Privacy Policy

Article 1 – Parties

This Privacy and Personal Data Protection Policy (“Policy”) is arranged between the Company, whose information is detailed below, on one side, and the User on the other.

Company / Data Controller

• Commercial Title: Colony Talents Teknoloji Anonim Şirketi
• MERSIS No / Tax ID: 0211154155800001 DOĞANBEY TAX OFFICE / 2111541558
• Address: ÜNİVERSİTELER MAH. 1596 CAD. TEKNOKENT KULUÇKA MERKEZ BİNASI NO: 6A İÇ KAPI NO: 4 ÇANKAYA / ANKARA
• Contact: privacy@colonytalents.com

User / Data Subject

All natural persons who download, install, use, or otherwise interact with the mobile game named Slice Challenge: Score via Google Play and/or Apple App Store.

Article 2 – Definitions

• Explicit Consent: Consent regarding a specific subject, based on information and expressed with free will; it refers to the User consciously approving the processing activity after being adequately informed about the scope of the data processing activity, without any pressure, coercion, or deception.
• Anonymization: The technical and administrative process rendering personal data impossible to link with an identified or identifiable natural person, even if matched with other data.
• Cookie: Small text files placed on the User's device storing information such as session data, preferences, analytics data, and advertising identifiers, as well as similar tracking technologies (pixel tags, local storage objects, device fingerprinting, and similar) used via SDKs.
• Personal Data: Any information relating to an identified or identifiable natural person; encompassing direct identifiers (name, surname, e-mail address, phone number) and indirect identifiers (IP address, device identifier, advertising ID, location data, in-game behavioral data, purchase history).
• User: The natural person who downloads, installs, runs, or otherwise uses the mobile game named Slice Challenge: Score on their device via Google Play and/or Apple App Store.
• Game: The mobile game application named “Slice Challenge: Score” published by Colony Talents Teknoloji Anonim Şirketi and distributed via Google Play and Apple App Store, including all versions, updates, and add-ons of this application.
• Ad Service Providers: Third-party advertising networks named ironSource Ads, Unity Ads, Chartboost, Liftoff, and Pangle, along with their affiliates, SDKs, and servers, integrated into the Game for ad serving, ad optimization, user acquisition, and ad monetization.
• SDK (Software Development Kit): Software development kits belonging to Ad Service Providers and other third parties integrated into the Game application; these kits perform functions such as collecting data from the User's device, displaying ads, conducting analytics, and measuring performance.
• Company: Refers to Colony Talents Teknoloji Anonim Şirketi, its legal successors, entities it acquires or transfers, and its affiliates.
• Third-Party Platforms: Refers to Google Play (Google LLC) and Apple App Store (Apple Inc.) platforms used for the distribution, downloading, and execution of in-app purchases of the Game, as well as the companies operating these platforms.
• Data Processing: Any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification, or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means.
• Data Subject / Concerned Person: The natural person whose personal data is processed, i.e., the User.
• Data Controller: Refers to Colony Talents Teknoloji Anonim Şirketi, which determines the purposes and means of processing personal data and is responsible for the establishment and management of the data registry system.

Article 3 – Subject and Purpose

This Policy is prepared to comprehensively, transparently, and comprehensibly explain the Company's data processing activities, their legal grounds, purposes, scope, the Users' rights, the technical and administrative measures taken for data security, and the data processing practices and cookie policies of Ad Service Providers and Third-Party Platforms regarding the personal data collected, processed, stored, and transferred during the processes of downloading, installing, using, making in-app purchases, and interacting with the mobile game named Slice Challenge: Score (“Game”) developed and published by Colony Talents Teknoloji Anonim Şirketi (“Company”).

This Policy applies to all Users of the Game worldwide; it is valid regardless of the User's country of residence, the platform used to access the Game, or the type of device used. There is no online chat area, messaging module, or direct communication channel between users within the Game, and the Company does not collect user-to-user communication data through any such functionality. In-app purchases are executed exclusively through Google Play and/or Apple App Store infrastructures, and the Company does not directly collect or process financial data such as credit card numbers, bank account information, or payment instrument details.

Article 4 – Duration

This Policy enters into force on 06.03.2026 and remains in effect indefinitely until withdrawn or updated by the Company, or until the Game is permanently removed from all platforms. The Company reserves the right to update, change, or renew this Policy at any time; any update is announced to Users via the in-game notification mechanism and/or the Company's official website and takes effect on the date the update is published.

If the User approves the Policy after an update and continues to use the Game, it means they have accepted the updated Policy; however, explicit consent is obtained anew for changes that expand the scope of the explicit consent previously given by the User.

Article 5 – Rights and Obligations of the Company

• The Company is authorized to collect, record, store, classify, analyze, transfer, and process Users' personal data, limited to the purposes, legal grounds, and scope specified in this Policy.
• The Company has the right to unilaterally update this Policy by providing prior notice in line with changes in legal regulations, technological developments, revisions in business processes, or security requirements.
• The Company has the right to collaborate with third-party service providers, including but not limited to ironSource Ads, Unity Ads, Chartboost, Liftoff, and Pangle, and to integrate their SDKs into the Game for the purposes of ad serving, analytics, performance measurement, and app optimization.
• The Company is obliged to inform the User clearly, comprehensibly, and accessibly about the identity of the data controller, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data may be transferred, the method of data collection, and the User's rights at the time of acquiring the personal data or at the latest before the first processing activity begins.
• The Company is obliged to take all appropriate technical and administrative measures to prevent the unlawful processing of personal data, to prevent unlawful access to personal data, and to ensure the retention of personal data.
• The Company is obliged to collect only the personal data mandatory for realizing the legitimate purposes specified in this Policy, to avoid data requests that are unconnected to the processing purpose or exceed the principle of proportionality, and to immediately delete, destroy, or anonymize the data if the purpose ceases to exist.
• The Company is obliged to transparently explain the data processing activities of Ad Service Providers and other third-party SDK providers to the Users, to provide an access link to the privacy policy of each Ad Service Provider, and to take contractual and technical measures to ensure that these providers do not process User data contrary to the principles stated in this Policy.
• In the event it is determined that personal data has been unlawfully acquired by third parties, the Company is obliged to notify the relevant supervisory authority and affected Users via in-game notification, e-mail, or the Company's official website as soon as possible and in any case no later than seventy-two (72) hours.
• The Company is obliged to conclude Users' applications regarding the exercise of their rights under this Policy free of charge or, if the transaction requires an additional cost, provided it does not exceed the fee tariff stipulated by the applicable legislation, within a maximum of thirty (30) calendar days from the date the application reaches the Company, and to inform the User in written or electronic format.

Article 6 – Rights and Obligations of the User

• The User has the right to learn whether their personal data is processed or not, to request information if their personal data has been processed, to learn the purpose of processing their personal data and whether they are used in compliance with their purpose, and to know the third parties to whom their personal data is transferred domestically or abroad.
• The User has the right to request access to their personal data, to request the correction of such data if it is processed incompletely or incorrectly, and to request that the correction process be notified to the third parties to whom the personal data has been transferred.
• The User has the right to request the deletion, destruction, or anonymization of their personal data if the reasons requiring processing cease to exist, and this request shall also be notified to the third parties to whom the data has been transferred.
• The User has the right to withdraw their previously given explicit consent at any time, without providing any justification, with prospective effect; the withdrawal of consent does not affect the lawfulness of the data processing activities carried out based on the consent until the withdrawal date.
• The User has the right to submit complaints regarding the processing of their personal data to the competent personal data protection authority in their country.
• The User is obliged to ensure that the personal data provided to the Company is accurate, complete, and up-to-date, to notify the Company of any changes in their data within fifteen (15) calendar days, and is individually liable for any consequences arising from providing incorrect or misleading information.
• The User is obliged to read, understand, and fully accept this Policy before starting to use the Game, and it is the User's responsibility to regularly review the updated version of the Policy.
• The User is personally responsible for the security of the Google Play or Apple App Store account used to access the Game, the confidentiality of its password, and all transactions executed through the account, and is obliged to immediately notify the Company and the relevant platform provider if account information is compromised by third parties.

Article 7 – Protection of Personal Data

Colony Talents Teknoloji Anonim Şirketi holds the title of Data Controller regarding all personal data collected and processed through the Game. Ad Service Providers (ironSource Ads, Unity Ads, Chartboost, Liftoff, Pangle) and Third-Party Platforms (Google Play, Apple App Store) act as independent data controllers as they also process User data for their own determined purposes and means; the data processing activities of these providers are subject to their own privacy policies.

Categories of Personal Data Processed

• The User's app store account name, e-mail address (only in case of a support ticket or direct communication), and username or nickname.
• Device model, operating system type and version, screen resolution, language and region settings, time zone, advertising IDs, and app version.
• Game session durations, play frequency, level progression data, in-game achievements and scores, engagement, app launch and closure times, screen viewing frequencies, and UI interaction patterns.
• In-app purchase history (purchased product type, purchase date, and amount); the payment transactions themselves are executed by Google Play or Apple App Store, and the Company does not collect credit card or bank account details.
• Advertising identifiers (IDFA, GAID), the number and type of ads viewed, ad click data, ad conversion data, ad display timing, user segmentation data collected via Ad Service Providers' SDKs, and interest profiles.
• IP address-based approximate geographical location (at the country, region, city level); the Game does not collect GPS-based precise location data.
• App crash reports, error logs, performance metrics, device memory usage, and battery status data.
• Cookies placed on the device by Ad Service Providers' SDKs.

Legal Grounds for Processing

• Personalized ad serving, data sharing with third-party ad networks, profiling, and targeted marketing activities are based on the User's explicit consent.
• Delivering the core functions of the Game, executing in-app purchases, and providing user support services are carried out within the scope of the performance of a contract.
• Improving the Game's performance, detecting and resolving bugs, fraud prevention, ensuring security, and conducting anonymous statistical analysis rely on the Company's legitimate interest.
• Fulfilling the obligations of record-keeping, reporting, and notification to supervisory authorities required by applicable legislation is carried out within the scope of legal obligations.

Data Retention Periods

The Company retains personal data only for the period necessary for the purpose for which they are processed; when the purpose ceases to exist, it deletes, destroys, or anonymizes the data. Game session and behavioral data are retained for a maximum of two (2) years from the last interaction date; advertising data for a maximum of two (2) years from the collection date; support ticket records and communication data for a maximum of two (2) years from the resolution of the request; purchase data throughout the period prescribed by relevant legislation under legal retention obligations; and error logs and performance data are retained for a maximum of two (2) years from the collection date.

The User may exercise all their rights listed in Article 6 via the e-mail address privacy@colonytalents.com or the application form on the Company's official website, and the Company will conclude the application within a maximum of thirty (30) calendar days.

Ad Service Providers

Ad Service Providers integrated into the Game collect data from the User's device via their own SDKs, use cookies and similar tracking technologies, and process this data on their own servers. The privacy policy of each Ad Service Provider can be accessed from the following links:

• ironSource Ads
• Unity Ads
• Chartboost
• Liftoff
• Pangle
• Google Play Store
• App Store

The User is responsible for reviewing the relevant provider's privacy policy regarding the data collected, processed, and transferred by the aforementioned Ad Service Providers and/or Platforms under their own data policies. Ad Service Providers' SDKs may place strictly necessary cookies, functional cookies (ad frequency and format preference), analytical cookies (ad performance measurement), and targeting cookies (interest-based ad profiling) on the User's device. The User can reset their advertising identifier or disable personalized ad tracking via device settings; they can also manage cookie preferences through the consent management screen within the Game.

In the event of termination of this Agreement, privacy and personal data protection obligations remain valid for the periods specified in this Policy.

Article 8 – Integrity of the Agreement and Amendments

Any amendment, addition, or deletion to be made in this Policy is only valid if made in writing by the Company and announced to Users via the in-game notification mechanism and/or the Company's official website. Obtaining explicit consent anew is mandatory for changes that expand the scope of the User's explicit consent.

This Policy is interpreted as a whole together with the Terms of Use of the Game; in case of any contradiction between these documents, the provision favoring the User regarding the protection of personal data shall prevail.

Article 9 – Governing Law

The interpretation, execution, and all disputes arising from or relating to this Policy are subject to the laws of the Republic of Türkiye, without prejudice to the mandatory consumer protection provisions and mandatory data protection provisions of the User's country of residence.

Article 10 – Evidentiary Agreement

The Parties accept and declare that the following records constitute conclusive evidence in any dispute that may arise from this Policy:

• The Company's server logs, database records, and backup systems
• In-game user activity logs and session data
• Data obtained from the reporting dashboards of Ad Service Providers
• Google Play and Apple App Store purchase receipts and transaction logs
• Electronic mail correspondence and support ticket records
• Time-stamped digital logs regarding the User's consent grant and withdrawal actions
• The Company's registrations made to the registry system of the relevant data protection authority

The Parties accept and declare that digital records, server logs, database records, consent logs, and electronic mail correspondence automatically generated and stored by the Company's IT systems constitute valid and binding evidence in accordance with the evidentiary provisions of applicable procedural law; the User can only object to the accuracy and integrity of these records by presenting digital evidence of equivalent nature.

Article 11 – No Waiver

The failure or delay by the Company or the User in exercising any right or authority arising from this Policy does not mean a waiver of said right or authority, and the single or partial exercise of this right or authority does not prevent the exercise of other rights and authorities. Any waiver is valid only if explicitly declared in writing by the waiving party, and a one-time waiver does not set a precedent for future violations of the same or similar nature.

Article 12 – Miscellaneous Provisions

If any provision of this Policy is found to be invalid, void, or unenforceable, said provision shall be severed from the Policy, and the validity, binding nature, and enforceability of the remaining provisions shall not be affected; the invalid provision shall be deemed replaced by a valid provision closest to the original intent of the parties.

Notifications to be made by the Company to the User are carried out via in-game push notification, in-game pop-up messages, announcements on the Company's official website, or by sending to the e-mail address provided by the User to the Company, and the notification is deemed to have reached the User at the moment it is sent; applications to be made by the User to the Company shall be submitted via the privacy@colonytalents.com e-mail address or the application form on the Company's official website.

The original text of this Policy has been prepared in Turkish, and in the event the Policy is translated into other languages, the Turkish text shall prevail in case of any contradiction or discrepancy between the translated text and the Turkish text. This Policy is continuously published on the Company's official website and in an accessible section within the Game; the User can access the current text of the Policy through these channels at any time.

Article 13 – Enforcement

This Privacy and Personal Data Protection Policy enters into force on 06.03.2026 and remains in effect until withdrawn or updated by the Company, or until the Game is permanently removed from all platforms. The User declares that they have read, understood, and accepted all provisions of this Policy, along with accepting this Policy the moment they download, install, or start using the Game.

This Policy consists of thirteen (13) articles in total, and the Company and the User accept and commit to their adherence to all the provisions stated above.