TycoonX · CK-Labs

Privacy Policy

Last updated September 6, 2026

This Privacy Policy explains how Atakan Cevik, trading as CK-Labs and operating TycoonX, processes personal data when you use the TycoonX mobile or web applications, websites, support services, community features, and related online services.

01

Information We Process

Account and profile data such as supported sign-in identifiers, email address, display name, avatar, language, time zone, settings, and account lifecycle events.

Gameplay and economy data needed to operate the persistent TycoonX world, including progression, inventory, virtual currency and Diamond balances, companies, production, market activity, housing, jobs, contracts, loans, stocks, transactions, and VIP entitlement state.

Purchase and entitlement data such as payment platform, product identifier, transaction identifiers, signed transaction or receipt information, purchase/activation/expiry status, refund/revocation/chargeback status, and delivery, restore, migration, or correction history. We generally do not receive your full payment-card number from platform stores or payment processors.

Security and fraud data such as login/session records, IP address, device/platform information made available to the Service, app version, diagnostics, suspicious access patterns, invalid purchase validations, exploit indicators, anti-abuse signals, and moderation/security logs.

Communications and community content such as public or private chats, reports, profile/company content, support tickets, contact-form submissions, bug reports, appeals, attachments, timestamps, sender/recipient identifiers, and moderation status.

Usage and analytics information such as feature usage, sessions, retention, performance, interaction events, and aggregated economy/balancing metrics.

02

Sources of Data

We receive data directly from you when you create or use an account, play TycoonX, contact Support, submit community content, or change settings. We also receive limited information from services you choose or use with TycoonX, including supported authentication providers and Apple, Google, Xsolla, or another authorized payment provider when they send purchase, entitlement, refund, revocation, fraud, or transaction-status information.

Payment providers may process payment-card, bank, billing-address, tax-location, or other payment details independently under their own privacy notices. CK-Labs generally receives the transaction and entitlement information needed to deliver and reconcile TycoonX purchases rather than the full payment instrument details.

03

Why We Process Information

We process information to create and secure accounts, operate and synchronize TycoonX, deliver and restore valid purchases, prevent duplicate delivery and fraud, detect cheating or exploits, investigate incidents, correct invalid game state, provide support, moderate community features, enforce the Terms and Community Standards, diagnose technical problems, improve the Service, send operational/legal notices, and comply with legal obligations.

04

Legal Bases

Where the GDPR or similar law applies, we rely on the legal basis appropriate to the specific processing: performance of a contract for gameplay, account access, purchase delivery and support; legitimate interests for security, anti-fraud, game integrity, diagnostics, proportionate community moderation and legal defense where those interests are not overridden; legal obligations for required recordkeeping and authority requests; and consent where the law requires it for optional processing.

Merely using TycoonX is not treated as consent to processing that legally requires consent. Where consent is required, we ask for it separately and it can be withdrawn for future processing.

05

Data Needed to Provide TycoonX

Some information is necessary to perform the TycoonX contract or process a purchase. For example, an account identifier is needed to maintain persistent game state, and valid transaction or entitlement information is needed to deliver, restore, refund, revoke, or reconcile paid content correctly. If required information is not provided or cannot be verified, we may be unable to create or authenticate an account, deliver a purchase, restore an entitlement, or provide the affected feature.

Optional information or processing that is not necessary for the core Service is handled separately where required, including consent controls where applicable.

06

How We Share Information

We do not sell personal data. We may share only what is reasonably necessary with service providers supporting hosting, databases, authentication, storage, analytics, diagnostics, moderation, communications, notifications or security; platform/payment partners such as Apple, Google, Xsolla or other authorized providers for purchase validation, restoration, refunds, revocations, fraud and disputes; other players where you intentionally use public/social game features; authorities where legally required; and parties involved in a lawful business transfer.

Apple, Google, Xsolla, banks, card networks, or other payment participants may act as independent controllers for parts of their own payment, fraud, tax, account, or platform processing. Their own privacy notices and legal obligations apply to that independent processing. TycoonX currently uses infrastructure such as Supabase for parts of its backend, and service providers are subject to applicable contractual and legal safeguards.

Where platform rules require it, third parties with whom CK-Labs shares user data must provide the same or an equivalent level of protection for the data they receive from CK-Labs as described in this Policy and required by the applicable platform rules.

Third-party AI services are not exempt from these rules. If TycoonX uses a third-party AI service in a way that involves sharing personal data, CK-Labs will disclose that sharing and obtain explicit permission before transmitting or sharing the data where applicable platform rules or law require it. Any such provider must be limited to authorized purposes and appropriate privacy and security safeguards.

07

Public and Private Community Content

Content you intentionally make public in TycoonX may be displayed to other users as part of the Service. Where the TycoonX Terms and Community Standards permit public user-generated content to be featured for TycoonX community or promotional purposes, CK-Labs will use an appropriate legal basis and respect the context in which it was shared, applicable settings, third-party rights, and mandatory law. If consent is required for a particular promotional use, CK-Labs will request it separately.

Private direct messages, private support communications, and non-public reports are processed as needed to provide, secure, moderate, support, investigate, or legally protect the Service. They are not made public or used for public promotional purposes merely because CK-Labs must process them for those operational purposes.

Moderation or legal-review access to private communications is limited to circumstances where the processing is reasonably necessary and lawful, for example responding to a report, protecting users, investigating abuse or fraud, complying with law, or establishing or defending legal claims.

08

International Transfers

TycoonX and some providers may process information outside your country of residence. Where the GDPR or similar transfer restrictions apply, we use an appropriate legal transfer mechanism where required, such as an adequacy decision, Standard Contractual Clauses, or another recognized safeguard. International transfers are not based merely on a statement that use of TycoonX equals consent.

Where applicable law gives you a right to information about the safeguards used for an international transfer, you may contact TycoonX Support to request further information or an available copy of the relevant safeguards, subject to lawful redactions and third-party confidentiality requirements.

09

Data Retention

We keep personal data only for as long as reasonably necessary for its purpose and for additional periods required or permitted by law. Active account/game data may be retained while the account is active; support records for reasonable follow-up and dispute periods; purchase, refund, entitlement, restore, accounting and tax records for legally required, contract-performance, fraud-prevention, or dispute-related periods; and security, anti-fraud, exploit, moderation and audit records for a reasonable period needed to protect the Service, investigate incidents or defend claims.

Private communications are not retained indefinitely merely because they were once reviewed for moderation. Any longer retention must have a separate lawful need such as an active dispute, safety investigation, legal claim, or legal obligation. Backups may remain for a limited backup lifecycle before deletion or overwrite. Anonymized or genuinely aggregated data may be retained where it no longer identifies a person.

10

Your Privacy Rights

Depending on applicable law, you may have rights to access, correct, delete, restrict, object, receive certain data in a portable format, withdraw consent where processing is consent-based, and lodge a complaint with a competent data-protection authority.

You can request account deletion through TycoonX where available or contact TycoonX Support. We may need to verify your identity. Certain records may still be retained where required or permitted for legal, tax, accounting, contract-performance, fraud-prevention, security, dispute-resolution, entitlement-restoration, or legal-claims purposes.

11

Account Deletion and Paid Entitlements

Deleting your TycoonX account is separate from requesting a payment refund. Account deletion may permanently remove account-linked gameplay progress, Diamonds, consumable value, inventory, social data, and other profile state. It does not automatically create a right to cash redemption or a refund.

Deleting the TycoonX account does not necessarily erase or invalidate a separate Apple, Google, Xsolla, or other payment-provider transaction record. Where a valid Lifetime VIP or other non-consumable/restorable entitlement remains associated with the purchaser under platform rules, provider records, the contract, or mandatory law, CK-Labs may retain the minimum transaction and entitlement evidence reasonably necessary to verify and restore that entitlement.

A later restore may require reasonable proof that the same purchaser controls the relevant platform or payment account. Restoring a paid entitlement does not recreate deleted gameplay progress, consumed Diamonds, inventory, history, or transferred assets unless applicable law requires otherwise. Refund rights remain governed by the payment provider process and mandatory law.

12

Children and Age-Related Controls

TycoonX is not directed to children below the minimum age permitted for independent use in the user’s jurisdiction. Where parental consent is legally required, the Service should not be used without the required authorization. If we learn that personal data was collected from a child in circumstances that do not satisfy applicable law, we may restrict the account and delete information as required.

CK-Labs may process limited age, age-range, parental-authorization, or platform age-control information where reasonably necessary to comply with law, apply age-appropriate social-feature restrictions, satisfy App Store or Google Play requirements, or protect minors. TycoonX may restrict or disable community features for certain age groups even where the underlying game remains available.

13

Security

We use technical and organizational measures designed to protect TycoonX data, such as access controls, authentication controls, encrypted network transport where applicable, monitoring, rate limiting, purchase validation, audit logging, backups, and other safeguards appropriate to the Service.

No online service can guarantee absolute security. If you believe your account has been compromised or discover a security vulnerability, contact TycoonX Support promptly. This does not reduce CK-Labs obligations for security measures required by applicable law.

14

Automated Security and Moderation

TycoonX may use automated rules, signals, or systems to identify suspicious activity, spam, fraud, abusive content, exploit patterns, invalid purchases, or other conduct that may threaten users or the Service. Automated signals may lead to review, temporary restrictions, moderation, or investigation.

Where applicable law restricts solely automated decisions that produce legal or similarly significant effects, CK-Labs will apply the required safeguards, including human involvement or review where the law requires it. Rights concerning such decisions remain unaffected.

15

Third-Party Links and Services

TycoonX may link to or interoperate with third-party services. Those third parties may process information under their own privacy policies. CK-Labs is not responsible for independent third-party privacy practices except to the extent applicable law makes CK-Labs responsible.

16

Changes to This Policy

We may update this Policy to reflect changes to TycoonX, data practices, providers, security measures, community features, or legal requirements. We will update the Last updated date and provide additional notice where required. If a change requires consent, we will request that consent rather than treating continued use alone as consent.

Controller & contact

For the personal-data processing described in this Privacy Policy, the controller is Atakan Cevik, trading as CK-Labs, Prämonstratenserstraße 80, 51069 Köln, Germany.

For privacy requests, account deletion, security reports, purchase-related privacy questions, moderation-data questions, economy-integrity investigation questions, or other data-protection concerns, use TycoonX Support or email us. Apple, Google, Xsolla, and other providers may separately act as independent controllers for their own processing where described in this Policy.

Privacy update · 5 September 2026

Economy-integrity, transfer and RMT analysis

To protect the TycoonX economy and enforce the genuine-transaction and real-money-trading rules, CK-Labs may analyze transaction and ledger records, counterparties, transaction chains, repeated transfers, pricing patterns, feature usage, account relationships that are directly observed or reasonably inferred from relevant service data, and related reports or communications where review is reasonably necessary and lawful.

This processing may be used to detect or investigate disguised wealth transfers, account farming, coordinated or circular transfers, exploit proceeds, unauthorized real-money trading, payment abuse, account compromise and other fraud or game-integrity risks, and to correct invalid game state. Where the GDPR applies, the legal basis may include performance of the TycoonX contract where the processing is necessary to operate the persistent multiplayer economy, legitimate interests in fraud prevention, security and game integrity subject to the required necessity and balancing assessment, or a legal obligation where applicable.

A high-value transaction, unusual price, friendship, company membership, shared household or network signal, or one unusual event does not by itself prove abuse. CK-Labs should use proportionate evidence, data minimization and access controls. Private communications are reviewed for this purpose only where reasonably necessary and lawful. Automated signals may flag activity for review, but where applicable law restricts solely automated decisions with legal or similarly significant effects, the required safeguards, including human intervention or review where required, apply.

Relevant anti-fraud and investigation records are retained only for as long as reasonably necessary for security, repeat-abuse detection, disputes, legal claims or legal obligations. Your applicable rights to access, correction, deletion, restriction, objection to processing based on legitimate interests, and safeguards relating to automated decisions remain available as described in this Privacy Policy and mandatory law.

Privacy update · 10 September 2026

Personal data breaches and required notifications

If CK-Labs becomes aware of a personal data breach affecting TycoonX, we will assess the incident, document it as required, take appropriate containment and remediation measures, and make any legally required notifications. Where the GDPR applies, CK-Labs will notify the competent supervisory authority without undue delay and, where feasible, within 72 hours after becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons. Where required, reasons for a notification delay will also be provided.

Where a personal data breach is likely to result in a high risk to your rights and freedoms, CK-Labs will communicate the breach to affected individuals without undue delay in clear and plain language, including the information and protective measures required by law, unless an applicable legal exception removes the individual-notification requirement. A security incident that does not meet a legal notification threshold may be handled without a public or individual notice. This section does not limit any mandatory data-protection rights or remedies.