Privacy Policy

No Surrender Yazılım ve Ticaret A.Ş.
Trade Registry: 306843-5

Thank you for playing our game! This Privacy Policy explains:

• How we collect personal data about you and why we do it
• How we use your personal data
• Your choices regarding your personal data

This Privacy Policy applies to all games, stores, sites and related services developed by No Surrender Yazılım ve Ticaret A.Ş. ("Company") for the Legendary Club Owner mobile game ("Game") and collectively referred to here as the Service. We may periodically update this Privacy Policy by publishing a new version on nosurrender.studio. If we make any material changes, we will notify you in the manner required by applicable law, including by posting a notice in the Service before the changes become effective. Your continued use of the Service after the effective date shall be subject to the new Privacy Policy.

The Game is released for users 18 years and older, and participation in the Rewards League system described below is available only to users 18 years and older. Your personal data is processed in accordance with applicable laws, including primarily Law No. 6698 on the Protection of Personal Data ("KVKK"). This Privacy Policy also serves to fulfill our notification obligations under the KVKK, and where necessary, we provide additional explicit consent documents.

Data Controller

Under this Privacy Policy, the data controller responsible for your personal data is No Surrender Yazılım ve Ticaret A.Ş. ("Company"). You can reach the Company through the contact methods specified in the "Contact Us" section below.

Contact Us

If you have questions about data protection or need to resolve any issues regarding your personal data, we recommend that you first contact us through the in-game support feature for faster response. Alternatively, you can reach us at:

Email: community@nosurrender.studio

You may submit requests under the KVKK (such as requests for information, correction, deletion, or objection to processing) to the email address above, or you may file a formal application with the Company through the methods prescribed by applicable law. Your request will be resolved within the timeframe specified in the KVKK.

Data We Collect

The categories of personal data we collect depend on the Services you use and the requirements of applicable law.

Data You Provide Directly to Us

• Identity information (name, surname, ID number, date of birth)
• Contact information (email address or phone numbers)
• In-game Account information
• Messages and other content you send while using the Service (such as chat logs and player support tickets)
• Bank account information
• Data provided in connection with surveys, promotions, contests and other events
• Records of consents and declarations you provide during registration, including timestamp, approved text version and relevant hash summary
• Identification document (such as national ID card, passport or driver's license) and a liveness detection video/selfie (biometric data), collected for identity verification purposes in connection with the Rewards League

Data We Collect Automatically

• Data about your account and game progress, including an internal account ID typically generated automatically
• Your IP address and mobile device identifiers (such as your device ID or advertising ID)
• Data about your device, such as device name and operating system, browser type and language, internet service provider and mobile operator
• Data we collect through cookies and similar technologies (see below for more)
• Approximate location data (as derived from your IP address)
• Data related to your use of the Service, such as game data, purchases made, and interactions with other players within the Service

You also have the option to create a No Surrender ID using your email address or other contact information.

Data We Collect from Partners

We also work with third-party partners such as social networks, data analytics providers, and advertising networks to supplement the information we have about you:

• Data we receive if you associate a third-party service with the Service (such as Apple and Google)
• Demographic data (such as determining the approximate location of your IP address)
• Data for fraud prevention (such as refund abuse in games or click fraud in advertising)
• Data from platforms on which games run or from payment service providers (such as payment verification data)
• Data for advertising and analytics purposes to better serve you (such as surveys)
• Data received from contracted financial institutions regarding identity and account (IBAN) matching/verification results during the reward verification process to confirm that the account (IBAN) you claimed belongs to you

Why We Collect Your Data

We use your data for various business purposes, including:

To Make the Service Work

We process the data necessary to fulfill our obligations arising from the Terms of Service relating to the Game:

• Create an account and allow you to play our game and use our Service
• Verify and confirm payments for virtual item purchases
• Provide the products and services you have requested and deliver them
• Send you communications related to the Service and respond to your support requests

To Conduct Rewards League Participation and Reward Processes

We process the necessary data for Rewards League participation, identity and financial account verification, determining reward eligibility, processing reward payments, and ensuring compliance with regulations including tax and financial crimes. In this context, your data is processed for contract performance, compliance with legal obligations (especially tax law and certified public accountant reporting processes), establishing and protecting reward rights, and our legitimate interests:

• Verification of your identity information and your account with a contracted financial institution
• Recording and retention of consents and representations you provide in the Rewards League registration flow with timestamp, text version and summary/hash information for evidence purposes in case of disputes
• Verification of your identity through a specialized identity verification service provider, including the processing of your identification document and a liveness detection video (biometric data), carried out on the basis of your explicit consent

To Make the Service More Suitable for Our Players

We have a legitimate interest in collecting and processing necessary data to provide our players with an excellent Service:

• Update and enhance player profiles
• Improve and enhance the Service and player experience
• Manage our relationship with you
• Provide social features as part of the Service
• Customize your Service experience
• Address your feedback and questions and provide player support
• Present the Company's offerings to you within the Service
• Send you relevant information such as updates, security alerts, and support messages
• Enable you to communicate with other players

To Show You Personalized Ads

We have a legitimate interest in processing necessary data to show you personalized ads in the Service and elsewhere (including email):

• Monitor the content you access and your online behavior in connection with the Service
• Deliver, target, and improve our ads and Service
• For information on how you can opt out of personalized ads, see the 'Your Rights and Choices' section below

To Keep the Service Safe and Fair

Providing an even playing field in the Service and preventing manipulation are our highest priorities. For more information about our acceptable use policy, see the Company Terms of Service.

We process your personal data to keep the Service and social features safe and fair, combat fraud, and ensure acceptable use, as this is directly related to our ability to properly perform game services under the Terms of Service:

• Analyze and monitor use of the Service and social features
• Manage chat automatically or manually
• Take action against players engaging in fraud or misconduct
• For the purpose of ensuring fair play, detect and take action against multi-accounting, account sharing, false statements, and unfair advantage attempts to ensure fair play; keep logs and transaction records related to bans, account restrictions, or actions affecting reward rights

To Analyze, Profile, and Segment

In all the above situations and purposes, we may analyze, profile, and segment all collected data.

Who Can See Your Data

Outside of the Company, your data may be accessed by others in the following circumstances:

Other Players and Users

Social features are a core component of our game. For example, other players and users can see your profile data, your in-game activities, and can read messages you send.

Our Service Providers

The Company has suppliers who help us provide the Service. Suppliers process your data only according to Company instructions and to provide their service, performing tasks such as hosting, player support, advertising, analytics, and fraud prevention.

Contracted Financial Institution

In the context of the reward verification and payment process; your declared identity information and account information are shared with the contracted financial institution only for verification and payment purposes and to the extent necessary.

Identity Verification Service Provider

To verify your identity as part of the Rewards League registration and eligibility process, we work with SUMSUB TECHNOLOGY LLC, a company incorporated and registered in the United Arab Emirates with commercial register number 2014604, with its registered office at Sheikh Mohammed bin Rashid Blvrd., Boulevard Plaza Tower 2, Floor 23, Downtown, Dubai, United Arab Emirates ("Sumsub"). For this purpose, your identification document and a liveness detection video (biometric data) are processed by Sumsub, acting as our data processor, solely to verify your identity and confirm your eligibility to participate in the Rewards League. As your identification document and liveness video constitute biometric data, a special category of personal data under Article 6 of the KVKK, this processing is carried out on the basis of your explicit consent. Sumsub retains this data only for as long as necessary to complete the verification process and to comply with applicable legal requirements.

Certified Public Accountants (CPA) and Financial and Legal Consulting Service Providers

Within the scope of financial record-keeping, reporting, and compliance processes related to reward distribution; necessary data may be shared with certified public accountants and related consultants for the purpose of fulfilling our legal obligations.

Additionally, within the scope of complaints and requests you have submitted regarding the game and disputes arising from the Terms of Service, your personal data may be shared with our legal advisors to the extent necessary to fulfill our legal obligations and legitimate interests.

Other Companies and Government Authorities

To verify payments and combat fraud and illegal activity, we may process data and share it with other companies and organizations, and may provide it to public authorities in response to legal requests. We may also disclose your data based on your consent, to comply with laws, or to protect the rights, property, or safety of us, our players, or others.

Advertising and Social Media Partners

The Service includes features from our partners through social media interaction tools, application programming interfaces (APIs), or software development kits (SDKs). These business partners may access your data and operate under their own privacy policies. These partners may access data related to your activities and device (such as your IP address, mobile identifiers, pages you visit, your location, time of day). If you prefer not to share your personal data with third-party advertising partners, follow the instructions in the 'Your Rights and Choices' section below.

International Data Transfers

Your personal data is stored in encrypted form in server infrastructure located in Turkey in accordance with the KVKK. In connection with the identity verification services described in the "Who Can See Your Data" section above, your identification document and liveness detection video (biometric data) may be transferred to and processed in the United Arab Emirates, where our identity verification partner, Sumsub, is located. This transfer is carried out on the basis of your explicit consent and in accordance with Article 9 of the KVKK.

Your Rights and Choices

Push Notifications

We may send you push notifications through our mobile app. You can opt out of such communications at any time by changing your settings on your mobile device.

Opting Out of Targeted Ads

You can opt out of interest-based ads by controlling your Android or iOS device privacy settings. You can also opt out of personalized in-game offers through options provided in game settings (if available).

Access Personal Data We Hold About You

Upon your request, we will provide you with a copy of your personal data in electronic format.

Your Other Rights

You also have the right to correct your data, request deletion, object to how we use or share your data, and restrict how we use or share your data. You may withdraw your consent at any time. We will respond to all requests within a reasonable timeframe.

Pursuant to Article 11 of the KVKK; you have the right to learn whether your personal data is being processed, to request information about it if it is, to learn the purpose of processing and whether it is used in accordance with the purpose, to know the third parties to whom it is transferred domestically or abroad, to request correction if it is processed incompletely or incorrectly, to request deletion or destruction within the conditions stipulated in the KVKK, to request that correction/deletion operations be notified to third parties to whom the data has been transferred, to object to decisions resulting only from automated processing of data, and to claim compensation for damages if you suffer damage due to unlawful processing.

If you wish to exercise any of your data subject rights described above, please use the support options explained in the "Contact Us" section above. To protect your privacy, we may take additional steps to verify your identity before fulfilling your request; for example, we may ask you to provide a proof of purchase or other account information, or we may ask you to link your email address to your game account. You have the right not to be discriminated against as a result of exercising these rights.

Cookies and Similar Technologies

As with most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyze usage, target ads, and prevent fraud. For details about the types of cookies, their purposes, and how you can manage your preferences, please see our Cookie Policy. Non-essential (analytics and advertising/marketing) cookies are subject to your explicit consent, and you may withdraw your consent at any time. Cookies and similar technologies allow us and our partners to save your preferences and track your activities within the Service.

How We Protect Your Data

Security Measures

Your data is stored in encrypted form in server infrastructure located in Turkey in accordance with the KVKK. To help provide a secure and safe player experience, we continuously develop and implement administrative, technical, and physical security measures to protect your data against unauthorized access, loss, misuse, or alteration.

Data Retention

We retain your data for as long as your account is active or as long as necessary to provide you the Service. For example, we may periodically anonymize unused gaming accounts and regularly review and anonymize unnecessary data.

Please note that if you request deletion of your personal data, we will retain your data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, as well as our legitimate interests and legal obligations (particularly tax and financial crimes regulations and financial records relating to reward payments).

Children

The Game is released for users 18 years and older, and participation in the Rewards League system is available only for users 18 years and older. The Game is not intended for individuals under 18 years of age and the Company does not knowingly collect personal data from such persons.

Protecting children's online privacy is very important to us. If you are a parent or guardian and wish to review personal data collected from your child or request that such information be modified or deleted, you may contact us as described above.

If we discover that a child has provided us with personal data in violation of the above, we will delete all personal data we have collected without a legal obligation to retain it, and we will close the child's account.