As GALTEM TEKNOLOJİ LİMİTED ŞİRKETİ ("Galtem" or the "Company"), we attach importance to the security of your personal data in the services we provide through the Triarch Online game and the triarch.online web portal. We process and store the personal data of those who use our services in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK") and related legislation.
This notice explains the collection, processing, transfer and storage of your data within the framework of Article 10 of the KVKK ("Obligation of the Data Controller to Inform") and Article 11 ("Rights of the Data Subject").
Personal Data We Process and Purposes
| Data Group | Scope | Purposes of Processing |
|---|---|---|
| Account Details | Username, e-mail address, encrypted password, IP address, login and usage history | Creating and managing the account; providing the services; contacting you when necessary; ensuring account security; providing information to the competent judicial authorities in cases of fraud, including account theft |
| Billing Details | Full name, Turkish ID number, billing address, phone number, IP address | Fulfilling legal obligations and performing the contract in purchase transactions; providing information to the competent judicial authorities in cases of fraud |
| Game Data | Character name, guild name, in-game statistics and activity records, IP address, device-specific identifiers | Providing the game service; analysis and development activities; moderation and protection of a fair play environment; providing information to the competent authorities in cases of fraud |
| Cookies | Small information files stored in your browser | Session management; improving our services; presenting content suited to you; analysis activities |
Legal Grounds for Processing
Your data is processed on the basis of the following clauses of Article 5/2 of the KVKK within the scope of your use of our services and your purchases:
- clause (a): it is expressly provided for by law,
- clause (c): it is necessary and directly related to the establishment or performance of a contract,
- clause (ç): it is necessary for the Company to fulfil its legal obligations as data controller,
- clause (e): it is necessary for the establishment, exercise or protection of a right of the Company.
How Personal Data Is Collected
We collect your personal data electronically through our web portal, our game client and our support channels.
Parties to Whom Personal Data May Be Transferred
Where necessary to comply with its legal obligations, to perform its contractual responsibilities, or to establish, exercise or protect a right, the Company may transfer your personal data:
- directly to law enforcement units, judicial authorities, relevant ministries and other public institutions authorised by law,
- limited to and proportionate with the fulfilment of obligations, to payment institutions, banks, hosting and technical infrastructure providers, audit firms, lawyers, financial advisors and similar service providers, taking the maximum precautions possible.
Transfer of Personal Data Abroad
Your personal data is primarily stored on servers in Türkiye. However, as our services are global in scale, your game data may be transferred to servers abroad that remain under the Company's control, in line with technical requirements. This transfer is based on the consent explicitly obtained from you during registration (KVKK Art. 9/1).
In addition, corporate e-mail and cloud infrastructure services are obtained from providers whose servers are located abroad. If you do not consent to your e-mails and their attachments being stored on these providers' servers abroad, we recommend that you do not send us personal data by e-mail.
Retention Period of Personal Data
Your personal data is processed for the period required by the purposes explained in this notice, in accordance with the data processing and limitation periods set out in the KVKK and other applicable legislation. When these periods expire or the purpose of processing ceases to exist, your data is deleted, destroyed or anonymised. If the periods in the legislation change, the new periods apply.
Your Rights Regarding Your Personal Data
Under Article 11 of the KVKK, you may exercise the following rights by applying in writing to ATAKÖY 7-8-9-10. KISIM MAH. ÇOBANÇEŞME E-5 YAN YOL CAD. ATAKÖY TOWERS A BLOK NO: 20/1 İÇ KAPI NO: 70 BAKIRKÖY/İSTANBUL, or by sending an e-mail to info@galtemgames.com from the e-mail address registered in our system:
- to learn whether your personal data is processed,
- to request information if it has been processed,
- to learn the purpose of processing and whether the data is used in line with that purpose,
- to know the third parties to whom the data is transferred, in Türkiye or abroad,
- to request the correction of incomplete or inaccurate data,
- to request the deletion or destruction of the data under the conditions set out in Article 7 of the KVKK,
- to request that corrections and deletions be notified to the third parties to whom the data was transferred,
- to object to a result arising against you from the analysis of your data exclusively by automated systems,
- to claim compensation for damage suffered due to unlawful processing of your data.
Handling of Applications
The Company concludes your request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on its nature. If the process additionally incurs a cost, the fees in the tariff determined by the Personal Data Protection Board may be charged.
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, applications must include your full name, signature, Turkish ID number, residential or workplace address, e-mail address and phone number for notification if available, and the subject of the request. Applications lacking these elements will not be processed. The Company either accepts your request or rejects it with an explanation, and notifies you of the outcome in writing or electronically.
Last updated: 20.07.2026
