Privacy Policy

Last Updated: July 10, 2025

This privacy policy (the “Policy”) explains how your personal information is collected and used when you visit this App owned by Fomo Oyun Yazılım ve Pazarlama Anonim Şirketi. We may change this Policy from time to time. If we make any changes, we will post the updated Policy on this page.

The laws in some of the jurisdictions in which we operate, including, for example, California, the European Union and the United Kingdom, and Turkey, grant additional rights, and require specific disclosures, to their residents.

For the purposes of this Policy, “personal information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly, with a particular consumer or household.

PERSONAL INFORMATION WE COLLECT

Personal Information Collected. We collect the following types of personal information:

· Identifiers, including, for example, Name-Surname, Date of Birth, Identity Number Phone Number, E-Mail Address, Address, Social Media Username (if shared), Country and City.

· Payment Information, including, for example, Order Amount, Date of Order, Information on the Purchased Product, Request Details, Information on the Benefitted Discount (if any).

· Finance Information: Bank Account Information and Invoice Information.

· Internet Activity: IP Address and Log Records.

· Inferences: Usage Habits and Behavioral Analysis.

· Other Communications: Request and Support Details and Information on the Current Level in the Game.

To the extent that any of the personal information we collect is defined as sensitive under applicable law, such as geolocation data, we only use the sensitive personal information for the purposes explicitly described in this Policy and in accordance with applicable law. We will obtain your consent before processing sensitive information.

HOW WE USE PERSONAL INFORMATION

We use personal information for the purposes set forth below and as otherwise described in this Policy:

To Offer and Deliver Goods and Services to You. We may use personal information to offer and deliver goods and services to you. For example, we may use personal information to process payments, invoice transactions and provide in-game sales.

To Provide the App. We may use personal information to operate our App. For example, we use personal information to:

· improve and personalize your experience on or with the App; and

· verify your identity for authentication and security purposes

For Maintenance and Support. We may use personal information to evaluate support requests, resolve order-related problems, and ensure secure access.

For Customer Service and Communication. We may use personal information to respond to inquiries or resolve issues.

For Direct Marketing. We may send you FOMO games-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us. We use personal information to personalize marketing by analyzing game behaviors and evaluating and optimizing the success of advertising and marketing campaigns, execution of in-game advertising and promotion campaigns. You may opt-out of our marketing communications as described in the “YOUR RIGHTS AND CHOICES YOU CAN MAKE” section below. If applicable law requires consent prior to sending you marketing communications, we will not send you direct marketing without your prior consent.

To Display Advertisements. We partner with advertising partners and other third parties that collect information to help us advertise our App and for purposes of displaying advertisements on the App and delivering more relevant advertising to you. These advertisements are delivered by our advertising partners and may be targeted based on your use of the App or your activity elsewhere online.

To Comply with Laws and Regulations. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For Sales or Transfers of Control. We may also transfer or assign personal information as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose personal information that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the App and our business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the App; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With Your Consent. We will disclose your personal information in accordance with your prior direction, or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

HOW WE SHARE PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy or at the point of collection, we may share your personal information with the following entities or persons:

Service Providers and Vendors. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers and vendors that help us process payments and provide billing services, deliver goods or services you purchase from us, perform App hosting, maintenance services, database management, analytics, fraud protection, marketing, finances, and other purposes.

Business and Advertising Partners. We may share your personal information with our partners and sponsors for services and engaging in joint marketing or promotional activities, to send you information about the game, products and services, including promotions, you may like.

Law Enforcement. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (for example, a court or a government agency).

Authorities and Others for Compliance, Fraud Protection, and Safety. We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”

Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

RETENTION OF PERSONAL INFORMATION

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, any applicable ongoing legal claims, and the applicable contractual obligations or legal requirements. We do not retain information specific to us beyond any limits imposed by law.

SECURITY OF PERSONAL INFORMATION

We have implemented reasonable security features designed to protect personal information. While we try our best to safeguard personal information once we receive it, please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. When we engage service providers or vendors to process personal information, we take steps to ensure that they do so securely, in accordance with our instructions and under appropriate contract terms that we have in place with them.

CHILDREN’S PRIVACY

Our App is not directed to people who are under 18 years old. We do not knowingly collect personal information from individuals under 18 years of age. Individuals under the age of 18 should not attempt to provide us with any personal information. If you think we have received personal information from individuals under the age of 18, please contact us immediately. We do not knowingly “sell” or “share” the personal information of individuals under 18 years of age.

LINKS TO APPS AND APPS

We may provide links to other Apps and apps not operated or owned by us. Please be advised that the practices described in this Policy do not apply to information gathered through these third-party Apps and apps. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other Apps and apps. We encourage you to read the privacy policies of the other Apps and online services you use.

YOUR RIGHTS AND THE CHOICES YOU CAN MAKE

You have the following rights regarding your personal information under applicable U.S privacy law, Turkish privacy law (Article 11 of the DPL) and the General Data Protection Regulation (GDPR) :

The Right to Know/Access. You can request the following information about how we have collected and used your personal information:

the categories of personal information we collected;
the categories of sources from which we collected personal information;
the business or commercial purpose for collecting, selling, or sharing (as applicable) that personal information;
the categories of third parties with whom we disclose personal information; and
a copy of the personal information that we collected about you in a portable, readily usable and machine-readable format.

The Right to Correct/Rectify. You can request that we correct inaccurate personal information that we maintain about you.
The Right to Delete/Erase. You can request that we delete the personal information we collected from you.
Right to Opt-Out of Targeted Advertising. You have the right to opt-out of “targeted advertising” under applicable state law.
The Right to Opt-Out of Sales/Sharing. If we “sell” or “share” your personal information, you can opt-out. While we do not “sell” your personal information to third parties in exchange for money, we may “sell” your personal information, as described by the CCPA, for other valuable consideration. We also “share” your personal information, as described by the CCPA, for purposes of cross context behavioral advertising.
Right to Opt-Out of Profiling. You may request to opt-out of profiling in furtherance of a decision that produces a legal or similar legal effect.
The Right to Data Portability. You have the right to obtain your personal data in a portable, and to the extent technically feasible, readily useable format, which you can use to transmit your data to another entity.
The Right to Withdraw Consent. Where we process your personal information based on consent (including direct marketing consents), you have the right to withdraw consent at any time. In case of a withdrawal, we may continue to use your personal information as permitted or required by law.
Right to Restrict Processing. In some situations, you may have the right to request that we do not use the personal information you have provided (for example, if you believe it to be inaccurate).
Right to Opt-out of Automated Decision Making. You may request opt-out of automated decision making, including profiling, or to learn more about algorithmic logic involved and to know about the likely outcome in our decision-making processes.
The Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
The Right to Appeal. You may appeal our decision to your request regarding your personal information. To do so, please contact us in any of the ways list below. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

If you direct us not to sell/share your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes. We will also honor opt-out preferences transmitted through Universal Opt-Out Mechanisms (UOOMs) as a valid means to opt-out of targeted advertising. We reserve the right to confirm your identity to process your requests. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it.

You may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay and may continue to update you regarding the progress of our response.

We note, however, that these rights, and rights listed elsewhere in this Privacy Policy may not be absolute, and in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

HOW TO EXERCISE THESE RIGHTS

You may exercise your rights in any of the following ways.

(i) Submitting a written application to “Esentepe Mh. Kore Şehitleri Cd. No:4 Propa Plaza K:8 Şişli İstanbul”,

(ii) Sending an email to hello@fomo.gs " from the email address that you previously used to communicate with us, and which is registered in our system

(iii) Sending a registered email to Company’s registered email address, fomooyun@hs01.kep.tr

ADDITIONAL CHOICES YOU CAN MAKE

Email Communications. If you provide us with your email address in order to receive communications, you can opt-out marketing emails at any time by following the instructions at the bottom of our emails. Please note that certain emails may be necessary for the operation of our App, such as to deliver notifications directly to you through the App. You will continue to receive these emails, even if you unsubscribe from our marketing communications.

Advertising Choices. If you wish to minimize the amount of interest-based advertising you receive (as described in the “To Display Advertisements”), you may block third-party cookies in your browser settings, use browser plug-ins/extensions, and use your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked Apps: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Some users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the App Choices mobile app, available here, and selecting the user’s choices. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.

Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online, but they may be less relevant to you.

Cross Border Transfers

We are a global business. As such, information we collect may be transferred to, stored, and processed in any country or territory where one or more of our business partners or service providers are based or have facilities which may be different to your home country. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws that country. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal information that we transfer in line with this Policy by requiring that our business partners or service providers adhere to this Policy and the applicable privacy regulations in your home country.

Your personal data mentioned above are shared with the following recipient groups for the following purposes:

With third party outsourced suppliers located abroad who provide infrastructure services for purposes of receiving services related to information technology infrastructure, as well as email delivery and storage services;
With our third-party business partner located abroad acting as a payment method intermediary for the provision of payment method services.

ADDITIONAL NOTICE TO RESIDENTS OF THE UNITED KINGDOM AND THE EUROPEAN ECONOMIC AREA

The company that collects the personal information of a resident of the United Kingdom or the European Economic Area (collectively, “UK/EEA Residents”) is the data controller for that personal information.

The legal grounds upon which we rely to use or process the personal data of UK/EEA Residents are:

Data Categories	Processing Purposes	Legal Basis
· Contact Information · Customer Transaction Information	Realizing in-game sales, provision of support for users’ refund requests or transaction histories	Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract as per Art. 5(2)(c) of the DPL Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject as per Art. 5(2)(f) of the DPL
· Contact Information · Customer Transaction Information	Provision of personalized offers based on in-game purchases	Explicit consent of the data subjects as per Art. 5(1) of the DPL
· Identity Information · Contact Information · Customer Transaction Information	Evaluation of support requests, evaluation and resolution of order-related problems	Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract as per Art. 5(2)(c) of the DPL
· Identity Information · Contact Information · Customer Transaction Information · Finance	Realization of payment and invoicing transactions for purchased products and services	Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract as per Art. 5(2)(c) of the DPL It is necessary for compliance with a legal obligation to which the data controller is subject as per Art. 5(2)(ç) of the DPL It is expressly provided for by the laws as per Art. 5(2)(a) of the DPL
	Execution of processes related to the sales contract	Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract as per Art. 5(2)(c) of the DPL
· Contact Information · Transaction Security	Ensuring secure access to services,	Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject as per Art. 5(2)(f) of the DPL
· Contact Information · Transaction Security
· Transaction Security	Creating technical support and error reports, and providing technical support to users in this context	Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject as per Art. 5(2)(f) of the DPL Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract as per Art. 5(2)(c) of the DPL
· Contact Information · Customer Transaction Information · Transaction Security · Marketing	Identification of potential security vulnerabilities, improving user experience	Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject as per Art. 5(2)(f) of the DPL
	Personalizing marketing strategies by analyzing in-game behaviors, optimizing marketing strategies	Explicit consent of the data subjects as per Art. 5(1) of the DPL
· Contact Information · Customer Transaction Information · Transaction Security	Evaluating and optimizing the success of advertising and marketing campaigns, execution of in-game advertising and promotion campaigns

As a UK/EEA Resident, you have the right to challenge our legitimate interest in using or processing your personal data. However, we may be entitled to continue processing your personal information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes. To exercise your rights, please see the section above titled “HOW TO EXERCISE YOUR RIGHTS”.

The personal data we collect from you may be transferred to and stored by our organization or our affiliates, or IT vendors and other service providers who operate on our behalf in the United States. In certain cases, there may not be an adequacy decision by the European Commission and/or United Kingdom authorities in connection with potentially applicable transfers. Adequacy of data protection is instead ensured by Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation, or any equivalent clauses approved by the authorities in the United Kingdom including any additional safeguards as required by EU / UK data protection laws that we have in place with that third party.

HOW TO CONTACT US

You may contact us at hello@fomo.gs or +90 546 521 9502.

If you are a UK/EEA Resident, you may contact our Data Protection Officer or GDPR Representative with any issues or questions you have regarding our processing of your personal data using the contact details below.

EMAIL: hello@fomo.gs

POSTAL ADDRESS: Esentepe Mh. Kore Şehitleri Cd. No:4 Propa Plaza K:8 Şişli İstanbul Türkiye

GDPR REPRESENTATIVE CONTACT DETAILS

EMAIL: hello@fomo.gs

POSTAL ADDRESS: Esentepe Mh. Kore Şehitleri Cd. No:4 Propa Plaza K:8 Şişli İstanbul Türkiye

ADDITIONAL NOTICE TO RESIDENTS OF THE UNITED STATES

This Section provides additional information required by the laws of certain states in the United States, including but not limited to California and Colorado. Our collection of personal information has not changed during the last 12 months.

As explained in this Privacy Notice, we may “sell” or “share” any personal information as those terms are defined under California privacy law. The following chart provides information about the categories of personal information we collect, how we collect it, why we collect it, with whom we share it, and how long we retain it.

Category	What we collect	How we collect it	Why we collect it	With whom we share it	Personal Information “Sold, “Shared” of Used for “Targeted Advertising”	How long we retain it
Identifiers	Name-Surname, Date of Birth, Identity Number Phone Number, E-Mail Address, Address, Social Media Username (if shared), Country and City. For more information, please see the Personal Information We Collect section of the Privacy Policy.	Collected online when you directly provide it to us or through your use of our App.	We collect this information for the purposes listed in the Why We Collect Personal Information section of the Privacy Policy.	Shared with our partners, sponsors, vendors, and service providers as described in the Sharing Personal Information section above.	We may use personal information for Targeted advertising purposes as described in the Why We Collect Personal Information Section of the Privacy Policy.	We may retain this information for as long as necessary for the purposes for which the information was first collected and any other business purpose, including, but not limited to, legal, archival, accounting, and/or audit purposes.
Protected classification characteristics under California or federal law	N/A	N/A	N/A	N/A	N/A	N/A
Commercial information	Including, for example, Order Amount, Date of Order, Information on the Purchased Product, Request Details, Information on the Current Level in the Game, Information on the Benefitted Discount (if any), Bank Account and Invoice Information. For more information, please see the Personal Information We Collect section of the Privacy Policy.	Collected online when you directly provide it to us or through your use of our App	We collect this information for the purposes listed in the Why We Collect Personal Information section of the Privacy Policy.	Shared with our partners, sponsors, vendors, and service providers as described in the Sharing Personal Information section above	We may use personal information for Targeted advertising purposes as described in the Why We Collect Personal Information Section of the Privacy Policy.	We may retain this information for as long as necessary for the purposes for which the information was first collected and any other business purpose, including, but not limited to, legal, archival, accounting, and/or audit purposes.
Biometric information	N/A	N/A	N/A	N/A	N/A	N/A
Internet or other similar network activity	Information on a customer’s interaction with our App or advertisements. For more information, please see the Personal Information We Collect section of the Privacy Policy.	Collected online when you directly provide it to us or through your use of our App	We collect this information for the purposes listed in the Why We Collect Personal Information section of the Privacy Policy.	Shared with our partners, sponsors, vendors, and service providers as described in the Sharing Personal Information section above	We may use personal information for Targeted advertising purposes as described in the Why We Collect Personal Information Section of the Privacy Policy.	We may retain this information for as long as necessary for the purposes for which the information was first collected and any other business purpose, including, but not limited to, legal, archival, accounting, and/or audit purposes.
Geolocation data	IP address. For more information, please see the Personal Information We Collect section of the Privacy Policy.	Collected online when you directly provide it to us or through your use of our App	We collect this information for the purposes listed in the Why We Collect Personal Information section of the Privacy Policy.	Shared with our partners, sponsors, vendors, and service providers as described in the Sharing Personal Information section above	N/A	We may retain this information for as long as necessary for the purposes for which the information was first collected and any other business purpose, including, but not limited to, legal, archival, accounting, and/or audit purposes.
Sensory data (Audio, video, etc.)	N/A	N/A	N/A	N/A	N/A	N/A
Professional or employment-related information	N/A	N/A	N/A	N/A	N/A	N/A
Non-public education information	N/A	N/A	N/A	N/A	N/A	N/A
Inferences drawn from other personal information	Information generated from your use of our product or services. For more information, please see the Personal Information We Collect section of the Privacy Policy.	Collected online when you directly provide it to us or through your use of our App	We collect this information for the purposes listed in the Why We Collect Personal Information section of the Privacy Policy.	Shared with our partners, sponsors, vendors, and service providers as described in the Sharing Personal Information section above	We may use personal information for Targeted advertising purposes as described in the Why We Collect Personal Information Section of the Privacy Policy.	We may retain this information for as long as necessary for the purposes for which the information was first collected and any other business purpose, including, but not limited to, legal, archival, accounting, and/or audit purposes.
Sensitive personal information	N/A	N/A	N/A	N/A	N/A	N/A