Palette Pour Privacy Policy

1. Who we are

Palette Pour is developed and published by Muhammed Çelik, sole proprietor, trading as Celik Works (Türkiye) (“we”, “us”). Celik Works is a brand name, not a separate company. On the App Store, Muhammed Çelik is shown as the seller.

We are the data controller for the personal data described here. In Türkiye, we are the veri sorumlusu under Law No. 6698 on the Protection of Personal Data (KVKK). Under US state privacy laws, we are the “business” or “controller”.

Palette Pour is first offered in the United States. Before we offer it in the European Economic Area or the United Kingdom, we will update this policy, including any representative we appoint there.

2. Data we collect

a. Data that stays on your device

Your game progress, settings, coins and the items you own (so they work offline) are saved in the game’s storage on your iPhone, which is included in your iPhone’s backups. The age band from our age question (for example “under 13” or “adult”, never your birth date) is kept in your iPhone’s secure storage (the iOS Keychain), so it can remain after you delete the app until you reset it in the game’s Settings or erase the device. We do not receive this data.

b. Data collected through partner software in the app

See section 5 for which partner receives what.

• Device identifiers: an app- or developer-specific device ID, an analytics app instance ID and installation ID, a purchase-service profile ID, and the Apple advertising identifier (IDFA) only if you allow tracking.
• IP address, used to estimate your approximate location (country or city), never your precise location.
• Ad data: which ads you saw, taps, video views, rewards earned, ad performance and viewability, and how much an ad earned. Our purchase service also receives a short-lived Apple attribution token, which can show whether the game was installed from an ad on the App Store; Apple says it does not identify you or your device and is not tracking.
• Game and app activity: for example app launches, screens, levels started and finished, boosters used, settings changed, shop and offer screens viewed, and errors.
• Diagnostics: crash reports and performance data (launch time, frame rate, hangs, energy use).
• Device information: model, operating system, language, screen size, connection type and app version.
• Purchase history: what you bought, the price, the date, the transaction ID and subscription status. Apple processes the payment itself.
• Consent and privacy choices: your answers in the consent form and in Ad privacy choices, stored on your device and passed to partners as signals. Our analytics also receive a privacy-mode label (for example “restricted”) that says which protections apply. It never contains your age band or birth date.

c. Data you send us

If you email us, we receive your email address, your message and anything you attach, including the Player ID if you send it. If you use Report an ad, the email also contains the ad’s network and ID, the time and your game version.

What we do not collect: your name, contacts, photos, microphone or camera data, precise location, payment card numbers, or “sensitive personal information” as US state laws define it.

3. How we use data, and our legal bases

We do not use your data for automated decisions that have legal or similarly significant effects on you.

4. Advertising and tracking

Ads in Palette Pour. Most ads are optional videos you choose to watch for a reward, such as extra pours, a mini tin or doubled coins. After some won levels the game may also show an ad between levels, never in your first session. A one-time purchase removes those ads, and reward videos stay optional. Ads are served through Google AdMob. For adult players, AdMob runs an auction in which other advertising companies that buy ads through Google can take part. For players under 18 and players whose age we do not know, only Google AdMob serves ads: no other ad company’s software is started for them.

Tracking on iPhone (App Tracking Transparency)

If our age question shows you are an adult, iOS asks whether Palette Pour may track you, before the game shows its first ad or when you open Settings › Ad privacy choices. “Tracking” means linking data from this game with data from other companies’ apps and websites, to choose or measure ads.

• If you allow it, ad partners may use the IDFA to show more relevant ads and to measure ad campaigns.
• If you do not allow it, the IDFA is not sent with ad requests, and neither we nor our partners may use any other identifier to track you across other companies’ apps and websites. You still see ads, but they may be less relevant. Saying no to tracking is not the same as the US opt-out below: to also opt out of the “sale” or “sharing” of your data for targeted ads, use Settings › Ad privacy choices or email us.

You can change your answer at any time in iOS Settings › Privacy & Security › Tracking. We never show this prompt to players under 18 or to players whose age we do not know.

Personalised and non-personalised ads

Players under 18, and players whose age we do not know, get non-personalised ads only, with ad content rated for their age. Adults who opt out also get non-personalised ads. In regions that require it, Google’s consent form asks before personalised ads are shown. You can change your choice at any time in Settings › Ad privacy choices.

Do Not Sell or Share My Personal Information (US states)

We do not sell data for money. Sharing device data with ad partners for cross-context behavioural advertising may count as a “sale” or “sharing” under the laws of California and other states. To opt out:

• in the game, open Settings › Ad privacy choices and opt out; or
• email hello@celikworks.com with the subject “Do Not Sell or Share” and the Player ID from the game’s Settings.

We then mark your ad requests and tell our ad partners that you have opted out. You still see ads, but they are not personalised using your data. We will not ask you to opt back in for at least 12 months unless you start the change yourself. For browser signals, see section 12.

Report an ad

If an ad seems wrong for your age, offensive, misleading, or will not close, open Settings › Report an ad. It opens an email to us with the ad’s network, its ID, the time and your game version, and nothing else about you; you can add a screenshot. We pass reports to the ad network and block ads that break the rules. Where an ad shows an AdChoices or “Why this ad?” icon, tap it to see why you were shown that ad.

5. Partners who receive data

Adapty and Google Firebase act as our service providers and use data only to provide their service to us. Google AdMob uses ad data both for us and under its own privacy policy. We work only with partners whose terms require them to protect personal data at least as well as this policy describes. If we add a partner in a later version, we update this list before that version is released.

We may also disclose data when the law requires it, to protect players or the game against fraud or abuse, or to a buyer or successor if the game is transferred. In that case this policy continues to apply unless you are told otherwise.

6. Children and teens

Palette Pour is made for a general audience. Because it may also appeal to younger players, the first time you open the game it asks for your birth month and year in a neutral way, before any analytics, advertising or purchase software starts. No answer is pre-filled. We keep only the resulting age band, on your device, and use it to choose your privacy mode. Your age band and birth date are never sent to us or to any partner. Our analytics receive only the privacy-mode label (for example “restricted”), so we can check that the right protections were applied and delete children’s data on time. If you skip the question, we treat you as under 13. Where Apple provides an age range for your account, we use whichever signal is more protective.

If you are under 13, or we do not know your age

• Ads are contextual only and come from Google AdMob only: no personalised ads, no cross-app tracking and no other ad companies. We do not show the tracking prompt and do not read the IDFA. Ad requests are marked as child-directed, with content rated for a general audience.
• Partners may use a device ID, device data and IP address only for the internal operations of the game: running it, serving contextual ads and limiting how often they appear, measuring how the game works, fixing crashes, preventing fraud and meeting legal duties.
• Analytics about these players are used only for those internal operations: never to target offers, and never in tests of purchase offers. The game shows them no pop-up purchase offers.
• There is no chat, no public profile and no user content, and we never ask a child for a name, email, photo or location. Purchases go only through Apple, where parents can use Ask to Buy and Screen Time.
• We do not disclose children’s personal information to third parties for advertising, or for any other purpose that needs a parent’s separate consent under the US Children’s Online Privacy Protection Rule (COPPA).

If you are 13 to 17

We do not sell or share your personal information, and we do not use it for targeted advertising. You get non-personalised ads from Google AdMob only, and no tracking prompt.

Parents

You can ask us to review or delete the personal information connected to your child’s game, and to stop further collection. Email hello@celikworks.com with the subject “Parent privacy request” and the Player ID from the game’s Settings (or the device type and roughly when the game was installed). We will take reasonable steps to confirm that you are the parent. Analytics and crash data about players under 13 are deleted within 12 months at the latest; purchase records are kept only as long as needed to restore the purchase and as tax law requires. A support email from a child is deleted once answered.

7. How long we keep data

8. International transfers

We are based in Türkiye. Our partners process data in the United States and other countries. Where the law requires it, we rely on safeguards such as the European Commission’s Standard Contractual Clauses and the standard contracts of the Turkish Personal Data Protection Authority, together with our partners’ data processing terms.

9. Your rights

United States. Depending on your state (for example California, Virginia, Colorado, Connecticut or Texas), you may have the right to know what personal information we have and to get a copy of it; to correct or delete it; to opt out of its sale or sharing and of targeted advertising; and to appeal if we refuse a request. To appeal, reply to our answer with the subject “Appeal”. We will not treat you differently for using these rights. You can use an authorised agent.

EEA, UK and Switzerland (if the game is offered there). You have the right to access, correct, erase, restrict, object to and port your data, and to withdraw consent at any time without affecting earlier processing. You may also complain to your data protection authority.

Türkiye (KVKK). Under Article 11 of Law No. 6698 you may ask whether we process your data and request information about it; learn the purpose and whether it is used for that purpose; learn the recipients in Türkiye or abroad; ask for correction, deletion or destruction, and for third parties to be told; object to a result that is against you and comes only from automated analysis; and claim compensation for damage caused by unlawful processing. You can apply in writing to the postal address in section 1, or by email to hello@celikworks.com. We reply free of charge within 30 days at the latest. You may also complain to the Personal Data Protection Authority (KVKK).

How to make a request

To opt out of sale or sharing, you can use Settings › Ad privacy choices in the game. For this or any other request, email hello@celikworks.com with the subject “Privacy request”. Tell us what you are asking for and include the Player ID from the game’s Settings. Because there are no accounts, we use the Player ID and details from the game to find your data and confirm the request is yours. We confirm requests within 10 business days and answer within 30 days, or within the shorter period your law sets. If we need an extension the law allows, we will tell you.

California notice at collection

Sources: you (support emails) and your device, through the game and the partners in section 5. We do not sell or share the personal information of players we know are under 18.

10. Deleting your data

There is no account to delete. Deleting the game removes the data stored on your device, except the age band (see section 2). To delete data held by us or our partners:

1. Email hello@celikworks.com with the subject “Data deletion request”.
2. Include the Player ID shown in the game’s Settings. If you can no longer open the game, include the Apple order ID of a purchase (it starts with “M”) or the email address you used to contact us before.
3. We confirm within 10 business days and complete the request within 30 days. We delete your analytics data in Google Analytics, ask Adapty to delete your purchase profile, delete your emails, and send deletion requests to the other partners that support them.

We may keep purchase records that tax law requires, and a record of your request. You can also reset or turn off tracking for your device in iOS Settings › Privacy & Security › Tracking. Deleting data does not cancel a subscription: cancel it in your Apple Account settings (see Support).

11. Security

Data sent by the game travels encrypted (TLS). Access to our partner and developer consoles is limited to the people who need it and protected with two-factor authentication. We review a partner’s security and privacy terms before adding its software. We keep a written information security program that also covers children’s data. No method is completely secure. If a breach affects your data, we will notify you and the authorities as the law requires.

12. These web pages and Global Privacy Control

The Palette Pour web pages (this policy, the game page, the terms and the support page) use no cookies, analytics, advertising trackers or third-party scripts. Our hosting provider processes your IP address and basic request data to deliver the pages and protect them from abuse.

Global Privacy Control (GPC) is a browser setting that tells websites you want to opt out of the sale and sharing of your personal information. We treat it as a valid opt-out request. These pages sell or share nothing, so there is nothing more to switch off here. Phones do not send GPC to apps: to opt out in the game, use Settings › Ad privacy choices, or email us your Player ID and we will apply your GPC choice to it.

Turn on JavaScript to see whether your browser is sending a Global Privacy Control signal.

13. Changes to this policy

When we change this policy, we update the version and the “Last updated” date at the top and keep earlier versions available on request. If a change is material, for example a new use of data or a new partner that tracks, we tell you in the game before it takes effect, and we ask for your consent again where the law requires it.

14. Contact

For privacy questions, start your email subject with “Privacy”.