Back to Home

Privacy Policy

Last Updated: February 25, 2026

1. Introduction and Data Controller Information

Welcome to Turing's Twist ("we," "our," or "us"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our game, website, and related services (collectively, the "Services").

Data Controller: ALİ NEHİR DÜNDAR - Turing's Twist

Product/Service: Turing's Twist

Tax ID:3220865946

Address: Erenkoy Mah. Arsan Sk. Lale Apt. No:6 Flat:8 Kadikoy/Istanbul, Turkey

Phone: +90 506 053 34 38

Email: [email protected]

As a company based in Turkey serving users globally, we comply with Turkish data protection law (KVKK - Kişisel Verilerin Korunması Kanunu), the European Union's General Data Protection Regulation (GDPR), and other applicable data protection laws based on your location.

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this policy, please do not use our Services.

2. Information We Collect

2.1 Personal Information

We collect personal information that you provide directly to us, including:

  • Account Information: When you create an account, we collect your email address, username, and authentication provider information (Discord, Google, or email)
  • Profile Information: Display name, avatar selection, and any optional profile details you choose to provide
  • Payment Information: Payment details are collected and processed by our authorized payment service provider (see Section 5)
  • Communication Data: Information you provide when you contact our support team or communicate with us

2.2 Automatically Collected Information

When you use our Services, we automatically collect certain information, including:

  • Game Data: In-game messages, gameplay statistics, game results, voting patterns, and performance metrics
  • Usage Information: Pages visited, features used, time spent in-game, and interaction patterns
  • Device Information: IP address, browser type and version, device type, operating system, and unique device identifiers
  • Log Data: Server logs, including access times, pages viewed, and system errors
  • Cookies and Similar Technologies: See Section 8 for more details

2.3 Information from Third Parties

We may receive information about you from third parties, including:

  • Authentication Providers: When you sign in with Discord or Google, we receive basic profile information such as your name, email, and profile picture
  • Payment Provider: Our payment processor provides us with information about your transactions and subscription status

3. How We Use Your Information

We use the information we collect for various purposes, including:

3.1 Service Provision

  • Creating and managing your account
  • Providing access to game features and functionality
  • Processing payments and managing subscriptions
  • Delivering game content and AI-powered interactions
  • Matching you with other players in multiplayer mode

3.2 Service Improvement

  • Analyzing usage patterns to improve game mechanics and user experience
  • Training and improving our AI systems
  • Developing new features and game modes
  • Conducting research and analytics

3.3 Communication

  • Sending you important updates about our Services
  • Responding to your inquiries and providing customer support
  • Sending promotional communications (with your consent where required)
  • Notifying you about subscription renewals and token purchases

3.4 Security and Compliance

  • Protecting against fraud, abuse, and security threats
  • Enforcing our Terms of Service
  • Complying with legal obligations
  • Resolving disputes and addressing complaints

4. AI and Game Data Processing

Turing's Twist uses artificial intelligence to power the game experience. Your in-game messages and interactions are processed by AI systems to:

  • Generate bot responses and behaviors
  • Analyze gameplay patterns
  • Determine voting outcomes
  • Improve AI performance and game balance

4.1 Third-Party AI Services

We currently use Google Gemini AI as our primary AI service provider. We may also use other AI services including OpenAI and Anthropic in the future. When you play our game, your in-game messages and gameplay data may be processed by these third-party AI services:

  • Google Gemini: Processes in-game chat messages to generate AI bot responses. Google's use of this data is governed by their Privacy Policy.
  • Data Location: AI processing may occur on servers located in the United States and other countries where Google operates data centers.
  • Data Retention: We send only the necessary context (current game messages) to AI services. These services may temporarily cache data for processing but do not use your data to train their models (based on our API usage agreements).

4.2 AI Content and Privacy

Important: While AI responses are generated based on your in-game messages, we do not store complete conversation histories permanently. Gameplay data is retained only as long as necessary for:

  • Active gameplay sessions
  • Game analytics and improvement (anonymized)
  • Abuse prevention and content moderation

No Marketing Use: We do not use your in-game conversations for marketing purposes or share them with third parties for advertising.

AI Unpredictability: Please note that AI-generated content can be unpredictable. We train our AI systems to avoid inappropriate content, but we cannot guarantee all AI responses will be appropriate. See our Terms of Service for more information about AI-generated content.

5. Payment Processing and Data Sharing

Merchant of Record: Our order process is conducted by our online reseller and Merchant of Record. The Merchant of Record is responsible for all customer service inquiries and handles returns for purchases made through our Services.

All payment processing for subscriptions and token purchases is handled by our authorized payment service provider. When you make a purchase, we share necessary information with them, including:

  • Your name and email address
  • Purchase details (items, pricing, subscription terms)
  • Your location information (for tax calculation purposes)

Our payment processor collects and processes your payment information directly. We do not store your full credit card numbers or payment details on our servers. Their use of your personal data is governed by their own privacy policies and terms of service.

The payment processor provides us with transaction information, including purchase confirmations, subscription status, and refund details, which we use to manage your account and provide our Services.

6. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

6.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

  • Payment Processing: Third-party payment processors for payment and subscription management
  • Cloud Infrastructure: Hosting and database services
  • AI Services: Third-party AI providers for game functionality
  • Analytics: Services that help us understand how users interact with our Services
  • Customer Support: Tools to provide customer assistance

6.2 Legal Requirements

We may disclose your information if required to do so by law or in response to:

  • Legal processes, such as a court order or subpoena
  • Requests from law enforcement or government authorities
  • Protection of our rights, property, or safety, or that of our users or the public

6.3 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have.

6.4 With Your Consent

We may share your information for any other purpose with your consent.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit and at rest
  • Secure authentication and access controls
  • Regular security assessments and updates
  • Employee training on data protection
  • Secure backup and disaster recovery procedures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and track information and to improve our Services. Cookies are small data files stored on your device.

8.1 Types of Cookies We Use

  • Essential Cookies: Required for the operation of our Services, such as authentication and security
  • Functional Cookies: Remember your preferences and settings
  • Analytics Cookies: Help us understand how users interact with our Services
  • Advertising Cookies: May be used to deliver relevant advertisements (if applicable)

8.2 Your Cookie Choices

Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies, but this may affect your ability to use certain features of our Services.

Note that disabling essential cookies may prevent you from accessing key functionality of our Services.

9. Data Retention

We retain your personal information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

  • Account Information: Retained while your account is active and for a reasonable period afterward
  • Game Data: In-game messages and gameplay data are retained for a limited time for service improvement
  • Transaction Records: Payment and subscription information is retained as required by law and for accounting purposes
  • Support Communications: Retained for customer service purposes and as required by law

When we no longer need your information, we will securely delete or anonymize it.

10. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

10.1 Access and Portability

You have the right to request a copy of the personal information we hold about you and to receive that information in a structured, commonly used format.

10.2 Correction

You can update your account information at any time through your account settings. You may also request that we correct inaccurate information.

10.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (such as legal requirements or legitimate business needs).

10.4 Objection and Restriction

You may object to or request restriction of certain processing of your information, such as for marketing purposes.

10.5 Withdrawal of Consent

Where we rely on your consent to process your information, you have the right to withdraw that consent at any time.

10.6 Marketing Communications

You can opt out of marketing emails by clicking the unsubscribe link in any marketing email or by contacting us. Note that you will still receive transactional and service-related communications.

10.7 How to Exercise Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within the timeframe required by applicable law.

11. International Data Transfers

As a Turkish company serving users globally, your information may be transferred to and processed in Turkey and other countries, including:

  • Turkey (where our primary servers and operations are located)
  • European Union countries (for EU-based service providers)
  • United States (for cloud services and AI processing)
  • Other countries where our service providers operate

These countries may have data protection laws that are different from the laws of your country. When we transfer your information internationally, we implement appropriate safeguards, including:

  • Standard Contractual Clauses approved by the European Commission (for EU data transfers)
  • Data processing agreements with all service providers
  • Technical and organizational security measures
  • Compliance with KVKK requirements for cross-border data transfers

For more information about our international data transfers and the safeguards we have in place, please contact us at [email protected].

12. Children's Privacy

Minimum Age: Our Services are intended for users who are at least 16 years old. We do not knowingly collect personal information from individuals under 16. If you are under 16, please do not use our Services or provide any information to us.

Age Verification: We may implement age verification mechanisms to ensure compliance with this age requirement. If we discover that we have inadvertently collected personal information from a user under 16, we will take immediate steps to delete that information.

Parental Consent (16-17 years): Users between the ages of 16 and 18 must have permission from a parent or legal guardian to use our Services. By allowing a minor to use our Services, parents/guardians agree to these Terms and assume responsibility for the minor's use of our Services.

AI Content Warning: Our game uses AI that can produce unpredictable content. Despite our best efforts to filter inappropriate content, we strongly recommend parental guidance for all users under 18.

For Parents/Guardians: If you are a parent or guardian and believe that your child under 16 has provided us with personal information or created an account, please contact us immediately at [email protected]. We will promptly delete the account and any associated data.

13. California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information:

  • Right to know what personal information is collected, used, shared, or sold
  • Right to delete personal information held by us
  • Right to opt-out of the sale of personal information (we do not sell personal information)
  • Right to non-discrimination for exercising your CCPA rights

To exercise these rights, contact us at [email protected].

14. Turkish Data Protection Rights (KVKK)

Under the Turkish Law on Protection of Personal Data (KVKK - Kişisel Verilerin Korunması Kanunu), as the data subject, you have the following rights:

  • To learn whether your personal data is being processed
  • To request information regarding processing if your personal data has been processed
  • To learn the purpose of processing and whether personal data is used in accordance with its purpose
  • To know the third parties to whom your personal data is transferred domestically or abroad
  • To request correction of incomplete or inaccurate data, if any
  • To request deletion or destruction of your personal data under the conditions set forth in Article 7 of KVKK
  • To request notification of corrections, deletions, or destructions to third parties to whom your personal data has been transferred
  • To object to the occurrence of a result against yourself by analyzing the processed data exclusively through automated systems
  • To claim compensation for damages incurred due to unlawful processing of your personal data

To exercise these rights, you can send your request to [email protected] or submit a written application to our address. We will respond to your request within 30 days in accordance with KVKK requirements.

If you believe your rights under KVKK have been violated, you can lodge a complaint with the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu - KVKK).

15. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA) or the United Kingdom, the General Data Protection Regulation (GDPR) provides you with certain rights regarding your personal data.

15.1 Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Contract Performance: To provide our Services and fulfill our contractual obligations
  • Legitimate Interests: For our legitimate business interests, such as improving our Services, fraud prevention, and network security
  • Consent: Where you have given explicit consent for specific processing activities (e.g., marketing communications)
  • Legal Obligations: To comply with applicable laws and regulations

15.2 Your GDPR Rights

Under the GDPR, you have the right to:

  • Access your personal data
  • Rectify inaccurate personal data
  • Erase your personal data ("right to be forgotten")
  • Restrict processing of your personal data
  • Data portability (receive your data in a structured, machine-readable format)
  • Object to processing based on legitimate interests
  • Withdraw consent at any time (where processing is based on consent)
  • Lodge a complaint with your national data protection supervisory authority

To exercise these rights, please contact us at [email protected]. We will respond to your request within one month in accordance with GDPR requirements.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of any material changes by:

  • Posting the updated policy on our website
  • Updating the "Last Updated" date at the top of this policy
  • Sending you an email notification (if you have provided your email address)
  • Displaying a prominent notice in the game

Your continued use of our Services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Privacy Policy periodically.

17. Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to those third-party services.

We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services before providing them with your information.

18. Do Not Track Signals

Some web browsers have a "Do Not Track" feature that signals to websites that you do not want your online activities tracked. Our Services do not currently respond to Do Not Track signals due to the lack of industry standards for implementing such signals.

19. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Data Controller: ALİ NEHİR DÜNDAR - Turing's Twist

Product/Service: Turing's Twist

Email: [email protected]

For payment and billing inquiries, please contact our payment processor directly as they are the Merchant of Record.

We will respond to your inquiry as soon as possible, and in any event within the timeframe required by applicable law:

  • KVKK (Turkey): Within 30 days
  • GDPR (EU/UK): Within 1 month
  • CCPA (California): Within 45 days

By using Turing's Twist, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and disclosure of your information as described herein.