Garawell Games

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Privacy Policy

Last updated: 21 October 2026

Garawell Games Oyun Yazılım A.Ş. (“Garawell”, “we”, “us”, or “our”) develops and operates games and applications and provides the Garawell software development kit (the “Garawell SDK”) used in games and applications.

This Privacy Policy explains what personal information we process, how we obtain and use it, when we share it, how long we retain it, and the choices and rights available to you.

1. Scope and Responsibility

This Privacy Policy applies to:

  • Games and applications operated by Garawell.
  • Processing carried out by Garawell through the Garawell SDK in games and applications operated by other developers or publishers.
  • Our public websites and communications with visitors and users.
  • Support enquiries and privacy requests relating to these services.

The information processed depends on the game or service, its configuration, the features you use, your device and platform, and your applicable privacy choices. Not every feature or provider described in this policy is used in every game.

Garawell is the data controller for processing whose purposes and means we determine. When another developer or publisher operates a game, that organisation may also be responsible for processing personal information. Its privacy policy describes its own activities.

This policy covers Garawell’s processing and does not replace the privacy policy of another developer, publisher, platform, or independent service provider.

2. Information We Process

2.1 Information you provide

When you contact us, request support, or exercise your privacy rights, we process the information you provide. This may include your name, email address, the content of your message, and information relevant to your enquiry.

To identify the game and records associated with a privacy request, we may process the game name, application identifier, player ID, and contact information included in the request.

2.2 Device, application, and identifier information

Our games and integrated services may process:

  • Device model, operating system, application version, platform, language, and related technical settings.
  • Network connection information, such as connection type.
  • IP address and approximate location, such as country or region, derived from that address.
  • Player IDs, installation IDs, app-instance IDs, and other identifiers used to distinguish a player, installation, device, or session.
  • Advertising identifiers, such as the Android advertising ID or Apple’s Identifier for Advertisers, where available and permitted by applicable settings, permissions, and law.
  • Consent status, privacy preferences, and related information needed to apply your choices.

A player or installation identifier may be randomly generated and may not reveal your name. Information linked to such an identifier can nevertheless be personal information and is not necessarily anonymous.

2.3 Gameplay and interaction information

Depending on the game and enabled integrations, we may process information about:

  • App launches, sessions, activity times, and interactions with game features.
  • Level starts and completions, successes and failures, progression, and other gameplay events.
  • Virtual items, virtual currency, rewards, quantities, balances, and in-game transactions.

This information helps us understand how games are used, identify problems, evaluate features, and improve game balance and the player experience.

2.4 Advertising and campaign information

Advertising and measurement services may process information about ad requests, impressions, clicks, video views, rewarded-ad interactions, advertising revenue, and related events.

Attribution services may process information about the campaigns or sources associated with installations and in-game events. Attribution means measuring which advertisement or campaign contributed to an installation or another measured event.

The information involved may include advertising or installation identifiers, IP addresses, device information, campaign information, and relevant app events, subject to applicable privacy choices and requirements.

2.5 Log data, diagnostics, and performance information

To investigate errors and improve reliability, our games may process crash reports, exception details, technical logs, and relevant application state.

Reports may include device and application information, a player or installation identifier, and the time and circumstances of an error.

Depending on the diagnostic features enabled, performance information may include frame rate, memory use, battery level, and low-memory events.

2.6 Purchase information

Where a game offers in-app purchases through the Apple App Store or Google Play, the relevant store processes the payment.

The game may receive product identifiers, transaction identifiers, purchase status, receipts, and entitlement information needed to deliver, verify, or restore purchases.

These store purchases do not require you to provide your full payment-card details directly to Garawell. The relevant store’s privacy policy also applies to its processing.

2.7 Website information and privacy records

Our websites and supporting infrastructure may process IP addresses, browser and device information, requested pages, request times, and technical or security logs.

When you contact us through a website or by email, we process the information you submit.

We may also process records of privacy choices and requests, including information needed to identify the relevant records, apply your choices, respond to your request, and demonstrate compliance with applicable requirements.

3. How We Obtain Information

We obtain information:

  • Directly from you when you communicate with us or submit a request.
  • Automatically through games, applications, websites, and integrated SDKs.
  • From the platforms, advertising services, measurement services, and other providers involved in delivering the services.
  • From a game’s developer or publisher where relevant to Garawell’s processing, support, or handling of a privacy request.

The sources involved depend on the particular game, service, and features you use.

4. Why We Process Information and Our Legal Grounds

We process information for the following purposes:

  • Providing games and their features: operating applications, applying settings and configuration, and delivering requested functionality.
  • Understanding gameplay: analysing sessions, progression, feature interactions, and in-game transactions to improve game design and balance.
  • Advertising: delivering advertisements, measuring ad performance and revenue, and applying advertising preferences.
  • Campaign measurement: understanding installation sources and evaluating the effectiveness of advertising campaigns.
  • Diagnostics and performance: investigating crashes, resolving technical issues, and improving reliability.
  • Purchases: delivering, verifying, and restoring purchased content where available.
  • Support and privacy requests: responding to enquiries, identifying relevant records, and carrying out applicable requests.
  • Security and legal requirements: protecting services, addressing fraud or misuse, maintaining required records, and responding to legally valid requests.

Where data protection law requires a legal basis, the basis depends on the purpose and circumstances:

  • Consent: for processing that requires your consent, including relevant analytics, personalised advertising, tracking, or non-essential device storage and access.
  • Performance of a contract or steps taken at your request: where processing is necessary to provide a service you request, deliver a purchase, or fulfil another applicable contractual obligation.
  • Legitimate interests: where permitted by law, for purposes such as protecting services, investigating technical problems, handling support, and improving services, subject to your rights and interests.
  • Legal obligations: where processing is necessary to comply with applicable law, including relevant recordkeeping requirements and legally valid requests.

Legitimate interests do not replace consent where consent is required. The applicable legal grounds may differ under local law. You can contact us for information about the grounds relevant to a particular processing activity.

5. Service Providers and Information Sharing

5.1 Integrated services

We use third-party services for advertising, consent management, analytics, attribution, diagnostics, and application configuration.

Depending on the game and its configuration, these may include:

Where a game offers in-app purchases, Apple or Google also processes purchase-related information under its applicable store terms and privacy policy: Apple and Google.

Providers may process information on our behalf or as independent controllers, depending on their role and the service concerned. Their policies provide additional information about their processing.

The providers and advertising partners involved can vary by game and configuration. Where an applicable consent interface presents a partner list, you can review that list and the choices it offers. You can also contact us to ask which providers are involved in a particular game.

5.2 Games operated by other developers or publishers

Other developers and publishers can integrate the Garawell SDK into their games. Integrations covered by this policy may send information to service-provider accounts managed by Garawell.

Garawell may access and use the resulting information for the purposes described in this policy, subject to applicable privacy choices and legal requirements.

We may share relevant gameplay, analytics, and diagnostic information with the game’s developer or publisher to operate, support, and improve that game.

The developer or publisher may determine aspects of the integration, such as which supported features are enabled and which game events are submitted. Its own privacy policy explains its separate processing activities.

5.3 Other disclosures

We may share relevant information with hosting, communications, security, and professional-service providers supporting our operations.

We may also disclose information where required by law, in response to legally valid requests, or where necessary and legally permitted to protect rights, resolve disputes, and address fraud or security incidents.

Links to provider policies do not replace Garawell’s responsibility for the processing described in this policy.

6. Advertising, Analytics, and Your Choices

Depending on the game, platform, and applicable requirements, in-game privacy settings or consent messages may allow you to manage analytics and advertising choices.

Where a consent form is provided, it may offer choices concerning specific purposes and partners. The available controls can vary between games and regions.

You can also manage tracking permissions and advertising-identifier settings through your device settings. On iOS, tracking that requires Apple’s permission is subject to App Tracking Transparency.

Turning off personalised advertising does not necessarily remove advertisements. You may still receive non-personalised or limited ads. Advertising services may continue to process information for permitted functions such as ad delivery, security, and fraud prevention, subject to applicable law and your choices.

Changing an analytics or advertising preference does not itself submit a deletion request for information previously collected. It also does not disable every function needed to operate a game, such as configuration delivery, purchase handling, or responding to a support request.

Where processing relies on consent, you can withdraw that consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

If you cannot find or use a privacy control, contact us using the details below.

7. Cookies and Local Storage

Our websites and embedded services may use cookies or similar technologies for functionality, security, and measurement where enabled. The technologies used depend on the website and features involved.

You can manage browser cookies through your browser settings and any consent controls provided by the website. Blocking certain cookies may affect functionality.

Games use local storage for information such as progress, settings, generated identifiers, and privacy preferences. Mobile SDK identifiers and local application storage are distinct from browser cookies.

Clearing browser or application storage does not automatically delete information already held by Garawell or service providers.

8. Data Retention

We retain personal information for as long as necessary for the purposes described in this policy, taking account of the information involved, why it is used, applicable legal obligations, and your rights.

There is no single retention period for every category of information or every provider.

In determining retention, we consider:

  • The period needed to provide the relevant game, service, or requested feature.
  • The period needed to understand gameplay, investigate errors, or resolve a support request.
  • The need to maintain records of privacy choices and requests.
  • Applicable transaction-record requirements and other legal obligations.
  • The time needed to establish, exercise, or defend legal claims.
  • Relevant provider retention settings, deletion procedures, and backup handling.

When information is no longer needed, we delete or anonymise it, subject to lawful retention requirements and the relevant service providers’ deletion processes.

A deletion request may be subject to lawful exceptions, such as retaining records required by law. We can explain the retention criteria relevant to a particular request.

Uninstalling a game, clearing local storage, or disabling analytics does not by itself request deletion of information already collected by online services.

9. International Processing

Garawell is based in Türkiye. Our providers operate internationally, so personal information may be processed in Türkiye and other countries, including countries outside your place of residence.

The locations involved depend on the provider, service, and configuration. Those countries may have different data protection laws.

International transfers are subject to applicable legal requirements. Depending on the relevant law and transfer, these requirements may involve an adequacy decision, approved contractual safeguards, or another permitted transfer mechanism.

You can contact us for information about the recipients, locations, and applicable transfer arrangements relevant to your information.

10. Your Privacy Rights

Your rights depend on applicable law and the circumstances of the processing. These rights may be subject to conditions and lawful exceptions.

10.1 Access, correction, deletion, and other rights

Depending on applicable law, you may have the right to:

  • Learn whether your personal information is processed and obtain information about that processing.
  • Access your personal information and request a copy.
  • Request correction of inaccurate or incomplete information.
  • Request deletion of your personal information.
  • Request restriction of certain processing.
  • Object to processing, including processing based on legitimate interests and direct marketing.
  • Receive certain information in a portable format.
  • Withdraw consent where processing relies on consent.
  • Challenge qualifying decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects, and request the protections provided by applicable law.
  • Complain to the competent data protection authority.

These rights may apply under laws such as the GDPR, UK GDPR, Swiss data protection law, or other applicable local requirements.

10.2 Rights under Türkiye’s data protection law

Where Türkiye’s Personal Data Protection Law No. 6698 (“KVKK”) applies, your rights under Article 11 include:

  • Learning whether your personal data is processed.
  • Requesting information about processing.
  • Learning the purpose of processing and whether your data is used in accordance with that purpose.
  • Knowing the third parties to whom your data is transferred in Türkiye or abroad.
  • Requesting correction of incomplete or inaccurate data.
  • Requesting deletion or destruction where the conditions provided by applicable law are met.
  • Requesting notification of relevant correction or deletion to recipients where applicable.
  • Objecting to an adverse result arising from analysis exclusively through automated systems.
  • Seeking compensation for damage caused by unlawful processing.

10.3 Additional rights under applicable U.S. privacy laws

Depending on your state of residence and applicable law, you may also have rights concerning:

  • The categories and sources of personal information collected.
  • The purposes for which information is used and the categories of recipients.
  • Access, correction, deletion, and portability.
  • Opting out of targeted advertising, the sale or sharing of personal information, and certain forms of profiling.
  • The use or disclosure of sensitive personal information where relevant.
  • Submitting requests through an authorised agent.
  • Appealing a decision concerning a privacy request.

Certain advertising-related disclosures may be considered a “sale,” “sharing,” or “targeted advertising” under applicable U.S. privacy laws, even where no money is exchanged.

Where these rights apply, you can use available privacy controls or contact us to make a request. We will not discriminate against you for exercising privacy rights protected by applicable law.

An authorised agent may need to provide evidence of their authority, and we may need to verify the request as permitted by law.

If applicable law gives you a right to appeal a decision concerning your request, you can contact us using the details below and identify the decision you wish to appeal.

11. How to Submit a Privacy Request

To ask a privacy question or exercise your rights, email:

sdk+privacyrequest@garawell.com

Please include:

  • The name of the game or service.
  • A description of your request.
  • Your player ID, if available.
  • Contact information so that we can respond.

Do not send passwords, payment-card information, or unrelated sensitive documents.

Where available, the in-game privacy request feature prepares an email containing information such as the game name, application identifier, player ID, and your contact email.

You must send that email to submit your request. Opening the email draft does not submit a request or automatically delete information.

We may need proportionate additional information to identify the relevant records and verify that a request concerns your information.

We handle requests according to applicable law, including its response deadlines, permitted extensions, and exceptions. Where relevant, this involves coordinating with service providers or the game’s developer or publisher.

For information held separately by another developer, publisher, or independent provider, you may also need to contact that organisation under its own privacy policy.

12. Children’s Privacy

Garawell’s games are not directed to children under 13. We do not knowingly collect personal information from children under 13.

Some jurisdictions apply additional age-related protections or require parental consent for particular processing activities.

Games operated by other developers or publishers may have their own audience restrictions and notices. Their privacy policies explain their practices.

If we learn that a child’s personal information has been collected without legally required parental consent, we will promptly delete that information.

If you are a parent or guardian and believe your child has provided personal information through our services, please contact sdk+privacyrequest@garawell.com and identify the relevant game so that we can address the information concerned.

13. Security

We use reasonable technical and organisational measures intended to protect personal information against unauthorised access, disclosure, alteration, loss, or misuse.

However, no method of transmission over the internet or electronic storage can guarantee absolute security.

Please avoid including sensitive information in support messages unless it is necessary for your request.

14. Links to Other Sites and Services

Our games and websites may contain links to third-party websites, applications, or services.

When you access a separate third-party service, its own terms and privacy policy govern its processing. We encourage you to review those policies before providing information.

We do not control the privacy practices of independent third-party websites or services. This does not remove Garawell’s responsibility for processing carried out by us or on our behalf as described in this policy.

15. Platform Privacy Requirements

We are committed to meeting the applicable privacy and data-protection requirements of Google Play, Apple’s App Store, and Meta.

This includes providing transparent information about data processing, applying relevant consent and privacy requirements, and maintaining methods for users to submit privacy requests.

The stores and platforms may also process information independently under their own privacy policies.

16. Changes to This Policy

We may update this Privacy Policy to reflect changes to our games, services, providers, processing practices, or applicable requirements.

The revised policy will be published on this page with an updated date. Where required, we will provide additional notice or obtain consent before a relevant change takes effect.

17. Contact Us

Garawell Games Oyun Yazılım A.Ş.

Privacy questions and requests:
sdk+privacyrequest@garawell.com

General enquiries:
info@garawell.com

Website:
www.garawell.com