Kingsgate: Tower Defense — Privacy Policy

Effective date: [REVIEW: set on publication]
Game brand: Dynokod (https://dynokod.com)
Publisher and data controller: DYNASYS TEKNOLOJİ YAZILIM VE DANIŞMANLIK LİMİTED ŞİRKETİ, Istanbul, Turkey
Registered address: [TODO: registered address] (needed for GDPR Art. 13 and KVKK Art. 10 notices and for EU DSA trader status)
Contact: info@dynasys.tech
Web address of this policy: https://dynokod.com/kingsgate/privacy

This policy explains what information the mobile game Kingsgate: Tower Defense, a Dynokod game published by DYNASYS TEKNOLOJİ YAZILIM VE DANIŞMANLIK LİMİTED ŞİRKETİ (“the game”, “we”, “us”), handles, why, and the choices you have.

1. Short version

• You don't need an account to play. We don't ask for your name, email address, phone number or location.
• Your progress (stars, upgrades, settings) is saved only on your device. We don't run any servers and we don't receive your game data.
• The game is free. It shows optional rewarded video ads only when you tap a "Watch ad" button. These ads come from Unity Ads, through Unity's LevelPlay mediation service. Unity collects some device and usage data to show and measure ads (see section 3).
• If you're in the EEA, the UK, Switzerland or Turkey, the game first asks whether our ad partner may personalise ads (Accept or Decline, same size buttons). You can change your answer any time in Settings > Privacy & Ads.
• On iPhone, we ask for your permission (Apple's App Tracking Transparency prompt) before ads can use your device's advertising identifier. If you declined ad personalisation on the consent screen, we don't show this prompt. The game works the same whatever you choose.
• Purchases are handled by Apple's App Store (or Google Play on Android). We never see your payment details.

2. Information stored on your device

Deleting the game deletes this data. The in-game Reset Progress option clears game progress but keeps purchases (so you don't lose what you paid for) and keeps your ad-consent choice.

3. Advertising (Unity Ads / Unity LevelPlay)

The game uses Unity LevelPlay (mediation) with the Unity Ads network, both provided by Unity Technologies, to show rewarded video ads. Ads only play when you choose to watch one, for example to double the stars from a win, to get a second chance after a defeat, or for bonus starting gold. Turning the reward down has no penalty.

When the ads SDK runs, Unity may collect and process, according to Unity's own disclosures:

• device and advertising identifiers (for example Apple's IDFA, only if you allow tracking, and the IDFV vendor identifier),
• coarse location derived from your IP address,
• device information (make, model, operating system, language, screen, network/connection type),
• ad interactions (ads shown, viewed, clicked, rewards granted) and performance data (for example load times),
• in-app purchase history, which Unity uses for ad measurement and optimisation [REVIEW: Unity lists "purchase history" for Unity Ads; confirm whether it applies to this integration].

Unity uses this data to deliver, cap, measure and improve ads, to prevent fraud, and, where you have allowed it, to personalise ads. For Unity Ads and the in-app purchase service, Unity acts as an independent controller for some of this processing [REVIEW: confirm controller/processor roles in Unity's current terms and DPA]. Read Unity's policy here: https://unity.com/legal/game-player-and-app-user-privacy-policy.

If you buy No Ads, the game stops showing ads, and offers that would have needed an ad are granted directly. From the next launch, the game doesn't start the ads SDK at all and doesn't show the consent screen or the tracking prompt.

4. Your ad-consent choice (EEA, UK, Switzerland and Turkey)

If your device or App Store country is in the European Economic Area, the United Kingdom, Switzerland or Turkey (or the game can't tell where you are), the game shows a Your privacy screen on first launch, before the ads SDK starts and before any tracking prompt. It asks whether Unity Ads (through Unity LevelPlay) may use your device's advertising identifier and similar data to show you more relevant ads and measure them.

• Accept: Unity and its ad partners may personalise and measure ads.
• Decline: you still get the same optional reward videos, but they aren't personalised. Some data is still processed to deliver ads safely (for example fraud prevention and frequency capping).

Both buttons are equally easy to tap and the game plays the same either way. We pass your answer to Unity LevelPlay with its official consent setting (LevelPlayPrivacySettings.SetGDPRConsent), and LevelPlay shares it with Unity Ads. You can change your answer any time in Settings > Privacy & Ads. A change is passed on straight away. We ask again after 13 months, or sooner if our ad partners or this screen change.

To decide where you are, the game checks your App Store country, your device's region setting and your time zone on the device. Nothing is sent to us for this.

5. App Tracking Transparency (iOS)

Before the ads SDK starts, the game shows a short explanation, then Apple's system prompt asking whether Kingsgate may track you across other companies' apps and websites. If you have just accepted on the consent screen, the explanation is skipped and the system prompt appears straight away. If you declined on the consent screen, the system prompt isn't shown. If you choose Ask App Not to Track, the advertising identifier (IDFA) isn't shared, ads are less personalised, and the game works exactly the same. You can change this any time in Settings > Privacy & Security > Tracking.

Ad attribution may also use Apple's privacy-preserving SKAdNetwork framework, which doesn't identify you.

6. In-app purchases

Optional purchases ("No Ads" and star packs) are processed by Apple (or Google). We use Unity In-App Purchasing to talk to the store. We receive the product, a transaction ID and the purchase result, but never your name, card or billing details. Unity may process purchase receipts and related data to provide this service (see Unity's policy above). Refunds are handled by Apple or Google under their policies. On a new device, use Restore Purchases in the in-game store to get "No Ads" back.

7. What we do NOT do

• We don't require or offer user accounts, social login, chat, or user-generated content.
• We don't collect precise location, contacts, photos, microphone or camera data.
• We don't sell your personal information. We don't run our own analytics or crash reporting. [REVIEW: update this if analytics or crash reporting is added later.]

8. Legal bases (EEA/UK GDPR, Swiss FADP) and Turkey (KVKK, Law No. 6698)

• Local saves and purchases: needed to provide the game and fulfil your purchase (GDPR Art. 6(1)(b); KVKK Art. 5(2)(c)).
• Ads: personalised advertising and the use of device identifiers rely on your consent, collected on the in-game consent screen (GDPR Art. 6(1)(a) and the ePrivacy rules on device storage and access; KVKK Art. 5(1) explicit consent). You can withdraw it any time in Settings > Privacy & Ads, as easily as you gave it. Non-personalised ads, frequency capping and fraud prevention may rely on legitimate interests. [REVIEW: the consent screen is our own (not an IAB TCF CMP). That fits the current setup, where Unity Ads is the only ad network and Unity Ads isn't an IAB TCF vendor. If Google AdMob/Ad Manager demand is ever added, Google requires a Google-certified TCF CMP for EEA/UK/Swiss users. Have a lawyer confirm the consent wording, and whether a Turkish-language version of the screen and of this notice is needed for KVKK.]
• International transfers: Unity may process data outside your country, including in the United States. [REVIEW: describe the transfer safeguards (for example SCCs or the EU-US Data Privacy Framework) and KVKK Art. 9 cross-border transfer requirements as amended in 2024.]
• KVKK specifics: [REVIEW: confirm whether DYNASYS TEKNOLOJİ YAZILIM VE DANIŞMANLIK LİMİTED ŞİRKETİ must register with VERBİS and whether a separate KVKK "Aydınlatma Metni" in Turkish is needed for Turkish users.]

9. Your rights

Depending on where you live (for example under GDPR, UK GDPR, KVKK, or US state laws such as the CCPA/CPRA), you may have the right to access, correct, delete, restrict or object to processing of your personal data, to data portability, to withdraw consent, and to complain to a supervisory authority. In Turkey, that is the Personal Data Protection Authority (KVKK Kurumu); in the EU, your local data protection authority.

Because we don't hold your game data on any server, the data we can act on is limited. Your save file is on your device, and you can delete it by uninstalling. For data held by Unity, use Unity's privacy request options (see Unity's policy) or contact us and we'll help. To withdraw or give ad consent, use Settings > Privacy & Ads in the game. To limit ad tracking, use the iOS Tracking setting described above, or on Android, Settings > Privacy > Ads.

California residents: we don't sell or "share" personal information for cross-context behavioural advertising ourselves. Our ad partner's processing is described in Unity's policy. [REVIEW: confirm CCPA "sale/share" wording given third-party ad SDK use; consider passing the CCPA flag via LevelPlayPrivacySettings.SetCCPA for opted-out users.]

10. Children

The game isn't made for children: it isn't directed at children under 13 (or the minimum age in your country, for example 16 in some EU countries), it isn't in Apple's Kids category, and its App Store age rating is 9+. The ads SDK isn't set up as child-directed. If you believe a child has given us personal information, contact us and we'll help delete it.

11. Security and retention

Game data and your consent choice stay on your device until you delete the game. We don't keep server copies. Unity keeps ad data according to its own retention policy.

12. Changes

If we change this policy, we'll update the effective date above and, for significant changes, show a notice in the game.

13. Contact

DYNASYS TEKNOLOJİ YAZILIM VE DANIŞMANLIK LİMİTED ŞİRKETİ
[TODO: registered address], Istanbul, Turkey
Email: info@dynasys.tech
Support page: https://dynokod.com/kingsgate/support
Kingsgate: Tower Defense is a Dynokod game.