Privacy Policy

Last Updated: May 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.
  • 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
  • Device type, model, and operating system version
  • Gameplay data (levels played, progression, session duration, in-game events)
  • 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

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)
  • Prevent fraud and abuse
  • Comply with legal obligations

We do not use your data for personalized advertising, and we do not sell your personal data.

6. 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.

7. Disclosure of Your Data

We may share your data with:

7.1 Service Providers

The third-party SDKs listed in Section 4 (Firebase, Adapty), as well as Apple and Google for store and payment processing. They are contractually bound to protect your data and use it only for the purposes we direct.

7.2 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

8. International Data Transfers

Your data may be processed in:

  • Turkey
  • The European Union
  • The United States
  • Other countries where our Service Providers 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.

9. 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
  • Consent — for push notifications and any other consent-based processing

You may withdraw consent at any time by adjusting device settings or contacting us.

10. 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)
  • Purchase records: retained as required by tax, accounting, and consumer protection laws

You may request deletion of your data at any time (see Section 12).

11. 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.

12. Your Privacy Rights

Depending on your location, you may have the following rights under GDPR, KVKK, CCPA, 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 (California)

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.

13. 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 display behavioral or interest-based advertising to users.
  • 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). We are not responsible for the privacy practices of those sites. Please review their privacy policies separately.

15. 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.

16. 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.