Privacy Policy

This Privacy Policy describes the information that "UPAPP" S.R.L. and its subsidiaries and affiliates ("we," "our" or "us") collect through websites that we operate and any mobile application of ours (each, an "App") (collectively, the "Service"), how we use, disclose and protect your information and the choices you can make about your information.
1. CONSENT

By accessing the Service, you expressly consent to the collection, use, disclosure and storage of your information and other information received by us as a result of such use in accordance with this Privacy Policy and the Terms of Use (http://betup.org/privacy/privacy.html) or your consent, and as permitted or required by applicable law. If you do not agree with the terms of this Privacy Policy or the Terms of Use, you should immediately stop using or accessing the Service. Please note that the Service may be hosted in countries other than yours, including the United States. By accessing the Service, you expressly consent to the transfer of your information outside of your home country, which may provide for different data protection rules than in your country. We make use of third-party service providers, including service providers located in Canada, the United States and the European Union to store and process data, including your information, on our behalf. When acting on our behalf, such service providers are only authorized to collect, use, disclose or store personal information as described in this Privacy Policy. However, the government, courts, law enforcement, security, or regulatory agencies of a particular country may be able to obtain access to or disclosure of personal information as permitted by the laws of that country.

Any questions in this regard may be directed to the Privacy Compliance Officer or the Data Protection Officer using the contact information provided below.

2. HOW WE COLLECT AND USE INFORMATION

What type of data we collect and process?

We collect and process the following data from you:

Information that you provide by filling in forms on our services (like: first name, last name, your email address, your username, your image/photo). This includes information provided at the time of registering to use our services, subscribing to our service, posting material or requesting further services. We may also ask you for information, and when you report a problem with our services.
If you contact us, we may keep a record of that correspondence.
Details of transactions you carry out through our site and of the fulfillment of your orders.
Details of your visits to our services including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Your unique ID (ID of user logged in to Google Play, Game Center, etc).
Unique device ID (if you are not logged in to any of the above services).
IP address.
Information concerning usage of our services (how and when you use the services, your language).
Location related info (Country, time zone etc).
Device model & device properties (GPU, resolution, operating system, etc).
All game-related info (Save, highscores, progress, progress history, items etc).
Session numbers with timestamp; session detailed process (e.g. user entered this level, user lost this level, user entered this screen etc).
Purchases with timestamp; what player purchased, when, purchases count etc.
Information related to usage of social media, if you connected your social media account to our services

Only part of the above mentioned data qualifies as the personal data. Some of the data we collect do not allow us to identify you, and a collection of such data is not intended for identification of an user.

We may collect and process additional data, for example, if you contact our support.

    Information we may collect and/or receive from third parties: We may receive information about you from third parties including third party social networking services. You should always review, and if necessary, adjust your privacy settings on third party websites and services before linking or connecting them to the Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service. We also may collect information about you from third party business partners, publicly available sources and our subsidiaries and affiliates.

    Analytics information. We may directly collect information, or we or our third party business partners may use analytics tools to help us measure traffic and usage trends for the Service ("Analytics Information").

    Cookies information: When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your device that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the Service ("Cookie"). A Cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us and/or our third party business partners to track your usage of the Service over time. A persistent Cookie remains on your device after you close your browser. Persistent Cookies may be used by your browser on subsequent visits to the Service. Persistent Cookies can be removed by following your browser's directions. A session Cookie is temporary and disappears after you close your browser. You can set your browser to refuse certain Cookies or to indicate when a Cookie is being sent. However, some features of the Service may not function properly if the ability to accept Cookies is limited or disabled.

    Log file information: Log file information is automatically reported by your browser each time you access a web page or other content within the Service. We may also receive log information relating to your device and your use of our Apps. When you use the Service, our servers automatically record certain log file information ("Server Logs"). These Server Logs may include anonymous information such as your web request, Internet Protocol (IP) address, operating system, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. The information contained in Server Logs is used to monitor, assess, manage, diagnose problems with, improve and otherwise administer the Service.

    Clear gifs/web beacons information: "Clear Gifs" (also known as web beacons) are used to anonymously track the online usage patterns of our users. We also may use Clear Gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. You can disable the ability of Clear Gifs to track certain information by setting your browser to refuse certain Cookies. The information allows for more accurate reporting, monitoring and improvement of the Service.

    Device identifiers: When you access the Service by or through a mobile device (including but not limited to smart phones or tablets), we and/or our third party business partners may access, assign, collect, monitor and/or remotely store one or more unique device-specific identifiers, such as a universally unique identifier (UUID) ("Unique Identifiers"). Unique Identifiers are small data files or similar data structures stored on and/or associated with your mobile device, which uniquely identify your mobile device. A Unique Identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us. A Unique Identifier may convey information to us about how you browse and use the Service. A Unique Identifier may also be used to help you log in faster and enhance your navigation through the Service.

    Advertising identifiers: Advertising identifiers are unique strings associated with your mobile device provided by the operating system ("Advertising Identifiers").

    Location data: When you access the Service by or through a mobile device, we may access, collect, monitor and/or remotely store location data, which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device ("Location Data"). Location Data may convey to us information about how you browse and use the Service. Location Data may be used to personalize and customize your experience when using the Service, facilitate the functionality of certain features within the Service, and to improve the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of Location Data is impaired or disabled.

    Commercial and marketing communications: We use the information we collect or receive to communicate directly with you. We may send you electronic messages containing Service-related notices (e.g., account verification, purchase and billing confirmations and reminders, feature notifications, technical and security notices). We may also send you electronic messages containing product and/or service offerings, promotions, invitations and special offers. You can also stop receiving electronic messages (other than Service-related notices) from us by clicking on the "unsubscribe link" provided in such communications or by changing your account preferences or settings.

    Use of certain service type information we collect: We use or may use Cookies, Server Logs, Unique Identifiers, Advertising Identifiers, Location Data and Clear Gifs information to: (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide personalized content and information; (iii) provide and monitor the effectiveness of the Service; (iv) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (v) diagnose or fix technology problems; (vi) help you efficiently access your information after you sign in; (vii) provide targeted advertising to your browser or device; (viii) automatically update our App on your mobile devices; (ix) allow you to comment on or provide content and participate in contests, special offers and/or promotions; and (x) conduct research, beta testing or surveys.

    With consent: We may use your information for any other purpose for which you consent.

    Combining information we collect: We may combine any of the information we collect from or about you and use it in the manner described in this Privacy Policy.

3. SHARING OF YOUR INFORMATION

Information may be disclosed to third parties in accordance with this Privacy Policy.

    Who we may share your information with: We may share your information with third party business partners that function on our behalf. Examples include, but are not limited to, companies that assist us with serving advertisement within the Service, analyzing data, and providing marketing assistance. We may share information about you that they need to perform their functions. We will use contractual or other means to protect personal information disclosed to such third parties. We may also share your information with any subsidiary or affiliate of ours for purposes consistent with this Privacy Policy. Any subsidiary or affiliate of ours will be required to maintain that information in accordance with this Privacy Policy.

    Who you may choose to share Your Content with; removal of content: Any information or content that you voluntarily disclose for posting to the Service, such as Your Content (as defined in the Terms of Use at http://www.betup.org/privacy/terms.html), becomes available to the public, except as limited by any privacy settings made available on the Service. Subject to your privacy settings, any of Your Content that you voluntarily make public may be searchable by others. If you remove information or content that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other users have copied or saved that information or content. Please note that such removal does not ensure complete or comprehensive removal of the content or information posted (for example, your content or information may remain visible because it was copied and posted or reposted by a third party).

    What happens in the event of a business change: If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to a third party or parties in connection therewith.

    Instances where we are required to share your information: Regardless of the choices you make regarding your information and to the extent permitted or required by applicable law, we may disclose information about you to third parties to: (i) enforce or apply the Terms of Use or any applicable end user license agreement; (ii) comply with law, in response to subpoenas, warrants, or court orders, or in connection with any legal process or cooperate with government or law enforcement officials or private parties; (iii) protect our rights, reputation, safety and property, or that of our users or others; (iv) protect against legal liability; (v) establish or exercise our rights to defend against legal claims; and/or (vi) investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety or property of us, users or others, violation of the Terms of Use, our policies or agreements or as otherwise required by law.

    Sharing certain service type information we collect about you: We may share certain service type information, including information obtained through tools such as Cookies, Server Logs, Unique Identifiers, Advertising Identifiers, Location Data and Clear Gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third party business partners for the purposes described in the section above on "How We Collect and Use Information." We may also aggregate or otherwise strip data of all personally identifying characteristics (such as your name and email address) and may share that aggregated, anonymized data with third parties.

    Ads on the Service: We may also share certain information and data, such as Location Data, browser and Cookie data, Unique Identifier data, Advertising Identifier data and other data relating to your use of our Service, with our advertising partners to deliver advertisements ("ads") that may be of interest to you. We may allow third party advertisers, including but not limited to direct advertisers, ad networks, ad exchanges, and private advertising marketplaces (collectively "Advertisers"), to serve advertisements on the Service. These Advertisers use technology to send, directly to your browser or mobile device, the ads and ad links that appear on the Service, and will automatically receive your Internet Protocol (IP) address when they do so. They may also use other technologies (such as Cookies, JavaScript, Unique Identifiers, Advertising Identifiers, Location Data, and Clear Gifs) to compile information about your browser's or device's visits and usage patterns on or off the Service and between multiple platforms such as your computer and your mobile device, measure the effectiveness of their ads, and personalize the advertising content to your interests. You can opt out of receiving certain Cookies by adjusting your browser settings to refuse certain Cookies or to alert you when a Cookie is placed. Your browser settings may not permit you to block the use of certain non-Cookie technologies, and those browser settings that block Cookies may have no effect on such techniques. You may also reset Advertising Identifiers and limit advertising tracking (See "Your Choices About Your Information" below).

    Please note that Advertisers may ask us to show an ad to a certain audience of users (e.g., based on demographics or other interests). In that situation, we may (i) determine the target audience and serve the ads to that audience, or (ii) provide certain data as described above to the Advertisers to enable them to serve the ads to the target audience. If you respond to such an ad, the Advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

    We do not sell, rent, or share PII we collect directly from you or about you from third parties with third party Advertisers for their own marketing purposes, unless you choose in advance to have such information shared for this purpose.

    Data Analysis: We may use third-party data analysis service providers to collect data and to provide information to us on the performance of our Service. These companies may use information about your use of the Service and other websites and mobile applications to compare information about the performance of our Service. These companies do not use personally identifiable information (such as your name, address, email address or telephone number) when performing data analysis. These companies may also use non-Cookie technologies to recognize your computer, browser or mobile device and/or to collect and record information about your browsing activity, including your activities on or off the Service and between multiple platforms such as your computer and your mobile device. Please keep in mind that your browser settings may not permit you to block the use of these non-Cookie technologies, and those browser settings that block Cookies may have no effect on such techniques.

This Privacy Policy does not apply to, and we cannot control the activities of, third party Advertisers. Please consult the respective privacy policies of such Advertisers or contact such Advertisers for more information.
4. HOW WE PROTECT YOUR INFORMATION

We care about the security of your information, and take physical, technological and administrative measures to protect the information you submit via the Service against loss, theft, and unauthorized access, use, disclosure or modification. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Service may not be accessed, disclosed, altered or destroyed. Electronic communications sent to or from the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email.

BETUP app uses Appodeal SDK to show ads. We strive always to use the latest SDK which is fully GDPR compliant. The full privacy policy from Appodeal can be found here

5. YOUR CHOICES ABOUT YOUR INFORMATION

    You control your account information and settings: You may update your account information and electronic message preferences at any time by logging in to your account and changing your profile settings or by contacting us as described in "How to Contact Us" below. You can also stop receiving electronic messages (other than Service-related notices) from us by clicking on the "unsubscribe link" provided in such communications.

    Access, questions or concerns: If you have any questions or concerns, or if you simply want to know whether we have any of your PII on file, you may contact our Privacy Compliance Officer as described in "How to Contact Us" below. Except as set out in applicable privacy laws, we can tell you whether we hold PII about you. We will allow you access to your PII. We will use reasonable efforts to tell you the source of the information and give an account of the use that has been made or is being made of the information and the third parties to whom it has been disclosed. If you are not satisfied with the response from the Privacy Compliance Officer after making a request, you may have recourse to additional remedies under applicable privacy laws.

    Do Not Track: At this time, we do not recognize "do not track" signals sent from browsers.

    Managing the collection of your information for Analytics and Advertising Purposes: Please refer to your device’s or browser's technical information for instructions on how to delete and disable Cookies, and other tracking/recording tools, including how to reset your Advertising Identifiers and limit advertising tracking. Depending on the type of device you are using to access the Service, it may not be possible to delete or disable tracking mechanisms on the device. Third parties may collect personally identifiable information about an individual user's online activities over time and across different sites when a user uses the Service.

6. HOW LONG WE KEEP YOUR INFORMATION AND YOUR CONTENT

We will retain your information and Your Content as long as necessary for the purposes outlined in this Privacy Policy, and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection, or audit purposes, or as otherwise required by law. We may use remote backup features that will send information from your device and/or browser to be stored on servers operated by or on behalf of BETUP and its affiliates. Except to the extent specifically prohibited by applicable law, BETUP has no responsibility for any data transmitted to and from your device and/or computer and BETUP recommends that you make regular back-ups of all information and data on your device and/or computer.
7. CHILDREN'S PRIVACY

We do not knowingly collect personal information from individuals under age 13. If you are under the age of 13, please do not submit any personal information through the Service. If you have reason to believe that we may have accidentally received personal information from an individual under age 13, please contact us immediately at privacy@betup.org.
8. LINKS TO OTHER SITES AND SERVICES

This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service. We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another site or service, our Privacy Policy does not apply to third party sites or services. Your browsing and interaction on any third party site or service are subject to that third party's rules and policies. If you choose to access or make use of a third party social networking service, we may receive information about you that you have made available to the third party social networking service. Also, the third party social networking service may receive information about you from the Service. While your decision to access or use a third party social networking service is voluntary, you should make sure you are comfortable with the privacy settings of the Service and the third party social networking service.
9. CHANGES TO OUR PRIVACY POLICY

We may update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before you provide any information. This Privacy Policy was made effective on the date indicated above. The most current version of this Privacy Policy will govern BETUP ’s processing of your information and data and will always be at http://www.betup.org/privacy/privacy.html.
10. CALIFORNIA PRIVACY RIGHTS

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties' direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one (1) request each year by emailing us at privacy@betup.org or writing us at:

UPAPP S.R.L.
stradela 3 Balcani, casa 12
Durlesti, Chisinau
Republic of Moldova

If you are a California resident under age 18 and a registered user of the Service, you may ask us to remove content or information that you have posted to the Service by emailing us at privacy@betup.org . Please note that such removal does not ensure complete or comprehensive removal of the content or information posted (for example, your content or information may remain visible because it was copied and posted or reposted by a third party).
11. EUROPEAN ECONOMIC AREA DATA SUBJECT RIGHTS

If you are a natural person residing within the European Economic Area ("Data Subject"), the following additional rights as expressed under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 known as the General Data Protection Regulations ("GDPR") are applicable to you:

    Personal Data: For the purposes of this section, "Personal Data" means collectively PII, Unique Identifiers, Advertising Identifiers, and Location Data which you have provided to, or otherwise collected by, BETUP when you use and otherwise access the Service.

    Basis for Processing Data: On certain occasions, BETUP relies on the consent of the Data Subject to process personal information. Data Subjects must be at least the age of 16 to consent to the processing of their Personal Data. Data Subjects under the age of 16 must obtain their parent’s or legal guardian’s permission to consent to the processing. In other occasions, we may process information when we need to do so to fulfill a contract, provide services or where we are required by law to do so. We may also process data when it is in our legitimate interests to do so and when these interests are not overridden by the Data Subject’s data protection rights (which may vary based on the Data Subject’s jurisdiction). Such legitimate interests include, but are not limited to, operation of our business and services, verifying user’s identity, serving advertisement, improving products and services, analyzing performance, debugging, troubleshooting, and providing customer support.

    Access: You may access, correct, or modify the Personal Data you provided to BETUP and associated with your account. You may do so by contacting our Data Protection Officer as described below.

    Forgotten: You may request to have your Personal Data erased, or otherwise request that your Personal Data not be processed. Please note that the Service, or parts of the Service, may become inaccessible or otherwise not function properly if you request to have your Personal Data erased or not be processed. You may do so by contacting our Data Protection Officer as described below.

    Object, Restrict, or Withdraw Consent: You may withdraw consent you previously provided to BETUP or otherwise object to or restrict the processing of your Personal Data. Please note that the Service, or parts of the Service, may become inaccessible or otherwise not function properly if you withdraw certain consents or otherwise object to ro restrict the processing of your Personal Data. You may do so by contacting our Data Protection Officer as described below.

    Portability: You may request to receive a copy of the Personal Data you have previously provided to us during your use of our Services. You may do so by contacting our Data Protection Officer as described below.

    International Transfers: Please be aware that the information we collect may be transferred to and maintained on servers or databases located outside your jurisdiction, where the privacy laws may not be as protective as those in your location. Please be advised that we may process and store information in Canada. The European Commission has recognized Canada as providing adequate protection under the Commission’s adequacy decisions. We may also transfer information to third parties as described herein. In such cases, those third parties will be subject to and bound by other privacy framework and regulations, including the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce.

    Supervisory Authority: If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

12. HOW TO CONTACT US

For user account related inquiries, please contact our customer support team by email at contact@betup.org.

For all other inquiries relating to this Privacy Policy, please contact the Privacy Compliance Officer by email at privacy@betup.org or postal mail at:

UPAPP S.R.L.
stradela 3 Balcani, casa 12
Durlesti, Chisinau
Republic of Moldova

If you live within the European Economic Area, please contact our Data Protection Officer in confidence at dpo@betup.org.