Privacy Policy — Regnia

1. Introduction

This Privacy Policy explains how KUTLUK LLC ("KUTLUK LLC", "we", "us") collects, uses, stores, shares and protects personal data when you use the Regnia mobile application and related services, websites, support channels and features.

Regnia is operated by KUTLUK LLC, a limited liability company registered in Wyoming, United States.

• Privacy contact: info@kutlukgames.com
• Support contact: support@kutlukgames.com

This policy is available in several languages. If the language versions differ, the English version prevails. This does not limit any mandatory rights you have under the law of your country.

2. Scope

This policy applies to:

1. The Regnia mobile application (iOS and Android)
2. Guest accounts and accounts linked with Sign in with Apple or Google Sign-In
3. Gameplay: match-3 levels, progression, the territory map, raids, reinforcements, clans ("Boy"), clan chat, rankings, badges and virtual items
4. Invitations and shareable conquest cards
5. Support communication
6. Future features described in Section 20

It does not apply to third-party websites, app stores, payment providers or services we do not control.

3. Data Controller

• Name: KUTLUK LLC
• Application: Regnia
• Address: 30 N Gould St #66912, Sheridan, WY 82801, United States
• Privacy contact: info@kutlukgames.com

4. Information We Collect

4.1 Account information

1. Player ID (generated by us)
2. Display name and portrait you choose; your profile photo if you upload one
3. Guest account identifier bound to your device installation
4. Sign in with Apple identifier and, if shared, email address (this may be an Apple private relay address)
5. Google account identifier and, if shared, email address
6. Email address if you sign in by email (to send the verification code and recognise your account). We keep the verification code and your IP address only as an irreversible hash (digest) and for at most 24 hours; your email address is kept with your account and deleted when the account is deleted
7. Account creation date, account status, language and country preference, theme and app settings
8. Age group derived from the birth year you enter at first launch (we store only the age group, not the birth year). If you are aged 13–17 you can re-declare your age at most once a year; in that case your birth year is sent to us only to work out the age group while your request is processed and is not stored. The only things we keep are the age group (13–17 or 18+) and the date of the re-declaration

Guest accounts are tied to your device. If you delete the app without linking Apple or Google, your progress may be lost permanently.

4.2 Gameplay and progression data

1. Levels played, attempts, wins and losses, moves remaining, boosters used
2. Move logs: for each level attempt we store the random seed, level version and the sequence of moves you made. Because the game engine is deterministic, this lets us replay a game exactly.
3. Scores, Influence ("Nüfuz"), Kut points, streaks, ranks and badges
4. Territory activity: settlements, spreading, raids, reinforcements, defenses, conquests
5. Inventory: Akçe (in-game currency), boosters, shields, chest openings and rewards
6. Clan activity: membership, rank, donations, votes in clan elections ("Kurultay"), rewards distributed by the clan leader
7. Invitation codes you create or redeem

We use move logs to validate results and prevent cheating, to measure how difficult levels are, and to improve level design. Move logs are stored linked to your account's internal player number. We may also use them to build internal statistical models that estimate level difficulty. These models are used only inside Regnia and are not sold or shared.

4.3 Location data

Regnia is a location-based game: territories correspond to real-world areas.

• Regnia asks only for approximate location permission, not precise location. If you grant it, your device converts its location on the device into a region cell (an H3 hexagon) covering an area of at least about 4 km² (typically a few square kilometres). Raw GPS coordinates and any smaller area never leave your device: we receive the region cell, not your coordinates and not an address. Because a cell is linked to your account, we treat it as personal data. Location is read only while the app is open and in use; we do not collect location in the background. Together with the cell we also receive the time of the measurement and whether the device reported a mock (fake) location.
• Anchor locations: You may set up to two "anchor locations" (for example home or work). We store them as the same region cell, not as addresses. You can change them at any time; they are deleted when your account is deleted.
• Earlier versions: Finer location records stored by earlier versions of the app (for example anchor locations saved as smaller map cells) have been coarsened to the region cell described above.
• Territories you claim, together with your display name, clan and rank, are visible to other players on the map. Depending on where you choose to claim territory, they may reveal the general area where you play. For players aged 13–17, players outside their clan see less detail about their territories; the name and player ID of these players are also not shown to people outside their clan in raid notifications, clan chat cards, map summaries and conquest cards (the clan name or "a player" is shown instead). Territory changes on the map (for example a change of owner or a raid) are delivered live to other players watching the map without any player ID, with a delay of at least 45 seconds and with the time rounded to the minute. We derive the district, city and country of that cell to show place names and run gameplay.
• If you deny location permission, you choose a country and the map opens at that country's capital. Some features may then be limited.
• You can change location permission at any time in your device settings.
• We use location only to run the game (map area, available territories, home base, anchor locations, fair play). We do not use location for advertising. For fair play we may check for implausible speeds between the centres of consecutive region cells and for mock-location signals reported by the device.

4.4 Device and technical data

Device model, operating system and app version, language and region settings, time zone (for the daily reset of rewards and limits; reset to the default when you delete your account), IP address (written to our logs partially masked; for abuse limits we use a keyed digest of the address instead of the address itself), performance and diagnostic data, and app error information: error type, code location, a short error message with personal data removed, and a random session identifier regenerated at each app start. To prevent abuse (for example invitation fraud and anchor-location abuse) we store a value derived from a device identifier with a keyed hash (HMAC) instead of the identifier itself. Because this value can be used to recognise actions linked to the same device, we do not treat it as anonymous. The device identifier used to recognise your guest account is likewise stored as a keyed hash rather than in raw form; the raw value exists only in memory while a request is being processed. With your account we store the platform you last used (iOS or Android), your app version and when they were last seen, for support and version compatibility. Error information is not linked to your player identity and contains no location. We collect crash information in our own systems; Apple and Google may also pass on crash reports you choose to share through your device settings.

4.5 Clan chat and user-generated content

1. Messages you send in clan chat
2. Your display name, portrait choice or uploaded profile photo, clan names and clan emblems you create
3. Reports you submit about other players or messages, and reports submitted about you
4. Moderation actions (message removals, mutes) taken by clan leaders or by us

Clan chat is visible to members of your clan. Messages pass through an automatic filter. For players aged 13–17, clan chat is off by default and can be turned on in Settings.

Profile photo. Uploading a photo from your library is optional; you can pick one of the built-in portraits instead. We resize an uploaded photo to 512×512 pixels and remove all of its metadata, including location. The photo is shown to other players as your profile picture (including leaderboards, clans and chat) and is stored on our own servers. Other players can report your photo; a photo with several reports is hidden until reviewed and deleted if it breaks the rules. Players aged 13–17 cannot upload photos.

4.6 Purchase data

If you make in-app purchases, payments are processed by the Apple App Store or Google Play. We do not receive your full card details. To deliver purchases, process refunds and prevent fraud we receive limited transaction data: product ID, transaction ID and original transaction ID, transaction status and environment (test or live), the price and currency reported by the store, the time of the store notification, and refund status. We do not keep the raw receipt, only an irreversible hash (digest) of it. If a purchase is refunded or reversed, the in-game rewards granted with it are deducted from your balance and your balance may go negative; we may review accounts with three or more refunds within 12 months for abuse. In-app purchases are closed to players under 18.

4.7 Analytics

We record gameplay events (for example level start and finish, raid started, invitation redeemed) in our own analytics system to understand how the game is used and to measure retention. We do not use third-party advertising or tracking SDKs, and we do not track you across other companies' apps or websites.

4.8 Support communication

If you use the support form or email: your name, topic choice, device and language information, email address, messages, attachments you send by email, and our responses. These messages also exist in our email service providers' systems; your access or deletion request covers those copies too.

5. How We Use Information

1. Create and manage your account; enable Apple and Google sign-in
2. Operate the game: levels, map, territories, clans, chat, rankings, rewards
3. Save and restore your progress across devices
4. Validate game results and prevent cheating, fraud, bots and abuse
5. Moderate clan chat and handle reports
6. Measure level difficulty and improve game design
7. Provide support
8. Maintain security, fix bugs, improve performance
9. Deliver purchases and process refunds
10. Comply with legal obligations and enforce our Terms

6. Legal Bases

Your personal data is collected electronically through the app, our servers and support channels, and processed on the following legal bases (including those in Article 5 of the Turkish Personal Data Protection Law No. 6698, "KVKK"):

• Performance of a contract: to provide the game and its features
• Legitimate interests: security, fraud and cheat prevention, moderation, analytics, game improvement
• Consent: where required, for example location permission, push notifications and optional features
• Legal obligation: where the law requires processing

7. Sign in with Apple and Google Sign-In

Apple or Google may share limited information with us depending on your settings (identifier, email, name). They process your data under their own privacy policies. When you delete your Regnia account, we revoke the Sign in with Apple token where applicable.

8. Service Providers

We use service providers only as needed to run Regnia:

1. Hosting and database infrastructure (OVHcloud, France (European Union))
2. Apple and Google (distribution, sign-in, purchases, push notifications if enabled)
3. Email delivery and support correspondence (Brevo for sign-in code emails and support form delivery; Zoho Mail for support requests)
4. Push notification delivery (Apple Push Notification service and Firebase Cloud Messaging, if you enable notifications)
5. Network and security infrastructure for our website and API (Cloudflare, where enabled)
6. Place-name lookup (LocationIQ, Unwired Labs): only for a game cell whose name we cannot resolve from our own district data, we send the centre coordinate of that cell; your location, identity and device information are never sent. The result is stored on our servers and the same cell is never looked up again.

Map data comes from OpenStreetMap (© OpenStreetMap contributors, Open Database License) and Natural Earth (public domain). Map tiles are served from our own infrastructure; your location is not sent to a third-party map provider.

9. Sharing

We do not sell your personal data. We share data only:

1. With service providers acting on our behalf (Section 8)
2. With Apple or Google for sign-in, distribution, purchases and refunds
3. With other players, to the extent the game shows it: display name, portrait, clan, rank, rankings, territories you hold, and your clan chat messages to your clan
4. When you share a conquest card: the card shows the place name, influence gained and clan emblem; your display name appears only if you turn it on (the cards of players aged 13–17 never show a display name)
5. When required by law or to protect the safety of users or the service
6. In connection with a business transfer, if one occurs

10. International Processing and Transfers

Regnia is operated by KUTLUK LLC, a company registered in the United States. Your personal data is stored and processed on servers located in France (European Union). Because KUTLUK LLC is a United States company and our service providers may be located in other countries, your data may be accessed from the United States and from other countries. Your data may therefore be processed or accessed outside your country of residence, including outside Türkiye, the European Economic Area and the United Kingdom. The level of data protection in those countries may differ from that of your country.

We protect personal data with technical and organizational measures such as encrypted connections, access controls and the limited retention periods in Section 11. Where the law of your country requires a specific safeguard for processing or transfers outside that country (for example an adequacy decision or approved standard contractual clauses, including under Article 9 of the Turkish Personal Data Protection Law No. 6698, "KVKK"), we take the steps that law requires of us, to the extent it applies to us. We do not rely on your consent as the general basis for operating the game from the United States. Our service providers (Section 8) may process data in the United States or in other countries under their own safeguards.

Contact info@kutlukgames.com for details about the safeguards we use.

11. Retention

12. Account Deletion

You can delete your account in the app, or by emailing info@kutlukgames.com.

If your account is linked (Apple, Google or email): Settings › Account linked: … › Delete Account. The account button in Settings shows your sign-in method, for example "Account linked: Google".

If you play as a guest: Settings › Save your progress › Account and data › Delete Account.

In app versions released before v21, the path is Settings › Account › Delete Account.

• Deletion takes effect after 30 days. Signing in during this period lets you cancel.
• After deletion we delete your personal data: sign-in identifiers, email, display name, portrait choice and profile photo, device and notification tokens, last used platform and app version, IP and session records, email sign-in records, support requests from email addresses linked to your account, the text of your chat messages, your age group and the date of any age re-declaration.
• Records we must keep for game integrity and legal retention (for example territory history, raid results, move logs, purchase and balance ledger records) are kept with your name, email and device information removed, under an internal player number only. These records are pseudonymous, not anonymous: the internal number can still link them to the same account. We keep them only for game integrity, fraud prevention, resolving disputes and legal obligations. Your chat messages are shown as "Deleted player — message removed".
• Territories you held become unowned; your clan membership ends. If you lead a clan, leadership passes to the highest-ranked member.
• Deletion removes your progress, badges, preferences and item stocks, and resets your Akçe, Influence and other balances to zero. These cannot be restored.
• Copies in backups and at our service providers (Section 8) may remain for a further period under their own retention cycles, after which they are overwritten or deleted.

13. Your Rights

Depending on applicable law you may: access your data; correct it; request deletion; object to or restrict processing; withdraw consent; receive a copy; and complain to a data protection authority. Contact info@kutlukgames.com.

13.1 Rights under KVKK (Türkiye)

Under Article 11 of KVKK you may: learn whether your data is processed; request information; learn the purpose and whether it is used accordingly; know third parties it is transferred to in Türkiye or abroad; request correction; request deletion or destruction; request that third parties be notified of correction or deletion; object to results arising exclusively from automated analysis that are to your detriment; and claim compensation for damage caused by unlawful processing. Applications: info@kutlukgames.com. We respond within 30 days at the latest.

13.2 Other regions

If you live in the European Economic Area, the United Kingdom or a US state with a privacy law, you may have additional rights under that law, including the rights listed above. Contact info@kutlukgames.com. We do not sell personal data or use it for third-party advertising.

14. Children

Regnia is not for children under 13. At first launch we ask for your birth year; if you are under 13 you cannot continue. Players aged 13–17 should use Regnia with parental consent; clan chat is off by default for them, they cannot upload a profile photo and in-app purchases are closed to them. If you believe a child under 13 has provided data, contact info@kutlukgames.com and we will delete it.

15. Push Notifications

If push notifications are enabled in the app, we use Apple Push Notification service and Firebase Cloud Messaging to send gameplay notifications (for example your territory is under attack). You can turn notifications off in device settings.

16. Security

We use reasonable technical and organisational measures to protect personal data. No system is completely secure.

17. Fair Play and Anti-Cheat

We analyse gameplay, move logs and technical data to detect cheating, automation, location spoofing and abuse. We may use automated checks and manual review. Violations may lead to the measures described in our Terms of Use.

18. Virtual Items

Akçe, boosters, shields, chests and other virtual items are part of the game. They have no real-world monetary value and cannot be exchanged for money.

19. Chest Odds

Where Regnia offers chests with random contents, the probability of each reward is shown in the app before you open the chest.

20. Future Features

We may add events, seasons, advertising or other features. If these materially change how we process personal data, we will update this policy and ask for consent where required.

21. Changes

We may update this policy. Each version shows its date and version number. For material changes we will notify you in the app and ask you to review the new version.

22. Contact

KUTLUK LLC · Regnia · 30 N Gould St #66912, Sheridan, WY 82801, United States
Privacy: info@kutlukgames.com · Support: support@kutlukgames.com