Biometric Data Consent
Version: v1.0 · Effective Date: September 2026
No Surrender Yazılım ve Ticaret A.Ş.
Trade Registry: 306843-5
Explicit consent text for the processing of facial biometric data
1. Why is this text being provided to you?
In order for the cash prizes distributed within the Rewards League of Legendary Club Owner to be paid to the person who has won the prize and to that person alone, and in order to act in compliance with our obligations under Law No. 5549 on the Prevention of Laundering Proceeds of Crime in this context, your identity must be verified. Verification is carried out by comparing, through automated means, the image of your identity document with still and moving images of your face.
Because the still and moving images of your face are processed through automated means for the purpose of uniquely identifying you, they constitute special categories of personal data (biometric data) within the meaning of Article 6 of Law No. 6698 on the Protection of Personal Data ("KVKK"). For this reason, such data may only be processed where your explicit consent is present. This text is provided in order to obtain your consent, which — pursuant to Article 3(1)(a) of the KVKK — must relate to a specific matter, be based on information and be given by free will. Your explicit consent is not required in order for you to play Legendary Club Owner.
2. What data will be processed, and for what purpose?
| Data category | Purpose of processing | Legal basis |
|---|---|---|
| Still facial photograph and short moving image (video) captured for liveness detection, together with the biometric template generated from them and the matching result | Verifying that the applicant is the same person as shown in the photograph on the identity document, and liveness detection for the purpose of preventing fraud and identity forgery | Your explicit consent pursuant to Article 6(3)(a) of the KVKK |
Your biometric data is processed solely for the purpose of verifying your identity; it is not used for advertising, marketing, profiling, player segmentation, tracking through facial recognition or any other purpose, and it is not transferred to third parties for such purposes.
3. Who will your data be shared with?
- Our identity verification service provider: SUMSUB TECHNOLOGY LLC. The verification process may be carried out through a service provider that acts on behalf of the Company and solely in accordance with the Company's instructions, and that is subject to the KVKK. The provider may not use this data for its own purposes.
- Contracted financial institution: Where necessary, only your identity information is shared for the purpose of confirming whether the IBAN you have declared belongs to you; your biometric images are not shared.
- Competent public authorities and institutions: Solely for the fulfilment of an obligation arising from legislation or the satisfaction of a duly made request, and limited to the scope requested.
4. How long will your data be retained?
The image of your identity document, the still and moving images of your face and the biometric template are retained for eight (8) years following completion of the verification process.
5. How is your data protected?
Access to the data is restricted to a limited number of specifically authorised personnel; the data is stored encrypted using cryptographic methods and the encryption keys are kept in separate and secure environments; every access is logged; transfers are carried out only over encrypted channels; confidentiality undertakings are obtained from the relevant personnel and regular training is provided.
6. Are you required to give consent?
No. Biometric verification is not required in order to play Legendary Club Owner, and withholding this consent does not prevent your participation in the Rewards League. However, if you become entitled to a prize during a Rewards League season, the cash payment of that prize may, pursuant to applicable legislation, only be made to bank accounts that correctly match users whose identity has been verified. Accordingly, verifying your identity using your biometric data for the purpose of collecting the prize amount is suitable for its purpose, necessary and proportionate, and the fact that the biometric data processed is limited to your face alone is consistent with the principle of data minimisation.
7. Explicit consent declaration
Ticking the box below means that you give your explicit consent to the processing activity concerned.
☐ I have read and understood the information above. I give my explicit consent to the processing of the still photograph of my face and of the moving image captured for liveness detection, for the purpose of verifying my identity within the scope of the Rewards League, limited to the purposes, retention period and recipient groups set out above.
Withdrawing your consent: You may withdraw your explicit consent at any time through the in-game menu "Account → Privacy → My verification preferences" or by sending an email to community@nosurrender.studio. Withdrawal takes effect prospectively; it does not invalidate processing lawfully carried out up to the date of withdrawal. If you withdraw your consent, your biometric data will be destroyed immediately and any ongoing verification processes will be conducted by an alternative method.
You may exercise the rights listed in Article 11 of the KVKK through the channels set out in the Privacy Policy.
8. Consent record
If you approve this text in the in-game registration flow, the date and time of approval (timestamp), the version number of the text you approved and the summary (hash) value of the text are recorded for evidentiary purposes in the event of a dispute.
Name and Surname: ..................................................
Date: ......../......../20......
Signature: ..............................
(For use with a wet signature. In the in-game flow, an electronic consent record is kept in place of this section.)