PUKABU KVKK Information Notice

PUKABU KVKK Information Notice

INFORMATIONAL MACHINE TRANSLATION — This document is an informational machine translation of the binding authoritative Turkish master. In the event of any discrepancy, the Turkish master prevails.

This document is an informational translation of the Turkey-specific text under the Republic of Türkiye Personal Data Protection Law No. 6698. It does not replace rights or procedures under the GDPR, CCPA/CPRA, or any other jurisdiction.

CHAPTER 1

AIM

1.1

This Personal Data Protection Law (KVKK) Information Notice has been prepared by Kader Narin, acting as the data controller under the Personal Data Protection Law No. 6698 ("KVKK").

The purpose of this text is to explain how the personal data of individuals using the PUKABU mobile application are processed;

what scope it was processed,

what legal grounds it is based on

what purposes it is used

to whom it can be transferred,

which methods were used to collect it,

rights of the relevant persons

about this matter .

1.2

This Privacy Notice has been prepared solely to fulfill the obligation to inform under the Law No. 6698 on the Protection of Personal Data .

More detailed explanations regarding the processing of personal data can be found in the PUKABU Privacy Policy (PDS-LEGAL-001) .

CHAPTER 2

DATA CONTROLLER

Data controller under the KVKK (Turkish Personal Data Protection Law):

Kader Narin

Republic of Türkiye

Email:

pukabupuzzle@gmail.com

The data controller aims to process personal data in accordance with applicable legislation.

CHAPTER 3

PERSONAL DATA PROCESSED

The following categories of personal data may be processed during the use of the PUKABU application:

device information,

operating system information,

application version,

language preferences

advertising identities,

crash logs ,​

analytical usage information,

Technical information regarding premium subscription status,

Application performance logs.

PUKABU;

identity document,

passport​

biometric data,

health data,

Location history,

bank card information,

credit card information

It does not directly process sensitive or payment data such as those mentioned .

CHAPTER 4

PURPOSES OF PROCESSING PERSONAL DATA

Personal data may be processed for the following purposes:

the application ,

Offering premium subscription services,

managing advertisements ,

Ensuring application security,

error detection and correction,

performance analyses,

improving user experience,

fulfillment of legal obligations.

Personal data is processed in a limited and proportionate manner for these purposes.

CHAPTER 5

LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

Personal data may be processed based on the legal grounds specified in Article 5 of the KVKK (Law on the Protection of Personal Data).

These include, in particular:

in the laws ,

directly related to the formation or performance of a contract,

data controller fulfilling its legal obligations,

the establishment, exercise or protection of a right,

subject are not harmed.

included .

In situations requiring explicit consent, the user's explicit consent is also obtained.

CHAPTER 6

PARTIES TO WHOM PERSONAL DATA MAY BE TRANSFERRED

Personal data processed within the scope of the PUKABU application may only be shared with third-party service providers to the extent necessary for the provision of the service and the fulfillment of legal obligations.

In this context, personal data includes:

Google Firebase ( Analytics and Crashlytics ),

Google AdMob (advertising services),

Google Play (Premium subscription and app distribution),

Apple App Store / StoreKit (Premium subscription and app distribution)

It can be shared with service providers such as these .

Personal data also includes:

where required by current legislation,

authorized public institutions and organizations,

for the purpose of fulfilling legal obligations

the relevant individuals or institutions.

Issues relating to data transfer abroad are evaluated within the framework of applicable legislation and the PUKABU Privacy Policy (PDS-LEGAL-001) .

CHAPTER 7

METHOD OF COLLECTING PERSONAL DATA

Personal data;

PUKABU mobile application,

Software development kits (SDKs) used within the application ,

Premium subscription infrastructures,

technical systems of application stores,

analytics and error reporting services

It can be collected electronically through automated methods.

The collected data will be processed only for the purposes stated in this Privacy Notice, in a limited and proportionate manner.

CHAPTER 8

RIGHTS OF THE DATA SUBJECT

of the Personal Data Protection Law (KVKK) , data subjects have the following rights within the framework of the conditions stipulated in the current legislation:

personal data is being processed

If it has been processed, request information about it.

of processing and whether it is being used for its intended purpose,

learning the third parties to whom personal data is transferred,

incomplete or incorrectly processed data,

Requesting deletion or destruction of data in accordance with the conditions stipulated in the KVKK (Personal Data Protection Law),

requesting that any corrections or deletions made be notified to the relevant third parties.

solely through analysis by automated systems,

The right to claim compensation for damages incurred due to unlawful data processing .

The exercise of these rights is subject to the procedures and principles specified in the Personal Data Protection Law (KVKK) and related secondary legislation.

CHAPTER 9

APPLICATION PROCEDURE

Requests under the Personal Data Protection Law (KVKK) can be submitted to the data controller through the following communication channel:

Data Controller

Kader Narin

Email: pukabupuzzle@gmail.com

During the application process, additional information or documents may be requested to verify the applicant's identity.

Applications will be evaluated and finalized within the timeframes stipulated in the current Personal Data Protection Law (KVKK) and related legislation.

CHAPTER 10

UPDATES

This Privacy Notice;

changes in legislation ,

New features added to the application ,

used ,

changes in personal data processing activities

due to [reason ].

The latest version is provided to users via the PUKABU application or relevant official distribution channels.

CHAPTER 11

FORCE

This Personal Data Protection Law (KVKK) Information Notice enters into force on the date of its publication.

It remains valid until a new version is released.

END OF DOCUMENT

Document Name: PUKABU KVKK Information Text

Document Code: PDS-LEGAL-004

Document Version: FINAL v1.2

Document Status: In effect

Document Owner: Kader Narin

First Publication Date: …

Last Update Date: …

CHAPTER 10 - VERIFIED TECHNICAL PROCESSING CATEGORIES

PDS-SDK-INVENTORY-2026-08-24

The local profile/avatar, preferences, locale, score, and game progress are stored on the device with Shared Preferences 2.5.5 and are not sent to a developer server. Firebase Analytics is active for anonymous usage measurement, Crashlytics for technical diagnostics, and Google Mobile Ads/UMP for advertising and consent management in the free version. StoreKit/Google Play processes purchase data; PUKABU does not process payment-card data. Web CanvasKit requests may send ordinary network metadata to www.gstatic.com.