1. Who we are

RH Pozitif Teknoloji A.Ş. ("RH Positive", "we", "us", "our") is a game development company registered in Türkiye. We develop and publish games for mobile devices and personal computers.

For the purposes of data protection law, we are the data controller for the personal data described in this policy.

This policy explains what personal data we collect when you use our games, our website at rhpositive.com, or contact our support, and what your rights are.

How to read this policy. Our games do not all work the same way. Some show advertising, some do not. Some offer in-app purchases, some do not. Where a section begins with a phrase such as "Where a game shows advertising", that section applies only to those of our games that actually have that feature. You can tell which apply to the game you are playing: if you see ads, the advertising section applies; if the game offers paid content or in-app purchases, the purchases section applies, and so on.

2. Age requirements

You must be at least 13 years old to use our games. Where the law of your country requires parental or guardian consent above that age, you may use our games only with that consent.

Individual games may carry a higher age rating because of their content. The age rating for each game is shown on its store page, and you should follow it.

Our games are not directed to children. We do not knowingly collect personal data from children below the applicable minimum age. If you believe a child has provided us with personal data, please contact us at support@rhpositive.com and we will delete it.

3. What we collect

3.1 Technical, analytics and diagnostic data

Depending on the game, the platform you play on and the services enabled in that game, we and our service providers may automatically receive:

• Device and technical data — device model, operating system and version, language, country and region derived from your IP address, screen and hardware characteristics, and the version of the game you are running.
• Device identifiers — resettable identifiers assigned by your device or platform, such as the vendor identifier or an app-instance identifier generated by our analytics provider.
• Gameplay and analytics data, where a game uses an analytics service — when you start and stop playing, session length, the levels or features you reach, settings you change, and similar events that tell us how the game is being used.
• Crash and diagnostic data, where a game uses a crash-reporting service — technical information captured when a game crashes or malfunctions, including the state of the device at that moment, so that we can fix the problem.

We do not receive your name, your phone number, your contacts, your photos, your precise GPS location, or the contents of your device.

3.2 Where a game shows advertising

Some of our games are supported by advertising. Advertising identifiers are used only in those games. In them, we and our advertising partners may additionally receive:

• your device's advertising identifier;
• your approximate location derived from your IP address (typically country or region);
• information about the ads you were shown and whether you interacted with them;
• the consent or tracking preferences you have given.

Whether the advertising you see is personalised depends on the choices you make. See section 5.

3.3 Where a game offers in-app purchases

Some of our games offer paid items or subscriptions. Purchases are processed entirely by the store you bought the game from — Apple App Store, Google Play, Steam or another platform.

We never receive your card number, bank details or billing address. We receive only a confirmation that a purchase was completed, which item was purchased, and a transaction identifier, so that we can deliver the item and handle support requests.

3.4 Where a game offers accounts, sign-in or social features

Some of our games may offer the ability to create an account, sign in through a third-party service such as a platform or social network account, add friends, appear on leaderboards, earn achievements, or send messages to other players. Some of these features are provided by the platform you play on — for example achievements, statistics and leaderboards on Steam. In those games we may additionally collect:

• the account identifier, display name and profile picture provided by the sign-in service;
• your email address, where you provide it;
• your in-game display name and progress, where these are shown to other players;
• friend connections you create, and content or messages you send to other players.

Signing in through a third-party service means that service also processes your data under its own privacy policy. Connecting an account never allows us to post on your behalf, and we do not receive information about your contacts who do not use our games.

Anything you choose to make visible to other players — a display name, a leaderboard entry, a message — is visible to those players. Please do not include personal details you would rather keep private.

3.5 When you contact us

If you email our support address, we receive your email address, whatever you write to us, and any information you attach, such as screenshots or a purchase receipt. We use it to answer you and to keep a record of the request.

3.6 Our website

Our website is a simple information page. It does not run advertising, analytics or tracking scripts, and it does not set cookies for those purposes. If we add optional cookies in the future, we will ask for your consent first where the law requires it.

4. Why we use your data, and our legal basis

If you are in the European Economic Area, the United Kingdom, Switzerland or Türkiye, we must have a legal basis for each use of your personal data. Ours are as follows:

Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights, and we limit what we collect accordingly. You may object to this use — see section 8.

Where we rely on consent, you can withdraw it at any time, and withdrawing is as easy as giving it. Withdrawal does not affect anything we did lawfully beforehand.

5. Advertising and your choices

Where a game shows advertising, you control whether that advertising is personalised.

• In the European Economic Area, the United Kingdom and Switzerland, we ask for your choice through a consent screen the first time you play a game that shows advertising. You can reopen that screen and change your answer at any time from the game's settings menu.
• On iOS and iPadOS, personalised advertising also requires your permission under App Tracking Transparency. You can change this at any time in Settings → Privacy & Security → Tracking.
• On Android, you can delete or reset your advertising ID, or turn off ad personalisation entirely, in Settings → Google → Ads.

These device settings apply to every app on your device, so you can also use them instead of, or in addition to, the in-game option.

If you turn personalised advertising off, you will still see ads in ad-supported games, but they will be less relevant to you. Advertising is how we are able to offer those games at no cost.

6. Who we share data with

We do not sell your personal data for money.

We share personal data only in the following situations:

Service providers and platform services. Which of these apply depends on the game and the platform you play on. Not every provider below is used in every game.

Where a game uses advertising mediation, further advertising networks may take part in serving a particular ad. The consent screen shown in the game lists the partners that apply to that game, and lets you review and change your choices for each of them.

Platforms and stores. Apple, Google, Steam and other stores through which you obtain our games process your purchase and account data under their own privacy policies.

Third-party sign-in services, where a game offers them and you choose to use one.

Legal and protective disclosures. We may disclose personal data where we are legally required to, or where it is necessary to establish, exercise or defend legal claims, to investigate fraud or abuse, or to protect the safety of players or the public.

Business transfers. If our business or a game is sold, merged or reorganised, personal data may transfer to the acquiring party, which will remain bound by this policy or a policy offering equivalent protection.

7. International transfers

We are based in Türkiye, and our service providers operate globally. Your personal data may therefore be processed outside your country, including in the European Union, the United Kingdom and the United States.

Where personal data is transferred internationally, we use the transfer mechanism and safeguards required by the applicable data protection law. Depending on the case, these may include an adequacy decision covering the destination country, an approved standard contract, contractual safeguards provided by the service provider, or another legally recognised mechanism. You may ask us which mechanism applies to a particular transfer by contacting us.

8. Your rights

Depending on where you live, you have some or all of the following rights:

• Access — to be told what personal data we hold about you and to receive a copy.
• Correction — to have inaccurate or incomplete data corrected.
• Deletion — to have your personal data deleted.
• Objection — to object to processing based on our legitimate interests.
• Restriction — to ask us to limit how we use your data while a question about it is resolved.
• Portability — to receive certain data in a structured, machine-readable format.
• Withdrawal of consent — at any time, where we relied on your consent.
• No automated decisions — we do not make decisions producing legal or similarly significant effects about you by automated means alone.

To exercise any of these, email support@rhpositive.com. We will respond within the period required by the applicable law — normally one month.

Because most of our games do not require an account, we often cannot connect a request to a specific person's data. If we cannot identify you within our records, we will tell you, and we may ask for information such as the device identifier or a purchase receipt so that we can locate the data. We will not ask for more information than we need.

If you are in Türkiye, you have the rights set out in Article 11 of Law No. 6698 on the Protection of Personal Data (KVKK), and you may lodge a complaint with the Personal Data Protection Authority (KVKK Kurumu).

If you are in the European Economic Area, the United Kingdom or Switzerland, you may lodge a complaint with your national supervisory authority. We would appreciate the chance to address your concern first.

If you are a resident of a U.S. state with a privacy law — including California, Colorado, Connecticut, Virginia, Texas and others — you may request access to, correction of, or deletion of your personal information, and you will not receive discriminatory treatment for doing so.

We do not sell personal information for money, and we do not knowingly sell or share the personal information of anyone under 16. However, where a game shows personalised advertising, the use of advertising identifiers for that purpose may be treated as a "sale" or as "sharing" for cross-context behavioural advertising under some of these laws. You can opt out at any time using the controls described in section 5, or by emailing us.

9. How long we keep data

We may retain data for longer where it is necessary to establish, exercise or defend legal claims, or where the law requires it.

10. Security

We take reasonable technical and organisational measures to protect personal data against loss, misuse and unauthorised access, including encrypted transmission, access controls, and limiting the data we collect in the first place.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Changes to this policy

We may update this policy. The date at the top shows when it was last changed. If we make a change that materially affects how we use your personal data, we will give you notice through the game or by another appropriate means before it takes effect, and where the law requires it we will ask for your consent again.

12. Contact

Questions, requests or complaints about this policy or about your personal data:

support@rhpositive.com

RH Pozitif Teknoloji A.Ş. Çifte Havuzlar Mah., Eski Londra Asfaltı Cad., Kuluçka Merkezi A1 Blok, No: 151/1C, İç Kapı No: B35, 34220 Esenler / İstanbul, Türkiye