Updated on March 3, 2024 Welcome to UpGames and thanks for playing our games! We respect your privacy rights and recognize the importance of protecting the information collected about you. This Privacy Policy is designed to provide clarity about the information we collect, how we use it to provide a better gaming experience as well as how you can exercise your privacy rights. By using the Services, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want us to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play our games or use our Services. We may amend the Privacy Policy from time to time, and we encourage you to consult the Privacy Policy regularly for changes. 1. What information we collect about you and how we use it In general, we only collect information that allows us to provide you with our best Services. This includes, for example, simple tasks like allowing other users to see the nickname and profile picture you choose to show for the possibility of friendly games implementing. It also helps us to keep our services clear of fraud and spam, and it allows us to get a unique understanding of what additional services may be useful to you, and all other purposes set out in this policy below. When you install UpGames' App you will be asked to provide us with your phone number and to allow us access to your mobile device’s address book. A copy of the phone numbers and names in your address book (but not emails, notes or any other Personal Information in your address book) will be stored on our servers and will only be used to: (a) notify you when your contacts become active in the App, (b) indicate which of your contacts is already an UpGames' user, (c) correctly display the name of each contact as it appears in your address book when you use the UpGames' App. (d) sync your contacts with the UpGames' App running on iOS and Android devices. The UpGames' App may interact with your phone’s SMS inbox for the sole purpose of service activation, placing incoming messages in your inbox, reading the contents of the activation SMS sent to you by UpGames' App. WE WILL NOT ACCESS THE CONTENTS OF ANY OTHER SMS. Should you provide your nickname and/or profile photo, it will be visible to other UpGames' App users as long as: · Such users have your UpGames' App number. · Other users will see your connection status whether you are online or not. Before you start using UpGames' App, it’s important you understand that by using our Services, you give us consent to collect, use, disclose, and retain your personal information and other information but we will never read to the content you are sharing privately in UpGames' App chat or transfer your personal information to third parties. You can be sure that we will only use your information as described in this Policy. In addition, the App may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system and information about the way you use the App. The App may access certain device information and/or components automatically. This collection is only for the purpose of providing the services within the UpGames' App. This information is not linked to personal information about the user. UpGames' uses Analytics Services to help us anonymously track and report user/visitor behavior information and users’ standard log information to the UpGames' App. This information (including but not limited to: IP address, data storage, maintenance services, database management, web analytics and information processing) helps us analyze and evaluate how the UpGames' App is used as part of our ongoing efforts to improve the UpGames' App’s features and services. No personally identifying data is included in this type of reporting. These Analytics Services have access to your information only for the purposes of performing these tasks and on behalf of UpGames' App and under obligation similar to those in this Privacy Policy. 2.Data Deletion We will delete or de-identify your personal data as reasonably possible in the following cases: a.When we have no ongoing legitimate business need to process your personal information; b.When we stop operating our Service; c.When you request your data to be deleted by sending email to us at support@upgames.ltd; d.When a platform, such as Meta requires the deletion of your Open Platform Data at their discretion, either to protect you or as part of their compliance review; e. When required by applicable law or regulation. We retain personal information we collect from you where we have an ongoing legitimate business need to do so, when we operate our Service and when we ensure that your personal data is subject to suitable safeguards. For example, to provide you with a Service you have requested, or to comply with applicable legal, tax or accounting requirements. We will for example periodically de-identify unused game accounts and we regularly review and delete unnecessary data. 3. Retention Period We will retain User Provided data for as long as you use the App and for a reasonable time thereafter. We may store information for longer periods for archiving or statistical purposes, in which case we will take appropriate measures to ensure that the information is used solely for this purpose. 4. Sharing and Disclosure of Information We do not rent, sell, or share any information about our users with any third-parties, except as specifically described herein. We may disclose your Personal Information if we believe such action is necessary to: (a) comply with the law, or legal process served on us; (b) protect and defend our rights or property (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of our users. In order to provide you with UpGames' App products you have requested, UpGames'App may sometimes, if necessary, share your Personal Information (excluding your address book and related information) and traffic data with trusted partner service providers and/or agents, for example: banking organizations or other providers of payment and analytical services, customer support, or hosting services. UpGames' App will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation. The following is a description of how we may share your Personal Information with trusted third party partners. Should we add additional partners, we will immediately update this description: · We use third party companies in order to send you an authentication SMS when you register with UpGames' App. In order to send you the SMS, we send one of these third party companies your phone number and the authentication message. These third parties are contractually obligated to only use your phone number for the transmission of the authentication SMS. · We may use Push Notification UpGames' Apps to notify you about various events related to the app. If we do, the phone number or the name of the person calling you or sending you a message may be part of the notification. This message is sent to the push notification service provider, for delivery to your device. · We use third parties to process the payment and/or billing information that you submit through the UpGames' App to facilitate payment transactions. We require that these third parties take the appropriate organizational and technical measures to protect your personal data and traffic data and to comply with relevant laws, but we are not liable or responsible for these third party transactions. Therefore, you should review such third party terms and conditions before providing your payment or billing information. We may disclose information about you if we determine that, for national security, law enforcement, or other issues of public importance , disclosure of information is necessary. We may contact you to send you messages about faults and service issues. Furthermore, we reserve the right to use email, the UpGames' App software or SMS to notify you of any eventual claims related to your use of our software, websites and/or products, including without limitation claims of violation of third party rights. We may send you alerts via the UpGames' App software to notify you when someone has tried to contact you. We may also use the UpGames' App software to keep you up to date with news about our software and products that you have purchased and/or to inform you about other UpGames' App products and related information. 5. Children’s Privacy UpGames' App software is not intended for or designed to attract anyone under the age of 18 and we do not intentionally or knowingly collect Personal Information from anyone under the age of 18 (or older in some jurisdictions). We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission. 6. Security We take reasonable precautions to protect Personal Information from misuse, loss and unauthorized access. We know that security is important to our users and we care about the security of your information. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use include firewalls, data encryption, physical access controls to our data centers and information access authorization controls. We need your help too: it is your responsibility to make sure that your personal information is accurate and that your account registration information is secure and not shared with third-parties. 7. Accessing, Reviewing, and Changing Your Personal Information As a registered member, you can review and change personal information at any time by accessing your account on the App. Please be sure to update your personal information promptly if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent you from re-registering. To easily access, view, update or delete your personal data, please visit “Profile Settings“ in your Profile. If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements. If you are unable for any reason to access your Profile Settings, you may also contact us by support@upgames.ltd. 8. Updates to this Policy From time to time, as our services evolve, we may update this Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the App. Please check the App frequently for updates. 9. Contact Us If you still have questions about our privacy policy, please feel free to send us an email to support@upgames.ltd.