6Hive OÜ ("us", "our", "we", "Gutsy") is committed to protecting and respecting your privacy.
This privacy policy (the "Policy") sets out the types of personal data we collect and use when you access and/or use one of our apps or games (each a "Property" and together the "Properties") and how we may use that data.
This Policy covers our collection, processing, and use of personal data when you use any of our Properties. When you supply any personal data to us, we have legal obligations towards you in the way we use that data.
It is important that you read this Policy together with any other privacy notices or fair processing notices that we may provide on the Properties at or around the time that we collect or process personal data about you (e.g., fair processing notices that may be displayed to you when you first download and begin using a Property, or when you are given the opportunity to sign up to receive email updates from us).
This Policy supplements our Terms of Service, Cookie Policy, and other notices and terms that appear in the Properties (which may vary from Property to Property) and is not intended to override or replace them.
By visiting or otherwise using our Properties, you agree to the practices set out in this Policy to the extent permitted by data protection legislations. If, for any reason, you do not agree to the terms of this Policy, please stop using the Properties.
We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavor to notify users of the relevant Properties. However, it is your responsibility to check this Policy before each use of the Properties. For ease of reference, the top of this Policy indicates the date on which it was last updated.
Please note that our Properties are not directed at children under the age of 13 ("Children"), and we do not knowingly collect personal data about Children. If you believe we have collected personal data about your Child, you may contact us at metin@6hive.co and request that we cease processing data about your Child.
When this Policy refers to "personal data," it refers to data about you from which you could be identified, such as your name, date of birth, contact details, and even your IP address.
When you voluntarily supply your personal data to us, for example when you:
We may collect, store, and use the personal data that you disclose to us. The personal data we collect from you may include your title, name, address, email address, phone number, financial, and/or credit card information, but will depend on what details you volunteer to us as you interact with the Properties.
We may also collect personal data about you when you visit a Property (in particular, the Gutsy website) through the use of technologies such as cookies. Examples of data we may collect include:
We use the data described above for several reasons:
Our Properties contain features that serve advertisements to you. To make those advertisements as relevant as possible, we use third-party advertising networks that collect and use details about you and your interests to target relevant advertisements to you (rather than showing all Property users the same material).
We will give you the opportunity to disable the collection and transmission of information about you to those networks. Any such refusal will not stop you from seeing adverts, but it will decrease the relevancy of the adverts shown to you.
For details of the advertising partners that we use, please see the section below which names our providers.
Depending on how and why you provide us with your personal data, we may share it in the following ways:
We will not share your personal data with third parties to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g., a competition where a third party is providing the prize) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your personal data may be used, which you will be notified of at the relevant time.
We may also disclose your personal data to third parties in the following events:
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfill the services we request, and we stipulate that they protect this data and do not use it for any other purpose. The following is a list of our major service providers:
Where we provide links to third-party websites that are not affiliated with Gutsy (for example, where you click or tap on adverts in a Property), such sites are out of our control and are not covered by this Policy. If you access third-party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those Properties.
We will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.
Where you sign up to receive email marketing from us, we will retain your email address on file should you ever "opt-out" of receiving emails from us. We will retain your email address in this way to ensure that we continue to honor and respect that opt-out request.
In some circumstances, you can ask us to delete your data: see the “Your Rights” section below for further information.
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.
Gutsy takes the protection of your personal data very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the data provided to us is stored on secure servers once we receive it.
Gutsy may store your personal data on secure servers either on our premises or in secure third-party data centers.
Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfillment of your order, the processing of your payment details, and the provision of support services.
In particular, if you engage with us for support services (e.g., if you report a problem with one of the Properties) it is highly likely that your complaint will be dealt with by our support team in Turkey.
Gutsy may process, store, or transfer your personal data in Turkey or abroad, in accordance with the Law on Protection of Personal Data – 6698 and the relevant legislation within the limits set forth in the Policy. Where we transfer your data to a service provider that is outside of Turkey, we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. If you would like more information about the mechanism via which your personal data is transferred, please contact metin@6hive.co.
If we ever give you (or where you have chosen) a password which enables you to access certain parts of this Property, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
As a data subject, you have several rights in relation to your personal data, particularly your requests under Article 11 of the Law on Protection of Personal Data – 6698 regarding the rights of data subjects. Below, we have described the various rights that you have, as well as how you can exercise them.
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is correct. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase, we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information), you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
Gutsy may process your data on the basis of a legitimate interest in the following ways:
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party, you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Where we send you email marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the “unsubscribe” link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly, you can unsubscribe by writing to us at metin@6hive.co and telling us which communications you would like us to stop sending you.
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us verify your identity.
It will help us process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above, or if you think that the Policy has not been followed, please contact us at contact@6hive.co.