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TIPTOP GAME LIMITED

“MJ Art-AI Art Generator ”

Update Date: 30 May 2023

1. Objective

TIPTOP GAME LIMITED (“Tiptop Game” or “Company”)is committed to handling user's personal information in accordance with the principles of privacy and the relevant data protection laws, including the Personal Data Protection Law No. 6698 and other applicable laws. The company aims to ensure that all user data is processed in compliance with these laws and regulations.

The personal information that you have provided or will provide to our company, as well as any data obtained by our company through external means, may be processed by our company as the "Data Controller."

In line with the purpose of processing your personal data, it will be done in a limited and measured manner, ensuring the accuracy and up-to-date status of the information provided to our company. This data may be recorded, stored, preserved, reorganized, and transferred to authorized institutions as required by law. Additionally, it may be shared with third parties domestically or internationally in accordance with legislation and with your explicit consent if necessary. Furthermore, it may be processed using other methods listed in legislation and subject to other procedures outlined in the legislation.

This Privacy Policy has been established to ensure the ongoing and improved activities of Tiptop Game, aligned with the principles outlined in the PDP Law. Our Privacy Policy outlines the data we collect, how we intend to use, store, protect, and share this data, as well as how you can withdraw your consent for processing the data and revise any inaccuracies. Any capitalized terms used in this Policy have the same meanings as specified in the Terms and Conditions, unless separately defined in this Policy.

2. Purposes of Processing Personal Data and Legal Reasons

Your personal data will be processed through automated or non-automated means for the purposes outlined below, in compliance with applicable legislation and Articles 5 and 6 of the PDP Law. Processing is permitted when it is explicitly allowed by law, necessary for the establishment or execution of a contract or direct relationship, or for the legitimate interests of Tiptop Game, as long as your fundamental rights and freedoms are protected.

a) Purposes of Processing Personal Data

In accordance with this text, your personal data is processed for the following purposes in accordance with the above general conditions:

Process Security

● execution of activities in compliance with legislation

● execution of company/product/service commitment operations

● execution of communication activities

● execution/auditing of business activities

● conducting after-sales support services for goods/services

● execution of goods/services sales processes

● conducting storage and archive activities

● execution of agreement processes

● execution of information security processes

● conducting audit/ethical activities

● execution/audit of business activities

● conducting activities to ensure business continuity

● providing information to authorized persons, institutions and organizations

Customer Transaction

● execution/auditing of business activities

● conducting after-sales support services for goods/services

● execution of goods/services sales processes

● conducting activities for customer satisfaction

● execution of agreement processes

Marketing Data

● conducting marketing analysis studies

● execution of advertising/campaign/promotion processes

Besides, the purposes of processing personal data may be updated in line with our

obligations arising from our company policies and legislation; in particular,

● Creating user accounts for the service recipients/application users,

● Customizing our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’ experience,

● Informing about new products, services and applications and delivering you information regarding advertisements and promotions,

● Carrying out a digital subscription and in-app purchase processes of service recipients,

● Carrying out the auto-renewable subscriptions for giving users access to content, services, or premium features in our service,

● Carrying out the processes of information security,

● Conducting activities in accordance with legislation,

● Fulfilling the demands of competent authorities,

● Conducting the processes of finance and accounting transactions,

● Conducting communication activities,

● Conducting the processes of contracts,

● Carrying out strategic planning activities,

● Following up requests and complaints.

b) Legal Reasons

Customer Transaction

● It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract

● We have to process data in order to establish a right for you, to exercise and protect this right

Process Security

● The law explicitly stipulates the process by which we process your personal data

● Conditions that are necessary in order to fulfill our legal obligation

Marketing Data

● Your explicit consent (acquired via Apple and/or Google)

Third Party Websites and Applications

The MJ Art app may contain links to other websites whose content is not controlled by Tiptop Game and may have terms and conditions that differ from those of Tiptop Game. Tiptop Game cannot be held responsible for any use or disclosure of information that these linked websites may process. Similarly, Tiptop Game is not responsible for any links from other sites that are provided to MJ Art and owned by Tiptop Game.

We collect information using fair and lawful means, with your knowledge and consent. We inform you of the reason for collecting the information and how it will be used. You have the option to refuse our request for this information, but please note that we may not be able to provide you with some of the desired services without it.

Cookies are small text files that are stored in your browser or on the hard drive of your computer or mobile device when you visit a website or application. They help websites run more efficiently and provide personalized web pages that are tailored to your specific needs and preferences. Cookies only contain data about your website visit history over the internet and do not collect any personal information or files stored on your device.

We may use cookies to operate our services, improve performance and functionality, and deliver content, including ads relevant to your interests, on our sites or third-party sites. You have the option to delete cookies that are already present on your computer and prevent the recording or location of new cookies on your internet explorer.

Internet browsers are predefined to automatically accept the cookies as default. As the management of cookies varies from browser to browser, you may look at the help menu of the browser or application to get detailed information.

Push Notifications

Tiptop Game may occasionally send you push notifications through its mobile applications to inform you of application upgrades or notifications about our services. You have the option to edit your communication and notification preferences through your device's settings and stop receiving such notifications.

Your personal data will be stored for a period specified by applicable legislation or for a reasonable time until the purpose of processing no longer exists, or during legal periods of limitation. Tiptop Game may continue to store your personal data, even after the purpose of its use has expired, if it is required by other laws or with separate consent granted by you in this regard.

If you allow Tiptop Game to store your personal data for an additional period by providing your consent, the data will be deleted, destroyed, or anonymized immediately upon the expiry of this additional time or once the purpose of processing no longer exists.

Technical and Administrative Measures

Tiptop Game stores the personal data it processes in compliance with relevant legislation for the periods specified in that legislation or necessary for the processing purpose. Tiptop Game is committed to taking all necessary technical and administrative measures and due care to ensure the confidentiality, integrity, and security of personal data. Measures are taken to prevent the unlawful processing of personal data, unauthorized access, unlawful disclosure, modification, or destruction of data. Accordingly, Tiptop Game takes various technical and administrative measures related to the personal data it processes, including:

- Installation of a periodically updated anti-virus application on all computers and servers in Tiptop Game's information technology infrastructure.

Firewall. The data center and disaster recovery centers hosting Tiptop Game servers are protected by periodically updated software-loaded firewalls; the relevant next generation firewalls control the internet connections of all staff and provide protection against viruses and similar threats during this control.

VPN. Suppliers can access Tiptop Game servers or systems through SSL-VPN defined on Firewalls. A separate SSL-VPN identification has been made for each supplier; with the identification made, the supplier only provides access to the systems that it should use or is

authorized to use.

User identifications. Tiptop Game employees' authorization to Tiptop Game systems is limited only to the extent necessary by job descriptions; in case of any change of authority or duty, systemic authorizations are also updated. Information security threat and event management. Events that occur on Tiptop Game servers and firewalls, are transferred to the “Information Security Threat and Event Management” system. This system alerts the responsible staff when a security threat occurs and allows them to respond immediately to the threat.

Encryption. Sensitive data is stored with cryptographic methods and if required, transferred through environments encrypted with cryptographic methods and cryptographic keys are stored in secure and various environments.

Logging. All transaction records regarding sensitive data are securely logged.

Two-factor authentication. Remote access to sensitive data is allowed through at leasttwo-factor authentication.

Penetration test. Periodically, penetration tests are performed on servers in the Tiptop Game system. The security gaps created as a result of this test are closed and a verification test is performed to show that the relevant security gaps have been closed. Besides, Information Security Threat and Event Management System automatically performs penetration tests.

Test results are recorded.

Information Security Management System (ISMS). At the ISMS meetings made within Tiptop Game, the topics contained in the control forum are audited monthly by the director of information technology and the director of financial operations.

Training. In order to increase the awareness of Tiptop Game employees against various information security violations and to minimize the impact of the human factor in information violation incidents, trainings are provided to employees at regular intervals.

Physical data security. It ensures that personal data on papers is necessarily stored in lockers and accessed only by authorized persons. Adequate security measures (for situations such as electric leakage, fire, deluge, thievery etc.) are taken based on the nature of the environment where sensitive data is stored.

Backup. Tiptop Game periodically backs up the data it stores. As a backup mechanism, it uses the backup facilities provided by the cloud infrastructure providers, as well as the backup solutions it develops when deemed necessary, provided that it is in compliance with relevant legislation and provisions of this Policy.

Non-disclosure agreement. Non-disclosure agreements are concluded with employees taking part in sensitive personal data processing.

Transfer of sensitive personal data. If transfer of sensitive personal data is required through email; such transfer is done through (i) encrypted corporate email or (ii) Registered E-mail.

If MJ Art or the Tiptop Game system experiences attacks that result in damage to personal data, despite the implementation of necessary information security measures by Tiptop Game, or if unauthorized third parties gain access to personal data, Tiptop Game will promptly inform Users of the situation and, if necessary, the relevant data protection authority, and will take appropriate measures.

3. Transferring Personal Data to Third Parties

The PDP Law regulates the procedures and principles regarding the transfer of personal data in Articles 8 and 9. As we may utilize servers and cloud systems located outside of the country, it is possible that personal and sensitive data of the provider may be transferred to third parties both domestically and internationally. Your personal data may be transferred abroad for the following reasons:

● Conducting storage and archive activities

● Conducting business activities

● Conducting after-sales support services for goods/services

● Managing customer relationship management processes Tiptop Game may also transfer your personal data to services providers of our Company, third parties such as Facebook SDK, Adjust and Firebase Analytics which are embedded into our service for the following purposes:

● Sharing identity, communication and transaction security information with authorized public institutions and organizations for the purpose of execution of activities in compliance with legislation, monitor and execution of legal affairs, informing authorized persons, institutions and organizations.

● Sharing customer transaction information to manage after-sales support services, conduct business activities and manage customer relationship management processes.

4. Your Rights as the Data Subject

Pursuant to Article 11 of the PDP Law, you may request the following regarding your personal data by applying to Tiptop Game:

● Learn whether or not your personal data have been processed;

● Demand for information as to if your personal data have been processed;

● Learn the purpose of the processing of personal data and whether data are used in accordance with their purpose;

● Know the third parties in the country or abroad to whom your personal data have been transferred;

● In case the personal data is processed incompletely or inaccurately; requesting notification of the transactions made under this scope to third parties to whom personal data have been transferred;

● Request deletion, destruction or anonymization of personal data if the reasons for the processing have disappeared and request notification of the transactions made under this scope to third parties to whom personal data have been transferred;

● Object to occurrence of any result that is to your detriment by means of the analysis of personal data exclusively through automated systems;

● Request compensation for the damages in case you incur damages due to unlawful processing of your personal data.

Where General Data Protection Regulation (GDPR) is applicable, data subjects have the following rights:

● Right of access - Learning whether personal data is being processed and, if so, accessing your personal data and the information regarding the processing of your personal data,

● Right to correction -To request the correction of information that you believe is inaccurate or the completion of information that you believe is incomplete by Tiptop Game,

● Right to delete – To request deletion of personal data under the conditions stipulated in GDPR,

● The right to restrict processing - To request the restriction of the processing of personal data under the conditions stipulated in the GDPR,

● Right to object to processing - To object to the processing of personal data under the conditions stipulated in the GDPR,

● Right to data portability - To request the data collected by Tiptop Game to be transferred directly to another organization or under certain conditions,

● Objection to the occurrence of a result against the person himself/herself, by analyzing the processed data exclusively through automatic systems, including profiling.

To exercise your rights as a data subject, you must provide a clear and understandable request, accompanied by appropriate documentation if you are acting on behalf of someone else. The request must include your identity and address information, and be submitted through the "Data Subject Application Form" at tiptopgame@163.com. Our company will process your request, free of charge, within a maximum of 30 (thirty) days, as per Article 13 of the PDP Law, depending on the nature of the request. In the event that your request is denied, we will provide a written or electronic explanation along with a justification for the decision.

If you believe that we or someone with whom we have transferred your data is violating your rights, you can file a complaint to the data protection authority in your country and to other competent supervisory authorities.

This Privacy Policy may be revised by our Company when deemed necessary. If you continue to access MJ Art and use or access MJ Art without benefiting from the Services offered by Tiptop Game after the notification period, you shall be deemed to have allowed the changes in this Privacy Policy.