Privacy Notice

In case of any discrepancy, the Turkish version of this document shall prevail.

Effective Date: 2025.09.29

Last Updated: 2026.02.11

This Privacy Notice explains how KUTUAMA ("we", "our", "us") collects, uses, shares, and protects your personal data when you use our peer-to-peer online backgammon platform available at kutuama.com.

We take your privacy seriously and comply with applicable privacy laws.

• 1. What Data We Collect
• 2. Why We Process Your Data (Purposes & Legal Bases)
• 3. How We Share Your Data
• 4. Cookies
• 5. Your Rights
• 6. Security
• 7. Children's Privacy
• 8. Updates to This Notice

1. What Data We Collect

We may collect the following personal data when you register or use KUTUAMA:

Account Information:

• Username (required)
• Email (required)
• Password (required)
• Other Profile Details (optional: Country, gender, etc.)

Technical & Usage Data:

• Temporary IP address (for security and session mapping)
• Device type, browser, operating system
• Country derived from IP
• Date and time of access
• Session statistics (e.g., activity logs, number of games played)

Cookies & Similar Technologies:

• Secure session cookies (to keep you logged in and enable gameplay)

We do not collect your real name or payment data.

2. Why We Process Your Data (Purposes & Legal Bases)

We only process your personal data where we have a valid legal basis under applicable privacy laws (such as GDPR or KVKK). These are:

Performance of a contract (GDPR Art. 6(1)(b); KVKK Art. 5/2(c))

We need to process certain data (e.g., username, email, password) to create your account, enable you to play, and provide you with the KUTUAMA service.

Compliance with legal obligations (GDPR Art. 6(1)(c); KVKK Art. 5/2(ç))

We may process your data where required by law, for example, to respond to lawful requests from official authorities or competent bodies.

Legitimate interests (GDPR Art. 6(1)(f); KVKK Art. 5/2(f))

We may process certain technical data (such as temporary IP addresses, logs, and usage statistics) under our legitimate interests to protect the security of the platform, prevent fraud, and improve performance.

Consent (GDPR Art. 6(1)(a); KVKK Art. 5/1)

When you provide optional profile details (e.g., gender identity, nationality) or choose to make them visible to others, we rely on your consent. You can withdraw your consent at any time by changing your profile settings or contacting us.

3. How We Share Your Data

We do not sell your data. We may share your data in limited cases:

• With service providers from whom we receive services (e.g., hosting, security, analytics) under our instructions and data protection agreements.
• With other users (only the username and optional profile details you choose to display).
• With relevant official authorities when legally required.

Data may be transferred outside Turkiye or the EU. Where we transfer data internationally, we take appropriate measures to ensure that your information is protected in line with applicable legal requirements.

4. Cookies

We use strictly necessary cookies for session security and to store temporary user information for the duration of your session. You can control cookies through your browser settings.

5. Your Rights

Depending on your location, you have certain rights over your personal data. These include:

• Right to information: Request information about your personal data and the purposes of its use.
• Right to transfer information: The right to know to whom your data has been transferred, whether domestically or internationally.
• Right to correction: The right to request correction of data that has been processed incompletely or inaccurately.
• Right to deletion: The right to request deletion or destruction of your data when the relevant conditions are met.
• Right to request notification: The right to request that any corrections or deletions of your data be communicated to third parties to whom your data has been transferred.
• Right to object to automated processing: The right to object to any outcome that is to your detriment arising from the analysis of your data exclusively through automated systems.

Depending on the data protection laws in your country, you may also have additional rights, such as the right to lodge a complaint with a data protection authority.

If you have given us your explicit consent, you may withdraw it at any time. Please use the relevant options on the Platform or you may contact us.

6. Security

We use industry-standard technical and organizational measures to protect your data, including encryption of user passwords and secure session handling. No system is completely secure, but we take steps to minimize risks.

Email to exercise your rights or contact us: contact@kutuama.com

Data Retention:

• Account data: Kept for as long as you maintain your account.
• IP and user logs: Retained temporarily for 90 days for security and analytics.

If you delete your account, we will erase or anonymize your personal data unless required by law.

7. Children's Privacy

KUTUAMA is not directed to children under 13 (US) or under 16 (EU) or under 18 (Turkiye). If we learn that we have collected data from a minor without parental consent, we will deactivate the account and delete the account information.

8. Updates to This Notice

We may update this Privacy Notice from time to time. We will notify you by posting the new version with a new "Last Updated" date.