With this statement, MagicLab Game Technologies Corp. (“MAGLAB”, “we”, “us”) shall inform you and explain the activities related to processing personal data under Personal Data Protection Law no. 6698 (“PDP Law”) ,General Data Protection Regulation (“GDPR”), CCPA, PDPA, LGPD.


By using MAGLAB software(s), mobile application(s), visiting MAGLAB web site(s) namely or other platform(s) (together “platforms”), as applicable, and/or using any of its content, including games, products, services and other material provided through the MAGLAB games including virtual in-game currencies such as coins, cash and/or diamonds, that can be purchased for real money and in turn used to purchase virtual in-game items (together “content”) by accepting the Explicit Consent Statement, you will be deemed explicitly consent us to proceed of your personal data in accordance with this Privacy Policy.


In the scope of this Policy, “proceed” or “process” means any operation which is performed upon your personal data such as collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization or blocking its use by wholly or partly automatic means or otherwise than by automatic means which form part of a filing system.


Information We May Collect About You

We will collect and process all or some of the following personal information about you:

  • Information you provide to us. Personal information that you provide to us, such as when using the contact form on our website, including your name, email address, and other contact details;


  • Our correspondence. If you contact us, we will typically keep a record of that correspondence;


  • Information about how you use our products and services. Such as information about the amount of time you use our products/services for the pages you visit, and other information about your activities while using our hardware or software or while logged into your MAGLAB ID account;


  • Survey information. We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;


  • We may request personal information to administer your participation in contests, sweepstakes or other promotions that we organize;


  • Device Information. Such as information about your operating system, browser, software applications, IP address, geolocation, security status and other device information in order to improve your experience, to protect against fraud and manage risk;


  • Marketing preference information details of your marketing preferences (e.g. communication preferences) and information relevant to selecting appropriate products and services to offer you;


  • Website and communication usage details of your visits to the websites and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs, posts on the MAGLAB forum, other communication data, and the resources that you access;


  • Activities on Social Networking Sites (SNS). If you choose to participate (for example, by “liking” MAGLAB’s profile on Facebook or Twitter, posting a message, or answering a poll), we will have access to the information you divulge which may include personal information, depending on your SNS privacy settings.


MAGLAB may use cookies pursuant to Cookies Policy and also processes your personal data as anonymous data in order to analyze and produce statistics related to the habits, usage patterns, and demographics of users as a group or as individuals. Such anonymous data does not allow the identification of the users to which it relates. MAGLAB may share such anonymous data with third parties without your consent.


Use of Personal Data

MAGLAB stores the data provided by you in a safe and secure way and takes all the necessary precautions to prevent unauthorized access or collection of the information you have shared, as is required by applicable law. Since MAGLAB may require you to update certain information from time to time, MAGLAB will make the necessary changes in this Privacy Policy in order to ensure the conformity of these documents and the new rules and regulations with the information you provide.


Additionally, MAGLAB may 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.


If you use a service provider and provide a personal or any other data for the payment of the purchased content, you acknowledge and agree that you are the sole responsibility from the accuracy, completeness of this data and any other material or non-material issues, losses, damages, etc. rising from this data or its transaction.


  • To provide and manage products and services you have requested, to administer our services, including to carry out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products.


Use justifications: contract performance; consent, legitimate interests (to enable us to perform our obligations and provide our services to you or to notify you about changes to our service).


  • To communicate with you regarding products and services that may be of interest, to provide you with updates and offers, where you have chosen to receive these. We may also use your information to market our own and our selected business partners’ products and services to you by way of in-app alerts, post, email, phone, SMS or online or social media advertisement. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option on the appropriate platform to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you.

Use justifications: legitimate interests (to keep you updated with news in relation to our products and services); consent.


  • To understand our customers and to develop and tailor our products and services, we may analyse the Personal Information we hold in order to better understand your usage patterns, preferences and marketing requirements, as well as to better understand our business and develop our products and services;

Use justifications: legitimate interests (to ensure the quality and legality of our services and to allow us to improve our services).


  • To monitor certain activities, to monitor queries and transactions to ensure service quality, compliance with procedures, terms of use and policies, and to combat fraud (including running anti-fraud checks against your payment method when processing your order(s) on our website);

Use justifications: contract performance, legal obligations, legal claims, legitimate interests (to ensure that the quality and legality of our services).


  • To inform you of changes, to notify you about changes to our services and products.

      Use justifications: legitimate interests (to notify you about changes to our service).


  • To ensure website content is relevant, to ensure that content from our platformsa re presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers.

Use justifications: legitimate interests (to allow us to provide you effectively with the content and services on the platforms).


  • To reorganize or make changes to our business, in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organization, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analyzing any proposed sale or re-organization. We may also need to transfer your Personal Information to that re-organized entity or third party after the sale or reorganization for them to use for the same purposes as set out in this Policy.

      Use justifications: legitimate interests (in order to allow us to change our business).


  • In connection with legal or regulatory obligations, We may process your Personal Information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Use justifications: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).


With Whom Your Information is Shared


MAGLAB will not share any personally identifiable information with third parties for marketing purposes without your consent. Whereas MAGLAB may share your personal data to our third party service providers under contract with MAGLAB such as order or payment processors or other service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) and affiliates of MAGLAB that perform activities on our behalf, as well as other members of the MAGLAB group, located in Turkey or abroad, to access and use personally identifiable information, but only to the extent necessary to provide MAGLAB services. Besides, MAGLAB may channel this data to our 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 MAGLAB collects will be shared with other users of MAGLAB for profile displaying purposes. The information that will be displayed in your profile will be your choice.


MAGLAB 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 also transfer personally identifiable information to the relevant third parties.


Children Data Protection

MAGLAB recognizes the importance of protecting children’s privacy online. As applicable, we strive to follow the different minimum age guidelines set by the laws.

Our services are not intended for and not directed to anyone under the age 13. We do not knowingly collect or store any personally identifiable information from children under age of 13.

We may limit how we collect, use and store some of the information of users between the age of 13 and 16.

When players identify themselves as being children we will:

(1) obtain consent from parents for the use of their children’s personal information when required by applicable law.

(2) disable features in certain services that could allow a child to share information that directly identifies them, unless a parent has provided relevant consent to us or the third-party platform on which their child is playing. In some cases, we may be unable to provide certain functionality to these users.

(3) collect and use certain information for limited purposes only

(4) with certain service-related activities where a child may expose personal information that directly identifies them, we may not permit children to participate at all, even if we have consent.

Also persistent identifiers (e.g. IP address or mobile advertising device identifier) may be collected to support our internal operations such as:

– Delivering the services;

– Maintaining or analyzing the functionality of the service;

-Serving contextual ads or frequency capping;

– Protecting the security or integrity of the user of service; or

– Legal or regulatory compliance.

Note to Parents:

We recognize a special obligation to protect personal information about young children. We encourage you to talk with your children about communication with strangers and the risks of disclosing personal information online.

If we become aware that a child has provided us with personal information without parental consent, we will delete any personal information we have collected, unless we have a legal obligation to keep it and terminate the child’s account and/or revert them to the underage experience as applicable.

If we make material changes to how we collect, use, share or otherwise process your child’s personal information, we will notify parents as required by applicable law.

Your Rights

We may transfer and share your information to third parties (including service providers operating on our behalf) which may be in countries other than the country in which you are resident. Your personal data shall be transferred abroad by obtaining your explicit consent stipulated in Article 4(2) of Law No. 6698 or without obtaining your explicit consent if the issues stated in Articles 5(2) and 6(3) shall take place and on the condition that the rules stated in Article 9 of Law No.6698 shall be obeyed.


If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards where we may transfer your personal data to such countries by considering the requirements under applicable law. However, these countries may not have the same standards of data protection laws envisioned in EEA and have lower standards in protection then the country where you are located. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures under the applicable law, such as standard contractual clauses adopted by the European Commission to protect your personal information before transferring your personal information to such countries. If you live outside the Turkey or EEA, we will make our best efforts to protect your personal information on a similar degree as described herein Privacy Policy.


  1. Protection of Your Data

The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

For this reason, we will take all reasonable technical and organizational precautions to prevent the loss misuse or alteration of your personal information.  We protect your personal information and keep it confidential. We use industry-standard practices such as encryption, firewalls, and password protection systems to safeguard the confidentiality of any personal information that we may collect from you. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.

Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. The complete security of any personal information collected, stored, or used by us cannot therefore be guaranteed. It is very important for you to understand that you control the security of your account to a great extent. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.

  1. Retention Period of Your Personal Data

We keep your personal data for no longer than necessary for the purposes for which the personal information is processed. the length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

If you exercise a right to object to the processing of your personal data, we will review your objection and delete your personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

Not to mention, we are required and obliged to retain certain data under statutory laws and regulations for a period of up to ten (10) years.

  1. Your Rights in Relation to your Personal Data

We are always ready to help you with all matters related to your personal information processed in our games and services. You have the following rights over the way we process personal data relating to you.

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

  1. Learn whether or not her/his personal data have been processed;
  2. Request information as to processing if her/his data have been processed;
  3. Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;
  4. Know the third parties in the country or abroad to whom personal data have been transferred;
  5. Request rectification in case personal data are processed incompletely or inaccurately;
  6. Request deletion or destruction of personal data within the framework of the conditions set forth under article 7;
  7. Request notification of the operations made as per indents (d) and (e) to third parties to whom personal data have been transferred;
  8. Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;
  9. Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.


As applicable, the rights as the data subject pursuant to the GDPR are as follows:

  1. Right of access (Article 15)
  2. Right to rectification (Article 16)
  3. Right to erasure (“right to be forgotten“) (Article 17)
  4. Right to restriction of processing (Article 18)
  5. Right to data portability (Article 20)
  6. Right to object (Article 21)


As applicable, the rights as the data subject pursuant to the CCPA are as follows:

  1. Right to access
  2. Right to data portability
  3. Right to erasure
  4. Right to opt-out
  5. Right to be free from discrimination

As applicable, the rights as the data subject pursuant to the PDPA are as follows:

  1. Right to access
  2. Right to erasure
  3. Right to rectification
  4. Right to data portability
  5. Right to object

As applicable, the rights as the date subject pursuant to the LGPD are follows:

  1. Right to access
  2. Right to erasure
  3. Right to rectification
  4. Right to data portability
  5. Right to object

As applicable, the rights as the date subject pursuant to the Mexico Privacy Law are follows:

  1. Right to access
  2. Right to erasure
  3. Right to rectification
  4. Right to data portability
  5. Right to object


As MAGLAB, we make the utmost effort to comply with the laws of your country, while fulfilling our responsibilities regarding the privacy of your data. Please convey your questions and requests regarding this matter to us in writing.


Within that framework, to use your abovementioned rights, we may require you to send your personal ID information and a letter of request indicating which of the abovementioned rights you would like to use to our following address or e-mail address:


MAGLAB Game Technologies Corp.


Üniversiteler Mahallesi, İhsan Doğramacı Bulvarı, ODTÜ TEKNOKENT Gümüş Blok No:29/A Çankaya / ANKARA / Turkey


[email protected]