Privacy Policy

Last Updated: June 2026

This Privacy Policy describes how Surge Games Teknoloji Anonim Şirketi (“Surge Games”, “Company”, “We”, “Us”, “Our”) collects, uses, discloses, and protects your personal data when you use our mobile games and related services (“Service”).

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Scope note: This Privacy Policy is a master document covering all Surge Games titles. Not every data practice described here applies to every game. The specific data collected by an individual game is disclosed in that game’s App Store “App Privacy” section and Google Play “Data Safety” section.

1. Company Information (Data Controller)

Company Name: Surge Games Teknoloji Anonim Şirketi Address: Fenerbahçe Mah. İğrip Sk. No:13 İç Kapı No:1 Kadıköy / İstanbul, Turkey Website: https://surgegames.co Contact Email: info@surgegames.co

Surge Games is the data controller responsible for your personal data.

2. Interpretation and Definitions

Interpretation

Words with capitalized initial letters have meanings defined below.

Definitions

  • Company: Surge Games Teknoloji Anonim Şirketi.
  • Device: Any device that accesses the Service.
  • Personal Data: Information relating to an identifiable individual.
  • Service: Our mobile games and related services.
  • Service Provider: Third parties processing data on our behalf.
  • Advertising Partner: Third-party advertising networks that deliver and measure advertisements within the Service.
  • Usage Data: Automatically collected data generated by use of the Service.
  • You: The user of the Service.

3. Data We Collect

Our games do not require you to register, sign up, or provide an email address to play. We collect only the data described below.

3.1 Anonymous Identifier

To save your progress and keep your gameplay data consistent across sessions, we use Firebase Anonymous Authentication, which creates an anonymous identifier tied to your device. This identifier is not linked to your name, email, or any account you control. It is automatically generated and cannot be used to personally identify you.

3.2 Usage Data (Automatically Collected)

We automatically collect technical and gameplay data, including:

  • Device identifiers (e.g., IDFV on iOS, Android ID)
  • Advertising ID (IDFA / GAID), only where permitted by your device settings and consent choices (see Section 6)
  • Device type, model, and operating system version
  • Gameplay data (levels played, progression, session duration, in-game events)
  • Advertising interaction data (e.g., ads served, viewed, or clicked), in games that contain advertising
  • Crash logs and diagnostic data
  • Coarse location (country/region, derived from IP)
  • App version and language

3.3 Support Communications

If you contact us via email for support, we receive whatever information you choose to send us (typically your message and email address). This is used solely to respond to your request.

3.4 Payment Data

In-app purchases are processed entirely by Apple App Store or Google Play Store.

We do not collect or store credit card, banking, or payment account information.

We may receive non-financial purchase data (e.g., item purchased, transaction ID, purchase status) for the purpose of unlocking content and validating purchases through our subscription/purchase management provider, Adapty.

4. Third-Party SDKs

Our games use the following third-party SDKs:

4.1 Firebase (Google LLC)

We use Firebase for:

  • Anonymous Authentication — to maintain anonymous device-tied identifiers for progress saving
  • Analytics — to measure engagement and improve gameplay
  • Crashlytics — to detect crashes and improve stability
  • Cloud Messaging — to deliver push notifications

Firebase’s privacy practices: https://firebase.google.com/support/privacy

4.2 Adapty

We use Adapty to manage in-app purchase validation, subscription state, and purchase analytics. Adapty receives non-financial transaction data (transaction ID, product ID, purchase status) and the anonymous device identifier.

Adapty’s privacy practices: https://adapty.io/privacy

4.3 Google AdMob (Google LLC)

In games that contain advertising, we use Google AdMob (via the Google Mobile Ads SDK) to serve banner, interstitial, and rewarded video advertisements. AdMob may collect and process:

  • Advertising ID (IDFA / GAID), where permitted by your device settings and consent choices
  • IP address and coarse location derived from it
  • Device and app information (device model, operating system, app version)
  • Ad interaction data (impressions, clicks, ad performance and fraud-prevention signals)

How Google uses data from apps that use its services: https://policies.google.com/technologies/partner-sites Google’s privacy policy: https://policies.google.com/privacy You can manage Google ad personalization at: https://adssettings.google.com

4.4 AppLovin

In games that contain advertising, we use AppLovin (including AppLovin MAX, its ad mediation platform) to deliver and mediate advertisements. AppLovin may collect and process:

  • Advertising ID (IDFA / GAID), where permitted by your device settings and consent choices
  • IP address and coarse location derived from it
  • Device and app information
  • Ad interaction data (impressions, clicks, viewability, fraud-prevention signals)

AppLovin’s privacy practices: https://www.applovin.com/privacy/

4.5 Facebook SDK (Meta Platforms, Inc.)

We integrate the Facebook SDK (provided by Meta Platforms, Inc.), including its App Events feature, to measure the performance of advertising campaigns that we run on Meta platforms (such as Facebook and Instagram) to promote our games. Unlike the SDKs in Sections 4.3–4.4, this SDK does not serve ads inside our games; it is used to attribute app installs and in-app events to our marketing campaigns and to help us reach relevant audiences. The Facebook SDK may collect and process:

  • Advertising ID (IDFA / GAID), where permitted by your device settings and consent choices
  • Device and app information (device model, operating system, app version)
  • App events (e.g., app installs, app launches, sessions, in-app purchases, and selected gameplay events)
  • IP address

This data may be used by Meta to measure and optimize advertising, and to build audiences for ad targeting. On iOS, the Advertising ID is shared with Meta only if you grant permission through Apple’s App Tracking Transparency prompt.

Meta’s Data Policy: https://www.facebook.com/privacy/policy/ Meta’s Business Tools Terms: https://www.facebook.com/legal/terms/businesstools

4.6 Mediated Advertising Networks

Because ads may be delivered through ad mediation, additional third-party advertising networks may serve ads in our games and receive the data categories described in Sections 4.3–4.4. Where required by law, these partners are listed in the in-game consent form (see Section 6). You may also request the current list of advertising partners for a specific game by contacting us at info@surgegames.co.

These SDKs may process data in countries outside your own. They are contractually bound to handle data in accordance with applicable data protection laws.

5. How We Use Your Data

We use your data to:

  • Provide and operate our games
  • Save and restore gameplay progress
  • Process and validate in-app purchases
  • Improve gameplay and game design
  • Analyze performance and engagement
  • Detect and fix crashes and errors
  • Provide customer support
  • Send push notifications (where you have enabled them)
  • Serve, measure, and (with your consent, where required) personalize advertising in games that contain ads
  • Prevent fraud and abuse, including advertising fraud
  • Comply with legal obligations

We do not sell your personal data in exchange for money. However, the disclosure of advertising identifiers and related data to our Advertising Partners may qualify as a “sale” or “sharing” of personal information under certain U.S. state privacy laws (such as the CCPA/CPRA). You may opt out of such sharing as described in Sections 6 and 13.

6. Advertising

Some of our games are supported by advertising delivered through our Advertising Partners, Google AdMob and AppLovin (including networks mediated through them). If a game does not contain advertising, this section does not apply to that game.

6.1 Personalized and Non-Personalized Ads

  • Personalized ads use your Advertising ID and related data to show ads more relevant to you. We allow personalized ads only where permitted by your device settings and, where legally required, your explicit consent.
  • Non-personalized (contextual) ads are selected based on general context (such as app content, coarse location, and current session information) rather than your behavior over time.
  • EEA, UK, and Switzerland: Before any personalized advertising, you will be asked for consent through an in-game consent form (Consent Management Platform). If you decline, you will receive non-personalized ads only. You can change your choice at any time in-game via Settings → Privacy Settings → Advertisement Consent, which re-opens the consent form, or through your device settings (see Section 6.3).
  • Türkiye: Where explicit consent is required under KVKK (Law No. 6698) for personalized advertising or related processing, we obtain it through the applicable consent mechanism, and you may withdraw it at any time through your device settings or by contacting us.
  • iOS: Under Apple’s App Tracking Transparency framework, your Advertising ID (IDFA) is used for personalized advertising only if you select “Allow” in the tracking permission prompt.
  • Other regions: Consent or opt-out mechanisms are applied as required by the laws of your jurisdiction.

6.3 How to Opt Out of Personalized Ads

You can limit or disable ad personalization at any time:

  • iOS: Settings → Privacy & Security → Tracking (disable “Allow Apps to Request to Track” or revoke permission for our games); Settings → Privacy & Security → Apple Advertising
  • Android: Settings → Privacy → Ads → “Delete advertising ID” or “Opt out of Ads Personalization” (wording varies by Android version)
  • In-game (EEA/UK/Switzerland players): Settings → Privacy Settings → Advertisement Consent re-opens the consent form, where you can review and change your advertising consent choices
  • Google: https://adssettings.google.com
  • Contact us: email info@surgegames.co to update or withdraw your consent choices

Opting out of personalized ads does not remove ads; you will still see non-personalized ads.

6.4 Rewarded Ads

“Rewarded” video ads are always optional. You choose whether to watch them in exchange for in-game rewards.

7. Push Notifications

With your permission, we may send push notifications for:

  • Game updates and new content
  • Reminders and re-engagement messages
  • System notices

You can disable push notifications at any time through your device’s notification settings.

8. Disclosure of Your Data

We may share your data with:

8.1 Service Providers and Advertising Partners

The third-party SDKs listed in Section 4 (Firebase, Adapty, Google AdMob, AppLovin, Meta (Facebook SDK), and mediated advertising networks), as well as Apple and Google for store and payment processing. Service Providers are contractually bound to protect your data and use it only for the purposes we direct. Advertising Partners process advertising data as described in Sections 4 and 6 and in their own privacy policies.

8.2 Business Transfers

In case of a merger, acquisition, or asset sale, your data may be transferred to the acquiring entity, subject to the same protections described in this Policy.

We may disclose data when required to:

  • Comply with applicable law
  • Respond to lawful requests from public authorities
  • Protect our rights, property, or safety, or that of our users
  • Prevent fraud or abuse

9. International Data Transfers

Your data may be processed in:

  • Turkey
  • The European Union
  • The United States
  • Other countries where our Service Providers and Advertising Partners operate

We use appropriate safeguards (such as Standard Contractual Clauses, where applicable) to protect international transfers. By using the Service, you consent to these transfers.

10. Legal Basis for Processing (EEA / UK Users)

We process data based on:

  • Contract necessity — to provide the Service you requested
  • Legal obligations — to comply with applicable laws
  • Legitimate interests — to operate, secure, and improve the Service, and to serve non-personalized (contextual) advertising in ad-supported games
  • Consent — for personalized advertising, push notifications, and any other consent-based processing

You may withdraw consent at any time by adjusting your device settings or contacting us. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

11. Data Retention

We retain data only as long as necessary for the purposes described in this Policy:

  • Anonymous identifier and gameplay data: retained while you continue to use the game; automatically dissociated if the device stops using the Service for an extended period
  • Crash logs and analytics: typically retained for shorter periods (up to 14 months for Firebase Analytics by default)
  • Advertising data: retained by our Advertising Partners in accordance with their own retention policies (see their privacy policies linked in Section 4)
  • Purchase records: retained as required by tax, accounting, and consumer protection laws

You may request deletion of your data at any time, either in-game via Settings → Privacy Settings → Delete My Data or by contacting us (see Section 13).

12. Security

We implement industry-standard security measures, including:

  • Encryption of data in transit
  • Access controls
  • Secure cloud infrastructure provided by reputable partners

However, no system is 100% secure. You use the Service at your own risk.

13. Your Privacy Rights

Depending on your location, you may have the following rights under GDPR, KVKK, CCPA/CPRA, and similar laws:

  • Right to access
  • Right to correction
  • Right to deletion
  • Right to restrict processing
  • Right to object
  • Right to data portability
  • Right to opt out of the sale or sharing of personal data, including sharing for cross-context behavioral advertising (California and certain other U.S. states)

California and other U.S. state residents: To opt out of the “sale” or “sharing” of your personal information for advertising purposes, use the device-level controls described in Section 6.3, or contact us at the email below with the subject line “Do Not Sell or Share My Personal Information.”

Requesting deletion of your data: You can request deletion of your data either in-game via Settings → Privacy Settings → Delete My Data (which opens a pre-addressed email to our support team) or directly by emailing info@surgegames.co. Once we receive and verify your request, we will delete the associated data within 30 days, except where we are required to retain certain records by law (e.g., purchase records kept for tax and accounting purposes).

Because we use anonymous identifiers tied to your device, we may need additional information from you (such as the device identifier or a recent transaction ID) to verify your request before acting on it.

To exercise your rights, contact: 📧 info@surgegames.co

We will respond within the timeframes required by applicable law.

14. Children’s Privacy

Our games are designed to be suitable for players of all ages and are rated accordingly on the App Store and Google Play.

We take children’s privacy seriously and design our games to comply with applicable children’s privacy laws, including the Children’s Online Privacy Protection Act (COPPA) in the United States and the GDPR (including provisions for users under the age of 16) in the European Economic Area, as well as KVKK in Turkey.

Specifically:

  • We do not knowingly collect personally identifiable information from children.
  • We do not require account creation, email, or any personal contact information to play.
  • We do not knowingly serve personalized (behavioral or interest-based) advertising to children. Where a game contains advertising and a user is known or indicated to be a child, our Advertising Partners are configured to serve non-personalized, contextual ads only, using the child-directed treatment settings provided by those partners (e.g., Google’s child-directed treatment tags).
  • We do not include social features, chat, or user-to-user communication.

If you are a parent or guardian and believe that we have collected information from your child in a manner inconsistent with applicable law, please contact us at info@surgegames.co and we will promptly delete the relevant data.

Our Service may occasionally link to third-party websites (for example, to our store pages, support resources, or partner services), and advertisements within our games may link to advertisers’ websites or app store pages. We are not responsible for the privacy practices of those sites. Please review their privacy policies separately.

16. Changes to This Policy

We may update this Policy from time to time. Changes will be posted on this page with a new “Last Updated” date. Continued use of the Service after changes are posted constitutes acceptance of the updated Policy.

For material changes, we will provide additional notice (e.g., in-game notice or push notification) where required by law.

17. Contact Us

For privacy questions, requests, or complaints:

📧 info@surgegames.co

You also have the right to lodge a complaint with your local data protection authority.