BlockRivals Data Protection Notice (Türkiye — Law No. 6698 / KVKK)

Effective date: 2026-08-14 — Status: draft

Draft — requires legal review before publication. This text is prepared to meet the disclosure ("aydınlatma") obligation under Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK"). Fields in double square brackets ([[EXAMPLE]]) are unfilled placeholders and must not be published before being completed and approved by a lawyer or KVKK specialist.

This page is prepared, in the capacity of data controller, to inform you about the personal data processed within the BlockRivals mobile game under Law No. 6698 on the Protection of Personal Data ("KVKK"). This notice applies to users resident in Turkey. For a more general explanation (aimed at international users) of the purposes and legal grounds for processing and of your rights, see the Privacy Policy as well; the two documents complement each other. For the Turkish version: KVKK Aydınlatma Metni (TR).

1. Data controller

Legal name: 43 Software Ltd
Address: [[DATA_CONTROLLER_ADDRESS]]
Tax ID / MERSİS No: [[MERSIS_OR_TAX_NUMBER]]
KVKK application email: [[KVKK_APPLICATION_EMAIL]]

2. Categories of personal data processed

The categories of personal data processed within BlockRivals and their details are listed in the Privacy Policy — Data inventory table section. In summary: identity data (username), transaction-security data (device registration, session-token hash, recovery-code hash), customer-transaction data (rating, in-game currencies, level, match history/move records), and the contact information you share as part of a support request. Email address, phone number, or Turkish national ID number are NOT collected for identity verification.

3. Purposes of processing personal data

Creating the game account, signing in, and maintaining the session.
Recovering the account with the recovery code after a device change.
Providing matchmaking, leaderboard, rating, and replay (move-recording) features.
Ensuring the reliability of the game, fixing errors, and preventing cheating and abuse.
Responding to support requests.
Fulfilling legal obligations.

4. Legal grounds for processing personal data

Your personal data is processed under Article 5/2 of the KVKK, on the grounds that processing is directly related to and necessary for the establishment or performance of a contract (the game's terms of use), is mandatory for the data controller to fulfil its legal obligations, and is mandatory for the data controller's legitimate interest, provided this does not harm your fundamental rights and freedoms. For processing activities that are not mandatory (e.g. features that may be added in the future), your explicit consent may additionally be requested.

5. Transfer of personal data

Your personal data may be shared with the hosting/infrastructure service providers necessary to provide the game, and with legally authorized public institutions and organizations, within the conditions and limits set out by the KVKK. Google AdMob processes the device's advertising identifier and technical information related to ad display/interaction through its own SDK, under its own privacy policy, when an ad is shown (see Privacy Policy Section 1, "Advertising"); other than this, there is NO data sharing with any third-party analytics provider. Our server infrastructure is currently hosted inside Türkiye (Istanbul); to the extent any transfer abroad takes place, this is carried out in accordance with Article 9 of the KVKK.

6. Retention period of personal data

Your personal data is retained for as long as your account is active and for the period required by the purposes stated above. Technical event and crash records are automatically deleted within 30 days. If you submit an account deletion request, the retention and deletion process described on the Delete Account page applies.

7. Your rights under Article 11 of the KVKK

Under Article 11 of the KVKK, by applying to us you have the right to:

Learn whether your personal data is being processed,
Request information about it if it has been processed,
Learn the purpose for which it is processed and whether it is used in accordance with that purpose,
Know the third parties, domestic or abroad, to whom it is transferred,
Request correction if it has been processed incompletely or incorrectly,
Request its erasure or destruction within the conditions set out in Article 7 of the KVKK,
Request that any correction or erasure be notified to the third parties to whom the data was transferred,
Object to a result that is to your detriment arising solely from analysis by automated systems,
Request compensation for damage suffered due to unlawful processing

you are entitled to the above rights.

8. How to apply

To exercise the rights above, you may send your request, together with information identifying you (e.g. your BlockRivals username), to [[KVKK_APPLICATION_EMAIL]]. Your application will be concluded as soon as possible depending on its nature and, in any case, within the period prescribed by the KVKK (no later than 30 days).

9. Cookies

This website (blockrivals.com.tr, or a domain to be determined) does NOT use cookies or similar tracking technologies. See the Cookie Notice for details. Within the game app itself, the advertising SDK's (Google AdMob) own technologies — separate from this website — are described in the Privacy Policy.

10. Other information

BlockRivals uses an identity model that works without a username, email address, or phone number being mandatory (see the Privacy Policy). Your username is visible to your rivals within the game — this may be regarded as a "sharing of personal data" within the meaning of the KVKK, and it is expressly disclosed through this notice.