DREAM GAMES PRIVACY POLICY
Effective Date: November 17, 2023
INTRO
Dream Games Teknoloji Anonim Şirketi ("Dream Games" or "we", "us", "our") is a technology company that designs and develops mobile games. With this Privacy Policy, we aim to explain how and why we gather, store, share and use your personal data in a manner consistent with the laws of the countries where we do business.
Where this Policy refers to "personal data" we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes "personal data," or "personally identifiable information".
This Privacy Policy applies to websites, mobile applications, forums, blogs, any offline services, our marketing and advertising activities on all platforms and other services that we may provide to you from time to time (collectively, the "Services"). This Privacy Policy does not apply to Dream Games job applicants, employees, or other personnel.
Dream Games is the controller of the personal data we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal data is used. Under this Privacy Policy, your personal data shall be processed in order to provide the Services once you download our mobile applications, access and/or play our games, or interact with our Services. If you have any other concerns about providing data to us or it being used as described in this Privacy Policy, you may contact us and use your rights explained under Control Over Your Information section of this Privacy Policy.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect personal data directly from you or third-party companies who have obtained your consent or have another legal right to share such personal data with us (including advertising platforms, partners and data aggregators who have obtained it). This may include attributes about you and your interests, as well as other games and services you use, demographic and general location information. We will use your personal data as described in this Privacy Policy.
Personal Data Collected Directly from You
Dream Games processes your personal data in order to provide the Services when you download, access and/or play our games or using our other Services. Most of this data comes directly from you. We collect the following information you provide in connection with our Services:
We use this data to provide our games and Services to you, including optimizing our Services, customization of in-game offers and verifying purchases. We may also use it for the other purposes set out in this Privacy Policy.
Information We Collect Automatically
Depending on which of our Services you interact with, we may collect and process the following types of information:
We and our third-party providers may use (i) cookies or small data files that are stored on an individual's computer and (ii) other related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies") to provide our website services. Please see the Cookies section of this Privacy Policy for the detailed information.
Personal Data Collected from Third Parties
As mentioned above, most of the information that we collect about you comes directly from you when you play our games or interact with our Services. However, when you allow third-party companies access to your personal data (e.g., downloading our mobile applications through App Store or Google Store and linking your Facebook account to mobile applications), we also collect information from such third parties.
PURPOSES FOR PROCESSING OF YOUR PERSONAL DATA
We collect and use your personal data for the following purposes:
DISCLOSURE OF YOUR PERSONAL DATA
We may also share, transmit, disclose, grant access to, make available, and provide personal data with and to the following third parties. We disclose your personal data for the purposes set forth in this Privacy Policy to provide the Services to our third-party service providers, to comply with legal obligations, and to protect and defend our rights and property.
THIRD-PARTY DATA COLLECTION AND ONLINE ADVERTISING
We participate in interest-based advertising and use third-party advertising companies to serve targeted advertisements based on your browsing history. We permit third-party online advertising networks, social media companies and other third-party services to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices, you may use.
Our advertising partners may help us serve ads to you by combining your personal data with data they have collected about you elsewhere. They collect this information when you use their services or the websites and services of third parties. Our partners use this information to make assumptions about the kinds of advertising you would prefer to see. If they determine that you would be interested in seeing an advert for Dream Games' Services, they will serve you with a Dream Games advertising while using other websites and services. We use ad identifiers and similar technologies to provide our Services to you and in order to collect data from your device. These technologies allow our third-party advertising partners and us to:
Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise location data and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices.
Our third-party partners and we may use this information to make the advertisements you see online more relevant to your interests and provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
Currently, our website uses strictly necessary, functional, analytical/performance, and advertising/targeting cookies. Please see the Cookies section of this Privacy Policy for detailed information.
COOKIES
Like most online services, our website uses the following types of cookies:
Please note, by playing our games, and unless you opt-out of interest-based advertising as explained in this section, your personal data shall be used by our marketing partners to collect and use information about you to improve advertising, targeting and measurement systems as described in their privacy policies.
You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Cookies used by our website operate differently than browser cookies, and cookie management tools available in a web browser may not remove cookies. Please be advised that if you disable cookies, you may lose some of the features and functionality of our website because the cookies are necessary to track and enhance your activities.
To make opt-out requests related to mobile apps on your device for businesses participating in the DAA's CCPA App-based Opt-Out Tool, you can download the appropriate app at https://www.privacyrights.info/.
CONTROL OVER YOUR INFORMATION
Delete or Reset our Services. There are other ways in which you can control the personal data that we collect about you. For instance, delete our games from your mobile device. You could also reset your mobile advertising identifier.
Access to Your Device Information. You may control the Services' access to your device information through your "Settings" app on your device. For instance, you can withdraw permission for the Services to access your network devices and location data and to integrate with your other applications.
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us by any method described in the Contact Us section below. We may not be able to modify or delete your information in all circumstances.
Push Notifications. We may occasionally send you push notifications through our mobile applications with game updates, high scores and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device.
Online Advertising. If you prefer that your personal data is not processed to receive interest-based ads, you can submit an opt-out request by contacting us via privacy@dreamgames.com. You should note that if you opt-out of receiving interest-based or targeted advertising, you will still see advertising, and you may see advertising for Dream Games products and Services, but that advertising will not be targeted using your personal data.
Cookies. Please see the Cookies section of this Privacy Policy for the detailed information on how you can control your cookie settings.
YOUR RIGHTS
Being a user of our Services, you may have certain rights in connection with your personal data and how we handle it. In some circumstances, if the exercise of these rights limits our ability to process personal data (such as in the case of a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner. You may be able to exercise these rights by contacting us at privacy@dreamgames.com.
You may also be a user in the EU and may have rights under the EU General Data Protection Data Privacy Regulation, or a user in Virginia and may have rights under Virginia Consumer Data Protection Act, or a user in Brazil and may have rights under Lei Geral de Proteção de Dados Pessoais, or a user in any other country having local regulations.
Those rights include:
We may need to verify your identity and confirm that you are a California resident in certain circumstances. In order to verify your identity, we will generally either require the successful authentication of your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal data from you, including, but not limited to, your email address, phone number, and/or date of the last transaction on our Services.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we cannot verify your identity or locate your information in our systems. If we cannot comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
European, UK and Swiss Residents: You also have the right to lodge a complaint to your local data protection authority. If you are based in the European Union, information about how to contact your local data protection authority is available here. If you are based in the UK or Switzerland, your local data protection authorities are the UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html).
California Residents: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes.
Authorized Agents: In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in this CA Notice, where we can verify the authorized agent's authority to act on your behalf.
For requests to know, delete, or correct personal data, we require the following for verification purposes:
Virginia Resident: You have the right to know whether your personal data is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes.
To opt out of (i) targeted advertising, (ii) the sale of your personal data, and/or (iii) profiling, you can contact us by any method described in the Contact Us section below. Please see the Control Over Your Information section of this Privacy Policy for detailed information.
CHILDREN
We do not intend to or knowingly collect personal data from children. We use the term "children" to refer to someone who is (a) under 13 years old or, if older (b) between 13 and 17 years old but under the age at which they can give valid consent to the processing of their personal data under applicable local or regional laws.
In general, we do not intentionally or knowingly collect any personal data from children. If a child under the age of 13 has provided personal data to us, we encourage the child's parent or guardian to contact us to request that we remove the personal data from our systems. If you believe that we might have any information from or about children, please Contact Us.
Additionally, parents can enable or disable chat and purchase features through the parental control setting under “Settings” menu. Once parental control is activated, chat and purchase features cannot be accessed without pre-set password.
INTERNATIONAL TRANSFER
All personal data collected or stored by Dream Games may be stored anywhere in the world, including, but not limited to, the Republic of Turkey, the United States, and the European Union. When we transfer your personal data internationally, we will take reasonable steps to ensure that it is treated securely, lawfully, and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your personal is transferred to or stored, used or processed may be different from the privacy laws applicable to the place where you are resident and may not provide the same level of protection for personal data as the country from which it was transferred.
We may transfer personal data about you outside of Europe. When we do so, we rely on appropriate or suitable safeguards recognized under applicable law, including adequacy decisions and standard contractual clauses.
If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that by providing your personal data to us, you consent to process your personal data in the above-mentioned locations.
By choosing to visit the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the Republic of Turkey and the adjudication of any disputes arising in connection with our Services will be in accordance with the terms of Dream Games Terms of Service.
SECURITY
The personal data you provide to Dream Games is stored on servers located in secured facilities and protected by protocols and procedures such as firewalls and data encryption designed to ensure industry-standard security of such data. However, no server, computer or communications network or system, or data transmission over the internet can be guaranteed to be 100% secure. As a result, while Dream Games strives to protect your personal data, Dream Games cannot ensure or warrant the security of any personal data you transmit to Dream Games or through the Services.
By using the Services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues related to your use of the Services. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on the Services or sending an email to you.
LEGAL BASES (FOR EEA, SWISS AND UK USERS)
If you are an individual in the European Economic Area (EEA), Switzerland or the United Kingdom, we collect and process personal data about you only where we have legal bases for doing so under applicable EU, Swiss or UK laws. The legal bases which we rely upon are the following:
In this Privacy Policy, we have explained how you can opt-out of certain types of processing that we undertake. Where any processing is based on your consent, you can withdraw that consent at any time in the ways described in this Privacy Policy. Nonetheless, if you use our Services, we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease using our Services.
THIRD PARTY WEBSITES
Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective Privacy Policies.
RETENTION
We retain your data for as long as your account is active or as needed to provide you with the Services.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time, and we will post the updated Privacy Policy on this page. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. Any new policy will be effective from the date it is published by us.
FOR SOUTH KOREAN RESIDENTS
Please visit dreamgames.com/ko/special-disclosure/ for special disclosures pertaining to residents in South Korea.
CONTACT US
For detailed information collected under this Privacy Policy, you may contact our Data Protection Officer here: privacy@dreamgames.com.
Address: Esentepe Mah. Büyükdere Cad. Maya Akar Center (B Blok) No: 102/106 Şişli / İstanbul / Türkiye
Name of the representative concerning privacy matters within the European Union:
Andrékó Ferenczi Kinstellar Ügyvédi Iroda
Correspondence address: 1054 Budapest, Széchenyi rkp. 3.
E-mail Address: art27.representation.hungary@kinstellar.com