Privacy Policy

WHO WE ARE

Pocket Giant is a trading name used by Kerim Sabuncugil, an individual independent developer based in Türkiye. It is not a registered company and has no employees, officers, directors or affiliated entities. References to "we", "us" and "our" in this Privacy Policy mean that individual developer.

Kerim Sabuncugil is the data controller for the personal data described here. You can reach us at any time by email at kerim.sabuncugil@gmail.com. We do not have a physical customer-service address; email is the contact channel for every request described in this policy.

If you are in Türkiye, a Turkish-language disclosure prepared under Article 10 of Law No. 6698 on the Protection of Personal Data is available at KVKK Aydınlatma Metni.

WHAT THIS POLICY COVERS

This policy applies to all mobile games we publish under the Pocket Giant name (together, the "Games"). The current list of Games is on our home page, and each Game's store listing links to this policy.

It also applies to this website, pocketgiant.net. The Games are currently distributed through the Apple App Store. Where a Game is later distributed through Google Play, the Google Play-specific processing described below applies to that version from the date it is published.

This policy does not apply to the separate services of the app stores, or of the advertising, analytics and infrastructure providers described under Third Parties. Those providers handle data under their own privacy policies.

WHAT DATA WE COLLECT

We do not ask you to create an account, and we do not ask for your name, postal address or telephone number. There is no social-network login in the Games. The data we and our providers collect is generated by your use of the Games:

Device and identifier data. Device model, operating system and version, device language, region and time zone, screen characteristics, app version, mobile network type, and IP address. IP address is also used by our providers to derive an approximate location, generally at country or region level — not a precise location. We do not collect GPS location.

Advertising and analytics identifiers. On iOS, the Identifier for Vendors (IDFV) and, only if you allow tracking through Apple's App Tracking Transparency prompt, the Identifier for Advertisers (IDFA). On Android, where a Game is published there, the Google Advertising ID. Also pseudonymous identifiers generated by our providers, such as an installation identifier generated by our analytics provider and a device identifier generated by our attribution provider.

Gameplay and product data. Sessions and session length, levels started, completed and failed, progression, in-game choices, settings, feature usage, and similar event data used to understand how the Games are played.

Advertising data. Which ads were requested, shown, clicked or rewarded, ad placement and format, and the estimated revenue associated with an impression.

Attribution data. Information about how you came to install a Game — the advertising campaign, network, creative and click or impression that preceded the install — provided to us by our attribution provider.

Purchase data. The in-app product purchased, the store transaction identifier, the amount and currency, and the date. Payment itself is handled entirely by Apple or Google. We never receive or store your card number, bank details or billing address.

Diagnostics. Crash reports, error and exception traces, stack traces, and performance and stability data, including a pseudonymous installation identifier and the device state at the time of the crash.

Leaderboard data. Where a Game offers a leaderboard, the score or result you achieve and the display name or nickname associated with it. A display name shown on a leaderboard is visible to other players. Please do not use your full legal name, your email address, or any other information you would not want other players to see.

Correspondence. If you email us, we receive your email address and whatever you choose to write to us.

WHY WE USE YOUR DATA

• To provide the Games and their features, including saving progress, delivering purchased in-app products and operating leaderboards.
• To show advertising, which is how the Games are funded, and to measure it.
• To measure the performance of our own advertising and understand which campaigns bring players to the Games.
• To understand how the Games are played, in aggregate, so we can balance levels, fix difficulty problems and decide what to build next.
• To detect and fix crashes, bugs and performance problems.
• To prevent fraud, cheating, invalid ad traffic and abuse, and to keep the Games and their infrastructure secure.
• To answer your messages and handle requests you make about your data.
• To comply with legal obligations, including tax and accounting rules that apply to purchase records.

We do not sell your personal data for money. We do not use your data to build advertising profiles ourselves. Where you allow tracking, our advertising providers may use identifiers from your device to personalise the ads you see — see Advertising and Tracking below.

LEGAL BASES

If you are in the European Economic Area, the United Kingdom or Switzerland, we rely on the following legal bases under the GDPR (and, for players in Türkiye, the corresponding grounds under Article 5 of Law No. 6698):

• Performance of a contract — providing the Game you installed, saving your progress, delivering in-app products you buy, and showing your leaderboard entry.
• Consent — personalised advertising and cross-app tracking, and any non-essential analytics or tracking technology where applicable law requires consent. You can withdraw consent at any time; see Advertising and Tracking.
• Legitimate interests — crash reporting and diagnostics, aggregate product analytics, non-personalised advertising and its measurement, attribution of our own marketing, and fraud, cheating and security protection. We balance these against your interests and use pseudonymous data wherever we can.
• Legal obligation — retaining purchase and accounting records, and responding to lawful requests from authorities.

ADVERTISING AND TRACKING

The Games are free to play and supported by advertising. Ad demand is handled by a third-party mediation platform, which requests ads from a number of advertising networks on our behalf. The set of networks enabled can change over time.

On iOS, we ask for your permission before any tracking takes place. Apple's App Tracking Transparency framework shows you a system prompt asking whether the Game may track you across apps and websites owned by other companies. If you allow it, your IDFA may be shared with our advertising and attribution providers and used to personalise and measure ads. If you decline — or if you never answer the prompt — the IDFA is not made available, and you will still see ads, but they will be contextual rather than personalised.

You can change this decision at any time in your device settings under Privacy & Security → Tracking. On Android, where a Game is published there, you can reset or delete your advertising ID and opt out of ads personalisation in your Google account and device settings.

Opting out of personalised advertising does not remove advertising from the Games, and it does not stop the collection we describe under legitimate interests, such as crash reporting or aggregate analytics.

The Games do not use browser cookies. Our providers use mobile SDKs and device identifiers rather than cookies. This website serves only static pages and a web font from Google Fonts; it does not set analytics or advertising cookies.

IN-APP PURCHASES

The Games offer in-app purchases. All payments are processed by the Apple App Store or, where applicable, Google Play. Those stores act as the merchant and handle your payment details; we receive only the transaction record described under Purchase data in "What Data We Collect" above. Refunds are handled by the store you purchased through, under its policies and subject to your mandatory consumer rights.

THIRD PARTIES AND WHAT THEY MAY DO WITH YOUR DATA

We never sell your personal data for money. But not every provider below plays the same role, and the difference matters: some act only on our instructions, while others decide for themselves how to use what they receive. We set this out honestly rather than describing everyone as if they worked only for us.

The Games are built with a third-party game engine. We do not enable that engine's optional analytics, advertising or cloud services, so the engine itself does not send your data to its vendor.

1. Providers that process data only on our behalf. These providers act on our instructions under a data processing agreement and may not use your data for their own purposes:

• A mobile analytics provider — product and gameplay analytics.
• A crash reporting provider — crash and stability reporting.
• A cloud infrastructure provider — hosting and storage for the analytics data described above, under our own account.
• A mobile attribution provider — measuring which marketing campaign led to an install, and detecting install fraud.

2. Advertising partners that also act for their own purposes. Advertising works differently, and we want to be clear about it:

• An advertising mediation platform — requests ads for the Games from a number of advertising networks.
• The advertising networks that supply those ads receive a request containing device and app information and, where you have allowed tracking, your advertising identifier.

These companies are not simply working for us. They decide for themselves how to use the data they receive — to select and target ads, to measure campaigns, and to build advertising audiences, both for our Games and for other advertisers. We do not control that use, and we cannot switch it off on your behalf. Under some laws, including California's, passing an advertising identifier to them counts as "sharing" personal information.

This is exactly why the tracking permission prompt matters. If you decline it, your advertising identifier is not passed to these companies and the ads you see are contextual instead. See Advertising and Tracking.

We identify our providers by function above rather than by name, because the set of providers — and especially the set of advertising networks enabled in the mediation platform — changes over time, and a list of names on this page would go out of date. You are entitled to know who they are: if you email us, we will tell you the current name of any provider in the groups above, and of the advertising networks enabled for a particular Game, and point you to their privacy policies.

3. Platforms with their own relationship with you. These companies are independently responsible for the data they collect from you, under their own terms and privacy policies:

• The Apple App Store — distribution of the Games, in-app purchase payments, and, where a Game uses it, the platform's own leaderboard service. Privacy policy
• Google Play — distribution and in-app purchase payments. This applies only from the date a Game is actually published on Google Play; at present the Games are distributed through the Apple App Store only. Privacy policy

Legal and safety disclosures. We may also disclose personal data where we reasonably believe it is necessary to comply with a legal obligation, court order or lawful request from a public authority; to establish, exercise or defend legal claims; or to protect the rights, property or safety of players, the public or ourselves.

If the Games change hands. If we ever transfer a Game or its assets to another developer or company, the personal data associated with that Game may be transferred as part of the change, and the recipient would have to handle it under a policy at least as protective as this one. The Games have no accounts and we hold no player email addresses, so we have no way to contact you individually. We will therefore announce a change like this on this page and, where we can, in the Game itself.

THIRD-PARTY LINKS AND ADVERTISEMENTS

The Games and this website contain links and references to services we do not operate. Advertisements shown in the Games are supplied by third-party networks and, when you tap one, they will normally take you out of the Game — to an app store listing, an advertiser's website, or another application. This website also links to the privacy policies of the providers listed above.

This Privacy Policy applies only to our own processing. It does not apply to, and we are not responsible for, how any third-party website, application, advertiser or online service collects or uses personal data once you leave a Game or this website — except where we have expressly said in this policy that a provider processes data on our behalf. Tapping an advertisement or a link means that third party's own privacy policy and terms govern what happens next.

Before giving personal data to any service you reach this way, please read its privacy policy. If a link in one of our Games or on this website leads somewhere that looks unsafe or deceptive, tell us at kerim.sabuncugil@gmail.com and we will look into it.

INTERNATIONAL TRANSFERS

We are based in Türkiye and the providers listed above are established in, or store data in, other countries, including the United States and countries in the European Economic Area. Your personal data will therefore be transferred outside your country of residence.

For transfers out of the EEA, the UK or Switzerland, we and our providers rely on the mechanisms permitted under applicable law, such as an adequacy decision or the European Commission's Standard Contractual Clauses. For transfers out of Türkiye, we rely on one of the grounds permitted under Article 9 of Law No. 6698 — an adequacy decision of the Personal Data Protection Board, an appropriate safeguard such as a standard contract notified to the Board, or, where required, your explicit consent.

Data protection law in a receiving country may not give you the same protection as the law where you live.

HOW LONG WE KEEP DATA

• Event-level analytics data (gameplay, sessions, ad and progression events) — retained for up to 14 months, both in our analytics provider's systems and in our own data warehouse, after which it is deleted or retained only in aggregated form.
• Attribution data — retained for the period provided by our attribution provider's retention settings, and no longer than needed to measure and audit a marketing campaign.
• Crash and diagnostic data — retained for up to 90 days.
• Purchase and transaction records — retained for as long as required by the tax and accounting law that applies to us, which is longer than the periods above.
• Leaderboard entries — retained while the leaderboard is active, or until you ask us to remove your entry.
• Email correspondence — retained for up to 24 months after the matter is closed.
• Aggregated or anonymised data that can no longer be linked to you or your device — retained without a time limit.

Where a longer period is required by law, or where data is needed for an ongoing legal claim, we keep it for that period instead.

YOUR RIGHTS

Depending on where you live, you may have the right to ask us to: confirm whether we process data about you and give you a copy of it; correct data that is wrong or incomplete; delete your data; restrict or object to how we process it, including objecting to processing based on legitimate interests; receive your data in a portable format; and withdraw a consent you previously gave, without affecting processing that already took place.

To exercise any of these rights, email kerim.sabuncugil@gmail.com. We do not charge for this. Because the Games have no accounts, we may need you to help us identify the right data — for example by telling us which Game you played, your approximate device model, and, where you can find it, the in-app identifier shown in the Game's settings or support screen. If we cannot connect a request to any data, we will tell you so rather than guess.

We will respond within the time limit that applies to your request — one month under the GDPR, and thirty days under Law No. 6698. If you are not satisfied, you can complain to your local data protection authority. In Türkiye that is the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu).

You can also stop all further collection at any time by uninstalling the Games. Uninstalling does not delete data already collected — use the rights above for that.

PLAYERS IN TÜRKIYE (KVKK)

We are established in Türkiye, so Law No. 6698 on the Protection of Personal Data applies to our processing. Under Article 11 of that law you have the right to learn whether your personal data is processed, to request information about the processing, to learn its purpose and whether it is used in line with that purpose, to know the third parties to whom it is transferred in Türkiye or abroad, to have incomplete or inaccurate data corrected, to request erasure or destruction, to have corrections and erasures notified to third parties, to object to a decision made solely by automated means that produces an adverse result for you, and to claim compensation for damage caused by unlawful processing.

The full Turkish-language disclosure, including the categories of data, purposes, legal grounds, recipients and retention periods, is at KVKK Aydınlatma Metni. Requests may be sent by email to kerim.sabuncugil@gmail.com or by the other methods described there.

PLAYERS IN CALIFORNIA (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect and the purposes for which we use it, to request a copy of it, to request its deletion, to request correction of inaccurate information, to opt out of the "sale" or "sharing" of personal information for cross-context behavioural advertising, to limit the use of sensitive personal information, and not to be discriminated against for exercising these rights.

We do not sell personal information for money. Allowing tracking through the App Tracking Transparency prompt, or leaving ads personalisation enabled on Android, may constitute "sharing" for cross-context behavioural advertising under California law. Declining the tracking prompt, or turning off ads personalisation in your device settings, is how you opt out. You can also email us at kerim.sabuncugil@gmail.com and we will apply the opt-out. We do not knowingly collect or process sensitive personal information as that term is defined under California law.

CHILDREN

The Games are general-audience puzzle games. They are not directed to children under 13, they are not published in a children's category, and we do not knowingly collect personal data from children under 13. Because the Games show advertising and use device identifiers, they are not designed or intended for use by young children.

Where applicable law sets a higher age for consenting to the processing of personal data, a parent or guardian must give that consent before the Games are used. If you are a parent or guardian and believe a child has provided us with personal data, email kerim.sabuncugil@gmail.com and we will delete it without undue delay and, where we can, disable the associated identifiers with our providers.

SECURITY

We use the security controls available to us as a small independent operation: access to analytics and store accounts is limited to the developer and protected with multi-factor authentication; data is transmitted over encrypted connections; and our analytics warehouse and provider dashboards are not shared with anyone else. No system can be guaranteed to be completely secure, and we cannot promise that data transmitted over the internet will never be intercepted.

DATA BREACH NOTIFICATION

If a personal data breach occurs and it is likely to result in a risk to your rights and freedoms, we will notify the competent supervisory authority within the period required by applicable law — 72 hours under the GDPR, and the shortest reasonable time under Law No. 6698 — and we will inform affected players where the law requires it, describing what happened, what data was involved and what we are doing about it.

CHANGES TO THIS POLICY

We may update this policy as the Games change or the law changes. The effective date at the top of the page always reflects the current version. If a change materially affects how we use your personal data, we will make that clear on this page and, where the law requires it, ask for your consent before the change takes effect. Earlier versions are available on request by email.

CONTACT

Questions, requests and complaints about privacy all go to the same place:

Kerim Sabuncugil (Pocket Giant)
kerim.sabuncugil@gmail.com