Privacy Policy
This Privacy Policy explains how Lanista Danışmanlık Anonim Şirketi (“Lanista”, “we”, “us” or “our”) collects, uses, shares and protects personal data when you use our websites (including lanista.vc), our mobile applications and games, and any related services, communications and marketing activities (together, the “Services”).
This Policy applies to players worldwide. Depending on where you live, a region-specific supplement also applies and prevails over this Policy where they differ:
- Türkiye: KVKK Aydınlatma Metni (English) — our information notice under Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”).
- European Economic Area, United Kingdom and Switzerland: Section 12 of this Policy.
- United States: U.S. State Privacy Notice (California and other U.S. states).
This Policy is also available in Türkçe.
1. Who we are (data controller)
The data controller responsible for your personal data is:
Lanista Danışmanlık Anonim Şirketi
Address: 15 Temmuz Mah. Bahar Cad. No: 61, Bağcılar, İstanbul, Türkiye
MERSİS No: 0608178021000001 · Trade Registry No: 1068521 (Istanbul Trade Registry Office)
Tax Office / No: Güneşli / 6081780210 · Share capital: TRY 250,000
Email: hey@lanista.vc
2. Personal data we collect
2.1 Data collected automatically
When you use our apps and games, we and our service providers may automatically collect:
- Device and technical data: device model, operating system and version, language, time zone, screen size, app version, and approximate location derived from your IP address (country / region level).
- Identifiers: IP address, app-specific or install identifiers, vendor identifiers (such as IDFV), and — only where permitted by you and your device settings — advertising identifiers (IDFA on iOS, Google Advertising ID on Android).
- Usage and gameplay data: install and first-open time, session length and frequency, levels and progress, in-app events, features used, ads viewed or clicked, and similar interaction data.
- Diagnostic data: crash logs, performance data and error reports.
On iOS, we ask for your permission through Apple’s App Tracking Transparency (ATT) framework before accessing your IDFA or tracking you across apps and websites owned by other companies. If you decline, we will not do so.
2.2 Data you provide to us
- Contact data: your name and email address and the content of your message when you contact us for support, feedback or business enquiries.
- Profile data: where a Service offers this feature, a username, avatar or display name you choose, and leaderboard entries.
2.3 Purchase data
In-app purchases are processed by the relevant app store (Apple App Store or Google Play). We do not receive or store your payment card details. We receive limited transaction information from the app store (for example, the product purchased, price, currency, date and a transaction identifier) to deliver the purchased item, prevent fraud and keep records.
2.4 Our website
This website does not use advertising or analytics cookies. Our hosting provider may process standard server logs (such as IP address, browser type and pages requested) for security and to keep the website running.
2.5 Sensitive data
We do not intentionally collect special categories of personal data (such as health, biometric or religious data) through the Services. Please do not send us such data.
3. How we use personal data and legal bases
| Purpose | Legal basis |
|---|---|
| Providing and operating the Services, saving your progress and delivering purchased items | Performance of a contract (KVKK Art. 5(2)(c); GDPR Art. 6(1)(b)) |
| Responding to your requests and providing customer support | Performance of a contract; legitimate interests (KVKK Art. 5(2)(c), (f); GDPR Art. 6(1)(b), (f)) |
| Analytics, improving and developing our Services, fixing bugs and crashes | Legitimate interests (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)) |
| Showing ads in our free-to-play products and measuring their performance | Legitimate interests for non-personalised ads; your consent for personalised ads and cross-app tracking (KVKK Art. 5(1); GDPR Art. 6(1)(a)) |
| Marketing attribution (understanding which campaigns led to an install) | Consent where required; otherwise legitimate interests |
| Preventing fraud, cheating and abuse, and keeping the Services secure | Legitimate interests (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)) |
| Complying with legal, tax and regulatory obligations and responding to lawful requests of authorities | Legal obligation (KVKK Art. 5(2)(ç); GDPR Art. 6(1)(c)) |
| Establishing, exercising or defending legal claims | KVKK Art. 5(2)(e); GDPR Art. 6(1)(f) |
We do not sell your personal data for money. We do not use automated decision-making that produces legal or similarly significant effects on you.
4. Who we share personal data with
- Service providers acting on our behalf: cloud hosting and storage, analytics, crash reporting, customer support and email providers.
- Advertising and measurement partners: ad networks, mediation platforms and mobile measurement partners that serve and measure ads in our free products. Where required, they process data based on your consent and may act as independent controllers under their own privacy policies.
- App store platforms (Apple, Google) for distribution and purchase processing.
- Business partners, such as a co-publisher or developer of a specific product, where needed to operate that product.
- Public authorities, courts and regulators where required by law.
- A buyer or successor in a merger, acquisition, restructuring or sale of assets, subject to this Policy.
The third-party SDKs used in each app or game are disclosed in that product’s App Store privacy details, Google Play data safety section and/or in-app privacy settings. A current list of our advertising and measurement partners, with links to their privacy policies and opt-out pages, is available on request at hey@lanista.vc.
5. International transfers
Some of our service providers are located outside Türkiye and outside your country (for example, in the European Union or the United States). We transfer personal data abroad only in accordance with Article 9 of KVKK and, where applicable, Chapter V of the GDPR — for example, based on an adequacy decision, standard contractual clauses (notified to the Turkish Personal Data Protection Authority where required), or, in exceptional cases, your explicit consent.
6. Data retention
| Data | Retention period |
|---|---|
| Gameplay, analytics and advertising data | Up to 24 months after your last activity |
| Account and profile data | While your account is active, and up to 24 months after your last activity or until you request deletion |
| Support correspondence | Up to 3 years |
| Transaction and accounting records | As required by Turkish tax and commercial law (generally 10 years) |
| Website server logs | Up to 12 months |
When no longer needed, personal data is deleted, destroyed or anonymised.
7. Your rights and how to exercise them
Depending on where you live, you may have the right to access, correct, delete or port your personal data, to restrict or object to processing, to withdraw consent at any time, and to lodge a complaint with a supervisory authority. Region-specific details are set out in the supplements listed at the top of this Policy.
To exercise your rights, email hey@lanista.vc with the subject line “Data Request” and, where relevant, the name of the app and your in-app player ID. We may need to verify your identity. We respond within thirty (30) days at the latest, free of charge unless the law allows a fee.
Account and data deletion
Where a Service lets you create an account, you can request deletion of your account and associated data from within the app (where available) or by emailing hey@lanista.vc. Uninstalling an app stops further collection from that device. Step-by-step instructions, including what is deleted and what is kept, are on our Support page.
8. Your advertising choices
- iOS: Settings → Privacy & Security → Tracking, to allow or deny apps from requesting to track.
- Android: Settings → Google → Ads (or Settings → Privacy → Ads) to delete or reset your advertising ID or opt out of ads personalisation.
- In-app: where a consent prompt is shown (for example, in the EEA and UK), you can change your choices at any time in the in-app privacy settings.
9. Children
Our Services are not directed to children under the age of 13 (or the higher minimum age in your country, such as 16 in some EEA countries), and we do not knowingly collect personal data from them. Where a product may be used by a general audience that includes children, we limit data collection and disable personalised advertising for users identified as under the applicable age. If you believe a child has provided us with personal data, please contact us and we will delete it.
10. Security
We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or alteration, including encryption in transit, access controls and working only with reputable service providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
11. Third-party links and services
Our Services may contain links to, or integrations with, third-party websites and services (including ads). We are not responsible for their privacy practices, and we encourage you to read their privacy policies.
12. Supplement for the EEA, UK and Switzerland
If you are in the European Economic Area, the United Kingdom or Switzerland, the GDPR (or the UK GDPR / Swiss FADP) applies to our processing of your personal data in addition to this Policy:
- Legal bases: as set out in the table in Section 3.
- Your rights: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), objection to processing based on legitimate interests or for direct marketing (Art. 21), and withdrawal of consent at any time without affecting the lawfulness of prior processing.
- Consent: we ask for your consent, through an in-app consent prompt, before personalised advertising and before storing or accessing information on your device where consent is required by law.
- Transfers: transfers outside the EEA/UK rely on adequacy decisions or standard contractual clauses (and the UK Addendum where applicable).
- Complaints: you may lodge a complaint with the data protection authority in your country of residence, place of work or place of the alleged infringement. We would appreciate the chance to address your concern first at hey@lanista.vc.
13. Changes to this Policy
We may update this Privacy Policy from time to time. We will post the updated version on this page and change the “Last updated” date above. Where changes are material, we will provide additional notice (for example, in-app) where required by law.
14. Language
This Policy is published in English and Turkish. For users resident in Türkiye, the Turkish version prevails in case of any inconsistency; for all other users, the English version prevails.
15. Contact
If you have any questions about this Privacy Policy or our data practices, please contact us:
Lanista Danışmanlık Anonim Şirketi
Address: 15 Temmuz Mah. Bahar Cad. No: 61, Bağcılar, İstanbul, Türkiye
MERSİS No: 0608178021000001 · Trade Registry No: 1068521 (Istanbul Trade Registry Office)
Tax Office / No: Güneşli / 6081780210 · Share capital: TRY 250,000
Email: hey@lanista.vc