MB Oyun Yazılım ve Pazarlama A.Ş. located in Istanbul, Turkey (hereinafter will be referred to as “we,” “company”) gives great importance to the protection of confidentiality of the personal data of visitors, users and customers (hereinafter will be referred to as “You”). When you download Zula PC application, you will have title of the “Data Subject”. Your personal data being collected by our company in the capacity of “Data Controller”, their collection purposes and other issues are provided below.
Through Zula PC (“Platform” or “Game”), you may access our services, provided by us and explained in detail in Terms of Conditions – ZULA PC (“Services”).
Use of Services is conditional on your reading and acceptance of this Policy in full. Also, by accepting this Policy, you will be deemed to have given your explicit consent to us for processing of your personal data, provided to us under this Policy within the scope of Law related to personal data protection to the country where you reside. The term “processing,” as used in this Policy, means all kinds of procedures, performed on data, such as provision, recording, storage, protection, modification, editing, disclosure, transfer, acquisition, making recoverable, classification or prevention of use of your personal data, through fully automatic or semi-automatic means or non-automatic means as part of any data registry system.
I. Types of Information, Collected From You
Company collects info in three main ways:
You provide some of it directly (such as by registering for an account).
We record some of it automatically (including with technologies like cookies).
We receive some of it from third parties (like social media companies).
I.1. Personal data, provided by you
Data Requested in Game for registry:
- User Name
- E-mail information
- In-game name
Data requested during various transactions:
- Last Name
- City you live in
- Date of Birth
- Phone Number
- Payment details
We collect info you choose to provide or give to us in any manner. You don’t have to share info when we ask you for it, but if you decline, you might not be able to access certain Zula services or take advantage of their full functionality.
The purposes of use of Users’ data by MADBYTE GAMES, are as follows:
• Personal and Contact Information: Name, surname, telephone, e-mail information is help us secure used for user registry to the site and for contact purposes.
• Demographic, Site and Application Browsing Data and Other data: Personal data such as gender, date of birth, are used to define the interests of the users and to provide better service by increasing the user experience, together with the execution and development of operational activities such as new business development and marketing of our new Zula mode, your hobbies, favorite Zula mode, or other info you share, like when you respond to a survey and communication.
• Address Data: Personal data such as the city where the user lives are used for the transmission of tournament and event information and marketing activities according to the location of the user.
• Billing and Payment Data: Your name, billing address, telephone number, payment method, and other details we collect to help process purchases you make (like when you buy Zula Gold or in-game items);
• Support ID Data: Your support-related info, including the nature of your concern and your account or order details (like when you request help from us, such as by submitting a contact ticket to our Zula contact system);
Without providing your personal data to us, you may only visit some sections of the Platforms; in order to use certain Contents or Services, such as playing the Game and to participate in community forums in Platforms, you need to provide us certain personally identifiable information. The personal data, collected from you and processed to play the game in Zula PC with registry, that is, current email address, username and in-game name information.
If you wish to buy any paid Services or products, these transactions will be performed via bank card, credit card or payment service provider of you or the third party buyer and your information is not recorded by us and only payment details and the information of financial instrument, used in payment system (such as credit cards, bank card or account number, limited to last 4 digits) are recorded. During entry of this information to the system, we encrypt it using secure socket layer (SSL) technology. Credit card transactions are performed on secure pages, provided by banks and we do not store credit card information. The user may use any payment option, given on the site, as deemed suitable. The obligation to comply technical and procedural rules, applicable to such payment option, will belong to the user.
In order to participate in esports events organized by Zula PC, in addition to creating a Zula account, citizenship number, date of birth, address information and picture information are required if it is required by the local law.
When you play Zula, note that some info will be publicly accessible to others, such as your game statistics and performance. We may record gameplay and related info (such as in-game Name, build order, and in-game actions), and replay or otherwise make it available to other players without further notice to you.
I.2. Personal Data Collected Automatically
We automatically collect some info about how you interact with and navigate the Zula services, as well as the device and software you use to do so.
To you, clearly understand the section, we will provide some examples without any limitation:
Your use of the Zula (such as timestamps, clicks, scrolling, browsing times, searches, referral/exit pages, and in-game activity and interactions);
Your computer or device (such as IP addresses, unique device IDs, processing capabilities, manufacturer and model, language and other regional settings, geographic location, and screen resolution and similar settings);
Your connection to the Zula, including details about the network and software you’re using (such as browser type and version, operating system name and version, ISP, and your preference settings); and
How the Zula services perform, including problems you may encounter (such as loading errors and response times).
I.3. Personal data collected from third parties
We obtain info from third parties to use along with the info we collect. For instance, if you link your Facebook account with your Zula account, Facebook may share info with us in accordance with Facebook’s privacy notice and your privacy settings on it. Facebook also shares info with us about Zula specific fan pages on Facebook. We also, for example, gather advertising and analytics info from third parties to help support our marketing initiatives, improve the Zula services, and better manage our ad campaigns.
- Social Network Information: With their social network accounts, the users provide easier access to the site, and collected data is used for identification of fields of interest of users and conduction and improvement of operational activities, such as business development, marketing, communication and provision of better service by improving user experience. In these way, We gather advertising and analytics info from third parties to help support our marketing initiatives, improve the Zula services, and better manage our ad campaigns (like by displaying more personalized ads and measuring how effective they are).
- IP Address: We collect info from third parties to help us identify from where you’re using the Zula services (like your approximate location based on your IP address). For example, process purchases (like assessing tax obligations), prevent fraud or abuse of the Zula services (such as identifying suspicious transactions or activity), and customize your visit (like displaying the Zula services in your local language).
When you register to the system with your social media accounts, such as Facebook or Google, or when you link these accounts with the game, social media platforms identify your friends over their own systems. By linking your social media account with the game with your explicit consent or by registering, you perform a transaction to play the game and you make an agreement with us to contact your friends. Your privacy settings on the third party’s service control what info they can share with us – it can include info like your name, profile picture, gender, username, language, country, your friends and other info you have made available on the platform.
I.4. Information, collected by technologies, methods and/or services.
In addition to info you provide, we and our partners automatically record some info about how you use and navigate the Zula services. We may combine this info with other info we gather from or about you as described in this notice, including to enforce our Agreement and for analytics and advertising purposes.
Through existing legal technologies, methods and/or services, information such as your computer's hardware, software, MAC address, Internet browser or computer operating system type, Internet service provider's domain name, IP address, http-https information, device language, and device model, may be collected and stored by us For Zula PC for user statistics and the order of online activities and more. The main purpose in collection of such information, is to protect the quality of Platforms, Platform contents and Services and to improve our way of doing our business. Providing better service to our customers and to improve our way of doing business, is key to our success and continuity. Therefore, in order to use some online features, you must accept/allow some features, such as Cookies and/or Beacons. You may choose not to accept/allow such tracking technologies, methods and/or services, used by us, with methods, such as blocking cookies by changing the settings of your web browser, however, this may cause improper operation of some features of Platforms, Platform contents and Services. From time to time, at our own discretion, we may change and/or test various technologies, methods and/or services. For details, specifications and up-to-date information concerning any technology, method and/or services, used by us at any given time, you may contact us.
In addition, we also keep log files, containing Internet Protocol (“IP”) addresses. IP address is a numerical address, assigned to your computer by your Internet Service Provider. We keep log files to monitor traffic on Site, to provide information to our advertisers and to remedy technical problems. In case of abuse of the Site by the user, we may block some IP addresses. IP addresses may be used to personally identify you in order to provide your acceptance of our Service Conditions and any current end user license agreement.
We use info gathered through our servers and technologies like cookies for several reasons based on MADBYTE GAMES’, third parties’ or players’ legitimate interest, including:
To monitor, secure, and maintain the Zula services (like preventing fraud);
To enhance your browsing experience (such as allowing you to log-in to your account);
To analyze and improve our operations (like aggregating traffic and usage patterns);
To control the display of ads (including providing you with targeted offers);
To support and gauge the effectiveness of our communications and marketing campaigns (like letting us know if you’ve clicked on our ads or opened our emails);
To better personalize your visit and store your preferences and settings (for example, displaying content in your local language); and
To otherwise manage our relationship with players and provide the Zula services under the Terms of Service (including help prevent toxicity and ensure a fair gaming environment,
We partner with third parties (like content providers, analytics companies, and advertising networks) to help us improve the Zula services and better understand how you interact with them, as well as support our marketing initiatives. These companies may collect info from you automatically in connection with your visit.
We’ve engaged to provide services on our behalf (like website analytics), as well as third parties that deliver content (like videos from YouTube) or offers (like ads from ad networks) contained on the Zula. We may receive reports based on our partners’ use of these tools on an individual or aggregate basis. For example, we use third-party analytics providers (like Google Analytics) to help evaluate and report on use of the Zula services. We also partner with ad companies to support our marketing efforts, including by serving you ads better tailored to your likely interests (such as based on your browsing activity on the Zula services and when visiting other online services). These companies may set and read their own cookies and similar technologies to gather info about your online activities across websites and services.
We take protection of personal data of children very seriously.
II. Use and Sharing of Provided Information
Essentially, all information, provided from you, whether personally identifiable or not, are used to support your use of Platforms, contents and Services and to achieve our legitimate business goals, in the following ways.
1. Intra-Company Commercial Uses
Commercial purposes are all activities, conducted by us to realize our legitimate business goals and/or to meet the requirements of our customers. The activities, conducted by the Company, may include, without limitation:
- To deliver commercial, administrative, informative and/or reminders concerning online and mobile content and new and/or existing features of our Services and/or requests concerning products, offered to our customers and/or certain information and/or paid and/or services.
- To send information or notices concerning a game in work in progress status,
- To answer your e-mails and to provide an effective user experience service,
- To provide information on new services (in-game characters, weapons, maps, tournaments),
- Contacting the user when necessary.
- where you have consented to the processing, which you may revoke at any time;
- for MADBYTE GAMES to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- where necessary for the purposes of MADBYTE GAMES’ or a third party’s legitimate interests, such as those of visitors, users or partners.
In addition to the purpose of use of personal data in the forms, described above, in order to serve our business goals by satisfying the needs of our customers, we may use any components of your personal data, provided from your and/or using other information collection technologies and/or methods and/or services. For example, after researching your internet browsing pattern and comparing the same with other information, provided through information collection technologies and third party services, it is used for purposes of renewal and improvement such as harmonizing our contents, services and products with internet browsing patterns of our customers.
In case the users do not want to receive notices, subject to this paragraph, they are entitled to opt-out of the notice subscription, pursuant to the legislation in effect, by marking opt-out option at Website.
Some of the most common examples of how we use info include:
To provide the Zula services to you, respond to inquiries, fulfil requests, and process transactions (like helping you create an account, find a match, and resolve Support issues). We engage in these activities to manage our contractual relationship with you and, where relevant, to comply with a legal obligation (e.g. related to payment transactions) or based upon our legitimate interest in doing so (such as to provide the Zula services to children below the age of legal capacity to enter a contract);
- To deliver and tailor our communications with you, like by sending you important account-related announcements or promotional communications that we believe may interest you. We engage in these activities with your consent, where we have a legitimate interest (e.g. to promote the Zula and keep you interested in them through personalised messages) or, in the case of account-related annoucements, to perform our contract with you;
- To administer surveys, contests, sweepstakes, and similar offerings (such as confirming your eligibility or sending you a prize if you win). We engage in these activities to manage our contractual relationship with you, or for our legitimate interest (e.g. to promote the Zula Services and keep you interested in them);
- To monitor, analyze, protect, test, and improve our services and operations (like measuring how the Zula services perform, tracking usage patterns, and fixing bugs or errors). We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation (e.g. to keep the Zula Services secure), and/or because we have a legitimate interest (e.g. understanding how the Zula Services are used, keep them secure and improve them and develop new products);
- To promote products and services and measure the effectiveness of those campaigns. We engage in these activities with your consent or for our and our partners’ legitimate interest (marketing our and others’ products and services and understanding the effectiveness of our marketing campaigns);
- To operate and expand our business. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest in operating and expanding our business; and
- To facilitate use of or integration with the Zula services, social sharing, and related functionality (such as supporting chat features and forums). We engage in these activities with your consent or where we have a legitimate interest (e.g. increasing customer engagement with our products and the Zula services).
2. Use and/or Sharing by Third Parties with Commercial Purposes
We don’t share your contact info (such as your email or home address) with independent third parties without your knowledge except as described in this notice (like to enforce the Agreement, secure the Zula services, or if we’re required to do so by law or respond to legal process). We don’t sell your information to independent third parties. We do share non-contact info (like your In-Game Name, match history, game stats, and other aggregate or anonymous info).
For example, when you buy something on the Zula services, we’ll share your payment-related info with entities we’ve engaged to process payments and provide similar financial services (like fraud prevention). Other common examples include partners that help us store data, send marketing emails, and provide Support services, assist with research and analysis of our services (like research institutions or universities), third party social media platforms or apps we permit to link to our products or Zula services. We may also transfer your info in some cases to our professional advisers (who are sometimes independent ‘data controllers’) such as lawyers and accountants (e.g. when enforcing our contract with you).
We may disclose player info in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). This means your info may be one of the assets transferred to the acquiring entity in such situations.
Please note that your in-game name and gameplay statistics (like your match history, item builds, and average number of kills and deaths) are viewable to others and may be shared in-game and out-of-game with players and other third parties. This means your info may be one of the assets transferred to the acquiring entity in such situations, according to MADBYTE GAMES’ legitimate interest in engaging in such transactions and operating and expanding our business.
3. Promotions, Contests and Lotteries
4. Disclosure, Use and/or Sharing of your Information for Non-Commercial Purposes
To keep the game operational and to control service quality, information sharing with third parties, is provided, limited to the component in provided service.
- Customer service providers to provide customer support service,
- All kinds of third party program restriction providers to prevent cheating tools and unauthorized programs,
- Cloud computing service providers to provide cloud storage services,
- Payment service providers to assist in payments, related to transactions or to provide money withdrawal services to sellers,
- Marketing platforms to organize the service and analysis service providers for behaviors of users,
- Online survey service providers to improve game service.
In addition, your personal data may be processed for the purposes of,
• Compliance with current legislation, court orders and other administrative authority decisions,
• To perform Services securely,
• To protect legal rights of players and third persons and to prevent crimes,
• To protect the rights and interests of the Company,
• To prepare various statistical assessments, without disclosing the identity of user, and to use the same in market studies,
• Detection of procedures, incompliant with the rules of the game, such as fraud and cheating,
• Solution of technical problems, and solutions to improve Service quality,
• To identity individual users to provide game service,
• Technical protection against the use of unauthorized programs,
• Prevention of inappropriate game behavior, which may damage other users.
For example, Users may report each other and submit descriptions of their in-game activity and actions to help us determine if the reported behavior constituted a violation of rules and procedures that apply to player conduct, as well as any potential repercussions (such as temporary or permanent account suspensions or chat restrictions).
From time to time, together with company units and/or third persons, we may be involved in acquisition, transfer of shares, cooperation, dissolution and/or merger. In these cases, unless the legislation states otherwise, the personal data pool is seen as part of the deal. If we transfer our company to third persons or dissolve it, we may transfer personal data, collected by us to third persons, within the framework of assets, transferred to purchaser/seller.
We also record and store, and reserve the right (but have no obligation) to monitor, chat and similar details about in-game interactions for a period we determine is appropriate to help us, among other things, detect and prevent toxicity, enforce our rules and policies and Agreement, and foster a more positive gaming community for our players. We engage in these activities to manage our contractual relationship with you, comply with a legal obligation (e.g. to keep the Zula Services safe and secure), and/or because we have a legitimate interest (e.g. understanding how the Zula Services are used, keep them secure and improve them).
III. Third Party Links
IV. International Data Processing
We’re a global gaming company with operations around the world. When you use the Zula services, your info may be processed anywhere we or our partners do business,
We may process and store info we collect anywhere that we or our partners operate, including the Europe, Turkey, South-America (LATAM region). These countries may not have the same level of data protection as where you live. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal info. We’ve implemented and maintain a framework consistent with applicable law and this notice for transfers of info outside the country of collection.
By using the Zula services, you acknowledge that we may transfer your info to (and process it in) countries outside of your country of residence, each of which may have different privacy rules than your country.
V. Purpose of Personal Data Processing Conditions
– In case processing is required to perform an agreement, made with you or to initiate the process of making an agreement with you on your request. Most of the time, the reason for processing your information, is to perform the user agreement made with us. For example, as long as you continue to use our Service, we use your information both to protect your account and profile and to provide customer support.
– In case processing is in line with your interests, and our legitimate interests, which are not overridden by your fundamental rights: We may use your information in line with our legitimate interests. One of our legitimate interests is to use the website user and visitor data to conduct and improve our Services and our commercial activities with these persons. Other than this, in order to improve our Service continuously, we may analyze the behavior of users concerning our services and we present offers, which may interest you and process the data in line with administrative purposes, fraud detection and other legitimate purposes.
– In case processing is required for compliance with a legal regulation: For example, in case product is purchased, in accordance with consumer protection legislation, we may process in order to comply with payment records rules and to make mandatory disclosures to authorities.
VI. Your Rights and Obtaining Information
You can use many parts of the Zula services without ever creating an account, purchasing our products or services, or otherwise submitting info like your in-game name, username or email address to us. If you do choose to visit or use the Zula Services, we generally retain the related personal information as long as your account is active or as is otherwise necessary to provide the Zula services, operate our business (including for legitimate purposes like complying with our legal obligations, managing internal books and records, preventing fraud, resolving disputes, and enforcing our contracts and terms, such as this notice and the Agreement or to achieve the purposes set out in this notice, unless a longer retention period is permitted or required by law.
The precise periods for which we keep your personal information vary depending on the nature of the information, why we need it and relevant legal or operational retention needs. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to a contract or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the retention period applicable for your personal data needed to provide the Zula service to you (such as accessing the Zula) is limited to your account life. When your account is deleted, MADBYTE GAMES will delete the relevant information for that purpose (providing the service to you) but will keep some personal information (in-game name for instance) for other defined purposes such as security and fraud detection. As another example, chat logs/history data is retained for a period of two years from its creation. This is to enable Zula to properly investigate infringements of our rules and policies such as fraud, toxicity, cheating and harmful behaviour.
We offer players choices about the types of communications they receive from Zula. If you choose to receive marketing and promotional emails from us but later change your mind, simply “unsubscribe” by following the instructions in the relevant email. These choices don’t apply to mandatory communications that are part of the Zula services, like important account-related notices.
If you’re concerned with the way we’re handling your info, or if you would like to request to access, correct, update, restrict or delete your personal info, object to or opt out of the processing of your personal info, withdraw your consent to our use of your info, or if you would like to request a copy of your personal info for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please contact to us and follow the instructions provided.
Your right to object includes where we process your info for direct marketing, for performing a task in the public interest or pursuing our legitimate interests or those of a third party.
If you withdraw your consent (including for marketing purposes), it does not affect the lawfulness of what we did up until that point.
Before we process such requests, we may ask you to verify your identity (like by logging-in to your account or providing us with certain info to help us confirm ownership) and we may request payment where allowed by law. Note that asking us to remove personal info or refrain from processing it may also result in account suspension or termination where this info is necessary to make Zula services available to you (we normally tell you this at the point we collect the info), in which case you’ll no longer be able to access those Zula services.
The User has the right to apply to MADBYTE GAMES as a data subject for the following right;
the purposes of the processing;
the categories of personal data concerned;
To learn whether your personal data is processed or not,
To request information if the personal data is processed,
the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Subject to restrictions in current legislation, along with contesting processing of your personal data and requesting restriction of processing, you are entitled to request access to your personal information, to request, revision of your personal information, deletion and transfer of the same. If you want to make any requests concerning your rights, contact us by sending an e-mail to us at the address, given in “Contact us” section. In line with current data protection laws, we respond all requests from individuals, who wish to exercise their rights within 30 days.
Please inform us in writing of your request for exercise of rights, specified above. Within this framework, in order to exercise your right, you need to deliver your requesting letter, containing your personal identity information and the rights you want to exercise, to the following address or e-mail:
Entity: MB Oyun Yazılım ve Pazarlama A.Ş.
Commercial Registry: İstanbul/846241
Address: Reşitpaşa Mah. Katar Cad. Arı 9 Binası No:2-61-3 Sarıyer İstanbul
Email: [email protected]
VIII. Technical and Administrative Measures, Taken for Security of Personal Data
We’re committed to securing player info and complying with our obligations towards applicable data protection laws, but can’t absolutely guarantee the security of any data we collect from you. By choosing to share info with us (or anybody else online these days), you’re acknowledging this risk.
- Prevent illegal processing of,
- Prevent illegal access to,
- Provide legitimate storage of personal data,
we adopt administrative and technical measures, considering practicality and costs thereof.
1. Administrative Measures;
- Our company conducts and causes the conduction of necessary audits,
- Our employees are trained and informed concerning legitimate processing of personal data,
- The operations, performed by our Company, are assessed in detail for all business units, and as a result of such assessment, personal data, is processed specifically for commercial activities, performed by related units,
- In case cooperation is made with third persons for processing of personal data, in agreements, made with companies, processing personal data, includes provisions for adoption of necessary security measures,
- In case of illegal disclosure of personal data or data leak, by notifying relevant Personal Data Protection Authority in the region, we perform examinations and adopt measures.
2. Technical Measures
To prevent personal data from being accessed in violation of law;
- We employ personnel with technical expertise,
- Periodically update and renew technical measures,
- Create access authorization procedures in the company,
- Determine procedures for reporting of technical measures and audit procedures,
- Create data record systems used in our company, in line with legislation and control the same periodically,
- Create emergency plans for any risks and develop systems for implementation of the same,
- Train and inform our employees concerning access to personal data and authorization issues,
- In case cooperation is made with third persons for processing and storage of personal data, in agreements, made with companies, providing access to personal data, includes provisions for adoption of necessary security measures, by the persons, who have access to personal data,
- We establish security measures in line with technological advances, to prevent illegitimate access to personal data.
We adopt administrative and technical measures for illegal disclosure of personal data and update the same in our procedures. In case we determine unauthorized disclosure of personal data, we create a system and infrastructure to notify this to related person and the relevant Personal Data Protection authority in the region.
We use appropriate physical, technical, and organizational security safeguards to help protect your info from unauthorized access, use, or disclosure both during transmission and in storage. For example, we use computer systems with limited access in controlled facilities to store info. We also use technologies like encryption and hashing to protect some of the info we collect.
However, please note that no server, communications network, or data transmission over the Internet is 100% secure. The Zula services are no exception. We can’t guarantee the security of any info transmitted through the Zula services and make no assurances about our ability to prevent any such loss or misuse.
In addition, since it is very important for your personal information to be up-to-date, correct and complete, in case of any changes in your personal information, please update your profile, so that we may provide you must up-to-date services and products, offered to our customers.
Entity: MB Oyun Yazılım ve Pazarlama A.Ş.
Commercial Registry: İstanbul/846241
Address: Reşitpaşa Mah. Katar Cad. Arı 9 Binası No:2-61-3 Sarıyer İstanbul
Email: [email protected]