Content Policy & Community Guidelines

In plain language (this box is a summary only and is not legally binding). Benerits is for players of all ages from 13 up, so games and profiles must be suitable for a general audience. No hate, no sexual content, no extreme gore, no real-money gambling, no promoting drugs or terrorism, no harassment, no sharing other people's personal data, no malware, and no misleading cover art. Child sexual abuse material means an immediate ban and a report to the authorities. Games carry age labels and content descriptors so players and parents can choose. Leaderboards are for real play only. If you see something wrong, report it; if we act on your content, we tell you why and you can appeal.

1. Purpose and scope

1.1 This Content Policy & Community Guidelines (the "Content Policy") sets out the standards that apply to everything made available on the Benerits game portal operated by [BENERITS LEGAL ENTITY NAME] ("Benerits", "we", "us"), including: (a) Games and each of their versions; (b) Game Listings; (c) User Content; and (d) the conduct of Players, Publishers and Creators on the Service.

1.2 This Content Policy forms part of, and is incorporated into, the Player Terms of Service, the Publisher Distribution Agreement and the Creator Programme Terms. A breach of this Content Policy is a breach of the agreement that applies to you. Publishers must also comply with the technical requirements and review guidelines published in Studio.

1.3 The standards in this Content Policy apply in addition to the law. Content that is illegal in Türkiye, in the European Union or in the country where it is made available is prohibited even if not specifically listed below. We may restrict content in specific countries where it is illegal only there.

2. Definitions

2.1 Capitalised terms not defined here have the meaning given in the Player Terms of Service. In addition:

• "Game Listing" means everything that describes or promotes a Game on the Service, including its title, short and long description, controls text, tags, genre, cover art, portrait cover, screenshots, videos and changelog.
• "Content Descriptor" means a label describing an age-sensitive element of a Game, as set out in clause 5.
• "Age Label" means the minimum recommended age assigned to a Game under clause 5.
• "Notice" means a report submitted to us by any person under clause 9 alleging that content is illegal or incompatible with this Content Policy.
• "CSAM" means child sexual abuse material, meaning any visual, audio or written material depicting or promoting the sexual abuse or sexual exploitation of a minor, or depicting a minor or a person appearing to be a minor engaged in sexually explicit conduct, whether real, drawn, animated, computer-generated or produced using artificial intelligence.

3. Prohibited content

3.1 The following content is prohibited in Games, Game Listings and User Content.

3.2 Child sexual abuse and exploitation (zero tolerance). Any CSAM; any content that sexualises minors or characters that appear to be minors, including in drawn, animated or AI-generated form; content that facilitates grooming or the sexual exploitation of children; and links to any such content. We remove such content immediately, permanently terminate all associated Accounts, preserve relevant evidence as permitted or required by law, and report it to the competent authorities, including the Turkish law enforcement and judicial authorities (including through the Information and Communication Technologies Authority's reporting channel) and, where relevant, the National Center for Missing & Exploited Children (NCMEC), the competent authorities of EU Member States and the INHOPE network of hotlines. We do not notify the uploader before reporting where doing so could prejudice an investigation.

3.3 Sexual content and nudity. Pornographic or sexually explicit content, including depictions of sexual acts, sexual services or sexually explicit nudity; sexual content presented for gratification; and content promoting sexual services or adult websites. Mild romantic themes (such as a kiss or a relationship storyline) are permitted and must carry the appropriate Content Descriptor. Non-sexual partial nudity in an artistic, educational or humorous context is permitted only if suitable for the assigned Age Label.

3.4 Hate and discrimination. Content that attacks, dehumanises, incites violence or hatred against, or promotes discrimination against, people on the basis of race, ethnicity, national origin, religion, disability, sex, gender, gender identity, sexual orientation, age, serious illness or other protected characteristics; hateful symbols, slurs and stereotypes used to demean; and content that denies or glorifies genocide or crimes against humanity.

3.5 Extreme violence and gore. Content whose main purpose is to shock or disgust through realistic depictions of dismemberment, mutilation, torture or graphic death; sexual violence of any kind; and content that glorifies, celebrates or recreates real-world mass-casualty attacks, school shootings or other real atrocities. Cartoon, fantasy and stylised violence, and non-graphic realistic violence, are permitted subject to clause 5.

3.6 Terrorism and violent extremism. Content that promotes, supports, glorifies, recruits for or provides instructions for terrorist or violent extremist organisations or acts, including content listed as terrorist content under Regulation (EU) 2021/784 or prohibited under the Turkish Anti-Terror Law No. 3713 and the Turkish Penal Code. We act on removal orders from competent authorities within the time required by law (including within one hour of receipt of a removal order under Regulation (EU) 2021/784, where it applies to us).

3.7 Real-money gambling. Games or features that allow players to stake, wager or win money, cryptocurrency, tokens, NFTs or any other item with real-world monetary value, or that can be exchanged for such value; links to, or promotion of, gambling or betting operators; and "play-to-earn" mechanics. Simulated gambling with no real-world value (such as casino-themed games using virtual chips that cannot be purchased or cashed out) is permitted only with the "Simulated gambling" Content Descriptor and a minimum Age Label of 16+.

3.8 Drugs, alcohol, tobacco and weapons. Content that promotes, glamorises or encourages the use of illegal drugs or the misuse of legal drugs; instructions for making or obtaining illegal drugs, explosives or weapons; and content that facilitates the sale of drugs, alcohol, tobacco, e-cigarettes, weapons, ammunition or other regulated goods. Depictions in a narrative, historical or humorous context that do not promote use are permitted with the appropriate Content Descriptor.

3.9 Self-harm and dangerous activities. Content that promotes, encourages or provides instructions for suicide, self-harm or eating disorders, or dangerous challenges or activities likely to result in serious injury.

3.10 Harassment, bullying and threats. Content that threatens, harasses, bullies, intimidates or humiliates any person; targeted insults; incitement to harass; and content that sexualises or degrades real individuals.

3.11 Personal data and privacy. Content that discloses personal data of any person without their consent (including names combined with addresses, telephone numbers, identity numbers, private photographs, location or financial information: "doxxing"); Games that request, collect or transmit Players' personal data (including names, email addresses, telephone numbers, precise location, contacts, photographs, camera or microphone input) except through Benerits features and as approved in review; and Games that use fingerprinting, trackers, third-party analytics or advertising SDKs.

3.12 Malware and security threats. Viruses, spyware, trojans, cryptocurrency miners and any other malicious or harmful code; code that attempts to escape the sandbox, access the portal's cookies or storage, navigate the top-level page, open pop-ups or pop-unders, redirect Players, or interfere with the portal's user interface or advertising; code deliberately obfuscated to conceal its behaviour from review; exploits; phishing; and links to any of the foregoing.

3.13 Misleading content and misleading cover art. Cover art, screenshots, videos, titles, descriptions or tags that do not accurately represent the actual Game and its gameplay, including artwork depicting content, characters, graphics quality or features not present in the Game; clickbait; content that imitates another Game, brand or Publisher so as to cause confusion; fake system dialogs, fake close buttons, fake advertisements or disguised advertising; false claims of prizes, rewards or endorsements; keyword stuffing and irrelevant tags; and manipulation of ratings, votes or play counts.

3.14 Impersonation. Content that impersonates any person, Publisher, brand, public authority or Benerits, or falsely implies an affiliation with or endorsement by them.

3.15 Harmful misinformation. Content that promotes false or misleading information likely to cause serious real-world harm, including to public health or the integrity of elections, and content that exploits real-world tragedies, disasters or crises for shock value.

3.16 Spam and unauthorised commercial content. Unsolicited advertising, referral spam, links to external stores or payment pages, and promotions not permitted under the Publisher Distribution Agreement or the Creator Programme Terms.

3.17 Illegal content generally. Any other content that is illegal under applicable law, including content that constitutes a crime listed in Article 8 of Turkish Law No. 5651, content that violates personal rights or privacy within the meaning of Articles 9 and 9/A of that Law, content that infringes intellectual property rights (see clause 6 and the Copyright Policy), and content that is illegal under the law of the European Union or its Member States.

4. Advertising and monetisation rules for Games

4.1 Games must not contain their own advertising, advertising SDKs, affiliate links, sponsorship placements, trackers or third-party analytics. All advertising is requested through the Benerits SDK.

4.2 Rewarded Ads must be optional, clearly labelled as advertisements and triggered only by a deliberate player action, and the reward must be described before the player chooses to watch.

4.3 Interstitial advertisements may be requested only at natural breaks in gameplay (such as between levels or after a game over), never during active gameplay, never on first load before the player has interacted, and never in a way that could cause accidental clicks.

4.4 Games must not encourage or incentivise players to click advertisements, must not place interactive elements near or over advertisements, and must not generate advertising requests automatically or repeatedly without genuine player activity.

4.5 Games must not offer in-app purchases, subscriptions, donations or any other payment mechanism, or link to external payment pages, unless we have expressly agreed otherwise in writing.

5. Age-sensitive content labelling

5.1 Purpose. Every Game carries an Age Label and any applicable Content Descriptors, displayed on its Game page, so that Players and parents can make informed choices. Age Labels are assigned by Benerits for use on the Service and are not official ratings of any rating authority.

5.2 Age Labels. Games are labelled Everyone, 7+, 12+ or 16+. Content that would be suitable only for adults (for example, content comparable to that which a recognised rating body would rate as suitable only for persons aged 18 or over) is not permitted on the Service.

5.3 Content Descriptors. Games must be labelled with each of the following descriptors that applies: Cartoon or fantasy violence; Realistic violence; Blood; Fear or horror; Crude humour; Mild language; Strong language; Romantic or suggestive themes; References to alcohol or tobacco; References to drugs; Simulated gambling; and Flashing lights.

5.4 Guidance on levels. As a guide: (a) Everyone: no more than mild cartoon or fantasy violence, no frightening scenes likely to scare young children, no bad language; (b) 7+: mild cartoon or fantasy violence, mildly frightening scenes; (c) 12+: non-graphic realistic violence against human-like characters, moderate horror, mild bad language, mild romantic or suggestive themes, references to alcohol or tobacco; (d) 16+: realistic violence with limited blood, strong horror, strong language, references to drugs, simulated gambling. Anything beyond 16+ is prohibited under clause 5.2.

5.5 How labels are set. Publishers complete a content questionnaire in Studio for each version of a Game and must answer it accurately and completely. Our reviewers verify the answers during review and may change the Age Label or Content Descriptors. Providing inaccurate answers is a breach of this Content Policy.

5.6 Effect of labels. Games labelled 16+ are not shown to Account holders who have told us that they are under 16, are excluded from shelves and collections aimed at younger players, and are shown with an age notice before play. Games labelled Flashing lights display a photosensitivity warning before play.

6. Respecting intellectual property

6.1 Publishers must own, or hold all licences and consents necessary for, every element of their Games and Game Listings, including code, engines, libraries, artwork, characters, music, sound effects, fonts, trademarks, names and likenesses, and must comply with the licence terms of any open-source or asset-store material used.

6.2 The following are prohibited without the rights holder's written authorisation: (a) uploading a Game made by someone else, or a copy, mirror or re-host of it; (b) clones and "reskins" that copy the protected expression of another game, including its code, artwork, audio, level designs or distinctive trade dress; (c) fan games and parodies that use protected characters, names, logos or assets beyond what the law permits; (d) use of third-party trademarks in titles, tags or cover art in a way likely to cause confusion; and (e) use of the name, image or voice of a real person without consent.

6.3 Players must not use others' trademarks, copyrighted material or likeness in usernames, avatars or bios in a way that infringes their rights.

6.4 Rights holders can report infringement under the Copyright & Takedown Policy. We apply a repeat infringer policy as described there.

7. Fair play, Leaderboards and cheating

7.1 Players. Scores, Leaderboards, votes and play counts must reflect genuine human play. The cheating, exploit and advertising fraud rules in clause 8 of the Player Terms of Service apply in full. In particular, using cheats, bots, macros, modified clients or forged requests, exploiting bugs instead of reporting them, colluding or using multiple Accounts to manipulate rankings, and trading Accounts or scores are prohibited.

7.2 Publishers. Publishers must not: (a) generate or procure plays, votes, likes, favourites, scores or advertising impressions for their own or others' Games by artificial means, including bots, incentivised traffic, click farms or their own repeated play; (b) submit scores or events through the SDK that do not result from genuine gameplay; (c) design Games to deceive our detection systems or reviewers, including by behaving differently during review; or (d) grant In-Game Rewards in exchange for advertising clicks.

7.3 Score integrity. Publishers must implement reasonable score validation for Games that submit scores to Leaderboards (for example, rejecting impossible values and preventing trivial client-side manipulation) and must fix exploits we report to them within a reasonable time.

7.4 Our measures. We may remove, reset or freeze scores and Leaderboards, exclude invalid traffic from rankings and revenue, and apply the measures in clause 10.

8. Username and profile rules

8.1 Usernames, display names, bios, website links and avatars must: (a) comply with clause 3; (b) not contain profanity, slurs, sexual references or references to drugs, violence or hate, including in disguised form (misspellings, leetspeak, symbols or other languages); (c) not impersonate any person, Publisher, Creator, brand or Benerits staff, or suggest an official role (such as "admin", "moderator", "official" or "Benerits"); (d) not contain personal data such as full names combined with other identifying details, telephone numbers, addresses or email addresses; (e) not contain URLs, advertising or promotional content (except the profile website link, which must not lead to prohibited content); and (f) not infringe trademarks or other rights.

8.2 We may reject, reset or reassign usernames and remove profile content that breaches these rules. Repeated breaches may lead to restrictions on your Account.

9. Reporting illegal or prohibited content (notice and action)

9.1 How to report. Anyone, whether or not they have an Account, can report a Game, Game Listing, profile, score or other content they consider illegal or incompatible with this Content Policy: (a) using the "Report" function on the relevant page; or (b) by email to [CONTACT EMAIL: [email protected]]. Copyright and trademark complaints should be sent as described in the Copyright & Takedown Policy.

9.2 Contents of a Notice. To allow us to take a diligent decision, a Notice should contain: (a) a sufficiently substantiated explanation of why you consider the content illegal or in breach of this Content Policy, including the law or rule concerned; (b) a clear indication of the exact electronic location of the content, such as the exact URL(s), and, where necessary, additional information enabling us to identify it (such as the Game version, the username or the time a score was shown); (c) your name and email address, except for Notices concerning information considered to involve CSAM or other offences referred to in Articles 3 to 7 of Directive 2011/93/EU; and (d) a statement confirming your good-faith belief that the information and allegations in the Notice are accurate and complete. A Notice that contains these elements is deemed to give us actual knowledge of the specific content concerned for the purposes of Article 6 of Regulation (EU) 2022/2065.

9.3 Our handling of Notices. We confirm receipt of Notices without undue delay where you have given contact details, review them in a timely, diligent, non-arbitrary and objective manner, and inform you of our decision and of the redress available. We may use automated means to process or prioritise Notices, and will tell you if we do. Notices from trusted flaggers designated under Article 22 of Regulation (EU) 2022/2065 are given priority. Notices concerning a threat to the life or safety of persons, or CSAM, are handled with the highest priority.

9.4 Turkish Law No. 5651. In respect of Games and User Content, Benerits acts as a hosting provider (yer sağlayıcı) within the meaning of Law No. 5651 and, for content it produces itself, as a content provider. Accordingly: (a) where content infringes your personal rights, you may apply to the content provider or, where the content provider cannot be reached, to us as the hosting provider, for the content to be removed under Article 9 of Law No. 5651; we respond to such requests within 24 hours at the latest; you may also apply directly to the criminal judgeship of peace (sulh ceza hâkimliği); (b) where content violates the privacy of your private life, you may apply to the Information and Communication Technologies Authority under Article 9/A of Law No. 5651; and (c) we comply with decisions to remove content or block access issued by courts, criminal judgeships of peace, the Presidency of the Information and Communication Technologies Authority and other competent authorities under Articles 8, 8/A, 9 and 9/A of Law No. 5651 within the periods set in those decisions and in the law. Applications under this clause may be made in Turkish to [CONTACT EMAIL: [email protected]] or to [REGISTERED ADDRESS].

9.5 Emergencies. If you believe that someone's life or safety is at immediate risk, contact your local emergency services first. Where we become aware of information giving rise to a suspicion of a criminal offence involving a threat to the life or safety of a person, we inform the competent law enforcement or judicial authorities.

10. Enforcement

10.1 Games and Game Listings. Depending on the nature and severity of a breach, we may: (a) reject a version in review or request changes before approval; (b) require corrections to Game Listings, Age Labels or Content Descriptors; (c) restrict a Game's visibility (for example, limit it to Basic launch, remove it from shelves or search, or restrict it in certain countries); (d) remove a version or delist a Game; (e) withhold, suspend or claw back revenue attributable to the breach as provided in the Publisher Distribution Agreement; (f) suspend Studio access; and (g) terminate the Publisher Distribution Agreement and all associated Accounts.

10.2 User Content and Players. We may take the measures described in clause 12.2 of the Player Terms of Service, including removing content, resetting usernames or scores, warnings, feature restrictions, temporary suspensions and permanent bans.

10.3 Proportionality. We choose measures proportionate to the breach, taking into account its severity and consequences, the number of people affected, whether it was intentional, whether the person has previously breached our rules, whether the person promptly corrected it, and any explanation given. Measures will be applied consistently and without discrimination.

10.4 Zero-tolerance breaches. CSAM, terrorist content, malware and deliberate attempts to compromise the security of the Service or its users result in immediate removal and, in principle, permanent termination of all associated Accounts, without prior warning.

10.5 Repeat breaches. Where a person repeatedly breaches this Content Policy, we may escalate measures up to termination, even where each individual breach would justify only a lesser measure.

11. Statements of reasons and appeals

11.1 Statement of reasons. When we restrict content or an Account, we provide the affected person with a clear and specific statement of reasons as described in clause 13.1 of the Player Terms of Service (for Players) or the Publisher Distribution Agreement (for Publishers), subject to the exceptions set out there.

11.2 Appeals. Players, Publishers and Creators may appeal a decision by email to [CONTACT EMAIL: [email protected]] with the subject line "Appeal" within 30 days of being notified of it, or within any longer period required by law (currently six months under Article 20 of Regulation (EU) 2022/2065, where that Article applies to us). People who submitted a Notice may likewise appeal our decision on their Notice. Appeals are decided by staff not involved in the original decision, not solely by automated means, and we inform the appellant of the outcome and reasons without undue delay.

11.3 Other redress. Our internal appeal process is without prejudice to your right to bring the matter before a competent court or authority and, where Article 21 of Regulation (EU) 2022/2065 applies, to select a certified out-of-court dispute settlement body.

12. Misuse of reporting and appeals

12.1 We may, after issuing a prior warning, suspend for a reasonable period of time: (a) the provision of the Service to persons who frequently provide manifestly illegal content; and (b) the processing of Notices and appeals from persons who frequently submit Notices or appeals that are manifestly unfounded. In deciding whether to do so, we consider the number of manifestly illegal items or manifestly unfounded Notices in a given period, their proportion relative to the total, the gravity of the misuse and its consequences, and, where it can be identified, the intention of the person. Knowingly submitting false Notices may also give rise to legal liability.

13. Transparency

13.1 We publish information on our content moderation, including the number of Notices received, measures taken and appeals decided, where and as required by applicable law, including Articles 15 and 24 of Regulation (EU) 2022/2065.

14. Changes

14.1 We may update this Content Policy to reflect changes in law, industry standards, the Service or risks we observe. Material changes are notified in advance in accordance with the Player Terms of Service and the Publisher Distribution Agreement. A Game approved under an earlier version of this Content Policy may be required to be brought into compliance with a new version within a reasonable period we specify, unless the change is required by law with immediate effect.

15. Contact and language

15.1 Reports, appeals and questions: [CONTACT EMAIL: [email protected]]. Post: [BENERITS LEGAL ENTITY NAME], [REGISTERED ADDRESS].

15.2 This Content Policy is available in English and Turkish, and the two versions are intended to be substantively identical. In case of conflict: for Turkish consumers, the Turkish version prevails; for Publishers and Creators, the English version prevails; in all other cases, the English version prevails, except where applicable law requires otherwise.