Welcome to the privacy policy of Dawn Town Games. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
Latest update: 17 September 2026
Owner and Data Controller
Dice Tower Games S.r.l.s. – Via Veneto, 11 – 20068 Peschiera Borromeo (MI), Italia – P.IVA 09811520965 – PEC: dtg-publisher@pec.it
Owner contact email: info@dawntowngames.com
Type of Data we collect
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Trackers
Usage Data
number of Users
session statistics
first name
last name
email address
payment info
password
billing address
shipping address
name
order ID
phone number
data relating to the point of sale
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics
Tag management
Handling payments
Managing contacts and sending messages
Advertising
Remarketing and behavioural targeting
Contacting the User
Registration and authentication provided directly by this Application
Platform services and hosting
Hosting and backend infrastructure
Marketing
Spam and bots protection
Handling activities related to compliance
Detailed information on the processing of Personal Data
Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Application.
For more information, please check the privacy policies of the relevant services.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Meta ads conversion tracking (Meta pixel)
Company: Meta Platforms Ireland Limited
Place of processing: Ireland
Personal Data processed: Trackers +1
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on this Application. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Application.
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics 4
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: number of Users +3
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
By completing the contact form with their information, the User authorises this Application to use these details to respond to the inquiries (like quotes, and any other requests).
Personal Data processed:
email address
Usage Data
Handling activities related to compliance
This type of service allows this Application to handle activities related to compliance.
Consent log
Company: this Application
To be able to demonstrate the User’s choices about emails, this Application records every consent given or refused at checkout and in the “Write to us” form and, for purchases, whether the notice about emails on games similar to those purchased was shown at checkout. Each record contains email address, name, IP address, language, date and time, the choice made, the text shown with its version and the number of the order or message. The log is never altered: if the User asks for their data to be erased, email address, name and IP address are removed and only the record of the choice remains. Legal basis: the Owner’s obligation to be able to demonstrate consent and compliance with the User’s choices (Article 6(1)(c) GDPR, in conjunction with Articles 5(2) and 7(1) GDPR). Retention period: for as long as the consent or the notice is relied upon, and for the following five years, the period within which the processing may be challenged (Article 28 of Italian Law 689/1981; Article 2947 of the Italian Civil Code). Place of processing: Italy.
Legal bases and retention periods
Company: this Application
Purchases (WooCommerce, Stripe, PayPal): performance of the contract (Article 6(1)(b) GDPR) and tax and accounting obligations (point (c)). Orders and invoices are kept for 10 years (Article 2220 of the Italian Civil Code). Stripe and PayPal also process payment data as independent controllers, under their own privacy policies. Account (Direct registration): performance of the contract, for as long as the account exists or until the User asks for it to be deleted; orders remain for the period stated above. Messages (Contact form): the User’s request (point (b)); the message is kept for as long as needed to reply and to handle what follows from it, such as an order, a return or a dispute. Service emails (Mailgun): order confirmations, replies and account notices are sent to perform the contract or to reply to the User (point (b)); Mailgun keeps sending logs for the period provided by the service plan. Marketing emails (Brevo): with consent (point (a)), until it is withdrawn; to customers, about games similar to those purchased, under Article 130(4) of Legislative Decree 196/2003, until they object. Analytics and advertising (Google Analytics 4, Meta, Google Ads): the consent given in the banner (point (a); Article 122 of Legislative Decree 196/2003), which can be withdrawn at any time using the preferences button; Google Analytics keeps event data for 2 months, Meta and Google Ads according to their own privacy policies. Tag management (Google Tag Manager): the Owner’s legitimate interest in managing the website’s scripts (point (f)); Google Tag Manager does not install cookies, and services that collect data start only with consent. Hosting (Ergonet): data remain on servers in Italy for the purposes stated; backups of the website and database are kept for 30 days, those of the mailboxes for 7 days.
Handling payments
Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe
Company: Stripe Inc
Place of processing: United States
Personal Data processed: email address +4
Stripe is a payment service provided by Stripe Inc.
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of this Application.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Ergonet
Company: this Application
Ergonet S.r.l. è il servizio di hosting su cui risiedono il sito e il negozio online. Dati personali trattati: varie tipologie di Dati secondo quanto specificato dalla privacy policy del servizio. Luogo del trattamento: Italia – Privacy Policy: https://ergonet.it/risorse-utili/informativa-privacy.html
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailgun
Company: Mailgun Technologies, Inc.
Place of processing: Germany
Personal Data processed: email address +2
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Emails to customers about games similar to those purchased
Company: this Application
Anyone who makes a purchase on the website may receive, at the email address given in the order, proposals for other Dawn Town Games titles similar to those purchased, without being asked for consent, as provided for by Article 130(4) of the Italian Personal Data Protection Code (Legislative Decree 196/2003). Only the purchases made are used to choose what to propose. The User is informed of this at checkout and may object at any time, free of charge and easily, by writing to info@dawntowngames.com or by using the link included in every email: from that moment on, the User no longer receives these communications. This processing does not cover text messages, news, fairs or events, which are sent only with the User’s consent. Personal Data processed: email address, name, purchase data. Place of processing: Italy.
Dawn Town Games emails with consent
Company: this Application
Anyone who chooses to, by ticking the box at checkout or in the “Write to us” form, receives emails from Dawn Town Games about new games, offers and discounts, campaigns and fairs. The box is optional, starts unticked and affects neither the purchase nor the reply to the message. Legal basis: the User’s consent (Article 6(1)(a) GDPR; Article 130(1) of the Italian Personal Data Protection Code, Legislative Decree 196/2003). The User may withdraw it at any time, free of charge, by writing to info@dawntowngames.com or by using the link included in every email; withdrawal does not affect emails already sent. Personal Data processed: email address, name, language. Retention period: until consent is withdrawn. Place of processing: Italy.
Order attribution (WooCommerce)
Company: this Application
Personal Data processed: Trackers
If the User accepts marketing cookies, WooCommerce notes where the visit comes from (referring website, search engine, campaign and UTM parameters, pages viewed in the session, device type and browser) and, at the time of purchase, saves this information in the order, to understand which channels bring sales. Without that consent the trackers are not installed and the order does not contain this information. First-party trackers: sbjs_migrations, sbjs_current, sbjs_current_add, sbjs_first, sbjs_first_add, sbjs_udata, sbjs_promo (session duration) and sbjs_session (30 minutes). Legal basis: the User’s consent, which can be withdrawn at any time using the preferences button. The data saved in the order is kept together with the order. Place of processing: Italy.
Personal Data processed:
Trackers
Service provided by:
this Application
Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
WooCommerce
Company: this Application
Personal Data processed: billing address +9
WooCommerce is a WordPress plugin used by this Application that allows the Owner to build and run an e-commerce website.
Personal Data processed:
billing address
data relating to the point of sale
email address
name
order ID
payment info
phone number
shipping address
Trackers
Usage Data
Service provided by:
this Application
Registration and authentication provided directly by this Application
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration
Personal Data processed: email address +3
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data processed:
email address
password
Trackers
Usage Data
Remarketing and behavioural targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section in this document.
Meta Custom Audience
Company: Meta Platforms Ireland Limited
Place of processing: Ireland
Personal Data processed: email address +1
Meta Custom Audience is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Meta Audience Network.
Users can opt out of Meta’s use of Trackers for ads personalisation by visiting this opt-out page.
Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
This type of service analyses the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognised as spam or protecting it from malicious bots activities.
Spam and bot protection for the contact form
Company: this Application
To stop automated submissions, before a message is sent the User’s browser solves a small calculation (ALTCHA, run by this Application, with no third-party services and no cookies), and only a few messages per hour and per day can be sent from the same connection. To count them, a cryptographic fingerprint of the IP address is used, not the address in clear text, and it is deleted automatically 24 hours after the last message. Legal basis: the Owner’s legitimate interest in protecting the website and its email inboxes from abuse (Article 6(1)(f) GDPR). Personal Data processed: IP address, as a fingerprint. Place of processing: Italy.
Tag management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralised fashion.
This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Trackers +1
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie
Policy.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users in the European Union
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User’s Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User’s browser.
Tracker
Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy relates solely to this Application, if not stated otherwise within this document.
While we strive to create a positive user experience, we understand that issues may occasionally arise between us and our users.
If this is the case, please feel free to contact us.
