BORN IN WAR — PRIVACY POLICY

Effective date: 14 October 2026
Last updated: 14 October 2026

1. Scope and data controller

This Privacy Policy explains how personal data is processed in Born in War, developed by Quell Studios, and in related player support services. Processing carried out by independent third parties within their own services is also subject to those providers' privacy notices.

Data controller / operator: Quell Studios
Address: Merkez Mahallesi, Abide-i Hürriyet Caddesi, Şişli, 34360 Istanbul, Türkiye
Support and privacy contact: [email protected]
Business inquiries and proposals: [email protected]

In this policy, “Quell Studios”, “we”, “us” and “our” refer to the operator identified above. This policy provides information about data processing; it does not replace consent where separate consent is required.

2. Data we process and its sources

Quell Studios processes the following information relating to Born in War players:

• Profile information: name, email address and age information.
• Game records: player ID, in-game name, inventory, all game progress, cosmetic and pet ownership, item upgrades and associated event records.
• Purchased-content records: ownership and inventory information for in-game content and transaction evidence provided where needed to verify a purchase or redelivery request.
• Support correspondence: the email address, message, attachments you choose to send and player information you provide when requesting support.

Information comes from what you provide directly, account information supplied to the game by the connected Google/Apple services you use, and records generated by your in-game activity.

Quell Studios keeps your name, email and age information together with inventory and game-progress records. Authentication of your Google and Apple accounts is handled by the relevant provider; we do not store those accounts' passwords. Player identifiers and verification information supplied by connected services are used to match you to your game account.

If your account has not been deleted, signing in again with the same Google/Apple account you previously linked lets you access your existing inventory and game progress. Announced planned resets during early access and account deletion at your request are subject to the conditions explained in the relevant sections.

Game records linked to a player may also constitute personal data and are covered by this policy. If you do not provide information necessary for a feature, that feature may not be available.

3. Purposes and legal bases

We limit processing to what is necessary for specified purposes. For processing governed by Turkish law, we rely on the relevant conditions in Article 5 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”):

• Authenticating players, maintaining game progress, and providing item upgrades and the event feed: necessity for entering into or performing a contract.
• Resolving game-support requests: contract performance where relevant; for matters outside contract performance, such as security or complaint investigations, our legitimate interest in operating a secure and reliable service, provided this does not harm your fundamental rights and freedoms.
• Preventing cheating, unauthorized access and misuse: our legitimate interest in protecting the service and players, following an assessment that respects your fundamental rights and freedoms.
• Keeping legally required records and responding to lawful authority requests: processing expressly provided for by law or necessary to comply with a legal obligation.
• Using evidence and relevant records in specific disputes: necessity for establishing, exercising or protecting a right.
• Verifying purchase transactions and delivering content: necessity for entering into or performing a contract; applicable legal obligations for required financial records.

Processing that requires separate consent does not begin without the required consent. Using the game or reading this policy does not by itself constitute consent.

Where other data protection laws apply, their processing conditions are also met.

Age information is used to apply the minimum-age requirement and determine necessary child-protection measures, relying on our legitimate interest in providing an age-appropriate service while respecting your fundamental rights and freedoms. Name and email are processed for contract performance to the extent necessary to identify and manage the game account and communicate about support you request. Other uses requiring a separate legal basis or permission are not automatically included in these purposes.

To preserve ownership of paid costumes, pets and similar content that does not affect game balance or players' power, progress or competition, and redeliver it where necessary after a reset carried out by Quell Studios during early access, data necessary to verify ownership and match it to the correct player is processed for contract performance. Quell Studios' inventory records and valid purchase evidence where needed are used for this purpose. This purpose is not a blanket basis for refusing a separate account/data deletion request or retaining all player data indefinitely.

4. Advertising and the event feed

The current version of Born in War does not display in-app advertising.

The current version does not offer player-written free-text chat, clan chat or private messaging. The feed called “event chat” displays notices automatically generated by the game about item upgrades. Players cannot write messages in this feed.

The in-game information displayed in the feed is visible to other players who can access the relevant event screen.

5. Recipients of data

Data is shared only to the extent necessary for the relevant purpose and where the appropriate legal conditions are met:

• Google and Apple: information needed for the Google Play Games, Apple Game Center and Sign in with Apple features you use.
• Infrastructure and support providers: information needed to operate game infrastructure and support on our behalf.
• Other players: the in-game information visible in the event feed described in Section 4.
• App stores or payment providers: information needed for purchase verification, content delivery and refunds.
• Competent authorities and legal advisers: where disclosure is necessary and lawful to comply with legal duties or protect a specific right.
• Parties involved in a business transaction: necessary data in a merger, acquisition or transfer, subject to appropriate confidentiality safeguards, legal conditions and notices.

Providers processing data on our behalf have access limited to the information needed for their tasks. Providers acting as independent controllers describe their own processing in their privacy notices.

Google privacy notice: https://policies.google.com/privacy
Apple privacy notice: https://www.apple.com/legal/privacy/

6. International transfers

Personal data may be processed outside Türkiye through Google, Apple or other providers used to deliver the service.

International transfers take place subject to the processing and transfer conditions required by Article 9 of the KVKK and other applicable laws. You can request information about transfers and relevant safeguards at [email protected]. Using the game is not treated as blanket consent to international transfers.

7. Retention and deletion

We keep name, email, age, inventory and game-progress records for as long as necessary to operate your account and provide the service you request. Signing out or uninstalling the app does not itself delete your game records while your account remains undeleted; those records can be used when you sign in again with the same connected account.

Support correspondence is retained to the extent necessary to resolve the request and address a specific related dispute. Purchase or ownership records are limited to the period needed to provide content, preserve the paid content described in Section 9.1 of the Terms of Service during a planned reset, and perform necessary verification.

Retention of event and other game records depends on the operation of the relevant feature, the record's purpose and any specific security or dispute-related need. When a record is no longer necessary for those purposes, it is erased, destroyed or anonymized so that it cannot be linked back to a person.

When you delete your account, all game data and content linked to it, together with associated personal data under our control, is deleted as described in Section 9. We do not retain data to restore the deleted account or its content later. Relevant data in any backups and with providers processing on our behalf is also covered by deletion.

If applicable law requires a particular record to be retained, only the required record is kept, limited to the relevant legal purpose and period; those records are not used to recreate the game account or deleted content. Such a requirement does not mean that your game account, progress or paid content will be preserved.

Account and store-transaction records held by Google or Apple as independent controllers are subject to the relevant provider's own privacy and retention rules.

8. Your rights and how to exercise them

Under Article 11 of the KVKK, you have rights to learn whether your personal data is processed; request information about processing; learn its purposes and whether use is consistent with those purposes; learn the domestic or overseas recipients; request correction of incomplete or inaccurate data; request erasure or destruction where legal conditions are met; request notification of corrections and erasure to relevant recipients; object to a result against you arising exclusively from automated analysis; and seek compensation for damage caused by unlawful processing.

Contact [email protected] with privacy requests. You may also submit a duly made KVKK request in writing to the postal address in Section 1 or through other methods recognized by applicable law. Writing from the email associated with your account helps verify your identity; we may request proportionate additional verification where necessary.

We resolve KVKK requests as soon as practicable according to their nature and within 30 days. Requests are generally free; a fee may apply only where permitted by law and the relevant conditions are satisfied. Your right to complain to the Turkish Personal Data Protection Board remains subject to the KVKK's application procedures and deadlines.

If the GDPR or another data protection law applies, you may also have rights, subject to the relevant conditions, of access, rectification, erasure, restriction, portability, objection and complaint to a competent supervisory authority. You may withdraw consent to consent-based processing without affecting the lawfulness of earlier processing. The applicable law's response periods and safeguards apply.

9. Account and data deletion

You may delete your account and associated data at any time using the account-deletion option in Born in War's Settings. If you cannot access the game or need help, contact [email protected].

Once account deletion is completed, all game data and content linked to the account is deleted. This includes profile information such as your name, email and age, player records, all game progress, inventory, items, upgrades, costumes, pets and in-game ownership records for other paid or free content. Other personal data linked to the account under our control is also covered by deletion. Section 7 explains the treatment of any records that must be retained by law.

Deletion is permanent. The deleted game account, progress and content are not restored. Signing in again with the same Google/Apple account you previously used does not bring back deleted data or paid content. Creating a new game account later does not transfer the previous account's content to it.

Deleting your Born in War account does not close your Google or Apple account. Account and store-transaction records held independently by those providers are subject to their privacy and retention rules. This does not remove our responsibility to delete game data under our control.

Uninstalling the game or signing out of a connected account does not itself delete your account.

In a planned early-access reset carried out by Quell Studios, paid costumes, pets and similar content that does not affect game balance or players' power, progress or competition are preserved under Section 9.1 of the Terms of Service; progress and values affecting gameplay are reset. This protection does not apply when you choose to delete your account. Deleting your account also deletes that paid content. Your statutory consumer and personal-data rights remain unaffected.

10. Children's data

The minimum age for using Born in War is 13. The game is not directed to children under 13, and they are not permitted to use it.

Being 13 or older does not mean that you can independently give valid consent to personal data processing in every country. If parental or guardian authorization is required because of your age and applicable law, the required authorization is obtained for that processing; processing requiring authorization does not begin before those conditions are met.

If we learn that a child's data has been processed without the required conditions being met, we take steps to stop the relevant processing, assess the situation and carry out deletion or other protective measures required by law. Parents and guardians can contact [email protected].

11. Security

We apply technical and organizational measures appropriate to the processing risks to protect personal data against unlawful processing, unauthorized access, loss and alteration. Access permissions are limited by role, and safeguards are assessed against the service's risks.

No system provides absolute security. This does not remove our statutory security duties. If a breach occurs, we carry out the response and notification obligations required by applicable law.

12. Changes and contact

When this policy is updated, we publish the revised version and change its last-updated date. We provide appropriate notice of material changes, in advance where required by law. If new processing requires consent, we obtain it separately.

If clan chat, private messaging or other social features are introduced later, their data, visibility, moderation and retention practices will be explained appropriately before use. This policy does not constitute blanket authorization for features that are not yet offered.

Privacy and player support: [email protected]
Business inquiries and proposals: [email protected]