the invitees of a Nebula Games can see the details of it.
12. We have a rate limit definition for requests from the same IP.
13. We work together with external security service providers regularly to perform penetration test to ensure our protection against unauthorized access.
14. AWS Identity and Access Management (IAM): Access to the meeting recordings and files is strictly controlled.

6. We regularly revise the security measures outlined in this Privacy Policy to ensure that we are always fully prepared and up to date with regard to data protection.

10. DATA LEAK PROTOCOL

1. In the unfortunate event that something does go wrong, Nebula Games will follow the following data breach protocol to ensure that data subjects are notified of incidents.
2. A relevant internal data breach procedure is in place. Nebula Games will set up a team in order to analyze the cause, the impact and the affected Users. Depending on the outcome of this analysis, Users will be notified as soon as possible. If required by any applicable law, Nebula Games shall also notify any applicable Data Protection Authority about the leak.
3. Nebula Games will provide highly detailed information about:

1. The nature of the breach, including a description of the incident, the nature of the personal data or categories of affected data subjects, an estimate of the number of affected data subjects and databases that may be affected, as well as an indication of when the incident occurred;
2. Any measures already taken by Nebula Games in order to stop the breach;
3. Any measures to be taken by the affected data subjects (what can the affected data subjects themselves do, such as “keep an eye on your e-mails, change your passwords”, etc.);
4. Any measures to be taken by Nebula Games in order to prevent a future breach.

11. NOTICE FOR CALIFORNIA RESIDENTS; CATEGORIES OF PERSONAL DATA PROCESSED

1. Please note that this notice for residents of the State of California is provided for the ease of said persons; however, the other provisions of this Privacy Policy are equally valid and in force for residents of the State of California. Also, Users accessing this Privacy Policy from other locations may find this section useful.
2. Please refer to Article 14 below for more information regarding your rights related to the personal information processed and how to pose questions or requests to us regarding your personal information.
3. The chart below includes details on personal data or “personal information” collected for customers. Within the last twelve (12) months, we may have collected the following categories of personal information from the sources identified below for the business and commercial purposes indicated, and disclosed, shared, or sold (as indicated) such categories of personal information with the specified categories of third parties:

12. NOTICE FOR TURKIYE RESIDENTS; KVKK LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER KVKK

If you are a resident of Turkiye, the following provisions will also apply to you.

4. What Kind of Personal Information Do We Collect?

1. The only personal data collected from visitors are explained in the Section titled “article 4.2.3.4 above.
2. Naturally, we collect more personal data from you when you sign up to the Platform as a User. As a User you more personal data including:

1. username (if you register using a third party service provider, such username may contain your name, surname or other identifiable personal information)
2. display name (in may contain your name, surname or other identifiable personal information)
3. user picture or “avatar” (in case it contains your personally identifiable information);
4. details of your correspondence with us;
5. technical information, such as your Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, screen resolution, flash version, time zone setting, browser plug-in types and versions, operating system, platform and traffic data, cookies data, web logs and other communication data, and details of the resources that you access, as well as your sessions records, which we collect from you when you access the Platform; and;
6. any other information you provide to us.

5. What Lawful Reasons Do We Have To Process Personal Data?

We collect and process your Personal Data one or more of the below-listed reasons:

3. Contract - We may process personal data to fulfill our contractual obligations.
4. Consent - We may rely on your freely given consent at the time you provide your personal data to us.
5. Legitimate interests - We may rely on legitimate interests based on our assessment that the processing is fair, reasonable and balanced.
6. Legal obligations and public interest - We may process personal data to fulfill legal obligations.

13. UPDATES TO THE PRIVACY POLICY

1. We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Entry Into Force" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes on the Platform or by directly sending you a notification through the Platform. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your personal data.

14. QUESTIONS AND REQUESTS ABOUT YOUR PERSONAL DATA ("CONSUMER REQUEST”)

1. As a User of Quiz Crush you may request the following from Nebula Games as Data Controller;

1. Access to your personal data.
2. Rectification or deletion of your personal data.
3. A restriction on the processing of your personal data.
4. Object to the processing of your personal data.
5. A transfer of your personal data (data portability) in a structured, machine-readable and commonly used format.
6. Withdraw your consent to us processing your personal data, at any time.

2. Please note that withdrawing your consent is only effective provided that consent is the only basis for the processing of relevant personal data. Similarly, even if you request the deletion of any personal data, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
3. You can make a request in relation to any of the above rights by writing to us at the contact address given at the end of this Privacy Policy. Only you, or someone legally authorized to act on your behalf, may make a consumer request related to your personal data. You may also make a consumer request on behalf of your minor child.
4. We will respond to such queries as soon as reasonably possible and deal with requests we receive from you, in accordance with the provisions of any applicable data protection law. Please note that you also have the right to appeal our responses to your consumer requests regarding this privacy policy. You can make your appeals to us using the same contact information below.

15. CONTACT US

1. You can contact us via post or email.

1. Via post:

NEBULA GAMES

Attn: Privacy

Zühtüpaşa Mah. Şefikbey Sk. No: 7a Kadıköy / Istanbul, Turkey  

2. Via email: 

 support@nblgames.com with “Privacy” in the subject line

2. If your letter or email involves one of the requests listed above in the section titled “Questions and Requests About Your Personal Data”, we may ask you to verify your identity before fulfilling your request depending on the method of your request.