Parental Consent Text

Children’s Privacy Policy
Information for Children

1. What is “Personal Data” and how do we collect it?
Personal data means any kind of information that helps us know who you are.
We can collect your personal data in different ways:

Directly from you: We may ask for your name.
From the phone or other device, you use: We can get some numbers and codes
through small files called cookies (these are not the kind you eat!).
From other people: For example, your parent or a friend might share your name with
us.

If you ever need help before sharing anything online, please talk to an adult or your parent
first.

2. The Information We Collect and How We Use It
To provide our services, we sometimes need certain information about you.
Depending on which product or service you use, we may collect different kinds of
information.

2.1 Online Products for Children (Websites and Apps)
a. Streaming services
To give you a safe and personalized streaming experience, you need to create your own
profile.
When you watch a movie or a show, we may collect the following information:

Your age or birth year, so we can show content that is right for your age.
Your country or city, so we can show content available in your area and offer the
right language options.
What you watch, how long you watch, and how you use the service, so we can
improve your viewing experience; always in a way that follows the law.

3. We Share Your Information in Some Situations
To give you the product you use, to provide a service you asked for, or when the law
requires it, we may need to share your personal data with others.

Sometimes your family may also need access to your information — for example, to
understand how you use the product or to help you when needed.

In these cases, we only share the information that is necessary, and only with trusted
companies or partners we work with.

We never sell your personal data to any company.

4. What Can You Do?
If you have questions about how your personal data is used — or if your parent or guardian
wants to learn more — you can read the full Children’s Privacy Notice or contact us anytime
at cocukkvkk@gain.com.tr

Remember this: You never have to share your personal data if you don’t want to.
You and your parent/guardian can:

Ask what information we have about you,
Ask us to stop collecting your data,
Or ask us to delete the data we already have.

Children’s Privacy Policy

Last updated: November 20, 2025

Hi there, welcome!This text explains how we, GAİN MEDYA A.Ş. (“GAİN”, “we”, “us”, or “our”), collect and use your personal information when you use our Services.

When we say “Services”, we mean our digital services such as our websites, mobile apps, games, subscription services, and our pages/channels on third-party social networks, as well as offline activities and events.

In this Privacy Policy, the term “Data Controller” means the company that decides why and how your information is processed. The Data Controller may change depending on which Service you use; usually it is the company that actually provides that Service. In some cases, there may be more than one Data Controller. You can check the detailed list in the “List of Data Controllers.” If you still have questions, feel free to contact us using the information below.

If you have trouble understanding anything in this document, you should ask a parent or guardian for help. In this text, we call this person your “guardian.”

This policy applies to our Services designed for children; but even if you are over the age of majority, it also covers how we process your information when you use our Services.

If you are the guardian of a child, this policy explains what information we collect about your child and how we use it.

In some countries, we need your guardian’s explicit consent before we can process your information in the ways described in this document. When this is required by law, we will ask for your guardian’s permission before you use our Services. Your guardian is the person who gives consent for us to process your information according to this Privacy Policy.

What Information Do We Collect from You?

1. Information About You

a) Contact and account information

When you use some of our Services, we may ask for certain information and for these, we may need your guardian’s permission. For example:

Your first and last name
The country/region you live in
Your email address
Your username
Your phone number
Your home address
Numbers that identify your account or device
Your photo or video
Your voice recordings
Your opinions about our Services or our partners
Your participation in our contests

If you use a Service that has a virtual world, game features, or social features, you may need to choose a screen name and create an account, possibly with a password.

For some Services, we collect your email address only to create your account. After that, we store it only in a “hashed” (scrambled) format, so it does not directly show who you are. This hashed address helps us, for example, when you forget your password and need help accessing your account.

b) Purchases and payment information

Before making any purchase, you must get your guardian’s permission.
If you buy an in-service product, virtual currency, or a membership, the real payment is made by your guardian.

During these transactions, we may process limited information such as:

The payment made
The item purchased
Subscription or membership details

c) Information about how you use the Service

We may collect data about how you use our Services such as your movements in a game, the content you watch, the pages you click on, the comments you make, and the actions you take inside the app.

d) Social media

If you like, comment on, or share a post on our social media accounts, we may receive information about these interactions.

Depending on what the social media platform allows, publicly visible information on your profile such as your photo, birth date may also be shared with us. For this, we may also need your guardian’s permission.

e) Device information

When you visit our Services, we may process technical data collected through your device such as the type of device you use (computer, game console, phone), your browser type, your IP address, and information collected through cookies.
You can check the Cookies section for more details.

f) Notifications

Some of our apps can show alerts inside the app.
If you want, we can also send push notifications to your device’s home screen.
For this, we may need your guardian’s permission.
You can turn off push notifications anytime in your device settings you may ask your guardian for help while doing this.

h) If you don’t want to share information

Some information is optional. But if you choose not to share information that we consider
necessary, certain Services or features may not be available to you.

i) When you contact us

If you email us for support, fill out a form, or reach out in another way, we receive information such as your name, email address, and the content of your message.
After we solve your problem, we delete this information within our storage periods.

2. Information About Your Guardian

In some situations, we also need to collect information about your guardian. For example:

To inform them about your interest in our Services
To ask for their permission before activating certain features for you
To verify their identity when they make a rights request
To explain how they can turn on or manage certain features for you

For these purposes, we may ask your guardian for:

Their name and surname
Their address
Their email address
Their phone number

How Do We Use Your Information?

We process your information for the purposes described in this Privacy Policy or explained at the time we collect it.

Not every purpose applies to every Service, what information we use and why depends on the Service you use and the permissions you or your guardian give.

1. To provide the Services

To make sure the Service works properly and all features run smoothly
To give technical support and keep the Service safe
To create an account for you
To register you for certain Services
To let you upload and share content you create, or your videos/photos

Legal basis:

Forming or performing a contract with you or your guardian
Our legitimate interests where necessary (running our business, providing the Service, receiving payments, etc.)
Your or your guardian’s consent, when required

2. To improve and personalize our Services

To analyse which content and features are used more
To tailor the Services to your interests

Legal basis:

Legitimate interests (improving Services, understanding user trends)
Consent in some situations

3. Marketing and advertising

To tell you about games, content, campaigns, and other Services
To introduce products or services offered by our partners

We usually need your or your guardian’s consent for this.
You or your guardian can limit or stop marketing anytime by emailing us at (insert email) or
by using the “unsubscribe/opt-out” link in our messages.

4. Support and communication

To respond to your questions, complaints, or requests
To monitor and improve customer support

Legal basis: Contract, legal obligations, or legitimate interests.

5. Preventing crime and misuse

To detect and prevent illegal or harmful activities such as fraud, piracy, or harassment
To protect the safety of other users and our systems

Legal basis: Legal obligations and legitimate interests; sharing information with authorities
when required.

6. Compliance with legal obligations

To keep records as required by tax, accounting, or local data protection laws
To identify your country/region so we can apply the correct legal rules

7. Statistics and analysis (anonymization/aggregation)

We may combine your information with other data in a way that does not identify you, to
create statistics.
These statistics are used only to improve our Services and products.

When Do We Involve Your Guardian?

This depends on the rules of the country you live in.

If your guardian’s permission is required to collect or use certain types of information, we involve them.
If there is an important security issue with your account (for example, suspected unauthorized access), we may contact your guardian.
When you want to use your data protection rights (like asking for your data to be deleted or accessed), depending on your age, we may ask your guardian to help.

When you become an adult, in places where the law requires it, consent can be taken directly from you instead of your guardian.

Who Do We Share Your Information With?

1. Sharing within our group

We may share your information with other GAİN group companies our “family” for the purposes explained in this policy.
You can always find the current list on our subsidiaries page.

2. Sharing outside our group
• Service providers (our helpers):
These are companies that help us run payments, manage technical systems, deliver rewards, or provide customer support.
We make them sign agreements to protect your information.
• Business partners / sponsors:
When we run joint content or campaigns, we may share information when needed usually after giving notice and getting your guardian’s permission.
• External websites:
Our Services may contain links to websites owned by other companies.
Those websites follow their own privacy policies, so you should check their terms separately.
• Social media platforms:
If social media buttons or plugins are used, the platform may receive information about your activity in our Services.
You should check that platform’s privacy policy for details.
• Advertising and measurement companies:
We may share limited information with companies that help us personalize content or measure performance.
For children, such uses are very restricted in many countries and usually require consent.
• Legal requirements:
We may share your information if required by a court order, prosecutor, police, or another authority — but only as much as the law requires.
• Company transfers or restructuring:
If our business (or part of it) is sold, merged, or reorganized, we may transfer your information to the company taking over the Services.
• If you or your guardian agrees:
If you or your guardian gives clear permission, we may share data within that permission.

Do We Transfer Your Information to Other Countries?
GAİN’s offices and most service providers are in Turkey.
However, your information may be transferred outside your country.
Some countries may not have the same level of data protection as yours — but we use extra technical and contractual safeguards to protect your information.
You can email us at (contact email) or check the country list on our website for more details.

How Long Do We Keep Your Information?
We keep your information only for as long as needed for the purposes explained in this Privacy Policy.

Basic account information may be kept while your account is active.
Legal obligations (like accounting, dispute resolution, security logs) may require
longer retention.

When information is no longer needed, we securely destroy paper records and permanently
delete or anonymize electronic records.

What Are Your Rights?
Depending on the laws of your country, you or your guardian may have some of the following rights:

Right to know: Learn whether your data is being processed and get basic information about it
Access and correction: See the information we hold about you and correct it if it is wrong or incomplete
Deletion (“right to be forgotten”): Ask us to delete your data if there is no legal reason to keep it
Limit marketing and sharing: Withdraw consent for marketing or sharing with third parties
Data portability: Get your data in a structured digital format or ask us to send it to another data controller when technically possible
Objection: Object to data processing done based on legitimate interest, giving your personal reasons
Withdraw consent: Take back your consent at any time for processes based on consent
Complain and seek compensation: File a complaint with your country’s data protection authority and seek compensation if your rights were violated

To use these rights, you can write to us at (contact email).
Each request is reviewed according to the relevant data protection law.
In some cases, we may not be able to fully comply because of legal exceptions (for example, records we must keep).

Cookies
Cookies are small data files placed on your device when you visit a website.
We may also use similar technologies such as pixels or SDKs.

Cookies help us:

Remember what you do on the site
Understand your preferences and interests
See which content gets more attention

Our partners may also use their own cookies to provide us with statistics about visits and interactions.

You can reject non-essential cookies through your browser or device settings — but some features may not work properly if you do.

It’s a good idea to ask your guardian for help when changing these settings.

How Do We Protect Your Information?
We use technical and administrative measures to stop unauthorized people from accessing your information.
No system is 100% secure, but we work to minimize risks.

You can also protect yourself by:

Not sharing your password with anyone except your guardian
Not writing your password down where others can find it
Using different passwords for different services
Changing your password regularly
Logging out when using shared devices

Can We Update This Policy?
Yes. When our Services or the laws change, we may update this Privacy Policy.
If we make important changes, we will announce them on our website, send an email, or notify you and/or your guardian in other ways.
You should check this page from time to time to stay informed.

How Can You Contact Us?
If you or your guardian has any questions about this Privacy Policy or your personal data, you can contact us at:

Email: cocukkvkk@gain.com.tr
Mail: Ömer Avni, Fındıklı Çelebi Hamamı Sk.Somer Han No:2, 34421 Beyoğlu / İstanbul