Turkish Data Processing Information

Avakin Life Privacy Policy Addendum for Türkiye

These terms apply to the use of games (including Avakin Life) and other products developed by Lockwood Group (“Lockwood”/“we”/“us”). Lockwood Group is formed by Lockwood Publishing Limited and its subsidiaries. Each member of the Lockwood Group acts as an independent data controller for the purpose of processing personal data in accordance with this Addendum and the Privacy Policy. For more information about each entity belonging to Lockwood Group, please see here.

This Privacy Policy Addendum (“Addendum”) applies solely to natural persons located in Türkiye and has effect in respect of all games, related online services (including online network play connectivity and interactivity), and other software and products made available by us (together the “Game(s)”), as well as any other online features relating to the Games, including our websites (http://www.avakin.com or http://lockwoodpublishing.com) (the “Website”), our online forums (the “Forums”), and our user support centre (the “Support Centre”). Together, the Game(s), the Website, the Forums, and Support Centre are referred to as the “Online Services.”

This Addendum supplements our main Privacy Policy and outlines how personal data of Turkish data subjects will be collected and processed by Lockwood as the data controller, in line with Türkiye’s Law on the Protection of Personal Data No. 6698 (“the Law”). It also fulfils our obligations as Data Controller to Inform under Article 10 of the Law and the Communiqué on Principles and Procedures to be Followed in Fulfilment of the Obligation to Inform. In the event of any conflicting terms between this Addendum and the main Privacy Policy, this Addendum shall take precedence.

Identity of the Data Controller and Representative

Data Controller: Lockwood Publishing Limited, 2 City Buildings, 24-48 Carrington Street, NG1 7FG, Nottingham, United Kingdom. Company number: 0624248.

Data Controller’s Representative in Türkiye:
BOSS Governance Services Inc.
Esentepe Mahallesi, Büyükdere Caddesi No:127B/8
Şişli, Istanbul, Türkiye

Email address: bossyonetisim@hs02.kep.tr 

For all requests relating to your personal data, you may contact us at dpo@avakin.com.

Personal data Processed

1. Account & Identity Information

  • Name, surname, age,
  • Identification documents: ID cards, passports, driving licences, certificates(if provided, implicitly date of birth will be collected)
  • Avakin profile photo (can only be avatars or characters created within the App.)  and username
  • User ID (generated and allocated when first playing games)
  • Age / date of birth
  • Social media accounts (YouTube, Instagram, Facebook, etc.)

2. Visual data

  • Photos of face (if provided through the identification documents)

3. Contact category

  • – Phone number (for account security or contact, solely if provided)
  • Email address
  • KEP address
  • Country information
  • Physical address( if you apply for data subject application)

4. Security transaction Data

  • Device ID
  • Device characteristics: make, model, operating system & version
  • Device properties: screen size, orientation, volume, battery
  • Device location, country, time zone, locale settings (preferred language)
  • Mobile network operator linked to device
  • Network connection type and speed
  • IP address
  • MAC address
  • Password
  • Apple ID
  • Steam ID
  • Google Play Games ID
  • Usercentrics consent preferences
  • Timestamps

5. Payment information

  • Purchase IDs (Xsolla / Apple / Steam / Google Play)
  • Transaction code

6. Advertising Data

  • Consent information
  • Google advertising ID
  • Apple advertising ID
  • Advertising data:
    • Games played
    • Advertisements viewed and clicked
  • Analytics data:
    • Game play statistics and events
    • Purchase transaction types and spend (inventory logs)
    • Country of device
    • Record of source link (where user found app/software)
    • Crash and defect identification

5. Customer data

  • Name, surname, age, date of birth
  • Email address
  • Password
  • Phone number (for account security or contact)
  • Identification documents: ID cards, passports, driving licences, certificates(if provided)
  • Avakin profile photo and username
  • User ID (generated and allocated when first playing games)
  • Gaming activity (actions, progression, virtual items used or collected)
  • User preferences (including analytics & advertising choices)
  • In-scene chat logs
  • Group chats
  • Direct chat messages (user mail / 1-to-1 messages)
  • User-generated content (photos, files, or other submissions containing metadata such as location or creation date)
  • Name, email, age
  • Game statistics
  • IP addresses (for unique survey tracking)
  • Telephone recordings (if provided with consent)

6. Social interface data

– Chat logs

7. Legal transaction data

– Data Subject Applications

– All evidence an documents used for legal transactions data

If you decided to take part in contests, as they appear from time to time, we may collect the following data:

  • Social media/public profile information (profile picture, unique ID/username, messages sent to Avakin)
  • Voice recordings (e.g., social activities, telephone recordings with consent)

If you decided to take part in the Influencer Program, we might collect the following data:

  • Name
  • Mobile telephone number
  • Email
  • Age / date of birth
  • Social media accounts (YouTube, Instagram, Facebook, etc.)
  • Videos submitted

Purpose of Processing Personal Data

In line with Article 10 of the Law, Lockwood processes personal data for the following purposes:

  • Providing and operating the Games and Online Services: to create and manage your account, record your progress, and deliver the features promised.
  • Improving our Games and services: including analysis, troubleshooting bugs, testing features, and gathering feedback.
  • Customer support and community features: responding to requests, managing reports, and ensuring proper forum and chat use.
  • User acquisition and engagement: promoting new content, re-engaging players, and managing influencer programs.
  • Advertising and monetisation: showing in-game ads, serving targeted ads (where consent is given), running campaigns, and measuring performance.
  • Security, fraud prevention, and compliance: preventing illegal activity, protecting accounts, dispute resolutions, payment verification, enforcing terms of use, and complying with applicable laws.
  • Research and surveys: conducting voluntary surveys to improve user experience.
  • Marketing campaigns: with your consent, using your content in campaigns across our or partner platforms.
  • Prize fulfilment and communication: sending items or rewards to winners.
  • Execution of the legal proceedings if a player applies including but not limited to data subject applications
  • Execution of business continuity activity
  • Execution of audit of business activities
  • Execution of finance and accounting processing

For detailed examples and categories of personal data processed, please also refer to Sections 2 and 3 of our main Privacy Policy and our Consent Management platform available in Settings directly in your Avakin Life account

To Whom and For Which Purposes the Processed Personal Data May Be Transferred

Your personal data may be shared with the following categories of recipients, to the extent necessary for the purposes listed above:

  • Group companies and subsidiaries of Lockwood Group for centralised operations.
  • Suppliers and subcontractors providing services such as cloud hosting, analytics, customer support, and bug fixing.
  • Advertising and marketing partners, where you have given consent for targeted advertising (full list available at: https://avakin.com/avakin-life-advertising-partners).
  • Payment processors such as Xsolla for purchases via the Avakin Store.
  • Platform providers (e.g. Apple, Google, Steam, Amazon) for account management, security, and fraud prevention.
  • Third-party service providers such as Helpshift (support services), Discord (account linking), and others listed here: https://avakin.com/avakin-life-processors.
  • Public authorities or courts, where required by law or necessary to defend legal claims.
  • Potential acquirers or business partners, in the event of mergers or acquisitions.

International Transfers: Where personal data is transferred abroad, Lockwood ensures compliance with Law No. 6698 by obtaining explicit consent where required or by implementing adequate safeguards (e.g. contractual clauses, approved transfer mechanisms).

Method and Legal Basis of Collection of Personal Data

Method and Legal Basis of Collection of Personal Data

Personal data is collected:

  • Directly from you when you create an account, play the Game, or contact support.
  • Automatically through your device and gameplay (analytics, advertising identifiers, crash logs).
  • From third parties such as social platforms if you log in via those.

The legal bases for processing under Turkish law are:

  • Performance of a contract (e.g. to provide and operate the Games and Online Services).
  • Legal obligations (e.g. compliance with applicable laws, fraud prevention, child safety).
  • Legitimate interests (e.g. improving our services, ensuring safety, preventing fraud, marketing to existing users).
  • Explicit consent (e.g. targeted advertising, data transfers abroad where no other basis applies, influencer programmes, surveys, and use of player content in marketing).
  • Data processing is necessary for the establishment, exercise or protection of any right.

You can manage or update your consent choices to our third-party service providers at any time in your account settings within the App.

In the event a player shares sensitive data with the company, this may be processed for a limited time period, however, unless is required for the purposes above the data will be deleted.

Your Rights Under Turkish Law

In accordance with Article 11 of the Law, you have the following rights:

  1. To be informed whether your personal data is being processed.
  2. To request information regarding the processing of your personal data.
  3. To learn the purpose of processing and whether your data is being used in line with those purposes.
  4. To know the third parties in Türkiye or abroad to whom your personal data is transferred.
  5. To request correction if your data is incomplete or inaccurate.
  6. To request deletion or destruction of your personal data under the conditions referred to in Article 7 of the Law.
  7. To request that the correction, deletion, or destruction of your personal data be notified to third parties to whom your data has been transferred.
  8. To object to outcomes to your detriment that result from analysis of your personal data by automated systems.
  9. To request compensation if you suffer damages due to unlawful processing of your personal data.

You may exercise these rights by contacting us at dpo@avakin.com, through the in-game Support Centre, or by post to our Turkish Representative (details above).

We will respond to your request within 30 days, as required under Law No. 6698. If additional time is needed, you will be informed.

Download Personal Data Request Form here:

Personal Data Request Form (KVKK – Turkey)