Last updated 27 September 2023.
Momend Ltd. Sti. ("us", "our", "we", "Momend") are committed to protecting and respecting your privacy.
This privacy policy (the "Policy") sets out the types of personal data we collect and use when you access and visit momend.com or when you use one of our apps or games (each a "Property" and together the "Properties") and how we may use that data.
1. Introduction
This Policy covers our collection, processing and use of personal data when you use any of our Property.
When you supply any personal data to us we have legal obligations towards you in the way we use that data.
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Properties at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you first download and begin using a Property, or that may be displayed where you are given the opportunity to sign up to receive email updates from us) so that you are fully aware of how and why we are using that data.
This Policy supplements our Terms of Service, Cookie Policy and other notices and terms that appear in the Properties (which may vary from Property to Property) and is not intended to override or replace them.
By visiting or otherwise using our Properties, you are agreeing to the practices set out in this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using the Properties.
We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the relevant Properties know. However, it is your responsibility to check this Policy before each use of the Properties for ease of reference the top of this Policy indicates the date on which it was last updated.
Please note that our Properties are not directed at children under the age of 13 (each a "Child" together "Children") and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at apps@momend.com and request that we cease processing data about your Child.
2. What is Personal Data and what do we collect?
What is personal data?
Where this Policy refers to "personal data" it is referring to data about you from which you could be identified such as your name, your date of birth, your contact details and even your IP address.
By law all organisations in the Turkey are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the Your Rights section of this Policy.
Data we collect from you when you use the Property
Voluntary Provision of Data
When you voluntarily supply your personal data to us, for example where you; use the Property to upload or send personal data (by filling out a form on our website, entering your details into a profile page on one of our game Properties, contacting our customer support team, subscribing to one of our publications or newsletters, or similar activities in which you volunteer data about yourself); contact us by post, telephone, email or SMS; report a problem with a Property; we may collect, store and use the personal data that you disclose to us.
The personal data we collect from you may include your title, name, address, email address, phone number, financial and/or credit card information but will depend on precisely what details you volunteer to us as you interact with the Properties.
Automated Collection of Data
We may also collect personal data about you when you visit a Property (in particular the Momend website) through the use of technologies such as cookies. The following are examples of data we may collect:
We use the data described above for several different reasons. Firstly we use it to ensure that the Properties work properly and that you are able to receive the full benefit of them. Second, we use the data to monitor online traffic and audience participation across the Properties. We undertake both of these activities because we have a legitimate interest in doing so.
We also use the data described above to provide a range of services to you these include answering your support queries, giving you access to in-game functions such as records of high scores, enabling you to purchase items in-game, and letting you connect with and communicate with your friends across our Properties.
Our Properties may include various functionality which lets you connect to social media (such as Facebook) if you choose to use this functionality then we will collect various data from you in order to enable those connections and to enable us to keep accurate records of the connections that you have made.
Third Party Resources
Our Properties contain various features that serve advertisements to you. In order to make those advertisements as relevant as possible we use third party advertising networks, which collect and use details about you and your interests in order to target relevant advertisements to you (rather than showing all Property users the same material).
Where we use these services we will give you the opportunity to disable the collection and transmission of information about you to those networks. Any such refusal will not cause you to cease seeing adverts, but it will decrease the relevancy of the adverts which are shown to you.
For details of the advertising partners that we use, please see the section below which names our providers.
3. How and why do we use/share your personal data
Sharing your personal data
Depending on how and why you provide us with your personal data we may share it in the following ways:
We will not share your personal data with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition where a third party is providing the prize) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your personal data may be used, which you will be notified of at the relevant time.
We may also disclose your personal data to third parties in the following events:
Service Providers
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of our major service providers:
Links to third party sites
Where we provide links to third party websites that are not affiliated with Momend (for example. where you click or tap on adverts in a Property) such sites are out of our control and are not covered by this Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those Properties.
4. For how long do we keep your personal data?
We will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected. Where you sign up to receive email marketing from us we will retain your email address on file should you ever "opt-out" of receiving emails from us. We will retain your email address in this way in order to ensure that we continue to honour and respect that opt-out request.
In some circumstances you can ask us to delete your data: see "Your Rights" below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.
5. Security
Momend takes the protection of your personal data very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the data provided to us is stored on secure servers once we receive it.
Momend may store your personal data on secure servers either on our premises or in secure third party data centres.
Please note that some of our service providers may be based outside of the European Economic Area (the "EEA"). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
In particular, if you engage with us for support services (e.g. if you report a problem with one of the Properties) it is highly likely that your complaint will be dealt with by our support team in Turkey.
By submitting your personal data, you agree to this transfer, storing or processing. Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld (for example, where we transfer your data to our Turkish group company it is transferred pursuant to the EU's standard contract clauses for international data transfers). If you would like more information about how the mechanism via which your personal data is transferred, please contact apps@momend.com.
If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Property, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
6. Your Rights
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
7. Contact Details
If you have any questions regarding our Privacy Policy, please contact our privacy officer at:
Privacy Officer
Momend Ltd.
ODTÜ Teknopark, Üniversiteler Mah. İhsan Doğramacı Bul. No:29 iç kapı No:113
Cankaya/Ankara
Email: apps@isandroid.net