Privacy Policy - CozmoGame

This Privacy Policy describes how CozmoGame, operated by Cem Demir (sole proprietor, Yenigün Mah. 599. Sk. No:27/6, Bağcılar, Istanbul, Türkiye), collects, uses, and protects your personal data. For privacy questions contact [email protected].

1. Data We Collect

Account data: email address, username, password (hashed), preferred language, country
Game data: planets, resources, fleets, chat messages, notifications, alliance membership, combat history
Purchase data: purchase history, product identifiers, amounts paid, Paddle transaction IDs
Technical data: IP address, browser type, device information, login timestamps, last activity time
Communication: support ticket contents and correspondence with us

We do not collect, see, or store payment card details. All payment data is handled directly by Paddle.

2. Why We Process Your Data and Legal Basis

To provide the Service (contract — GDPR Art. 6(1)(b), KVKK Art. 5(2)(c)): account creation, gameplay, matchmaking, in-game communication
To process payments (contract): granting purchased Dark Matter to your account, issuing receipts
To prevent fraud and abuse (legitimate interest — GDPR Art. 6(1)(f)): IP logging, anti-cheat, banning abusive accounts
To comply with legal obligations (Art. 6(1)(c)): keeping tax records, responding to lawful authority requests
To send service emails (legitimate interest): password resets, security alerts, purchase confirmations
To send news or updates (consent — Art. 6(1)(a)): optional, opt-in only, withdrawable at any time via the unsubscribe link

3. Sharing with Third Parties

We share limited data only with:

Paddle.com Market Limited — payment processing (Merchant of Record)
Our hosting provider — infrastructure for operating the Service
Our email delivery provider — sending transactional emails
Law enforcement or regulators — when legally required

We do not sell your personal data. We do not share data for advertising purposes.

4. Data Retention

Active accounts: as long as the account exists
Inactive accounts: may be deleted after 12+ months of no activity
Purchase records: 7 years (Turkish tax law requirement, Law No. 213)
Chat logs: 90 days unless flagged for moderation review
Support tickets: 3 years after resolution
Backups: up to 30 days

5. Your Rights (GDPR & KVKK)

You have the right to:

Access the personal data we hold about you
Rectify inaccurate or incomplete data
Erase your data ("right to be forgotten")
Restrict processing of your data
Data portability (receive your data in a machine-readable format)
Object to processing based on legitimate interest
Withdraw consent for anything you previously consented to
Lodge a complaint with your local data protection authority — in Türkiye, the Personal Data Protection Authority (kvkk.gov.tr); in the EU, your national DPA

To exercise any of these rights, email [email protected]. We will respond within 30 days.

6. International Data Transfers

Our servers are hosted in the European Union. If any data is transferred to a country outside the EU/EEA (for example, via our payment processor), we rely on Standard Contractual Clauses or equivalent safeguards approved by the European Commission.

7. Cookies

We use session cookies only, for authentication and CSRF protection. We do not use third-party tracking cookies, advertising cookies, or analytics cookies.

8. Children

The Service is not intended for users under 16. We do not knowingly collect personal data from children. If you are a parent or guardian and believe we have collected data from your child, contact [email protected] and we will delete it.

9. Security

We use industry-standard security measures including TLS encryption for data in transit, hashed passwords, restricted access controls, and regular security reviews. No system is perfectly secure, however — you should use a strong unique password and notify us immediately of any suspected unauthorized access.

10. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" date shows when the latest version took effect. Significant changes will be notified by email or in-game announcement.

11. Contact

Privacy questions or data requests: [email protected].