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PRIVACY NOTICE AND PRIVACY POLICY ON THE PROCESSING OF PERSONAL DATA

1. Data Controller

This KVKK (Turkish Personal Data Protection Law) Privacy Notice and Privacy Policy has been prepared to explain the principles regarding the processing of personal data within the scope of the TFF Fantasy League game ("Game"), its related website, and mobile application, offered by TFF Digital Leagues Technology Inc. ("Company").

The Company acts as the data controller pursuant to Law No. 6698 on the Protection of Personal Data ("KVKK").

2. Personal Data Processed

Within the scope of the Game and website, users' email addresses, user-created and cryptographically protected password information, user ID and account information, in-game usage and transaction data, game performance information, as well as technical data such as IP address, device information, and log records are processed. In addition, usage data obtained through cookies on the website is also included within the scope of processed personal data.

Your personal data may be processed via email for purposes such as providing the platform's gaming services and ensuring user experience; sending reminder notifications regarding weekly squad update deadlines; and communicating game performance, score, and ranking information to you.

Third-party services such as Firebase may be used within the website for analysis and performance measurement purposes, in which case data relating to users' device information, IP address, and usage behavior may be processed. Within the mobile application, advertising SDKs may be used for the purpose of displaying advertisements, in which case device information and usage data may be processed.

Important Note:

Users' credit card or debit card information is not stored by the Company; such information is processed by the relevant payment service providers during payment transactions.

3. Purposes of Processing Personal Data

The personal data collected is processed for purposes such as creating and managing the user account, providing the Game and website services, ensuring user verification and session management, carrying out in-game transactions, ensuring system security, resolving technical issues, and fulfilling the Company's legal obligations.

In addition, data may be processed through analytics tools such as Firebase for the purpose of improving services and user experience, and through advertising SDKs for the purpose of presenting advertising content suitable for the user.

4. Transfer of Personal Data and Technical Requirements

Your personal data may be transferred to the Turkish Football Federation (TFF) and its affiliates, to Amazon Web Services as the cloud service provider, to third-party service providers such as Firebase within the scope of analytics services, to advertising SDK providers within the scope of advertising services in the mobile application, and to authorized public institutions and organizations within the scope of legal obligations, for the purposes of providing and improving the services and carrying out related processes. Personal data is not sold to third parties for commercial purposes.

In order for TFF Fantasy League to serve a large number of simultaneous users at scale, to perform instant score calculations without error, and to be protected at the highest level against global cyberattacks, world-standard global cloud computing infrastructures (Cloud Service Providers) are used in our data storage and processing activities.

In this context, your personal data is transferred to secure data centers located abroad for the purposes of:

High Availability and Continuity: Balancing the instantaneous traffic load generated by millions of users (Load Balancing) and preventing server crashes,

Data Security: Storing data encrypted with the AES-256 encryption standard both at rest and in transit, and protecting it with international security protocols (DDoS protection, SOC 2 Type II, etc.) and certified data security systems (ISO 27001, ISO 27017, ISO 27018, and BSI C5),

Technical Performance: Meeting the need for per-second data processing required by fantasy football dynamics.

This transfer is mandatory for the technical performance of the gaming service.

5. Transfer of Personal Data Abroad

The Company uses Amazon Web Services infrastructure for data hosting services, and in this context, personal data may be transferred to the location abroad where the servers are located and may be stored in accordance with the GDPR (EU). In addition, personal data may be transferred abroad through third-party services such as Firebase and advertising SDK providers.

Cross-border data transfers are carried out in compliance with Article 9 of the KVKK, with the necessary technical and administrative security measures in place.

6. Use of Cookies/SDKs

Cookies are used within the website, and SDK services are used within the mobile application, for purposes such as managing user sessions, ensuring the proper functioning of the website and application, carrying out security and verification processes, and conducting analytics activities. These elements are used to improve the user experience, and users may manage their preferences regarding performance and marketing elements—other than mandatory cookies and providers—through their preference settings, if they wish.

7. Method of Collecting Personal Data and Legal Basis

Personal data is collected electronically through website registration forms, in-game transactions, cookies, analytics tools such as Firebase, and technical systems. This data is processed in accordance with the KVKK on the basis of the establishment or performance of a contract, the Company's fulfillment of its legal obligations, and its legitimate interests.

8. Retention Period

Personal data is retained for as long as the user account remains active; following account closure, it is retained for the period required by applicable legal obligations.

9. Data Security

The Company takes the necessary technical and administrative measures for the protection of personal data, and user passwords are stored securely using irreversible encryption.

10. User Rights

Under the KVKK, users have the right to learn whether their personal data is being processed, to request information about such processing if it has taken place, to request correction of their data, to request deletion of their data, and to learn the third parties to whom their data has been transferred.

11. Contact

You may submit your requests under the KVKK through the following contact information:

TFF Digital Leagues Technology Inc. TFF Hasan Doğan National Teams Camp and Training Facilities, Riva, Beykoz – Istanbul iletisim@tff.org

12. Updates

The Company may update this notice as it deems necessary. The updated text will be made available to users through the Game or related platforms.

13. Effective Date

This KVKK Privacy Notice and Privacy Policy takes effect upon the user's registration to TFF Fantasy League.