Customer Privacy Notice

Who are we?

With this Privacy Notice, we aim to inform you as Fomo Oyun Yazılım ve Pazarlama Anonim Şirketi (“Fomo”, "Company", "We") whose address is “Esentepe Mh. Kore Şehitleri Cd. No:4 Propa Plaza K:8 Şişli Istanbul/Türkiye”, as the data controller, about the processing of your personal data within the scope of the EU General Data Protection Regulation (“EU GDPR”).

This privacy notice tells you what to expect us to do with your personal data while you purchase or play mobile games developed by Fomo, contact our customer service or technical support or use other services that we offer.

Contact details

If you have any issues, queries or complaints regarding the processing of your personal data, you can contact by email to hello@fomo.gs.

What information we collect

We collect or use the following personal data:

· Identity Information; name-surname, date of birth, identity number

· Contact Information; phone number, email address, address, social media username (if shared), country and city

· Customer Transaction Information; order amount, date of order, information on the purchased product, information on the current level in the game, requests and complaints, information on the benefitted discount (if any)

· Finance; bank account information, invoice information

· Transaction Security; IP address, log records

· Marketing; usage habits and behaviour analysis

Purposes and legal bases of the processing

Data Categories	Processing Purposes	Legal Bases
· Contact Information · Customer Transaction Information	Realizing in-game sales, provision of support for users' refund requests or transaction histories	Processing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR Processing is necessary for the purposes of the legitimate interest pursued by the controller as per Art. 6(1)(f) of the GDPR.
	Provision of personalized offers based on in-game purchases	Explicit consent of the data subjects as per Art. 6(1)(a) of the GDPR
· Identity Information · Contact Information · Customer Transaction Information	Evaluation of support requests, evaluation and resolution of order-related problems	Processing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR
· Identity Information · Contact Information · Customer Transaction Information · Finance	Realization of payment and invoicing transactions for purchased products and services	Processing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR Processing is necessary for the compliance with a legal obligation to which the controller is subject as per Art. 6(1)(c) of the GDPR
	Execution of processes related to the sales contract	Processing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR
· Contact Information · Transaction Security	Ensuring secure access to services	Processing is necessary for the purposes of the legitimate interest pursued by the controller as per Art. 6(1)(f) of the GDPR
· Transaction Security	Creating technical support and error reports and providing technical support to users in this context	Processing is necessary for the purposes of the legitimate interest pursued by the controller as per Art. 6(1)(f) of the GDPR Processing is necessary for the performance of a contract to which the data subject is party as per Art. 6(1)(b) of the GDPR
· Contact Information · Customer Transaction Information · Transaction Security · Marketing	Identification of potential security vulnerabilities, improving user experience	Processing is necessary for the purposes of the legitimate interest pursued by the controller as per Art. 6(1)(f) of the GDPR
	Personalizing marketing strategies by analysing in-game behaviors, optimizing marketing strategies,	Explicit consent of the data subjects as per Art. 6(1)(a) of the GDPR Explicit consent of the data subjects as per Art. 6(1)(a) of the GDPR
· Contact Information · Transaction Security · Customer Transaction Information	Evaluating and optimizing the success of advertising and marketing campaigns, execution of in-game advertising and promotion campaigns

Who we share your personal data with

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

· Third party outsourced suppliers in the United States of America, Ireland or the Netherlands from whom we receive infrastructure services for purposes of receiving services related to information technology infrastructure and server hosting services,

· Third party business partners in Ireland from whom we receive infrastructure services for payment methods,

· Third party outsourced supplier in Turkey from whom we receive accounting and accounting software services for the purposes of issuing and archiving invoices.

When we will transfer personal data outside of the European Union, we comply with the GDPR and implement the transfer mechanisms such as the appropriate safeguards. For further information or to obtain a copy of the appropriate safeguard for any of the transfers above, please contact us using the contact information above.

How we collect your personal data

The types of personal data we may collect may vary upon the service/product you get or relationship between us. Please find below which type of personal data we collect and the ways of collection.

We collect your personal data directly from you when you register and create your player account, communicate with us in relation to a refund or support requests and use our products and services.  In such case, Fomo collects name-surname, date of birth, identity number, social media username (if shared), phone number, email address, address, order amount, date of order, information on the purchased product, information on the current level in the game, requests and complaints, country and city, IP address, log records, information on the benefitted discount (if any), usage habits and behaviour analysis.

Fomo may also collect your personal data indirectly from the following sources:

· Our business partners (such as AppStore), when you make in-game purchases that are processed by that business partner application and subject to that business partner’s application’s terms of service and privacy policy. In such case, Fomo may collect address, email address, order amount, date of order and information on the product purchased.

· Third party applications (such as Meta, TikTok and Google Ads) when you interact with relevant third-party applications via campaigns realized. In such case, Fomo may collect country information, IP address, log records and information on the benefitted discount (if any).

How long we keep your personal data

We will not keep your personal data for any longer than is necessary for the purposes for which we collect it and legal requirements to which we are subject.

Automated decision making

We use automated decision making to direct users to the right ads and promotions based on their past behaviour, interactions or demographics if we obtain customers’ consent for such processes. Via automated decision making, users only receive ads and promotional offers that match their interests and past interactions. Types of personal data we use for automated decision making consist of country, order amount, date of order, information on the purchased product, IP address, log records, information on the benefitted discount (if any), usage habits and behaviour analysis.

Profiling

We use profiling to provide you with a personalized gaming experience, and to improve our service quality.   Via profiling, users are targeted for in-game advertising and promotional campaigns. Types of personal data we use for automated decision making consist of address, email address, order amount, date of order, information on the purchased product, country and city, IP address, log records, information on the benefitted discount (if any), usage habits and behaviour analysis.

Your rights

You have the following rights under the GDPR. Which lawful basis we rely on may affect your data protection rights which are in brief set out below.

· Right of access - You have the right to ask us for copies of your personal data. You can request other information such as details about where we get personal data from and who we share personal data with.

· Right to rectify - You have the right to ask us to correct or delete personal data you think is inaccurate or incomplete.

· Right to erasure - You have the right to ask us to delete your personal data.

· Right to object - You have the right to object to the processing of your personal data.

· Right to restrict processing - You have the right to ask us to limit how we can use your personal data.

· Right to data portability - You have the right to ask that we transfer the personal data you gave us to another organization, or to you.

· Right to withdraw your consent - When we use consent as our lawful basis you have the right to withdraw your consent at any time.

· Right to not to be subject to a decision based solely on automated processing - You have right to not to be subject to a decision based on automated processing which produces legal effects/significantly affects you.

· Right to launch a complaint - You have right to launch a complaint with your local data protection authority.

Last Updated: April 10, 2025

Explicit Consent Text for Marketing Activities

☐ I agree to the processing and transfer of my Contact, Customer Transaction, Transaction Security and Marketing information by Fomo Oyun Yazılım ve Pazarlama Anonim Şirketi for the purposes of providing personalized offers, personalization of and optimizing marketing strategies via analysis of in-game behaviors, evaluating the success of advertising campaigns,  receiving in-game advertising and promotion campaigns that match my interests and past interactions for a personalized gaming experience.