Privacy Policy - Dawnbright Games

Dawnbright Games - Privacy Policy
Effective Date: March 01, 2025
Please also review Dawnbright Games’ Terms and Conditions which also takes effect on the same date as these Privacy Policies.

1. Purpose
This Privacy Policy is incorporated by reference into the Dawnbright Terms of Service. The terms “Dawnbright,” “we,” and “us” include Dawnbright Games. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use, store, protect, disclose and share that information, and how you can opt out of a use or correct or change such information.

2. Scope
This Privacy Policy applies to Personal Information that is Processed by Dawnbright in the course of our business, including on Dawnbright websites (each a “Site”), mobile applications, forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Dawnbright (the “Services”)). All individuals whose responsibilities include the Processing of Personal Information on behalf of Dawnbright are expected to protect that data by adhering to this Privacy Policy.
This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, Turkey, APAC, and other jurisdictions.
- By visiting, installing, using or otherwise accessing the Services, you agree to this Privacy Policy and Terms of Services of Dawnbright and give an explicit and informed consent to the processing of your Personal Information in accordance with this Privacy Policy.
- Please do not install or use the Services if you do not agree to this Privacy Policy or Terms of Services.
- Please note that Dawnbright is not responsible for the actions of Third Parties, the content of their sites, the use of information you provide to them or any services they may offer.
- Dawnbright reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

3. Types of Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third-party sources) and our privacy practices depend on the nature of the relationship you have with Dawnbright and the requirements of applicable law.
Some of the ways that Dawnbright may collect Personal Information include:
- You may provide Personal Information directly to Dawnbright through interacting with the Services, participating in feedback, questionnaires, surveys, contests or forum discussions, and requesting Services or information.
- As you navigate the Services, certain passive information may also be collected about your visit, including through Cookies and similar technologies.
Primary goals in collecting information are to provide and improve our Services, administer your use of the Services, and enable you to easily navigate and enjoy our Services.
We endeavor to collect only that information that is relevant for the purposes of Processing.
Below are the ways we collect Personal Information and how we use it.

3.1 Types of Personal Information We Collect
Dawnbright collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).

3.1.1 Information Collected from Third-parties when Installing and Playing the Games
If you play any of the games or use any of the Services on connected Third-party applications or connect the Services to any Third-party applications (e.g. Apple, Google, Amazon or Social Networking Sites like Facebook), Dawnbright may receive certain information about you from the provider of the Third-party application.
- The information received depends on the Third-party application, your privacy settings and, if applicable, your friends' privacy settings.
- When connecting via an SNS, the information may include your first and last name, SNS user ID/username, profile picture or its URL, location, sex, login email provided during registration, age-range (e.g. min 21), locale, language, time zone and SNS user IDs for friends connected to the Services.
- When using mobile platforms, information such as your unique device ID (persistent/non-persistent), device operating system, version, model, CPU, RAM, disk space, hardware type, Identifier For Advertising (IDFA), Advertising ID, OS version, device name, Game Center ID, and IP-based location may be collected.
- This information is useful for troubleshooting and understanding usage trends.
- For payment processing via Third Parties, Dawnbright does not collect/store personally identifiable financial information.
- Third Party payment processors may share non-financial purchase-related information with us.
- You can manage the information received from Third-party applications via the respective privacy settings and mobile device permissions.
- If you access the Services via a Third-party application, please review that application’s terms and privacy policy.

3.1.2 Information Collected Directly from You
When you use the Services or engage in certain activities (e.g. registering for an account, completing surveys, requesting services or information, or contacting us), we may ask you to provide:
- Registering for an Account: Personal Information such as your name, email address, player name, password, and profile information (e.g. profile photo).
- Communications with Us: Personal Information like email address, phone number, or mailing address when you request support or information.
- User Reviews: Comments about our games, which may include Personal Information, provided voluntarily to help improve our products, Sites, or Services.
- Fan Pages, Forums, and Posting on the Site: Content you share on publicly accessible pages (blogs, forums, private messages) may be collected along with any Personal Information you include. Public submissions will not be subject to the privacy protections described here.
- Registration for Contests: Contact information (e.g. email address) provided for contest entry may be used to reach you regarding the contest and for promotional purposes, with an opt-out option available.

3.1.3 Automated Data Collection
We or our Service Providers (e.g. Fabric Analytics, Google Analytics) may:
- Store log files and use tracking technologies (Cookies, web beacons, tracking pixels) to automatically collect information such as IP address, cookie IDs, mobile advertising IDs, device identifiers, browser type and language, pages visited, duration of visit, clicked links, and preferences.
- In some cases, link this information with your social network ID, Device ID, Game Center ID, or Advertising ID.
- Refer to Section 3.3 for further details on tracking technologies.
- Additionally, any content you submit via the Services may be used by Dawnbright for developing, manufacturing, and marketing the Services unless you specify otherwise or legal requirements apply.

3.1.5 Ad Networks
Dawnbright may display advertising within the Services. Advertisers may collect information such as:
- Game performance and contextual data (e.g. session activity),
- Aggregated or de-identified information,
- Technical data (device identifier, Advertising ID, IP address).
- Ad Networks use this information for interest-based or targeted advertising.

3.1.6 Social Media Widgets
The Services include Social Media Features (e.g. Facebook, Twitter buttons) and Widgets (e.g. “Share” button) that may:
- Collect your IP address and page visits,
- Set cookies to function properly,
- Be hosted by Third Parties or directly on the Services.
- Your interactions are governed by the privacy policies of the providing companies.
- Technical protection measures (“2 click solution”) are implemented to allow you to permit data transfer on a case-by-case or permanent basis.
- Permanent agreements can be withdrawn at any time.

3.2 How We Use Your Information
Our primary uses of collected information include:
- Providing and improving the Services,
- Administering your use of the Services,
- Contacting you,
- Conducting marketing and research,
- Creating internal reports.
- Data is stored on servers (e.g. via Amazon Web Services in the United States) and possibly in other countries.
- Specific purposes include:
• Providing Services or Information Requested:
- Operating and optimizing our games and Services,
- Creating game accounts,
- Personalizing your experience,
- Granting access to features,
- Sending notifications (e.g. in-game updates, technical notices, security alerts),
- Facilitating player communication,
- Responding to inquiries and providing customer support,
- Preventing illegal activities,
- Verifying identity.
• Informing You about Our Games, Products, and Services:
- Sending promotional materials (via in-game offers, push notifications, email, etc.),
- Tailoring content and advertisements,
- Notifying you of offers, rewards, contests, and surveys.
- An opt-out option is available for such communications.
• Sending Push Notifications:
- For game updates, high scores, and other important notifications via mobile applications.
- You can opt out by changing device settings.
• Using Anonymous and Aggregated Information:
- To create de-identified demographic or location data,
- For research, internal analysis, and analytics.
- Such aggregated data is not personally identifiable.
• Providing Services via Mobile Devices:
- Collecting mobile-specific information (device identifier, user settings, location, carrier, OS) for Services optimized for mobile devices.
- Usage data may be linked with your account.

3.3 Cookies, Pixel Tags, Web Beacons, Analytics Information and Interest-based or Targeted Advertising
- We and Third Parties may use Cookies, pixel tags, and similar Technologies to collect information automatically.
- These small data files are stored on your device to record information about your interactions with our Services.
• Cookies:
- Small text files that store your preferences.
- Can be blocked or deleted via browser settings (which may affect site functionality).
• Pixel Tags/Web Beacons:
- Code embedded in the Site to record user engagement (e.g. page visits, ad clicks).
• Social Media Widgets:
- Embedded features (e.g. Facebook “Like”, LinkedIn “Share”) that may set cookies and collect visit data.
- Governed by the privacy policies of the respective Third Parties.
• Analytics:
- Use of tools like Google Analytics to collect visitor behavior and demographics.
- Data (including a truncated IP address via anonymization) is transmitted to and stored by Google.
- For more information or to opt out, visit the relevant Google pages.
• Categories of Technology Usage:
- Operationally Necessary: Essential for site functionality, security, and preventing fraud.
- Performance-related: To assess website/app performance.
- Functionality-related: To offer enhanced user experiences (e.g. remembering preferences).
- Advertising or Targeting-related: To deliver interest-based advertisements.
• Opting Out:
- You may adjust your browser settings to restrict Cookies.
- Note that Flash Cookies require separate management.

3.4 Third-party Websites, Social Media Platforms and Software Development Kits
- The Site may include links to and references from Third-party websites.
- These sites are not under Dawnbright’s control; please review their privacy policies.
- Publicly accessible blogs, forums, and messaging features may expose any information you post.
- Use of social media platforms may result in cookies being set on your device.
- Information shared publicly may be viewed and used by others without restrictions.

3.5 Third-party Payment Processing
- When you purchase Virtual Items or Merchandise, payments are processed via Third-party applications (e.g. Apple App Store, Google Play, Amazon App Store, SNS such as Facebook).
- These Third Parties collect financial information (name, email, billing address, etc.) to process your payment.
- App Stores do not share this financial information with Dawnbright.

4. How We May Disclose Your Information
- Other Players and Users:
- Social features may allow other players to view your profile, in-game activities, achievements, messages, and leaderboard scores.
- Third-party Websites, Social Media Platforms, and Software Development Kits:
- Your information may be shared with Third-party Service Providers to provide the Services, comply with legal obligations, or protect our rights, or with your consent.
- Service Providers:
- Information may be shared with providers of IT services, customer support, payment processing, etc.
- Contracts are in place to restrict the use of your Personal Information by these providers.
- Business Partners:
- Information may be shared with Business Partners or affiliates for internal business purposes or joint product/service offerings.
- Confidentiality agreements are required.
- Displaying to Friends and Other Users:
- When you interact on social networks (e.g. Facebook Connect), your name, profile photo, and game activity may be visible to your friends and other players.
- Publicly shared content may also reveal your social network or player ID.
- Marketing – Interest-based or Targeted Advertising and Third-party Marketing:
- Third-party advertisers may set tracking tools to collect performance data, technical information, social network IDs, gameplay context, and pseudonymous data.
- This data is used to measure ad effectiveness and deliver targeted advertisements.
- Disclosures to Protect Us or Others:
- Your Personal Information may be disclosed to comply with legal requests, protect rights, enforce policies, collect debts, or prevent harm.
- Server logs may be reviewed and shared with law enforcement if unauthorized activity is detected.
- Merger, Sale, or Other Asset Transfers:
- In the event of corporate transactions (mergers, acquisitions, sales), your information may be transferred.
- Dawnbright will endeavor to require the transferee to adhere to the existing Privacy Policy.

5. International Transfer
- All Personal Information collected may be stored anywhere in the world (e.g. Turkey, United States, European Union, cloud servers).
- When transferring data internationally, reasonable steps are taken to ensure its secure and lawful treatment.
- Privacy laws may vary between jurisdictions.
- By providing your information, you consent to its storage and processing in these locations.
- If you use the Services from regions with data protection laws, you agree to the transfer of your information to Turkey, the United States, and other regions as described.
- Disputes regarding privacy will be governed by Turkish law and the Terms of Services.

6. Opt Out (Right to Restrict Processing)
- You have the right to opt out of certain uses and disclosures of your Personal Information.
- Consent previously given to process your data may be withdrawn via an in-game support ticket or by contacting [email protected].
- Even if you opt out, anonymized and non-Personal Information may still be collected.
- Note that certain records (e.g. payment or customer service) are retained for legal and accounting purposes.
- Email Communications:
- Unwanted emails can be unsubscribed using the link in the email.
- Transaction-related emails (e.g. order confirmations) will still be sent.
- Mobile Devices:
- Push notifications sent via mobile applications can be opted out by adjusting device settings.
- Location-based information collection can also be disabled via device settings.
- Cookies and Interest-based or Targeted Advertising:
- You may restrict or delete Cookies via your browser settings.
- For flash Cookies, visit Adobe’s Global Privacy Settings Panel.
- Online opt-out tools (e.g. Network Advertising Initiative, Digital Advertising Alliance) are available, though they must be applied on each device and browser.
- Mobile opt-out may require resetting the Advertising Identifier or using specific apps (e.g. “AppChoices”).

7. Rights of Access, Rectification, Erasure, and Restriction
- You have the right to request access to, rectification or erasure of, and restriction on the processing of your Personal Information, as well as the right to object and data portability.
- The general right to object applies to all processing types described herein.
- For direct marketing, an objection will be followed only if specific grounds are stated.
- To exercise these rights, open a support ticket or email [email protected] with:
• Your full name,
• User identifier,
• Email address associated with your account,
• A detailed description of your request.
- Requests will be processed according to applicable law.
- In some cases (e.g. legal privilege, risk to privacy, or disproportionate burden), access may be restricted, with an explanation provided.
- Verification of your identity will be performed before any changes are made.

8. Data Retention
Dawnbright retains Personal Information for as long as you use our Services or as necessary to:
- Fulfill the purposes for which it was collected,
- Provide our Services,
- Resolve disputes,
- Establish legal defenses,
- Conduct audits,
- Pursue legitimate business purposes,
- Enforce our agreements,
- Comply with applicable laws.

9. Security of Your Information
- Your Personal Information is stored on secured servers with industry-standard measures (firewalls, encryption).
- However, no system or transmission over the Internet can be guaranteed 100% secure.
- By using the Services or providing Personal Information, you agree to electronic communication regarding security, privacy, and administrative issues.
- In the event of a security breach, Dawnbright may notify you via the Services, email, or push notifications.

10. Children’s Privacy
- The Services are not directed to children under 13, and Dawnbright does not knowingly collect Personal Information from children under 13.
- If you are a parent or legal guardian of a child under 13 (or under 16 in certain EU jurisdictions) using our games, please contact [email protected].
- Dawnbright will delete your child’s Personal Information if identified, unless verifiable parental consent is provided for continued use.

11. Redress/Compliance and Accountability
- For questions about our privacy practices or this Privacy Policy, please contact us at [email protected].
- We will address your concerns and attempt to resolve any privacy issues in a timely manner.

12. Changes to Our Privacy Policy and Practices
- Revision to the Privacy Policy:
• We may revise this Privacy Policy at our sole discretion; please review it periodically.
• Continued use of the Site and Services after changes constitutes your consent.
- Posting of Revised Privacy Policy:
• Material changes will be notified by email or as required by law.
• Adjustments will be posted on this web page and become effective immediately (or as specified).
• Bookmark and review this page periodically if concerned.
- New Uses of Personal Information:
• Before using Personal Information for a new purpose not previously authorized, Dawnbright will provide information on the new purpose and offer an opt-out.
• Dawnbright will comply with applicable law or contract regarding new processing purposes.

13. California Privacy Rights
- California residents may request, once a year and free of charge, a list of Third Parties to whom we have disclosed their Personal Information for direct marketing purposes in the prior calendar year, including the type of information disclosed.
- Dawnbright does not share Personal Information with Third Parties for their own marketing purposes.

14. Contact Info of Data Controller
- For questions about our privacy practices or this Privacy Policy, please contact Dawnbright’s data protection officer by email at [email protected].
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