Privacy Policy

Effective date: November 15, 2026 · Last updated: November 15, 2026

1. Who we are

Huggle Games ("Huggle Games", "we", "us") is the data controller (veri sorumlusu) for the personal data described in this policy:

This policy is also our information notice (aydınlatma metni) under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK"), and our notice under Articles 13 and 14 of the EU General Data Protection Regulation ("GDPR") and the UK GDPR.

2. What this policy covers

This policy applies to the mobile games and apps we publish on the Apple App Store and Google Play (the "Games"), to our website at hugglegames.com and its related domains (the "Website"), and to any support communication with us (together, the "Services").

An individual Game may show an additional in-game notice if it works differently from what is described here. If so, that notice applies together with this policy.

3. Data we collect

3.1 Data collected automatically when you play

• Device and advertising identifiers: the Apple Identifier for Advertisers (IDFA, only if you allow tracking), the Apple Identifier for Vendors (IDFV), the Google Advertising ID (GAID), Android App Set ID, and identifiers created by our SDK partners (for example a Firebase installation ID).
• Device and technical information: device make and model, operating system and version, language, time zone, screen size, network type, mobile carrier, app version, and IP address. We and our partners use the IP address to derive your approximate location (country and city level). We do not collect precise GPS location.
• Gameplay and usage data: levels, scores, progress, session start and length, in-game events, settings, and which features you use.
• Advertising data: which ads were requested, shown and clicked, and related measurement data.
• Crash and performance data: crash logs, stack traces, device state at the time of a crash, and loading times.
• Attribution data: information about the ad campaign or source that led you to install a Game.

3.2 Purchase data

If you buy virtual items, the payment is handled entirely by Apple or Google. We receive a transaction record (such as an order or transaction ID, the item purchased, price, currency and date) to deliver the item and prevent fraud. We never receive or store your payment card details.

3.3 Data you give us

• Support messages: if you email us, we receive your email address, your name if you include it, the content of your message and any attachments. We may ask for your in-game player ID so we can help you.
• Optional features: if a Game offers optional features such as sign-in with Apple, Google Play Games or Game Center, a nickname or leaderboards, we receive the information you choose to share through them.

3.4 Data we do not collect

We do not intentionally collect special categories of personal data (such as health, biometric or religious data), and we do not access your contacts, photos, microphone or camera unless a Game clearly asks for a specific feature and you grant permission.

4. How we use data and legal bases

We process personal data only where we have a legal basis under the GDPR (Article 6) and KVKK (Article 5). The table below explains what we do and why.

Where we rely on legitimate interests, we have balanced our interests (running and improving free games) against your rights, and you can object at any time (see Section 11). We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing.

5. Advertising and your choices

Our Games are free and are mainly funded by ads. Ads are delivered by Google AdMob and other ad networks, often through a mediation platform that picks which network shows an ad.

• EEA, UK and Switzerland: before personalized ads are shown, we ask for your consent through a consent management platform certified under the IAB Transparency & Consent Framework (for example Google's User Messaging Platform). If you do not consent, you will see non-personalized or limited ads. You can change your choice at any time from the privacy or settings menu in the Game.
• iOS: we only access the IDFA if you allow tracking in Apple's App Tracking Transparency prompt. You can change this in Settings → Privacy & Security → Tracking.
• Android: you can reset or delete your Advertising ID in Settings → Google → Ads (or Settings → Privacy → Ads, depending on your device).
• In-app opt-out: where a Game offers a "Privacy" or "Do Not Sell or Share" option, you can use it to opt out of personalized ads.

Opting out does not remove ads. It means the ads you see will be less relevant to you.

6. Third-party partners (SDKs)

Our Games include software development kits ("SDKs") from trusted partners. These partners may collect the data described in Section 3 directly from your device, and they process it under their own privacy policies, either as our processors or as independent controllers. Not every Game uses every partner below. The partners used in a specific Game are shown in that Game's privacy settings or on request.

Ad mediation platforms may also pass ad requests to further ad networks. Google publishes a list of the ad technology providers it works with at support.google.com/admob/answer/9012903.

7. When we share data

We do not sell your personal data for money. We share personal data only with:

• Service providers and partners listed in Section 6, for the purposes described in this policy;
• Hosting and IT providers (such as Google Cloud) that store data on our behalf;
• Professional advisers such as lawyers, auditors and accountants, under confidentiality duties;
• Authorities, when the law requires it, or to protect our rights, our players or the public;
• A buyer or successor in a merger, acquisition or sale of assets, who will be bound by this policy.

8. International transfers

We are based in Türkiye, and many of our partners process data in other countries, including the United States and EU member states. When personal data is transferred outside Türkiye, we rely on the safeguards in Article 9 of KVKK, such as standard contracts notified to the Personal Data Protection Authority, or your explicit consent where no other mechanism applies. When personal data of people in the EEA or UK is transferred to a country without an adequacy decision, we and our partners rely on the European Commission's Standard Contractual Clauses (and the UK Addendum), the EU–US Data Privacy Framework where a partner is certified, or another lawful mechanism. You can ask us for more information about these safeguards.

9. How long we keep data

• Gameplay and account data: for as long as you play, and deleted or anonymized within 24 months after your last activity.
• Analytics and crash data: usually up to 14 months in identifiable form, then deleted or aggregated.
• Purchase records: for 10 years, as required by Turkish commercial and tax law.
• Support emails: up to 3 years after the conversation ends.

Our partners keep data according to their own retention periods. When data is no longer needed, we delete, destroy or anonymize it in line with KVKK's Regulation on the Deletion, Destruction or Anonymization of Personal Data.

10. Security

We use reasonable technical and organizational measures to protect personal data, including encrypted connections (HTTPS/TLS), access controls, and choosing partners with strong security practices. No system is completely secure, so we cannot guarantee absolute security. If a data breach affects you, we will notify you and the relevant authorities as the law requires.

11. Your rights (GDPR and KVKK)

11.1 If you are in the EEA, UK or Switzerland (GDPR)

You have the right to:

• access your personal data and get a copy of it;
• have inaccurate data corrected;
• have your data erased ("right to be forgotten");
• restrict how we process your data;
• receive your data in a portable format;
• object to processing based on legitimate interests, and to direct marketing at any time;
• withdraw your consent at any time, without affecting processing that happened before;
• lodge a complaint with your local data protection authority.

11.2 If you are in Türkiye (KVKK Article 11)

You have the right to:

• learn whether your personal data is processed, and request information about it;
• learn the purpose of processing and whether it is used for that purpose;
• know the third parties in Türkiye or abroad to whom your data is transferred;
• request correction of incomplete or inaccurate data, and notification of the correction to those third parties;
• request deletion or destruction of your data under Article 7 of KVKK, and notification of this to those third parties;
• object to a result against you that arises from analysis of your data exclusively by automated systems;
• claim compensation for damage caused by unlawful processing.

11.3 How to make a request

Email privacy@hugglegames.com with the subject "Privacy Request", and include the name of the Game and your in-game player ID (usually shown in the settings screen) so we can find your data. Under the Communiqué on the Procedures and Principles of Application to the Data Controller, you may also send a written request to our address in Section 1, or use a registered electronic mail (KEP) address or secure electronic signature.

We will respond as soon as possible and within 30 days at the latest. We may ask for information to confirm your identity. Requests are free of charge, unless they require additional cost, in which case a fee set by the Personal Data Protection Board may apply. If you are not satisfied with our answer, you may complain to the Turkish Personal Data Protection Board (kvkk.gov.tr) or, if you are in the EEA or UK, to your local supervisory authority.

Deleting your game data: you can also ask us to delete all data linked to your player ID by emailing us as above. Uninstalling a Game stops further collection but does not by itself delete data already collected.

12. US state privacy rights

If you live in California or another US state with a consumer privacy law, you may have the right to know, access, correct and delete your personal information, and to opt out of "sale" or "sharing" of personal information for targeted advertising. We do not sell personal information for money, but allowing ad partners to collect identifiers for personalized ads may count as "sharing" under these laws. You can opt out by turning off ad tracking on your device (see Section 5), using the in-game privacy option where available, or emailing us. We will not discriminate against you for using these rights.

13. Children

Our Games are designed for a general audience and are not directed at children under 13 (or under 16 in the EEA, or the age of digital consent in your country). We do not knowingly collect personal data from children below these ages. If a Game asks for your age and you are below the relevant age, we show only non-personalized ads and limit data collection. If a Game is designed for children, we follow the rules that apply to it, including the US Children's Online Privacy Protection Act (COPPA) and the Google Play Families and Apple Kids Category requirements. If you believe a child has given us personal data, please contact us and we will delete it.

14. Our website

Our Website is a simple informational site hosted on Google Firebase Hosting. It does not use cookies, analytics, advertising or tracking. Like any web server, our hosting provider processes your IP address, browser type and the pages you request in technical logs, to deliver the site and keep it secure. If you click the email link, your email app opens a message to us, and anything you send is handled as described in Section 3.3. Links to other sites, such as the App Store, Google Play or LinkedIn, are governed by those sites' own policies.

15. Changes to this policy

We may update this policy from time to time. When we do, we will change the "Last updated" date above, and if the changes are significant, we will let you know in the Games or on this page before they take effect.

16. Contact us

If you have any questions about this policy or your personal data, contact us: