Privacy Policy

Effective date: October 18, 2026

This Privacy Policy explains how information is handled when you play Polar Rush and any other game published by Gamer Turtles (together, the “Games”) — currently Polar Rush, and future games once released. It should be read together with our Terms of Use. The Games are published by UMUT CAN KAYIKCI (trade name), Türkiye, under the brand Gamer Turtles (“we”, “us”). We are the data controller for the purposes of the EU/UK General Data Protection Regulation (GDPR) and the Turkish Personal Data Protection Law No. 6698 (KVKK).

In short: we do not run our own servers, we do not ask you to create an account, and we do not collect your name, email address or contacts. Your game progress stays on your device. The Games do use third-party services from Google and Apple — mainly for advertising and analytics — and those services collect some device information and gameplay events, as described below.

1. Information stored on your device

The Games save your progress locally on your device: scores, in-game currency, unlocked items, achievements, settings, and counters such as how many rewarded ads you watched today. This data is not sent to us. It is removed when you uninstall the Game or clear its app data.

2. Advertising (Google AdMob)

The Games show ads, including optional rewarded ads, through Google AdMob, a service of Google LLC / Google Ireland Limited. To serve and measure ads and prevent fraud, AdMob may collect:

• your device’s advertising identifier (Android Advertising ID or Apple IDFA, where permitted);
• IP address and approximate location derived from it;
• device and app information (model, operating system, language, app version);
• ad interactions (impressions, clicks, rewarded-ad completions) and diagnostics.

Google processes this information under its own policies. See How Google uses information from sites or apps that use its services and the Google Privacy Policy.

Your choices. If you are in the European Economic Area, the United Kingdom or Switzerland, you will be asked for consent before personalized ads are shown, and you can change your choice later from the Game’s settings. On iOS, the Games ask for permission before accessing the IDFA. On any device you can reset your advertising ID or opt out of personalized ads in the system settings (Android: Settings → Google → Ads; iOS: Settings → Privacy & Security → Tracking). Opting out does not remove ads; they become less relevant.

If you buy the in-app “Ad-Free” option, the Games stop showing and requesting automatic (interstitial) ads. Optional rewarded ads, which you choose to watch in exchange for an in-game reward, remain available and are still requested from AdMob.

3. Analytics (Google Analytics for Firebase)

To understand how the Games are played and to measure our own advertising campaigns, the Games use Google Analytics for Firebase, a service of Google LLC / Google Ireland Limited. It records gameplay events — for example when a run ends and the distance reached, when a new record is set, when an in-app purchase is completed and when a rewarded ad is watched — together with device and app information (model, operating system, language, app version), an app-instance identifier, approximate location derived from the IP address and, where permitted, the advertising identifier. We see this information only as aggregated reports; it is not linked to your name or any account. Where Google’s advertising services are linked, aggregated events may be used to measure and optimize our ads.

Your choices. Analytics collection starts only after the consent step described above. In the European Economic Area, the United Kingdom and Switzerland, analytics storage is used only if you accept in the consent form, and advertising use of the data follows your choices in that form; you can change them later from the Game’s settings. On iOS, the advertising identifier is used only if you allow tracking. See How Google uses information from sites or apps that use its services.

Crash reports. If a Game crashes, Firebase Crashlytics (Google) sends us a crash report so we can fix the problem: the error and the code location where it happened, the app version, device model, operating system version and an app-instance identifier. Crash reports do not include your advertising identifier or any account information, and are used only to keep the Games stable.

4. In-app purchases

Purchases are processed entirely by Google Play or the Apple App Store. We never receive your payment card or billing details. The store tells the Game only which item was purchased so that it can be delivered and restored. See the Google Privacy Policy and Apple Privacy Policy.

5. Leaderboards and achievements

Online leaderboards are provided by Google Play Games Services on Android and Apple Game Center on iOS. If you are signed in to one of these services, your player name, avatar and scores are shared with that service and may be visible to other players. Your gaming profile and its visibility are managed in the Google Play Games or Game Center settings, not by us. These services may also collect diagnostic and usage data to operate and improve them, under Google’s and Apple’s own policies.

6. Connectivity check

To tell whether you are online, the Game performs a simple network lookup of a public Google domain. This check does not send any game or personal data to us.

7. Summary of third parties

We do not sell personal information, and we do not share it with anyone other than the service providers listed above.

8. Legal bases (GDPR / KVKK)

• Consent — personalized advertising, analytics in the EEA/UK/Switzerland and, on iOS, tracking.
• Legitimate interests — non-personalized ads that fund the free Game, fraud prevention, and keeping the Game working.
• Performance of a contract — delivering and restoring in-app purchases.

Where third-party providers process data outside Türkiye or the EEA, they rely on the transfer safeguards described in their own privacy policies.

9. Children

The Games are not directed at children under 13, and we do not knowingly collect personal information from children. If you believe a child has provided personal information through a Game, contact us and we will help remove it.

10. Retention and security

We do not keep a copy of your game data. Data on your device stays until you uninstall the Game or clear its data. Data collected by Google or Apple is kept under their own retention policies. If you email us, we keep the correspondence only as long as needed to answer you.

11. Your rights

Depending on where you live, you may have the right to access, correct, delete or object to the processing of your personal data, to withdraw consent, and to lodge a complaint with a supervisory authority (in Türkiye, the Personal Data Protection Authority — KVKK). Because we do not hold your data ourselves, most requests are best directed to Google or Apple, and we will gladly help you do so. You can also reach us directly at the address below. Under Article 11 of KVKK you may, in particular, ask whether your personal data is processed, request information about it, learn the purpose of processing and the third parties it is transferred to in Türkiye or abroad, request its correction or deletion, object to a result arising solely from automated processing, and claim compensation for damage caused by unlawful processing. We answer requests free of charge within 30 days.

12. Changes to this policy

We may update this policy when the Games change. The effective date at the top shows when it was last revised. Significant changes will also be announced in the Game.

13. Contact

UMUT CAN KAYIKCI (Gamer Turtles)
Email: gtstudio@gamerturtles.com
Website: www.gamerturtles.com