Last updated: October 13, 2025
We, Dream Games Teknoloji A.Ş. (as of November 1, 2025, we will
become Dream Games Dijital Teknolojiler A.Ş.), 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 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; and
- 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; and
- 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; and
- 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"),
and
- 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.
- For personal data collected through essential technologies, we
rely on the Contract Performance Legal Basis or Legitimate Interest
Legal Basis.
|
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 you 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.
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.