Kimboo Privacy Statement

1) About This Statement

This statement, which is a part of our Terms of Use / User Agreement, is pertain to what your personal information consists of and how it is protected by Data Birikim, Teknoloji ve Yatırım A.Ş.,the owner of the “Kimboo” mobile application, once you signed up by using via your Facebook account or Turkcell Mobile Connect (Mobile Connect) and started playing Kimboo. By signing up and logging in to Kimboo, using your Facebook account or Mobile Connect, means that you have accepted the rules of Kimboo User Agreement and this Privacy Statement.

2) What does Personal Information mean?

The Law No. 6698 on “Protection of Personal Data” (KVKK) under the Republic of Turkey, which regulates the protection of personal data in Turkey; defines personal information as “any kind of information about an identified or identifiable real person”.

Accordingly, your name, surname, and -if your name and surname are also included in- your e-mail address, your mobile (GSM) number, your education, your occupation are considered your personal information as they are suitable to determine your identity. Data Birikim, Teknoloji ve Yatırım A.Ş. carefully takes necessary precautions to protect your personal information not only under the rules of Law No. 6698 but also in accordance with the relevant provisions of our Constitution and other applicable legislation, i.e. the European Human Rights Convention, the European Union Data Protection Directive principles and its self ethic rules.

3) What kind of Personal Information does Kimboo collect?

Kimboo is currently designed only for iOS and Android mobile devices and can be developed to be played on other operating system devices and/or on desktop computers via When you start using the Kimboo application:

a) Your “Name and Surname”, “E-mail address”, “Gender”, “Profile photo” (Avatar), “Birth date” and “mobile (GSM) number” information that you have provided via your Facebook account or Kimboo’s Profile Creation Form; are automatically retrieved and saved to Kimboo servers. If some of this information is missing, your registration with Kimboo can not be completed. If you are younger than 18 years old or you appear to be registering on Facebook or Profile Creation Form with some misinformation, this will prevent you from using this application.

b) Since the Kimboo application is a game played with mobile communication devices, the users’ communication with Kimboo servers is “real time” and in addition to the above information, “Occupation” and “Status of education” information are also requested. Yet these are not compulsory to continue to play.

c) When a player in Kimboo adds you to his/her favorites and chooses to inform you of this (named “Karma” within the game), an automatic message is sent to you via both within the application and your registered email address in Kimboo. As this e-mail message are essential part of this game, your acceptance of this Privacy Statement and our Terms of Use means you are clearly consenting to the sending of such e-mails to you.

d) To become a Kimboo user, no other information, data or permission other than those mentioned above is required and recorded. However, Kimboo can use the tools of third parties such as Google Analytics, CloudFlare to improve the application in optimizing and distributing user traffic by sending cookies, saving usage data through the website which is established for you to be better informed about the game. In fact, you are free to choose from scratch by changing your Internet browser settings to accept “cookies”.

e) Kimboo is collaborating with the third parties – iTunes/App Store (Apple Application Store) and Google Play Store – which are currently in operation for downloading applications that match the type of your mobile device. Therefore, we recommend you to read the privacy statements of these organizations’ pages about their usage information such as IP numbers and Cookies they send.

4) How do we protect your personal information?

“Data Birikim, Teknoloji ve Yatırım A.Ş.”, takes the most appropriate and advanced technological security precautions necessary to prevent illegal and unauthorized access, modification, conversion or destruction of your personal data.

a) Your personal information, which is automatically retrieved via Facebook verification during registration, or you have filled-up in Kimboo’s Profile Creation Form, will be encrypted and recorded to the servers protected by Kimboo’s advanced technology. Other than our authorized “Data Supervisor”s, who are obliged to protect data and prevent illegal processing and access, it is not possible for others to access your information and only you can see them on your personal profile page. For other players, only your “Name” is reflected to your open profile and your “Last Name” is kept confidential. Likewise, even if you are a friend in the game, information such as who you are friends with, your favorites, the total number of questions you have answered, your answers, your events in the game are also kept confidential. (See. FAQ)

b) When you purchase Karma’s (which one of the features of Kimboo application) via in-app-purchase tools, the purchase and all realted transactions adnd payment is handled via iTunes/App Store or Google Play secure payment systems, terms of use and infrastructure.

5) How do we use your personal information?

The Nature of Personal Information:

“Personal data” is processed in various forms and turned into a trade commodity in general, while the “sensitive information” can not be processed in some legal schemes, wherein specified and its crimes are covered by the law. In Turkey, the Law No. 6698 on the Protection of Personal Data states that the data about persons “race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, appearance with costume and clothing, association, foundation or trade union membership” and their “biometric and genetic” data are considered “sensitive information” by referring them as “personal data of special nature “. Data Birikim, Teknoloji ve Yatırım A.Ş. is aware of its responsibility in this matter too and does not share or process the personal data of the users illegally, never asks for “private data” and also does not make “profiling”.

Anonymous Data: On the other hand, the answers given to the questions of the game that are completely independent of the identity of the Users in the Kimboo application are “anonymous data”.
We may use anonymous data to:

a) Deliver and improve our products and services, and manage our business;
b) Manage your account and provide you with customer support;
c) Perform polls, research and analysis about your use of, or interest in, our or others’ products, services, or content;
Communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
d) Develop, display, and track content and advertising tailored to your interests on our Service and other sites, including providing our advertisements to you when you visit other sites;
e) Website or mobile application analytics;
f) Verify your eligibility and deliver prizes in connection with contests etc.
g) Enforce or exercise any rights in our Terms of Use,
h) Perform functions or services as otherwise described to you at the time of collection.

In all circumstances, we may perform these functions directly or use a third party vendor to perform these functions on our behalf who will be obligated to use your personal information only to perform services for us. Also, if you access our Service from a third party social platform, such as Facebook, we may share non-personal information with that platform to the extent permitted by your agreement with it and its privacy settings.

Custom Ads – Permission based e-mails for marketing purposes: Data Birikim, Teknoloji ve Yatırım A.Ş. hold the right to generate personalized native advertisements within Kimboo. Additionally, by signing into Kimboo, you agree to receive commercial notices to your registered e-mail address in Kimboo as well. However, to avoid receiving these email messages, you can provide feedback to Data Birikim, Teknoloji ve Yatırım A.Ş.

Collaborating with Turkcell A.S. and subsidiaries: Data Birikim, Teknoloji ve Yatırım A.Ş., may share various personal data with Turkcell İletişim Hizmetleri A.Ş. (NYSE – TKC) and/or any of Turkcell’s subsidiaries in accord with relevant rules and regulations.

6) Duration of keeping your personal information:

The information you keep in Kimboo is kept in records as long as you want to take advantage of the service provided. If you want to quit Kimboo, you can delete your account from the “Settings” page in the application. In this case, your personal data are kept passive on servers of Data Birikim, Teknoloji ve Yatırım A.Ş. in case of any legal disputes in the future.

If you freeze your Facebook account and remove the authority you give to Kimboo within Facebook, you will not be able to log in to the game and benefit from Kimboo services. All previous information is kept in the system passively. If you can reactivate your Facebook account and re-register with Kimboo with the same Facebook account, you can go on playing from where you left. However, if you register with a new Facebook profile, Kimboo treats you as a new player.

7) Limitations of Liability
In case of a request from competent authorities during a criminal investigation or prosecution in accordance with the applicable legislation in force, we must disclose personal information of the related person.

Kimboo/Data Birikim, Teknoloji ve Yatırım A.Ş. is not responsible for:

a) The privacy policies of the third party websites and/or institutional sites those might be accessed via the links given by the website,
b) Damages arising from the occurrence of personal data due to breakdowns, maintenance and interruptions that may arise in the country’s technological infrastructure services, corporate mergers or acquisitions, legally compelling reasons, judicial and administrative interventions, and cyber-attacks,
c) Breaches of privacy and possible harm which may occur in the event that your device has been compromised or your private information is illegally entered (identity theft, hacking etc.), as you entered into application through your Facebook account or Mobile Connect, damages because of changes on Facebook or Mobile Connect privacy statements, or your or 3rd parties own negligence or faults,

The protection of your personal data is of course not only entrusted to Kimboo, but as a user you must be careful when you share information with other users and using the application.

8) Privacy Statement updates:

We may update this “Privacy Statement”, which is part of the User Agreement, as necessary and as the legal regulations change. So please check here periodically, if you have any questions or problems, please contact us.


Data Birikim, Teknoloji ve Yatırım A.Ş.
Evliya Çelebi Mahallesi
Meşrutiyet Caddesi No:92 Daire:1
Beyoglu / 34430
Istanbul / Turkey
[email protected]

Privacy Statement – – Version 1.3 – December 1st, 2017