Privacy Policy

This Privacy Policy (“Policy”) outlines how RedHorizon Teknoloji A.S., a company established under the laws of Türkiye, with registration number 7340961772 (“we”, “us”, “our”), collects, uses, and manages the personal data of:

  • Customers of our video games (“Games”) developed by us and visitors to our websites connected to it,
  • Influencers, journalists, and other media representatives engaging with us.

This Policy is accessible on our website at . We may update this Policy from time to time to reflect changes in our practices or legal requirements. You can always find the latest version of this Policy through the provided link. In the event of significant changes that affect your rights or how we handle your data, we will notify you in advance via email or through a notification on our website.

Some terms used in this Policy are technical. If you encounter any terms that are unfamiliar, please reach out to us using the contact details provided in Section 6.

The Privacy Policy addresses:




We prioritize your privacy and handle your data with utmost care, focusing only on delivering a safe and immersive gaming experience. Below is a comprehensive breakdown of the data collection practices associated with "Black Trail."

When You use our Games

  • Purposes: To diagnose and resolve issues, improve game functionality, and ensure a seamless gaming experience. This includes investigating and rectifying bugs or glitches.
  • Data Collected:
    • Personal Identifiers: Name, contact details (e.g., email, username Discord nickname)
    • Gameplay Information: Game progress, settings, inventory, descriptions of encountered bugs, etc.
    • Technical Information: Operating system details, device type, hardware specifications, installed software, and any additional information you provide.
  • Legal Basis: Consent that you give when running our games.
  • Retention Period: Up to 3 years after your last use of the Games.

When You Create an Account or Make Purchases

  • Purposes: To register and manage your "Black Trail" account and to process transactions including delivering digital goods, processing refunds, and preventing fraud.
  • Data Collected:
    • Account Details: Name, email.
    • Purchase Information: Order details, transaction IDs, item descriptions, and shipping information if applicable.
    • Communication Data: Additional details shared during support interactions.
    • Financial Information: Data received from payment processors (we do not directly access full payment card details).
  • Legal Basis: Performance of a contract to which you are a party.
  • Retention Period: 3 years from your last login or as necessary for tax and legal compliance.

Community Engagement and Contests

  • Purposes: To manage community interactions, conduct contests, and gather feedback through surveys.
  • Data Collected:
    • Contact Information: Full name, email, social media handles, and shipping address for contest winners.
    • Contribution Data: Entries submitted for contests or feedback from surveys.
  • Legal Basis: Performance of a contract (contest rules) and your consent for surveys.
  • Retention Period: 3 years for both contest-related data and survey feedback.

Newsletter Subscription

  • Purposes: To send you news, updates, and promotions related to our games.
  • Data Collected: Email address and details related to newsletter engagement.
  • Legal Basis: Your consent and our legitimate interest in promoting our game.
  • Retention Period: 3 years following the last communication.

Collaboration with Influencers

  • Purposes: To foster partnerships and collaborations, including content creation and promotional activities.
  • Data Collected:
    • Influencer Details: Name, contact information, channel statistics, banking information for contractual purposes.
    • Public Relations Data: Information from media representatives or journalists including contact details and professional affiliations.
  • Legal Basis: Legitimate interests in promoting "Black Trail" and performance of contracts.
  • Retention Period: During the term of our partnership or contract, with financial information kept for up to 6 years for compliance.

Web Analytics

  • Purpose: To analyze web traffic and improve user experience on our websites.
  • Data Collected: Information via cookies and similar technologies regarding your interaction with our websites.
  • Legal Basis: Your consent, captured through our cookie consent mechanism.
  • Retention Period: As specified in our Cookie Policy.



We are committed to maintaining the confidentiality and integrity of your personal data. Sharing of your data is conducted with strict adherence to legal requirements and to enhance your gaming experience across all our Games. Here are the circumstances under which your data may be shared:

  • Affiliates and Group Companies: We share data with our affiliates and other companies within our group to carry out our business operations more effectively.
  • Service Providers: We engage with Software as a Service (SaaS) and hosting providers to utilize necessary software and to host our IT systems. These services are essential for processing your data securely and efficiently.
  • Shipping Providers: To fulfill physical orders and deliver rewards, we share necessary details (such as your name and address) with shipping service providers.
  • Game Credits: In recognition of your contributions, your name may be displayed in the credits of our Games, visible to other players.
  • Influencer Partnerships: If you are involved in our influencer partnership program, your details may be shared with other influencers within dedicated channels, such as Discord, to foster community engagement and collaboration.
  • Business Transfers: In the event of a sale, merger, or acquisition of our business, your personal data may be shared with the new owners under the same privacy considerations.
  • Legal Obligations: We may disclose your data to governmental agencies or courts as required by law, to comply with legal processes, or to protect the rights, property, or safety of our Games, our users, or others.
  • Professional Advisors: Data may also be shared with our professional advisors, including lawyers, bankers, auditors, and insurers, as necessary for them to provide their services to us.

Third-Party Links

Our Services may contain links to external sites operated by third parties. Please be aware that we do not control these third-party sites or their privacy practices. We encourage you to review the privacy policies of any third-party services you interact with, as their practices govern the collection and use of your information, not ours.



In providing our Games and services, it is sometimes necessary to share your personal data with service providers and partners located outside of Türkiye. Given the global nature of our operations and the technologies we employ, these international transfers are essential for delivering the high-quality experience you expect from us.

Compliance with Türkiye Law

Under the Personal Data Protection Law (PDPL), Law No. 6698, we are committed to ensuring the protection of your personal data when it is transferred outside of Türkiye. The Turkish Personal Data Protection Authority (KVKK) requires that certain measures are taken to protect personal data when it is transferred internationally, especially to countries not recognized by the KVKK as having adequate data protection laws.

Measures for Data Protection

To comply with Turkish law and ensure the protection of your personal data, we take the following measures when transferring your data internationally:

  • Data Transfer Agreements: We enter into Data Transfer Agreements that include clauses specifically designed to ensure the protection of your personal data, mirroring the safeguards required by the PDPL and the regulations set forth by the KVKK.
  • Standard Contractual Clauses (SCC): For transfers to countries where the data protection level is not deemed adequate by the KVKK, we use Standard Contractual Clauses approved by the European Commission, adapted to meet the requirements of the PDPL and the KVKK's guidance.
  • Risk Assessment: Before any data transfer, we conduct thorough risk assessments to evaluate the data protection practices of the receiving country and entity, ensuring they provide sufficient safeguards for your personal data.
  • Additional Security Measures: Depending on the outcome of our risk assessments, we may implement additional security measures to further protect your data during its transfer and storage in foreign jurisdictions.

You have the right to obtain information about the safeguards in place for data transfers outside of Türkiye, including copies of the Data Transfer Agreements and any additional measures we have taken to protect your personal data. Requests for such information can be made as specified in Section 6 (Contacts).


Under the Personal Data Protection Law (PDPL), Law No. 6698 of Türkiye, you are granted several rights regarding your personal data that we hold. Below is a summary of these rights and how you can exercise them:

Accessing Data

You have the right to request information about the processing of your personal data, including obtaining copies of the personal data we hold about you.

Data Portability

You have the right to have the personal data you have provided to us transferred to another data controller or to yourself, under certain conditions.

Changing or Updating Data

You are entitled to request the correction of inaccurate personal data and to have incomplete personal data completed.

Deleting Data

You have the right to request the deletion or removal of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected or when you withdraw your consent upon which the processing is based. However, we may retain data as required or permitted by law.

Objecting and Restricting Processing

You have the right to object to the processing of your personal data in certain circumstances, including for direct marketing purposes. You can also request the restriction of processing of your personal data, limiting how we can use your data.

Revoking Consent

You may withdraw your consent at any time, leading us to cease processing activities based on that consent. To withdraw consent, especially for direct marketing, you can follow the "unsubscribe" link in communications or contact us as outlined in Section 6.


If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Personal Data Protection Authority (KVKK) of Türkiye. However, we encourage you to contact us first to attempt to resolve any issues.

You may manage some aspects of your personal data directly within your account settings for our Games.

Exercising Your Rights

To exercise any of the rights mentioned above, please reach out to us using the contact information provided in Section 6. We aim to respond within 30 days of receiving your request. We may request additional information to verify your identity before we can fulfill your request.



While no information technology system or online communication can be guaranteed to be completely secure, we are fully committed to the protection and security of your personal data in compliance with the Personal Data Protection Law (PDPL), Law No. 6698, of Türkiye. To this end, we implement a range of technical, organizational, and legal measures designed to safeguard your personal data against unauthorized or accidental access, deletion, alteration, blocking, copying, and distribution.

Security Measures

Our security measures include, but are not limited to, the use of encryption technologies where appropriate, rigorous access controls, and the establishment of procedures to address potential data security breaches. We continually evaluate and update these measures to address emerging security threats and to align with best practices and legal requirements.

Your Role in Data Security

You play a crucial role in the security of your account and personal data. Access to your account is secured with your login credentials, including your email address and a password that you set. It is your responsibility to keep these credentials confidential and to ensure that they are not shared or exposed to others. If you ever suspect that your account has been compromised, such as through misuse, loss, or unauthorized access, we urge you to inform us immediately.

Response to Data Breaches

In the event of a data security breach, we have established procedures to promptly address and mitigate any potential impact. This includes notifying you and the relevant regulatory authorities in Türkiye, specifically the Personal Data Protection Authority (KVKK), of the breach in accordance with legal obligations. We are committed to transparency and will provide you with all necessary information and guidance on how to protect yourself if your data are involved in a breach.



Should you have any questions or concerns regarding this Privacy Policy or the processing of your personal data, please do not hesitate to get in touch with us through the following means:

  • Email: Please direct your emails to, ensuring to include your name and any other relevant information to assist us in addressing your inquiry comprehensively and promptly.
  • Postal Address: For written correspondence, you can send letters to the following address:

RedHorizon Teknoloji A.S.

Maslak Mh. Maslak Meydan Sk. Beybi Giz A Blok No:1 D:55 

Sarıyer / İstanbul, Türkiye

Please include sufficient details to allow us to fully understand and respond effectively to your request or concern.