CodeCar.io Privacy Policy CodeCar.io (owned and operated by Cyber İstanbul Bilişim Teknolojileri A.S.) is founded on the principle of improving the world s access to quality educational games and activities and we are committed to providing an educational, entertaining, and safe service for kids and parents. We know that you care about how your family s personal information is used and shared, and we take your privacy and safety very seriously. We are extremely sensitive to family and educator concerns about their and their children s personal information and safety. We will never include any pop-up ads or other advertisements directed at children. In addition, Child Users are blocked from accessing external links, which will only be available if an Adult User enters a password or answers a security question. CodeCar.io is committed to protecting your privacy. We take privacy seriously at CodeCar.io and this policy is designed to share what information we collect and how we use it. CodeCar.io may change or update the Privacy Policy at any time as we add new or different features, or as the law changes. Unless another date is given, the changes are effective upon posting. If we make a material change to this policy and we have your parent email address, we will contact you to notify you before making the changes. You should review the Privacy Policy frequently. This Privacy Policy is also part of the Terms of Service that explain your rights and responsibilities and CodeCar.io when using CodeCar.io application. If you don t agree with this Privacy Policy or the Terms of Service, you should not use the sites and services. If you have any questions please contact us at: destek@cyberistanbul.com What Kind of Information is Collected? We collect information, including Personal Information, when you register with and log in to our services or communicate with us.  We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the application. The information we collect automatically helps us to improve our application and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, allowing us to customize our application according to your individual interests and recognize you when you return to our application. There are two types of data that may be collected. The first one is called personal data. This is personally identifiable information that identifies a user as an individual. CodeCar.io may collect personal data that parents voluntarily provide on the application. The second type is non personal data which doesn t directly identify an individual or which may have been personal information but has had the personally identifiable information removed. CodeCar.io may collect non personal information about the use of the app to help us improve our services. More about Personal Data We collect personal data when a parent subscribes to a newsletter or alert, submits content to a forum or blog, or requests technical support. This data may include a name (screen or nickname), gender, birth date, and email address. This information may be used to contact parents about new services and features and to send push notifications if consent to receive them has been given. If you contact us for help we will only use your email address to reply to your question. Please note that if a parent posts personal information about themselves in a community forum or blog in the parent section, in addition to being collected, this data is made public for others to see. The parent is responsible for the disclosure of any such data in those forums. How We Use Data We use data collected from you to: Provide, administer, and facilitate your use of our application, including to display customized content; process or fulfill your request(s) and/or order(s) for products, services, information or features; display consumer surveys, communicate with you concerning your account by: Responding to your questions or concerns; Sending you administrative messages and information, those about changes to the Services, and updates to our Terms, and Privacy Policy; Emailing you information or providing in app messages about your rewards programs, new services, new features, promotions, newsletters, which you can opt out of at any time; Sending push notifications to your wireless device to provide updates and other relevant messages. You can manage push notifications from the “options” or “settings” page for the mobile application. Understand and improve the services and develop new products, services or features; Enable user-to-user communication and interaction; Manage your account preferences, establish your profile and registration information; Facilitate the technical functioning of our application, including without limitation to troubleshoot and resolve issues, secure the Services, and prevent fraud and abuse; Respond to customer support questions and issues and resolve disputes; Create, review, analyze and share technical information; Analyze trends and user traffic, track purchases and usage information; Advertise our Services on third party websites or mobile applications; Market, process or fulfill promotions administered or sponsored by us; Solicit feedback from users; As required or permitted by law; As we, in our sole discretion, otherwise determine to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, members of the public, and/or our Services; Identify unique users across devices; or Tailor advertisements across devices. Aggregate Data: We may de-identify and aggregate information collected through the application and use it for any lawful purpose. Child User Information: Information collected from Child Users may be used: To measure a Child User s performance in activities and to adapt a Child User s learning experience to the Child User s learning needs. To analyze, provide progress reports on, or provide an assessment of a Child User s performance.   Information collected from Child Users is never used to market to Child Users. Specifically, Personal Information collected from Child Users will never be used to serve targeted advertising, to build behavioral marketing profiles, or be shared with independent third parties for marketing purposes. Both Adult and Child User Information. Information collected from both Adult and Child Users may be used: To allow us to assess and improve the application, its educational content, and other services we provide, for example, to improve our content and user experience; to research, evaluate, and improve the application s educational efficacy; and to inform our understanding of the application s user base. To customize, adapt, and personalize users viewing and content-consumption experience, for example by measuring a Child User s performance in activities and adapting the Child User s learning path to his or her learning needs. To maintain and analyze the functioning of the application. As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to detect violations of and enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates, including the security of the Services; (f) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. More about Non Personal Data To help us provide you with the best service, we work with third party analytics providers. These companies help us to understand your use of the apps. In association with them, we may collect your unique device identifier, IP address, mobile phone carrier, game progress, time spent playing, and achievements. This information is for internal use only and can t be shared. It s just for us to help us improve our services for you. CodeCar.io may also use third parties from time to time to deliver a service, such as payment processing, sending emails, or helping with customer or technical support. We only work with companies that follow this privacy policy and agree not to use your information for any other purposes. If you d like more information on this, please contact us at destek@cyberistanbul.com A Word about What We Might Disclose As you can see, we collect minimal personal data from parents who wish to provide it, and some nonpersonal data for internal use only or in conjunction with third parties to help us operate, analyze, and improve our services. In addition, we may disclose your personal or nonpersonal information to additional parties if we believe we are required to by law, by a judicial proceeding, to protect CodeCar.io rights and properties, or to investigate fraud, intellectual property infringement, and any other conduct that might be illegal or expose CodeCar.io or a user of its services to legal liability. In addition, CodeCar.io may disclose your information in the event of a change or proposed change in the ownership of the company; for example, a sale, a merger, or bankruptcy. Parents may disclose information about themselves by posting in the public forums on the site. CodeCar.io is not responsible for what parents say and post in these sections. Tracking CodeCar.io does not track you; that is, CodeCar.io does not collect personally identifiable information about your online activities over time and across third-party web sites or online services. Links We may include links to third parties from our services. CodeCar.io isn t responsible for these companies and including a link to them doesn t mean that CodeCar.io endorses them. So be sure to check their privacy policies if you decide to visit them. And remember, your use of CodeCar.io services may also be subject to the terms and conditions and privacy policies of other services that CodeCar.io doesn t control such as mobile application stores, mobile software platforms, online social media sites, or payment processors. Security CodeCar.io uses generally accepted security measures and safeguards in an attempt to keep the data it collects secure and requires that the third parties it works with agree to do the same. The measures and safeguards include limiting access to the data to those persons who need it to complete their work for CodeCar.io, using a fire-wall protected environment, and storing personal information in secure operating environments. That said, CodeCar.io cannot and does not guarantee and does not accept liability for unintentional disclosure. Children s Privacy The Children s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform you, as parents and legal guardians (as used in this section, “parents”) about our practices for collecting, using, and disclosing Personal Information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child s parent for certain collection, use, and disclosure of the child s Personal Information. This section notifies parents of: The types of information we may collect from children. How we use the information we collect. Our practices for disclosing that information. Our practices for notifying and obtaining parents consent when we collect Personal Information from children, including how a parent may revoke consent. Information We Collect from Children: We only collect as much information about a child as is reasonably necessary for the child to participate in the educational activity in our application, and we do not condition his or her participation on the disclosure of more Personal Information than is reasonably necessary. Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including children, when they access and navigate through the application and use certain features. The information we collect through these technologies may include: One or more persistent identifiers that can be used to recognize a user over time and across different services We may combine non-personal information we collect through these technologies with Personal Information about you or your child that we collect online. How We Use Your Child s Information: We use the Personal Information we collect from your child to: Collect automatically through technology and other non-personal information we collect to improve our application and to deliver a better and more personalized experience by enabling us to: Estimate our customer size and usage patterns. Store information about the child s preferences, allowing us to customize the content according to individual interests. Our Practices for Disclosing Children s Information: We do not share, sell, rent, or transfer children s Personal Information other than as described in this section: We may disclose aggregated information about many of our users, and information that does not identify any individual. In addition, we may disclose children s Personal Information: To third parties we use to support the internal operations of our application or Services and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential. To law enforcement agencies or for an investigation related to public safety. If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CodeCar.io, our customers or others, including to: protect the safety of a child; protect the safety and security of the application or services; or enable us to take precautions against liability. Accessing and Correcting Your Child s Personal Information: At any time, you may review the child s Personal Information maintained by us, require us to correct or delete the Personal Information, and/or refuse to permit us from further collecting or using the child s Personal Information. You can review, change, or delete your child s Personal Information by sending us an email to destek@cyberistanbul.com To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections. How to update or remove your information CodeCar.io keeps your content for as long as necessary in providing its services. If you want to opt out of services, or review or delete your information, please contact us at destek@cyberistanbul.com Your Rights The people who provide us with any personal data have the following rights: Right of access: The data subjects shall have the right to obtain from the Controller confirmation that their data are processed properly and they shall have the right of access their personal data. Right to rectification of information: The data subject shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning his or her. Right to erasure (to be forgotten): The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her. Right to restriction of processing: The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; Right to data portability: The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided. Please have in mind that this right will not be enforceable to: – The third parties data that you have provided to the Controller. – The data that concern you, but have been provided to the Controller by third parties. Right to object: The data subject shall have the right to object to processing of personal data concerning him or her. You shall be able to object to the commercial communications submitting. You can exercise this right by sending us an e-mail to the following address: destek@cyberistanbul.com Contact Us Cyber İstanbul Bilişim Teknolojileri A.S. ( Cyber İstanbul ) located in Turkey, is the operator and owner of CodeCar.io. Questions regarding this Privacy Policy and issues related to you or a Child User s information for which you are responsible should be directed to us via any of the following methods: Merkez Mah. Hasat Sok. Alver Apt. No.52 Şişli Istanbul Turkey Attention: Legal Department Phone: (+90) 5438391116 Email address: destek@cyberistanbul.com