Privacy Policy and Personal Data Processing Agreement

Last updated: October 8, 2026 · Effective on publication · The Turkish text prevails if there is any difference

This text explains how your personal data is processed through the HalfReal mobile app, the halfreal.wtf website and all related services, social rooms, mini games and voice features (together the "Service"), in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK"), Law No. 5651, the Law on the Regulation of Electronic Commerce No. 6563, the Consumer Protection Law No. 6502 and related secondary legislation. By using the Service or creating an account you confirm that you have read and understood this text. Where the law requires explicit consent, we ask for it separately on the relevant screen; accepting this text is not by itself explicit consent for those operations.

Contents
  1. Data controller
  2. Personal data we process
  3. Purposes and legal bases
  4. Photos, facial images and AI generation
  5. Voice and speech moderation
  6. Automated processing and moderation
  7. What other users can see
  8. Trading between users and Partner transactions
  9. Who we share data with
  10. Transfers abroad
  11. Retention and deletion
  12. Security and breach notification
  13. Children and teenagers
  14. Device permissions and consent
  15. Cookies and similar technologies
  16. Your obligations
  17. Scope of our responsibility
  18. Your rights and how to apply
  19. Changes, severability and governing law

1. Data controller

Company: WDG Ltd
Address: halfreal.wtf
Company number (Companies House): 14424600 · ICO registration no.: [ICO no.] · MERSIS (if any in Türkiye): [MERSIS]
Data controller representative (Türkiye): [Representative name and address] · VERBIS: [Registration status / number]
KEP address (if any): [KEP address]
Email: [email protected]

Infrastructure, payment, AI and notification providers act as "data processors", or, to the extent they process for their own purposes, as independent controllers (see Section 9).

2. Personal data we process

CategoryDataSource
Identity and accountAccount ID; the identity and email address Google shares when you sign in with Google; a random technical ID for guest sign-in; nickname; country and language preference; registration and last-seen timesYou, your sign-in provider
Visual dataYour chosen character; photos you upload for avatar or item generation and images generated from them; profile imagesYou
Game and profile dataLevel, XP, health, location and room information, inventory, items, pets, cosmetics, SVIP status, achievements, rankings, friend/club/room memberships, profile bioYour use
Transaction (ledger) dataCoin and diamond movements, stall/trade records, gifts, reward and refund recordsYour use
Content and communicationPublic/room chat messages, private messages and attached media, gift notes, reports, blocks and support correspondenceYou
Voice dataLive voice stream in voice rooms (not recorded); where moderation is enabled, text produced from speech fragments (audio is not stored)Microphone
SecurityIP address, country derived from the IP, anonymised device identifier, device model, platform and OS version, app version, root/emulator signals, sign-in times, security alerts, sanction recordsAutomatic
Payment and payoutPurchase amount, pack, status, payment provider session/transaction ID; card details never reach us. For user-to-user real-money transactions, the payment method and payee/payment details you enterYou, the payment provider
NotificationsPush notification token, notification preferencesYour device, with your permission
Usage and technicalIn-app event records, error and performance logs, browser/device informationAutomatic

We do not ask for special categories of personal data (health, religion, race, sex life etc.). We recommend that you do not write such information in free-text fields such as chat, bio, nickname or photos; information you choose to share may be visible to other users.

3. Purposes and legal bases

PurposeLegal basis (KVKK Art. 5/6)
Registration, sign-in, account management, game world, chat, trading and rewardsPerformance of a contract (Art. 5/2-c)
Taking payments, refunds, dispute resolution, accounting and tax obligationsContract, legal obligation (Art. 5/2-c, ç), establishment of a right (Art. 5/2-e)
Information security, preventing fraud, cheating and abuse; preventing banned users from returning; moderationLegitimate interest (Art. 5/2-f), legal obligation (Art. 5/2-ç)
Record keeping, notices and responding to authorities under Law No. 5651 and other legislationProvided by law, legal obligation (Art. 5/2-a, ç)
Processing photos that may contain a face for avatar/item generationPerformance of a contract; additionally explicit consent when you upload (Art. 5/1)
Speech moderation (when enabled)Legitimate interest; explicit consent where required
Push notificationsDevice permission and explicit consent
Commercial electronic messages (marketing)Prior permission under Law No. 6563
Improving the Service, statistics and debugging (aggregated and, as far as possible, anonymous)Legitimate interest (Art. 5/2-f)
Establishing, exercising or defending legal claimsEstablishment, exercise or protection of a right (Art. 5/2-e)

Where we rely on legitimate interest, we balance our interest against your rights and freedoms. We do not use your data for advertising profiling and we do not sell or rent it.

4. Photos, facial images and AI generation

5. Voice and speech moderation

6. Automated processing and moderation

For the safety of the Service we use automated processes such as rate limiting, profanity/prohibited-content filters, AI-assisted content checks, and cheating and multi-account detection. As a result, content may be removed, your account restricted, or access to features limited. If you face a decision based solely on automated processing that has a negative result for you, you can object under KVKK Art. 11/1-(g) and ask for human review at [email protected]. For security reasons some detection methods are not disclosed in detail.

7. What other users can see

Your nickname, avatar, level, frame and badges, chat and room messages, your place in rankings, gifts and some game events (such as reward announcements) can be seen by other users. You share these because of the nature of the Service. We recommend choosing a nickname that contains no personal information. Private messages are delivered only to the recipient, but the recipient can copy or share the content.

8. Trading between users and Partner transactions

9. Who we share data with

Recipient groupExamplesPurpose
Infrastructure and hostingSupabase, CloudflareAuthentication, database, storage, servers, content delivery, real-time voice, speech-to-text
PaymentsStripe; Google Play; Apple App StoreTaking payments, refunds, fraud prevention
AuthenticationGoogleSign in with Google
AIOpenRouter and the model providers behind itAvatar/item image generation, content checks
NotificationsGoogle FCM, Apple APNsDelivering push notifications
Other usersPlayers in your room or game, the other party of a transactionVisibility inherent in the Service (Sections 7–8)
Professional advisersLawyers, accountants, auditorsLegal and financial obligations
Competent authoritiesCourts, prosecutors, law enforcement, the ICTA (BTK), MASAK, the KVKK Board and other public bodiesRequests under law; reporting suspected crime, fraud or unlawfulness; protecting our rights
Corporate transactionsParties to a merger, transfer or acquisitionContinuity of the Service; the new owner remains bound by this policy

10. Transfers abroad

Because our infrastructure, payment and AI providers' servers are outside Türkiye, providing the Service technically requires transferring your data abroad. Transfers are made under KVKK Art. 9 and related regulations: to countries with an adequacy decision, otherwise with standard contractual clauses, binding corporate rules, an undertaking or other safeguards the law provides (and, where required, a notification to the Board). Where the law allows, we may also rely on your explicitly informed consent. You can request information on the countries and safeguards at [email protected].

11. Retention and deletion

DataPeriod
Account, profile and game dataWhile the account is open. If nobody signs in within 7 days of a deletion request it is deleted (Delete Account)
Uploaded photos and generation inputsAs long as needed for generation and objections; at most until the account is deleted
Sign-in, device and IP recordsDetailed records 30 days; summary records archived for security up to 1 year; the period the law requires where an official request exists
Access logs (Law No. 5651)The period the law prescribes (currently between 6 months and 2 years)
Usage events and statisticsDetailed for a short time; afterwards only as anonymous daily totals
Payment and invoice recordsThe period tax and commercial law prescribe (generally up to 10 years), at the payment provider
Moderation, sanction and appeal recordsAs needed to prevent repetition and protect rights, depending on the violation
Legal dispute recordsFor the limitation period

Data whose period has ended is deleted, destroyed or anonymised in periodic destruction processes. Data in backups is deleted when the backup cycle completes.

12. Security and breach notification

Under KVKK Art. 12 we take appropriate technical and administrative measures such as encryption in transit, role-based access, row-level authorisation in the database, separation of duties, rate limiting, logging and processor agreements. No system can be guaranteed absolutely secure. If personal data is unlawfully obtained by others, we notify the Personal Data Protection Board within the period the law prescribes (72 hours) and, where needed, affected data subjects. For your account security please use a strong device lock, do not share your sign-in details, and tell us about anything suspicious.

13. Children and teenagers

The Service is not designed for children under 13; they may not open accounts, and accounts of users we learn are under 13 are deleted with their data. Users aged 13–18 may use the Service only with the knowledge and permission of a parent or guardian; paid transactions and the processing of personal data need the parent's or guardian's approval. If you are a parent or guardian and think your child's data is being processed, you can request access, correction or deletion at [email protected]. Uploading photos of children is not recommended; a user who uploads a child's photo promises to hold the necessary parental permission.

14. Device permissions and consent

15. Cookies and similar technologies

This website (halfreal.wtf) does not use cookies or tracking technologies. The app uses local storage on your device for essential settings such as keeping your session and your language and sound preferences; it is not used for advertising or cross-site tracking. If we add new tracking technologies covered by this policy, we will inform you in advance and obtain the necessary permission.

16. Your obligations

17. Scope of our responsibility

Subject to mandatory law, and unless we acted with intent or gross negligence, we are not responsible for damage arising from: (i) information you chose to make public or visible to other users being copied, recorded or misused by others, (ii) money and value transfers between users made outside the Service, and the other party's use of the payment information you share in those transactions, (iii) outages, breaches or practices in the systems of third-party providers, (iv) your device or account being taken over through your negligence. This clause does not limit your statutory consumer rights or mandatory provisions (Turkish Code of Obligations Art. 115, Consumer Protection Law Art. 5).

18. Your rights and how to apply

Under KVKK Art. 11 you have the right to: learn whether your personal data is processed; request information if it is; learn the purpose of processing and whether it is used accordingly; know the third parties it is transferred to in Türkiye or abroad; request correction of incomplete or incorrect data; request deletion or destruction under Art. 7; request that these operations be notified to the third parties the data was transferred to; object to a result against you arising from analysis exclusively by automated systems; and claim compensation if you suffer damage from unlawful processing.

Send your application in writing under the Communiqué on Procedures and Principles of Application to the Data Controller, with information that identifies you, to the postal address above, our KEP address or [email protected]. Requests are answered free of charge as soon as possible and at the latest within thirty days; where the operation needs extra cost, the fee in the Board's tariff may be charged. If you are not satisfied with the answer you can complain to the Personal Data Protection Board within thirty days of learning the answer and in any case within sixty days of applying (kvkk.gov.tr). We may ask for extra verification if your request does not contain enough information to confirm you are the right holder. To delete your account: Delete Account.

19. Changes, severability and governing law

For a short summary see the KVKK Privacy Notice; for the rules see the Terms of Use.