PRIVACY AND PERSONAL DATA PROTECTION POLICY
Introduction
We, Ritzy Games Yazilim Limited Sirketi (“Ritzy”), hereby inform you that we collect and
process personal data in full compliance with the Regulation EU2016/679-General Data
Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“UK GDPR”).
Ritzy Games Yazilim Limited Sirketi is a data controller within the meaning of the GDPR and
we process personal data. Where we act as a data processor on behalf of a data controller, we
provide an additional schedule setting out required information as part of that agreement. That
additional schedule should be read in conjunction with this Privacy and Personal Data Protection
Policy (“Privacy Policy”). We may amend this Privacy Policy from time to time. If we do so, we will
supply you with and/or otherwise make available to you a copy of the amended Privacy Policy.
Ritzy’s contact details are as follows;
Address: Yakuplu Mahallesi Hürriyet Bulvarı Skyport Sitesi Skyport Residence No:1/62
Beylikdüzü/İstanbul
Web Site: www.ritzygames.com
E-mail: support@ritzygames.com
What does Ritzy do?
Ritzy is an online gaming website and application established to provide players with the best
service and elevate their gaming experience. Over the years, Ritzy has served thousands of
players, listened to their needs, addressed their concerns, and successfully kept pace with the
ever-evolving gaming industry.
Feedback, complaints, and requests from its customers have been the key drivers of Ritzy’s
continuous development. This process has taught the company to remain open to innovation,
better understand player expectations, and deliver tailored solutions. Ritzy has evolved beyond
being just a service provider, creating a strong and engaged community of players.
The expectations and aspirations shared by players over the years form the foundation of the
games developed by Ritzy. The company’s primary goal is to win the loyalty of gamers and
deliver a unique experience that redefines the concept of entertainment.
What kinds of information do we collect from you?
WEBSITE and/or APPLICATION VISITORS
Personal data from visitors who visit the website and/or application without registering or
playing/downloading Ritzy games is collected as specified below for the purposes and methods
outlined.
Data Security: IP Address
Location: Location information based on the IP address
WEBSITE and/or APPLICATION USERS
Personal data from users who play and/or download Ritzy games without registering on the
website is collected as specified below for the purposes and methods outlined.
If you use third-party applications or connect via third-party platforms like Apple, Google,
Amazon, or social network sites (“SNS”) like Facebook to play Ritzy games, the data obtained
from those third-party applications falls under this scope.
The data collected depends on the third-party application, your privacy settings on that
platform, and potentially the privacy settings of other players/friends on the same platform. You
can manage the personal data collected by the third-party application. We recommend
reviewing the terms of service and privacy policy of the respective application.
When connecting via SNS:
Identity: Name, gender, age range
Contact: Email address
Biometric Data: Profile photo
Location: Location
Other: Profile avatar, SNS user ID and/or username, URL, local settings when registering
with the SNS (locale, language, time zone), SNS user IDs of friends/other players
When using the mobile platform:
Data Security: IP Address
Location: Location information based on the IP address
Other: Unique device ID (persistent/non-persistent), device OS, version, model, CPU,
RAM, disk space, hardware type, advertising identifier (IDFA), advertising ID, OS version,
device name, Game Centre ID
For payment transactions:
Customer Usage: Purchased products/services
WEBSITE and/or APPLICATION MEMBERS
Personal data from data subjects who create an “Account Registration” on the Website,
regardless of playing/downloading Ritzy games, is collected as specified below for the purposes
and methods outlined.
Identity: Name
Contact: Email address, phone number
Biometric Data: Profile photo
Other: Player name, avatar, password, other profile details, requests, order information,
customer reviews, purchase history
PERSONS CONTACTING VIA THE WEBSITE and/or APPLICATION WITHOUT
REGISTRATION
Personal data from data subjects who request information, provide feedback, report issues, seek
support, respond to surveys, or contact Ritzy for any other reason via the Website/Application is
collected as specified below for the purposes and methods outlined.
Identity: Name
Contact: Email address, phone number
Other: Personal data voluntarily provided by data subjects
PERSONS WHOSE PERSONAL DATA IS COLLECTED THROUGH AUTOMATIC DATA
COLLECTION METHODS
Personal data may be collected using tracking technologies such as cookies, web beacons, and
tracking pixels by Ritzy or service providers acting on behalf of Ritzy (e.g., Google Analytics), for
the purposes and methods specified below. Additionally, personal data may also be collected by
advertisers who provide ads through Ritzy.
• Data Security: IP Address.
• Location: Location information based on the IP address.
• Other: Automatically collected cookie identifiers, mobile advertising identifiers, mobile device
identifiers, advertising identifier (IDFA), ad ID, Game Centre ID, device type (mobile, tablet, or
computer), operating system, version, model, hardware type, and other device identifiers.
• Other: Browser type and language, hardware type, internet service provider, previously and
subsequently visited pages, date and time of visit, time spent on each page, clicked links, and
other similar data.
• Other: Information obtained through cookie logs and campaign activities.
EMPLOYEES / INTERNS / SHAREHOLDERS
Personal data of employees, interns, and shareholders within Ritzy is published in detail only in
a way that is accessible to them, and they have been thoroughly informed about this matter.
JOB APPLICANTS
In Ritzy’s recruitment processes, personal data may be collected from data subjects who have
applied to work at Ritzy, those contacted through references, those who have come through
employment agencies or other channels, or those who reach out to Ritzy through various means.
The following personal data may be collected for the purposes and methods specified below.
• Identity Information: First name, last name, Turkish ID number, date of birth, gender.
• Contact: Contact address, email address, phone number.
• Personal Details: CV details, military status, reference information.
• Professional Experience: Educational background and details, work history and details,
diploma information, foreign language proficiency, computer usage skills, position/title
information.
SUPPLIER EMPLOYEE
• Identity: First name, last name, signature.
• Contact: Contact address, email address, phone number.
We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing a
specific web site feature.
How does Ritzy collect information from you?
Direct Interactions:
o From data subjects who provide requested information during membership registration.
o From those who, without registering, request information about games or other topics,
leave comments, report issues, seek support, respond to surveys, or contact Ritzy for
other reasons via the Website and/or Application
o Through resumes sent to Ritzy via email, private employment agencies, other platforms
(e.g., LinkedIn), or the direct statements of job applicants
o Through contracts, forms, request/order and response emails, invoices, and documents
related to procurement activities.
Automated technologies or interactions:
As people interact with our websites, we may automatically collect Technical Data about your
equipment, browsing actions and patterns. We collect this personal data by using cookies and
other similar technologies.
Third parties: We may receive personal data about you from various third parties as set out
below:
o Technical Data from the following parties: analytics providers such as Google.
o Via cookies
o Via cookies on third-party applications and social networking sites
Persons / Organisations to whom we may give personal data
For Visitors and/or Members
We may share your personal data with:
Our Employees
Our Subcontractors
For Employees
We may share your personal data with:
Our Suppliers
Our Other Employees
Our Shareholders
For Suppliers and Subcontractors
We may share your personal data with:
Our Employees
If you ask us not to share your personal data with such third parties we may need to cease to
act.
If the law allows or requires us to do so, we may share your personal data with:
The Police and Law Enforcement Agencies
Courts and Tribunals
Requesting Personal Data, we hold about you (Subject Access Requests)
You have a right to request access to your personal data that we hold. Such requests are known
as “Subject Access Requests” (“SARs”). Please provide all SARs in writing marked for the
attention of Data Protection Officer, Ritzy. To help us provide the information you want and deal
with your request more quickly, you should include enough details to enable us to verify your
identity and locate the relevant information.
We comply with a SAR promptly and in any event within one month of receipt. There are,
however, some circumstances in which the law allows us to refuse to provide access to
personal data in response to a SAR (e.g. if you have previously made a similar request and there
has been little or no change to the data since we complied with the original request). We will
not charge you for dealing with a SAR.
You can ask someone else to request information on your behalf – for example, a friend,
relative or solicitor. We must have your authority to respond to a SAR made on your behalf.
You can provide such authority by signing a letter which states that you authorize the person
concerned to write to us for information about you, and/or receive our reply.
Putting things right (Right to Rectification)
You have a right to obtain the rectification of any inaccurate personal data concerning you that
we hold. You also have a right to have any incomplete personal data that we hold about you
completed.
Deleting your records (Right to Erasure)
In certain circumstances you have a right to have the personal data that we hold about you
erased. In certain circumstances we have the right to refuse to comply with a request for
erasure. If applicable, we will supply you with the reasons for refusing your request.
The Right to Restrict Processing and the Right to Object
In certain circumstances you have the right to block or suppress the processing of personal
data or to object to the processing of that information. If you want us to cease to process your
information or you object to processing so that we can consider what action, if any, is
appropriate.
Withdrawal of Consent
Where you have consented to our processing of your personal data, you have the right to
withdraw that consent at any time.
Automated decision-making
We do not intend to use automated decision-making in relation to your personal data.
Requests and Complaints
In accordance with the applicable regulations, you have the right to access, update or request
deletion of your Personal Data as we explained above. And also, if you are not happy with our
response or you think we have not complied with the GDPR in some other way, you can
complain to us.
Please send your requests and your complaints to [email protected]m . You can submit
by filling this Complaint Form.
