Privacy Policy

AVAXTARS, (hereafter "the Company", "we", "us" or "our") is committed to protecting the privacy and security of the personal information that is provided to us or collected by us during the course of our business. We store and process personal information in accordance with the Turkish Personal Data Protection Act (KVKK) and to the extent applicable to the EU General Data Protection Regulation.

This Privacy Notice does not limit or exclude any of your rights under the KVKK or other applicable laws. This notice should be read in conjunction with our Terms of Use, as referred to herein from time to time.

This Privacy Notice applies to “AVAXTARS” offered by the Company through Internet Websites as defined in clause 1 of the Terms of Use, mobile devices, or other platforms (collectively, the "Services"). This Privacy Notice explains how we may collect and use any personal information that we obtain about you and your rights in relation to that information. Please read this carefully. By using the Services, you affirm that you have read and understood this Privacy Notice and that you consent to the collection and use of your personal information as outlined in this Privacy Notice.

We may provide you with additional Privacy Notices where we believe that it is appropriate to do so. Those additional notices supplement and should be read together with this Privacy Notice.

Overview

1. Who is responsible for your personal information?
2. Which information about you is collected?
1. information you provide directly to us, including:
2. information collected during the course of your use of the Website, Materials or Services, including:
3. information collected from third parties where you have authorized this or the information is publicly available, and
4. information collected through our use of cookies or similar technologies.
5. billing information
6. Other contacts
3. How we use your personal information?
1. We use the information provided by you in connection with providing our Services:
2. We use the information generated by your access or use of the Website, Materials, or Services:
3. We may also use your personal information in connection with our rights and interests:
4. How and why, we may share your personal information?
5. Transfer of Data outside of the EEA
6. Statistics
7. How we protect your personal information?
8. How long we keep your personal data?
9. Your rights

1. Who is responsible for your personal information?

AVAXTARS is responsible for your personal information as provided to us or collected by us during the course of our business.

2. Which information about you is collected?

Whenever you access or make use of any of the Website, Materials, or Services, we may collect the following types of information from you:

2.1 information you provide directly to us, including:

1. whenever you create a User Account (as defined in clause 4 of the Terms of Use), your email address if you provide one, Avalanche compatible digital wallet address and username;
2. if you use Marketplace, your Avalanche C-Chain Wallet address;
3. your purchase history and other information relating to transactions made through the Website; and
4. information contained in your correspondence with us, for example, when you send us an email;

2.2 information collected during the course of your use of the Website, Materials or Services, including:

1. character names and gameplay information;
2. any Posts or Images (as defined in clauses 8 and 9 of the Terms of Use);
3. Images (as defined in clause 9 of the Terms of Use);
4. your credited name (if any);
5. ‘crash reports’ in the event that a software crash occurs, which may include details of your User Account, a portion of the memory state of the game when the crash occurred, and the game settings you were using, but not other information from your computer or its memory; and
6. information about the computer or device you use to access our Service, including the hardware model, operating system and version, MAC address, unique device identifier (“UDID”), phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information.
7. data contained in log files. The information in log files may include your IP address, your ISP, the Web browser you used to visit the Services, the time you visited the Services, which web pages you visited on the Services, and other anonymous usage data.

2.3 information collected from third parties where you have authorized this or the information is publicly available; and

2.4 information collected through our use of cookies or similar technologies. Please refer to our Cookies Notice for further information, including information on how you can disable these technologies.

2.6 Other contacts we collect and process information about you if you offer or provide products or services to us, if we evaluate your products or services, and generally when you request information from us or provide information to us.

3. How we use your personal information?

3.1 We use the information provided by you in connection with providing our Services:

1. to provide the Website, Materials, and Services in connection with our Terms of Use to you;
2. to verify your identity and verify that your User Account is not being used by others;
3. to fulfill any orders for merchandise ordered through the Website;
4. to market products and services to you, including contacting you via email that you may choose (or opt-in) to receive. You can stop receiving our promotional emails by following the unsubscribe instructions included in those emails; and
5. to respond to communications from you.

3.2 We use the information generated by your access or use of the Website, Materials, or Services:

1. to monitor the performance of the Website, Materials, and Services and ensure that the Website, Materials, and Services perform in the best manner possible;
2. for security and system integrity purposes; and
3. to conduct research and statistical analysis (on an anonymized basis) (see more in the Statistics section of this privacy notice below);

3.3 We may also use your personal information in connection with our rights and interests:

1. to protect and/or enforce our legal rights and interests, including defending any claim;
2. for any other purpose authorized by you, the KVKK, or other applicable law;
3. to respond to lawful requests by public authorities, including to meet law enforcement requirements; and
4. where this is necessary for our legitimate interests (except where such interests would be overridden by your fundamental rights and freedoms which require the protection of personal data).

We do not use personal information to make any automated decisions - automated processes do monitor gameplay to identify cheating and fraud but human intervention is applied in the decision-making process. Information is gathered transiently for these purposes but is not stored.

4. How and why we may share your personal information?

We may share your personal information with third persons (such as advisors, authorities, and other persons) in Turkey, the EU or other countries if required or useful for providing our products and services. Further, we may share your personal information with third persons where:

• you have consented to us doing so (where necessary) or any other person has obtained your consent for us to do so (where necessary);
• we are under a legal, regulatory or professional obligation to do so (for example, to comply with anti-money laundering or sanctions requirements);
• it is necessary in connection with legal proceedings or in order to exercise or defend legal rights.

We use third parties who provide products and services on our behalf and may share your information with them, for example, banks, insurance companies, or technology suppliers who may have access to your personal information when providing software support. We may disclose research and statistical analysis (on an anonymized basis) derived from your personal information to third parties (see more in the Statistics section of this Privacy Notice below).

5. Transfer of Data outside of the Turkey or EEA

The personal data we collect in relation to the Website, Materials, and/or Services may be transferred to, and stored in, a country operating outside Turkey or European Economic Area (“EEA”). Under the GDPR, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequate decision, we may transfer personal data provided appropriate safeguards are in place.

6. Statistics

We may use and publish non-personal aggregate statistics and group data about those people who access or make use of any of the Website, Materials or Services and their usage of any of the Website, Materials, or Services.

7. How we protect your personal information?

Unfortunately, no data transmission over the Internet can be guaranteed as totally secure. We will take reasonable steps to keep your personal information safe from loss, unauthorized activity, or other misuses. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks inherent in processing personal information. You can play an important role in keeping your personal data secure by maintaining the confidentiality of any password and accounts used in relation to the Website, Materials, and Services, including using a unique password that you do not use on any third-party websites or related services. Please do not disclose your User Account password to third parties. Please notify us immediately if there is any unauthorized use of your account or any other breach of security. While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk. If you post your personal information on the Website’s public pages, you acknowledge that the information you post is publicly available. If you follow a link on the Website to another website, the owner of that website will have its own privacy policy relating to your personal information that you should review before you provide any personal information.

8. How long we keep your personal data?

We will retain your personal information for as long as is necessary for the purpose for which it was collected. We will further retain your personal information to comply with legal and regulatory obligations, for as long as claims could be brought against us and for as long as legitimate interest, including data security, requires.

9. Your rights

In relation to the processing of your personal information, you have rights that you can exercise under certain circumstances. These rights are to:

• request access to your personal information and certain information in relation to its processing;
• request rectification of your personal information;
• request the erasure of your personal information;
• request that we restrict the processing of your personal information; and
• object to the processing of your personal information.

If you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.

We may refuse to provide access if the relevant data protection legislation or other legislation allows or obliges us to do so, in which case we will provide reasons for our decision as required by the law.

If you would like to exercise these rights, please contact us in writing by email to: Information request, [email protected] or by Telegram Group https://t.me/AvaxtarsOfficial.

You will not, in general, have to pay a fee to exercise any of your individual rights. However, we may charge a fee for access to your personal information if the relevant data protection legislation allows us to do so, in which case we will inform you as required by the law.

If you feel we have not handled your query or concern to your satisfaction you can contact the competent data protection authority in Turkey, the Personal Data Protection Authority (https://www.kvkk.gov.tr/).

We reserve the right to update and change this Privacy Notice from time to time in order to reflect any changes to the way in which we process your personal information or changing legal requirements. Any changes we may make to our Privacy Notice in the future will be posted on this website. Please check back frequently to see any updates or changes to our Privacy Notice.

31 March 2021