Supplemental Türkiye Privacy Statement

English

Last updated: November 11, 2024

We, Dream Games Teknoloji Anonim Şirketi, address this Supplemental Türkiye Privacy Statement to individuals located in Türkiye. This document supplements our Dream Games Privacy Policy.

1. What laws apply?

If you are located in Türkiye, the Law No. 6698 on Protection of Personal Data ("DPL") applies to the processing of your personal data.

2. Who is the data controller?

The data controller is:

Dream Games Teknoloji Anonim Şirketi

Esentepe Mah. Büyükdere Cad. Maya Akar Center (B Blok) No: 102/106 Şişli / İstanbul / Türkiye

3. What lawful bases of processing do we rely on?

You are not legally required to provide personal data to us but we cannot provide our websites, mobile applications, forums, blogs or other services (collectively, “Services”) without receiving some personal data from you. If you provide personal data, we rely on the following legal bases to process it:

  • Necessary for us to perform a contract with you or take steps at your request prior to entering into a contract per Article 5(2)(c) of the DPL ("Contract Performance Legal Basis");
  • Necessary for us to comply with an applicable legal obligation per Article 5(2)(ç) of the DPL ("Legal Obligations Legal Basis");
  • Necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests per Article 5(2)(f) of the DPL ("Legitimate Interest Legal Basis"); or
  • According to your consent per Article 5(1) of the DPL ("Consent Legal Basis"). In these cases, you can withdraw your consent at any time with future effect by emailing us at privacy@dreamgames.com.

The following table outlines the legal basis along with processing purposes and processed data categories (where appropriate).

Data Categories, Purposes, and Legal Basis
Data Categories Purposes of Processing Legal Basis
  • Contact information
  • User generated content
  • Profile and gameplay information (including Dream Games ID defined to user)
  • Device information
  • Commercial information (the purchased products and services within Services, including data received from application store providers)
  • To enable us to provide our games (including the social elements of our games, such as team play and competitions), to ensure that your purchases are activated in the games, to provide you with player support if you need it;
  • To provide access to certain areas, functionalities and features of our Services, including social features and multiplayer competitions;
  • To enable us to optimize our games for you and for the device that you are using, as well as to deliver customized in-game events, offers and promotions;
  • To verify your identity and entitlement to products or Services when you contact us or access our Services;
  • To help maintain the safety, security and integrity of our property and Services, technology assets and business;
  • To respond to your comments and inquiries and provide customer support services.
 Contract Performance Legal Basis
  • Contact information
  • User generated content
  • Profile and gameplay information (including Dream Games ID defined to user)
  • Survey information
  • Device information
  • Analytics information
  • Commercial information
  • Information that may be received from social media network providers (strictly limited to your privacy settings with the social network provider)
  • To manage our organization and its day-to-day operations;
  • To request your participation in our surveys about our organization, organizations we partner with, and the Services;
  • To develop new games and other Services;
  • To enable players to communicate with each other in games or on our social media accounts;
  • To measure interest in our Services;
  • To conduct internal research and analytics;
  • To personalize your in-game profile;
  • To personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users' experience;
  • To ensure internal quality control.
 Legitimate Interest Legal Basis—namely, to operate and optimize our business; improve our Services; administer communities of users; develop new Services; manage our relationships with users; and ensure the security and integrity of our platforms and systems.
  • Contact information
  • User generated content
  • Profile and gameplay information
  • Parental information
  • Other information required to address your concern submitted through customer service channels
  • To communicate with you regarding Services-related information, including confirmations, technical notices, updates, security alerts and support and administrative messages;
  • To provide support through our customer service channels when requested.
  • If we are contractually required to provide such communications or support, Contract Performance Legal Basis.
  • If applicable laws require us to provide such communications or support, Legal Obligations Legal Basis.
  • Otherwise, Legitimate Interest Legal Basis—namely, to manage our relationship with you.
  • Contact information
  • User generated content
  • Profile and gameplay information
  • Survey information
  • Device information
  • Analytics information
  • Commercial information
  • Parental information
  • To enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our Terms of Service or, where necessary, to defend, exercise or establish our legal rights, including our rights under our Terms of Service;
  • To comply with contractual and legal obligations and requirements;
  • To activate, verify and give effect to parental control settings;
  • If we are contractually required to process your personal data for these purposes, Contract Performance Legal Basis.
  • If applicable laws require us to process your personal data for these purposes, Legal Obligations Legal Basis.
  • Otherwise, Legitimate Interest Legal Basis—namely, to enable us to comply with laws, prevent fraud, enforce contracts and defend, exercise or establish our legal rights.
All related information for the transaction
  • To evaluate and enter into a reorganization, restructuring, merger, acquisition, or whole or partial sale or transfer of our business or assets ("Business Transaction")
  • To engage in the marketing activities described in this Privacy Policy.
 Legitimate Interest Legal Basis—namely, to engage in a transaction that our management team considers to be advantageous to our business interests. But we will seek your consent if we wish to use your personal data for any new purpose incompatible with those set forth in our Privacy Statements, and if you provide such consent, the Consent Legal Basis applies.
  • Analytics information
  • Device information
  • Commercial information
  • Inferences
 To use or disclose personal data for cross-context behavioral advertising, targeted advertising, or interest-based. We obtain consent before using tracking technologies other than essential technologies on your device and rely on the Consent Legal Basis to process your personal data to customize our advertising to you or deliver cross-context behavioral advertising, targeted advertising or interest-based advertising to you.

4. Where is your personal data processed and on what basis do we transfer personal data across borders?

Your personal data is transferred abroad in accordance with Article 9 of the DPL.

5. Your Rights

In Türkiye, you have the following rights, subject to the conditions under the DPL:

  • Right to learn whether your personal data are processed or not; and
  • Right to request information regarding your data, if your personal data are processed; and
  • Right to learn the purpose of processing of your personal data, and whether your personal data are used for the intended purposes or not; and
  • Right to learn the identity of third parties to whom your personal data are transferred in Türkiye or abroad; and
  • Right to request completion or correction of your data, if your personal data are processed incompletely or inaccurately, and
  • Right to request deletion or destruction of your personal data; and
  • If your personal data are corrected, deleted or destroyed, to request notification of these transactions to third parties to whom your personal data are transferred; and
  • Right to raise objections against any consequences that may arise in disfavor of you as a result of analysis of the processed data solely and exclusively through automatic systems; and
  • Right to claim indemnification of your damages and losses, if any, incurred due to illegal or unlawful processing of your personal data  

To submit a request to exercise your privacy rights, you can contact us by any method described in the Contact Us section below. In your request, please describe what rights you are exercising and how you would like us to assist. We may need to request specific information from you to help us verify your identity and that you have the right to request what your are requesting. These are security measures to ensure that we do not disclose personal data to any person who has no right to receive it, or otherwise process the data in unauthorized ways. We may also contact you to ask for further information about your request to clarify the scope of your request and speed up our response. The requests in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest.

6. Contact Us

If you have any questions about our privacy practices, personal data processing activities, or would like to exercise your rights under privacy laws, you may contact our privacy team here: privacy@dreamgames.com.

Address: Esentepe Mah. Büyükdere Cad. Maya Akar Center (B Blok) No: 102/106 Şişli / İstanbul / Türkiye

7. Changes

From time to time, we may revise this Supplemental Türkiye Privacy Statement. When we do so, the changes will be posted and the revised document will be available online and the “last updated” date above revised.