Privacy Policy

Nano Influencers Platform — Privacy Policy

Last updated: 17 December 2025

This Privacy Policy ("Policy") explains how Games Dijital Medya Hizmetleri Anonim Şirketi ("Company", "we", "us") collects, uses, discloses, and protects personal data in connection with the Nanofluencers / Nano Influencersmobile application and related services (including the web dashboards and websites) (collectively, the "Platform" or "Services").

This Policy is designed to be comprehensive and usable as a single, unified privacy agreement. Where applicable, it is intended to align with:

  • Turkish Law No. 6698 (KVKK) on the Protection of Personal Data; and

  • Where relevant to your situation, EU/EEA GDPR principles (e.g., if you are located in the EEA/UK or our processing otherwise falls under GDPR).

If there is any conflict between a translated summary and the English text, the English text prevails.

1. Definitions

  • Personal Data / Personal Information: Any information relating to an identified or identifiable natural person.

  • Special Categories of Personal Data: Sensitive data as defined by applicable law (e.g., certain health, biometric, or similar categories under KVKK/GDPR).

  • Data Subject / User: You, an individual using the Platform.

  • Controller (Data Controller): The entity that determines the purposes and means of processing personal data.

  • Processor: A third party that processes personal data on behalf of the controller.

  • Processing: Any operation performed on personal data (collection, storage, use, disclosure, deletion, etc.).

2. Data Controller and Contact

Data Controller:

Games Dijital Medya Hizmetleri Anonim Şirketi

Address: Akat Mah. Meydan Cad. Edin Suner Plaza No:14 İç Kapı No:6, Beşiktaş/İstanbul, Türkiye

Tax No: 3881455293

Contact: For privacy requests and questions, contact us via the contact channel(s) displayed in the Platform or on our official website(s). Where a dedicated privacy email or contact form is provided, you should use that channel to ensure proper routing.

Note: If you require inclusion of a specific email address, phone number, or DPO/contact person name, insert it into this section.

3. Scope

This Policy applies to personal data processed when you:

  • create an account and use the Nanofluencers mobile app;

  • participate in campaigns (UGC, engagement, gifting, surveys, or other);

  • communicate with brands, the Company, or other users via the Platform;

  • receive products or rewards;

  • use our websites, dashboards, and customer support.

This Policy does not cover the privacy practices of third-party platforms (e.g., Instagram, TikTok, YouTube) that you connect to or use. Those platforms are governed by their own privacy policies.

4. Categories of Personal Data We Collect

We may collect and process the following categories of personal data, depending on how you use the Platform:

4.1 Identity and Account Data

  • Name, surname

  • Date of birth and age confirmation (where required)

  • Username, profile photo

  • Account identifiers (user ID)

4.2 Contact Data

  • Email address

  • Phone number

  • Address details for deliveries (when gifting/shipments apply)

4.3 Campaign and Participation Data

  • Campaign applications and participation history

  • Content submission metadata (timestamps, campaign IDs)

  • Content review outcomes (approved/rejected/revision requested) and review notes

  • Survey responses (including open-ended responses)

4.4 Social Media and Public Profile Data

When you connect social accounts or provide handles/links:

  • Social media usernames/handles

  • Public profile data (e.g., follower counts and publicly visible metrics)

  • Links to your posts (URLs)

We do not control third-party platforms; we may only access data that you provide or that is made available through authorized APIs and permissions.

4.5 Content Data (UGC/Media)

  • Photos, videos, captions, hashtags, and related creative assets you upload

  • Engagement links and proof of posting (e.g., URL submissions)

4.6 Financial, Tax, and Payment Data

Depending on payout method and legal requirements:

  • Wallet balances and payout history

  • Invoice information, tax-related information, and required documentation (e.g., e-invoice/e-archive data, if applicable)

  • Banking details necessary to execute payments (where applicable)

4.7 Transaction and Logistics Data

  • Product shipments: recipient name, address, phone, delivery notes

  • Delivery confirmations (including delivery photos where required)

4.8 Technical, Device, and Usage Data

  • Device identifiers, operating system, app version

  • IP address, approximate location derived from IP (not precise GPS unless you opt-in)

  • Log data (access times, pages/screens viewed, clicks)

  • Crash logs and performance diagnostics

4.9 Security and Fraud-Prevention Data

  • Authentication logs

  • Risk signals (e.g., suspicious activity indicators)

  • Records of policy violations, disputes, enforcement actions

4.10 Special Categories (Sensitive Data)

We do not intentionally request sensitive personal data. If campaign participation or surveys inadvertently collect sensitive data, we will treat it with enhanced safeguards and process it only where legally permitted.

5. Sources of Data

We collect personal data from:

  • You (directly), when you register, complete your profile, submit content, communicate, or request support;

  • Brands participating on the Platform, when they provide campaign requirements, approvals, or reports related to your deliverables;

  • Service providers (e.g., analytics, cloud hosting, email/SMS providers) to the extent needed to operate the Platform;

  • Third-party platforms (e.g., social media) when you connect them and authorize access, limited to permitted scopes.

6. Purposes of Processing

We process personal data for the following purposes:

6.1 Providing and Operating the Services

  • account creation, authentication, and user management

  • enabling campaign participation and execution

  • enabling content uploads, reviews, and approvals

  • enabling communications, notifications, and support

6.2 Campaign Management and Performance

  • matching creators with campaigns

  • verifying deliverables (content submissions and posting URLs)

  • measuring campaign performance and generating reports for brands and internal operations

6.3 Payments, Rewards, and Compliance

  • calculating rewards and eligibility

  • managing wallets and payouts

  • issuing invoices/records and fulfilling tax and accounting obligations

6.4 Logistics (Gifting / Shipments)

  • organizing product shipments and delivery confirmations

  • handling returns, damages, or disputes

6.5 Safety, Integrity, and Enforcement

  • preventing fraud, spam, abuse, and unlawful activities

  • enforcing community standards, campaign rules, and contractual obligations

  • investigating and responding to claims and legal requests

6.6 Improving and Developing the Platform

  • analyzing usage patterns to improve user experience

  • debugging, performance monitoring, and product development

6.7 Marketing and Communications

  • sending service messages (important updates, security notices)

  • sending marketing communications where legally permitted and/or with your consent

7. Legal Bases for Processing

We rely on one or more legal bases depending on the purpose and applicable law:

  • Performance of a contract: providing the Platform and administering campaigns, content approvals, and rewards.

  • Legal obligation: compliance with tax, accounting, consumer, and other mandatory regulations.

  • Legitimate interests: platform security, fraud prevention, service improvement, and operational analytics (balanced against your rights).

  • Consent: where required for specific processing (e.g., certain marketing communications, optional cookies/SDKs, or optional permissions).

  • Establishment, exercise, or defense of legal claims: handling disputes and legal proceedings.

Where required by law, we will obtain your explicit consent before processing.

8. Sharing and Disclosure of Personal Data

We may share your personal data only as necessary and proportionate for the purposes described in this Policy.

8.1 With Brands (Campaign Partners)

To run campaigns, we may share with the relevant brand(s):

  • your profile and eligibility attributes relevant to the campaign (e.g., location, interests, public social handles)

  • submitted content and related metadata

  • performance and completion status

  • communication necessary to deliver the campaign

Brands may act as independent data controllers for their own purposes. Where possible, we require brands to process data in line with applicable law and campaign terms.

8.2 With Service Providers (Processors)

We use trusted vendors to operate the Platform, such as:

  • cloud hosting and storage

  • analytics and crash reporting

  • email, SMS, push notification services

  • payment and banking partners

  • shipment/logistics partners

These providers process data under contractual obligations to protect it and only on our instructions.

8.3 With Legal Authorities and for Legal Reasons

We may disclose data where required by law, court order, or to protect rights, safety, and security, including:

  • responding to lawful requests

  • investigating suspected unlawful activity

  • protecting users and the public

8.4 Business Transfers

If we undergo a merger, acquisition, reorganization, or sale of assets, your data may be transferred as part of that transaction, subject to safeguards.

9. International Data Transfers

Your data may be stored and processed in Türkiye and/or other countries where our service providers operate.

Where international transfers occur, we apply appropriate safeguards as required by applicable law, such as:

  • contractual protections

  • access controls and encryption

  • data minimization and localization where feasible

If you need details about specific transfer locations and safeguards, you may request them via the contact section.

10. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, including:

  • the duration of your account and platform usage

  • campaign lifecycle and warranty/return periods for shipments

  • mandatory legal retention requirements (e.g., tax and accounting)

  • dispute resolution and enforcement needs

When retention is no longer required, we delete or anonymize data in a secure manner.

11. Your Rights

Subject to applicable law, you may have the right to:

  • learn whether your personal data is processed

  • request access to your personal data

  • request correction of inaccurate or incomplete data

  • request deletion or destruction where legal conditions are met

  • object to processing in certain circumstances

  • request restriction of processing

  • request data portability where applicable

  • withdraw consent (where processing is based on consent)

  • lodge a complaint with the competent authority

11.1 How to Exercise Your Rights

Submit your request through the contact channel(s) described in Section 2. We may need to verify your identity before fulfilling the request. Requests are handled within the timeframes required by law.

12. Cookies, SDKs, and Similar Technologies

We may use cookies (on web properties) and SDKs (in mobile apps) to:

  • enable core functionality (authentication, session management)

  • remember preferences

  • measure performance and improve the Platform

  • prevent fraud and abuse

12.1 Types of Technologies

  • Strictly necessary: required to operate the Services

  • Preferences: remember settings

  • Analytics/performance: understand usage and improve

  • Marketing/advertising (if used): measure and optimize campaigns

Where required, we will request your consent for non-essential technologies. You can manage preferences via device settings and, where applicable, the Platform settings.

13. Security Measures

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal data, including:

  • role-based access controls

  • encryption in transit and, where appropriate, at rest

  • logging and monitoring for suspicious activity

  • secure development and vulnerability management practices

No method of transmission or storage is completely secure. You acknowledge that residual risks may remain despite safeguards.

14. Content, Intellectual Property, and Publicity Notes

Campaign content you upload may include personal data (e.g., your image, voice, and account identifiers). Processing such content is necessary to:

  • review and approve deliverables

  • provide the content to brands as campaign outputs

  • measure and report performance

Your content usage rights, licenses, and approvals are governed by the Platform’s Terms and any campaign-specific agreements. This Policy explains privacy aspects only.

15. Children’s Privacy

The Platform is not intended for children. We do not knowingly collect personal data from children under the minimum age permitted by applicable law.

If you believe a child has provided personal data to us, contact us and we will take appropriate steps.

16. Automated Decision-Making

We may use automated tools to support:

  • fraud detection

  • spam prevention

  • campaign matching and eligibility signals

Where such processing produces legal or similarly significant effects, and where required by law, you may have rights to request information and contest decisions.

17. Data Breach Notification

If we become aware of a personal data breach that is likely to result in risk to individuals’ rights and freedoms, we will notify affected users and/or authorities as required by applicable law.

18. Changes to This Policy

We may update this Policy from time to time. If changes are material, we will provide notice through the Platform or other appropriate means.

Continued use of the Services after an update becomes effective means you acknowledge the updated Policy.

19. Governing Law

This Policy is governed by the laws of Türkiye, without prejudice to mandatory consumer or data protection provisions that may apply to you.

20. Contact

If you have questions, requests, or complaints regarding privacy, contact us using the contact channel(s) stated in Section 2.

Optional Annex A — Practical Examples of Data Use

  • Example (Gifting shipment): We share your name, phone, and delivery address with the logistics partner to deliver the product.

  • Example (Content review): Operations team reviews your uploaded media for compliance and quality; brands may receive approved deliverables.

  • Example (Payout): Finance team processes your payout based on completion criteria and tax requirements.

Optional Annex B — Data Categories by Feature

  • Account: identity, contact, device logs

  • Campaign participation: participation history, content metadata, survey answers

  • Content: media files, captions, posting URLs

  • Payments: wallet and payout records, invoices

  • Security: authentication logs, enforcement records