Chained Wheels Privacy Notice
This notice explains how Karga Games processes personal data in connection with the video game Chained Wheels (the “Game”). It supplements the Karga Games Privacy Policy. If the two notices conflict about the Game, this game-specific notice controls.
1. Data controller
Legal name: KARGA OYUN YAZILIM TEKNOLOJİLERİ ANONİM ŞİRKETİ (trading as Karga Games)
MERSİS number: 0524165627900001
Trade registry: Doğanbey / 5241656279
Address: Üniversiteler Mah. İhsan Doğramacı Blv. No: 27 İç Kapı No: B01 Çankaya / ANKARA, Türkiye
Email: legal@kargagames.com
2. Data we process
- Platform and multiplayer data: platform account ID, display name, lobby or session identifiers, invitation and connection information, and limited network information required to establish and maintain online co-op sessions. The current version uses Steam networking.
- In-game communications: real-time text and voice communications transmitted to other session participants. Karga Games does not record or store live text or voice chat, unless a player separately includes communication content in a report sent to us.
- Gameplay analytics: GameAnalytics and Google Analytics process pseudonymous installation or device identifiers, game version, platform, operating system, device characteristics, session and progression events, feature usage, approximate region, and IP address as technically received by those services.
- Crash diagnostics: Sentry processes crash reports, error messages, stack traces, game and operating-system version, device characteristics, timestamps, pseudonymous identifiers, and technical network information.
- Platform features: the relevant platform may process cloud-save files, achievements, leaderboard entries, account identifiers, and related timestamps under its own terms and privacy notice.
- Reports and feedback: when a player voluntarily sends an in-game report or feedback message, we receive the player's applicable platform account ID, the message, approximate playtime in minutes, and the submission date and time. The current Steam version submits the Steam ID.
- Technical and security logs: our web host may temporarily log IP address, request time, requested endpoint, response status, and similar security information when the Game connects to a Karga Games endpoint.
- Support: if a player contacts us, we process the email address, message, attachments, and other information the player chooses to provide.
The Game does not use advertising profiles or cross-game behavioral tracking. Platform operators independently process purchases, platform accounts, network services, parental controls, and other platform data under their own terms and privacy notices.
2A. Platform-specific processing and launch status
Only the row marked Active currently applies. A planned row becomes applicable only when Karga Games launches that version and changes its status and the “Last updated” date before processing begins.
| Platform/service | Status | Data and functions when active | Platform operator role |
|---|---|---|---|
| Valve / Steam | Active | Steam ID and display name; Steam Networking lobbies, sessions and invitations; voice/text transport; Steam Cloud; achievements; leaderboards; ownership and entitlement status. | Valve independently controls Steam accounts, store transactions and Steam services. Karga Games controls data it receives for its own Game operations. |
| Epic Games Store and Epic Online Services (EOS) | Planned — not active | Epic Account ID or Product User ID; display name where enabled; Connect account links; authentication; lobbies, sessions, matchmaking, invitations, voice/text services, achievements, sanctions or reports, and cross-platform account associations, depending on the EOS services actually enabled. | Epic and Karga Games may act as independent controllers for Epic Account Data received by Karga Games. EOS processor/controller terms apply according to the selected service. |
| GOG / GOG Galaxy | Planned — not active | GOG account identifier and display name; entitlement; Galaxy multiplayer, invitations, achievements, leaderboards, cloud saves and communication features, if integrated. | GOG independently controls GOG accounts, store transactions and GOG services. Karga Games controls data it receives for its own Game operations. |
| Microsoft / Xbox network | Planned — not active | Xbox user ID and gamertag; entitlement; multiplayer sessions, cross-network play, invitations, achievements, leaderboards, cloud/title storage, safety reports and communications, depending on the approved Xbox integration. | Microsoft independently controls Microsoft/Xbox accounts, transactions and Xbox network services. Karga Games is an independent controller for Xbox user data it receives. |
| Sony Interactive Entertainment / PlayStation Network | Planned — not active | PSN account identifier and online ID; entitlement; multiplayer, invitations, trophies, leaderboards, cloud storage, parental controls, safety reports and communications, depending on the approved PlayStation integration. | Sony independently controls PSN accounts, transactions and PlayStation services. Karga Games controls data it receives for its own Game operations. |
| Nintendo | Planned — not active | Nintendo Account or platform identifier and nickname; entitlement; multiplayer, invitations, achievements where supported, rankings, cloud storage, parental controls, safety reports and communications, depending on the approved Nintendo integration. | Nintendo independently controls Nintendo accounts, transactions and Nintendo services. Karga Games controls data it receives for its own Game operations. |
When cross-play is enabled, platform identifiers may be associated with an EOS Product User ID or another cross-platform identifier only as necessary to authenticate the player, connect requested accounts, and provide cross-platform sessions and social features. Karga Games will not use platform data for advertising or sell it.
3. Why we process data and our legal bases
- To provide online co-op and Game functionality: performance of our contract with the player.
- To provide optional gameplay analytics: consent where applicable law requires it; otherwise, our legitimate interest in understanding and improving the Game, provided that interest is not overridden by the player's rights.
- To diagnose crashes, receive and investigate reports, provide support, improve stability, prevent abuse, and secure our systems: our legitimate interests in operating, supporting, and protecting the Game and its players.
- To comply with tax, accounting, legal-process, and regulatory duties and to establish or defend legal claims: compliance with law and our legitimate interests.
Under Türkiye's Law No. 6698 on the Protection of Personal Data (“KVKK”), the corresponding grounds include necessity for performance of a contract, compliance with a legal obligation, establishment or protection of a right, and legitimate interests that do not override the player's fundamental rights and freedoms. We do not rely on consent where another lawful basis properly applies.
4. How data is collected
Data is collected electronically and automatically from the applicable platform or online-service SDK and the player's device when the player launches the Game or uses online features, and directly from the player when they change a privacy choice, voluntarily submit a report, or contact support.
5. Who receives data
We disclose only what is reasonably necessary to:
- Valve/Steam, which currently distributes the Game and provides account, cloud, achievement, leaderboard, communication, and online functionality;
- Epic, GOG, Microsoft/Xbox, Sony/PlayStation, or Nintendo only after the corresponding version or online service is activated, and only for the platform functions described in Section 2A;
- GameAnalytics for gameplay analytics;
- Sentry Cloud for crash diagnostics and error monitoring;
- Google for Google Analytics integrated into the Game;
- Hostinger's Frankfurt, Germany data center for Karga Games endpoints, report storage, databases, and security logs;
- professional advisers, courts, regulators, law enforcement, or other parties when required by law or necessary to protect rights and safety; and
- a buyer or successor in a merger, reorganization, financing, or sale of the relevant business, subject to applicable law.
We do not sell personal data or share it for cross-context behavioral advertising.
Teneke Kafalar acts only as a publisher of the Game and does not receive Game player personal data from Karga Games.
6. International transfers
Karga Games is established in Türkiye, and Karga Games hosting is located in Hostinger's Frankfurt, Germany data center. Sentry Cloud, Valve, GameAnalytics, Google, and the subprocessors of these providers may process data in Türkiye, the European Economic Area, the United States, or other countries disclosed by the relevant provider and account configuration. Where a restricted international transfer occurs, we use a legally recognized transfer mechanism and any required supplementary safeguards, including applicable adequacy decisions, standard contractual clauses, or another mechanism permitted by KVKK, the GDPR, UK GDPR, or other applicable law.
7. Retention
- In-game reports and associated Steam ID and playtime: up to 24 months after submission, unless longer retention is reasonably necessary for an active investigation, dispute, or legal duty.
- Web, hosting, and security logs controlled by Karga Games: normally up to 90 days, unless a security incident requires longer retention.
- GameAnalytics player-level analytics: up to 24 months unless a shorter period is configured.
- Sentry crash diagnostics: up to 90 days.
- Google Analytics user-level and event-level data: up to 14 months; aggregated reporting may be retained longer without player-level identifiers.
- Support correspondence: up to 24 months after the request is closed, unless longer retention is required for a dispute or legal duty.
- Live multiplayer and communication data handled by Karga Games: only for the session or as technically necessary to transmit it; we do not intentionally retain its content.
After the applicable period, data is deleted or anonymized unless law requires continued retention.
7A. Analytics choices and automated decisions
Where required, optional analytics must remain disabled until the player receives an in-game disclosure and provides consent. A player may withdraw an analytics choice through the Game's privacy settings when that control is available in the relevant build. Withdrawal stops future optional analytics but does not affect prior lawful processing. Crash diagnostics that are strictly necessary for security and stability may be processed under legitimate interests where law permits.
Karga Games does not use the data described in this notice to make solely automated decisions that produce legal or similarly significant effects, or to determine prices, eligibility, or access based on profiling.
8. Player rights
Depending on location, a player may have the right to ask whether we process their data and to request access, correction, deletion, restriction, portability, or information about recipients; object to processing based on legitimate interests; withdraw consent where consent is used; and complain to a competent data-protection authority. KVKK Article 11 provides additional rights, including learning the purpose of processing and whether data was used accordingly, learning third-party recipients, and seeking remedies for unlawful processing.
Use the Chained Wheels Data Request and Deletion page or email legal@kargagames.com. Please include enough information to identify the relevant record, such as the platform and account ID used to submit a report. We may take proportionate steps to verify identity, but we will not request a government identity number unless it is strictly necessary and legally appropriate.
Deleting Karga Games-controlled data does not delete a Steam, Epic, GOG, Microsoft/Xbox, PlayStation, or Nintendo account. Platform-account requests must also be directed to the relevant platform. When Epic or another platform forwards a valid deletion request concerning data controlled by Karga Games, we will process it as required by the applicable platform terms and law.
9. Age requirements
The Game is intended for players aged 13 and older and is not directed to children under 13. Platform age, child-account, and parental-control requirements also apply. Players who have not reached the age at which they may independently consent to applicable terms under local law must have a parent or legal guardian review and agree to the applicable terms. A parent or guardian who believes a child under 13 provided personal data to Karga Games should contact us so we can investigate and delete it where required.
10. Security
We use reasonable technical and organizational measures intended to protect personal data. No method of transmission or storage is completely secure.
11. Changes
We will update this notice and the platform status table before enabling EOS, launching another platform version, or adding advertising, in-game purchases, paid DLC telemetry, anti-cheat, stored communications, or another material data use. We will change the date above and provide any additional notice or consent legally required before the new processing begins.
12. Contact
Questions, privacy requests, and complaints may be submitted through the Data Request and Deletion page, emailed to legal@kargagames.com, or mailed to the controller address in Section 1.