General Disclosure

Herein with this statement, Creasaur Teknoloji Ticaret Anonim Sirketi (“Creasaur”, “We”) shall inform you and explain the activities related to processing personal data as Personal Data Protection Law (“PDP Law”) no. 6698.


1. Identity of Data Controller 

Creasaur pays strict attention to the security of your personal data as the Data Controller. Having that awareness, we are extremely cautious in processing, recording, saving all kinds of personal data belonging to you for the following purposes in conformity with law and ethics as well as transferring and briefing third parties limited by the purpose of processing within the framework of the limitations permitted by the legislation with the full comprehension of our responsibility.

2. Purposes of Processing Your Personal Data 

Your personal data obtained by Creasaur are kept physically or electronically for a time period befitting processing purposes in accordance with the basic principles stipulated in PDP Law. Creasaur processes your personal data internally to increase the quality of service, deliver and improve products which the users have signed up for and to maximize customer satisfaction. Creasaur acts in conformity with the liabilities stipulated mainly in PDP Law and other relevant legislations. 

3. Disclosure of Personal Information

Creasaur may share your personal data to third parties under contract with Creasaur such as order or payment processors or other service providers, located in Turkey and abroad, to access and use personally identifiable information, but only to the extent necessary to provide those services. Additionally, Creasaur may use cookies pursuant to the Cookies Policy a nd use your personal data to generate internal statistics for marketing, consumer profiles or demographic research, etc. to tailor our products and services to satisfy your requirements. Our aim is to better understand and serve our users. As per the purposes mentioned above, your processed personal data can be shared to third party vendors as a response to a product order or to add you to a commercial bulletin circulation list. Certain parts of the information Creasaur collects shall be shared with other users of Creasaur for profile displaying purposes. The information that shall be displayed in your profile will be your choice.

Creasaur may release personally identifiable information to comply with court orders or laws that require us to disclose such information without your consent. In the event of a reorganization, sale or merger we may transfer personally identifiable information to the relevant third parties.

4. Methods and Legal Grounds of Collecting Personal Data 

Your personal data is being collected by Creasaur for the purposes stated above through all kinds of verbal, written or electronic communication channels to carry out in the platforms such as Creasaur game(s), mobile application, website or other platforms and in relation to the contents such as virtual in-game currencies coins, cash and/or diamonds, that can be purchased for real money and in turn used to purchase virtual in-game items, as defined in Creasaur Privacy Policy. The collected data is processed and transferred within the context of personal data processing conditions and purposes of PDP Law.

5. Your Rights as the Data Subject

In the event that you would submit your requests related to your rights to Creasaur as data subjects with the procedures mentioned below herein this General Disclosure, Creasaur shall conclude the requests included in the application free of charge and as soon as possible consider the nature of the request and within 30 (thirty) days at the latest. However, in case the operation necessitates a separate cost, the fee in the tariff designated by the Personal Data Protection Committee shall be collected.

The rights as the data subject pursuant to the 11th article of Law No.6698 are as follows:

a) Learn whether or not her/his personal data have been processed;

b) Request information as to processing if her/his data have been processed;

c) Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;

d) Know the third parties in the country or abroad to whom personal data have been transferred;

e) Request rectification in case personal data are processed incompletely or inaccurately;

f) Request deletion or destruction of personal data within the framework of the conditions set forth under article 7;

g) Request notification of the operations made as per indents (d) and (e) to third parties to whom personal data have been transferred;

h) Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;

i) Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data

As per the Article 13.(1) of PDP Law, you can convey your request to Creasaur relating to the use of rights stated above in writing or by other means designated by the Personal Data Protection Committee. As the Personal Data Protection Committee did not define any certain method, you are required to submit your application to Creasaur in writing pursuant to the PDP Law. Within that framework, in order to use your rights stated above, you have to send your personal ID information and a letter of request indicating which of the above mentioned rights you would like to use, to the following address or e-mail address:

Address: Üniversiteler Mah. 1605. Cad. Bilkent Cyberpark E Blok No: 3/A Çankaya Ankara/TURKEY

E-mail: [email protected]

The General Disclosure was drawn up on 08.05.2019. If there would be any amendment in the General Disclosure, then the enforcement date and content of the General Disclosure shall be updated and published on platforms specified in