Upopa Games Privacy Policy
Last updated: March10, 2024
Table of Contents:
1.
About Us
2.
Scope
3.
Information We Collect
4.
How We Use the Information
We Collect
5.
Maximum Information
Retention Period
6.
How We Share Information
7.
How to Control Information
8.
Children
9.
Third-Party Services
10. International Transfers
11. Changes to This Privacy Policy
12. Contact Us
13. Representation for data subjects in the EU
1.
About Us
Upopa Games is a subsidiary of and is operated by ironSource
Mobile Ltd. (“ironSource”) which, among other things,
develops and publishes game titles for mobile devices (each game title,
“Title”).
We collect information in either of 2 ways:
A.
Directly – through
the Titles. For this purpose, we also engage with analytics partners that
collect the information on our behalf.
B.
Indirectly – through
our advertising and analytics partners.
We collect information as described in this privacy policy for Upopa Games’ own purposes, as a data controller under data
protection law where relevant.
2.
Scope
This privacy policy describes Upopa
Games’ privacy practices with respect to information it processes in relation
to its Titles. This privacy policy does not govern the use of any website, and
any additional services.
The titles are available to users all around the world.
Accordingly, throughout the document, we try to harmonize our approach and the
language of the privacy policy as much as possible. However, sometimes we refer
to specific laws that require further disclosures. For example, whenever
you see throughout the policy the annotation “The GDPR angle”, it means that
the purpose of such section is to satisfy the transparency requirements of the
General Data Protection Regulation (the “GDPR”), and therefore it applies only
to personal data (as defined by the GDPR) associated with devices who we deem
to be located in the European Economic Area, United Kingdom, or Switzerland. If
you are a resident of California, please see “The CCPA Angle” for information
related to the California Consumer Privacy Act (the “CCPA”). “The CCPA
Angle” sections apply only to “personal information” that is subject to the
CCPA. For purposes of the CCPA, this Privacy Policy serves as both the Privacy
Policy and Notice at Collection of Personal Information.
3.
Information We Collect
A.
Information collected
through our Titles, and information provided to us by advertising and analytics
partners:
1)
Identifiers:
a.
Advertising ID – Advertising
ID refers to the Google Advertising ID ("GAID") on Android
devices, or ID For Advertising ("IDFA") on iOS devices. The
Advertising ID is a resettable persistent identifier generated by Android or
iOS that allows online advertising companies to recognize a device across apps,
for advertising purposes.
Additional
information about how to limit our use of the Advertising ID can be found under
“How to Control Information”.
b.
IP address.
c.
A unique ID generated by
our advertising partners to recognize a device in a specific Title.
d.
ID of a device which is
unique only to our Titles.
2)
General technical
information about a device – Technical information such as:
a.
The device type and
language, operating system name and version.
b.
The device's time zone.
c.
The amount of free memory
on the device.
d.
The name and version of
the Title.
e.
Battery status.
f.
The name of the mobile
carrier.
g.
The device's internet
connection type (e.g., Wi-Fi).
3)
Activity in connection
with the Title: Transactions and in-app purchases made in the Title, progress
or movement in the Title, and in-game events.
B.
Information received from
advertising and analytics partners:
a.
Campaign information
- An indication if an ad of a Title was
viewed or clicked.
b.
The total amount of
revenues received as a result of advertising served to
a specific device.
4.
How We Use the Information
We Collect:
We use the information we collect mainly to provide services to players
of our Titles. In addition, we use the information for the following purposes:
o to improve and optimize the Titles and our players’ experiences.
o to provide players with information about our Titles, including
in-game updates, new Titles, and promotional offers.
o to provide technical support.
o to protect the safety and well-being of our players.
o to protect our rights and property in connection with the Titles.
o to prevent fraud or potentially illegal activities.
o to manage and deliver advertising, including for the purpose of
analytics, measuring the effectiveness of ads, limiting the number of ads
served, generating aggregated reports, and attribution.
o to administer rewards, or other promotional activities or events
sponsored or managed by us or our business partners.
o To conduct marketing campaigns across our advertising and
marketing partners, including campaigns that use audience lists created based
on player interactions with the Titles.
o to comply with our legal obligations, resolve any disputes we
may have with players, and to enforce our agreements with third parties.
o to conduct research.
The GDPR Angle:
Under the GDPR, we rely on the following legal basis for the
processing of personal data:
o We process personal data for providing services to players of
our Titles for the performance of our contract with them.
o We process personal data for the purposes of preventing fraud or
potentially illegal activities, protecting our rights and property, serving
advertising (except for personalized advertising), conducting marketing
campaigns (except for audience lists based campaigns), improving and optimizing
the Titles, providing information and promotional offers to players of our titles,
administering rewards and conducting research, based on our legitimate
interests.
o We, or our advertising partners, may process personal data for
the purpose of serving personalized advertising, game usage analytics, or
conducting marketing campaigns based on audience lists and creating such
audience lists, if we, or our advertising partners, obtained that player's consent.
o We may also process your personal data for compliance with
applicable legal obligations.
The CCPA Angle:
A.
Personal Information We
Collect, Disclose for a Business Purpose, and Sell – We collect
the categories of personal information about California users identified in the
chart below. As further set forth
in the chart below, in the past 12 months, we have disclosed and sold personal
information about California users to third parties for business or commercial
purposes.
|
Categories of Personal Information |
Categories of sources from which information is collected: |
Business or commercial purposes for collection, use, and
sharing: |
Disclosed for business purposes to the following categories of
third parties: |
Sold to the following categories of third parties: |
|
Personal and online identifiers (such as first and last name,
email address, or unique online identifiers) |
See the
“About Us” Section |
See the
“How We Use the Information We Collect” Section |
See the
“How We Share Information” Section |
All
categories listed below. |
|
Internet or other electronic network activity information
(such as browsing history, search history, interactions with a website,
email, application, or advertisement) |
See the “About Us” Section |
See the “How We Use the Information We Collect” Section |
See the “How We Share Information” Section |
All categories listed below. |
|
Geolocation information |
See the “About Us” Section |
See the “How We Use the Information We Collect” Section |
See the “How We Share Information” Section |
All categories listed below. |
|
Other information about you that is linked to the personal
information above |
See the “About Us” Section |
See the “How We Use the Information We Collect” Section |
See the “How We Share Information” Section |
All categories listed below. |
B.
Recipients of California
Personal Information – Although we do not sell personal information for monetary
consideration, we do sell personal information under the definition of
"sale" in the CCPA, subject to our players' choices with respect to
“sale” of personal information, to the categories of third parties listed
below:
1)
Advertising partners.
2)
Analytics partners.
5.
Maximum Information
Retention Period:
We store information for as long as is reasonably necessary for
the purposes for which it was collected, as explained in this privacy policy,
for a maximum period of one year from its collection. In some circumstances we
may store information for longer periods of time, for instance when the
information is required for us to establish or exercise our rights or to defend
against legal claims.
6.
How We Share Information:
We share information with:
A.
Other advertising partners – for the
purpose of receiving, or delivering, advertising campaigns from such advertising
partners.
B.
Our corporate affiliates – from
which we receive services, such as IT, security, storage, and other internal
operations.
C.
Advertisers – for the
purpose of attribution.
D.
Analytics partners – for the
purpose of receiving analytics services.
E.
Service providers – we
share your information with our service providers for the purpose of receiving
services such as fraud detection and prevention, analytics, reporting, and
storage.
We may also disclose information if we have a good faith belief
that disclosure of such information is reasonably necessary to:
A.
Comply with any applicable
law, regulation, legal process or governmental request.
B.
Enforce our agreements and
policies, including investigations of potential violations thereof.
C.
Investigate, detect,
prevent, or take action regarding illegal activities
or other wrongdoing, suspected fraud or security issues.
D.
Establish or exercise our
rights to defend against legal claims.
E.
Prevent harm to the
rights, property or safety of us, our users, yourself or any third party.
F.
Collaborate with law
enforcement agencies or in case we find it necessary to enforce intellectual
property or other legal rights.
G.
When we are undergoing any
change in control, including by means of merger, acquisition, or purchase of
all or substantially all of our assets.
7.
How to Control
Information:
Collection of device data – Updated versions of iOS, and Android, enable you to
control how apps can collect the Advertising ID. please follow the below instructions:
1) iOS devices (iOS 14+):
go to Settings > Privacy > Tracking > Allow Apps to Request to Track.
Please note that if you use more than one device, you need to opt-out
separately in each device.
2)
Android devices: Please follow the instructions set
forth at: https://support.google.com/ads/answer/1660762 (under Mobile Controls). Please note that if you
use more than one device, you need to opt-out separately in each device.
The GDPR Angle:
A.
Withdraw consent – You have the
right to withdraw the consent you provided to us from within each of our Titles
(this will affect only our processing within the specific Title), or by
following the instructions above on how to control collection of device data
(this will affect our processing of data in all our Titles on your device).
B.
Data subject rights – Please
note that you have the right to request from us access to and rectification or
erasure of your personal data we process as controllers, or to restrict or to
object to processing of your personal data in accordance with the provisions of
the GDPR.
For access and erasure
requests, submit your request through our online form, which can be accessed at
https://ironsrc.formtitan.com/Data_Subject_Request.
For other data subject
requests, please send an email with your request to the following address: grow_dpo@unity3d.com.
C.
Complaint to a supervisory
authority – You also have the right to file a complaint with the
relevant supervisory authority (e.g., of your country or domicile) where we
have not addressed your concerns.
The CCPA Angle:
A.
Your Rights Regarding
Personal Information – California residents have certain rights with respect to the
personal information collected by businesses.
If you are a California resident, you may exercise the following rights
regarding your personal information, subject to certain exceptions and
limitations:
1)
The
right to know the categories and specific pieces of personal information we
collect, use, disclose, and sell about you, the categories of sources from
which we collected personal information, our purposes for collecting or selling
personal information, the categories of personal information that we have
either sold or disclosed for a business purpose, and the categories of third
parties with which we have shared personal information.
2)
The right to request that
we delete the personal information we maintain about you.
3)
The right to opt out of
our sale of your personal information. Please note that if you opt out of
certain types of sales, we will be unable to provide you with the services that
rely on such sales.
4)
The right not to
receive discriminatory treatment for the exercise of the privacy rights
conferred by the CCPA.
B. Exercise your rights – To exercise your rights to know and to delete personal information, please contact us by sending an email to grow_dpo@unity3d.com. To exercise your right to opt out of sale of your personal information, please open the privacy settings in the Titles in which you would like to opt out, and toggle on the Do Not Sell My Personal Information button. For more information on how you can exercise your rights you may also call our toll-free phone number: +1(888)835-5392.
C.
Verification Process and
Required Information – Note that we may need to request additional information from
you to verify your identity or process your request, although you will not be
required to create an account with us to submit a request or have it
fulfilled. We will require you to
provide, at a minimum, your email address. We will also collect information
that identifies your device when you submit a request in
order to help us verify your identity.
D.
Authorized Agent – You may
designate an authorized agent to make a CCPA request on your behalf by
verifying your identity and providing the agent with written permission to make
the request on your behalf.
8.
Third-Party Services
Our services may link to other websites or mobile apps. Please
be advised that we are not responsible for the privacy practices of such other
websites or mobile apps as those may have different privacy policies and terms
of use and are not associated with us. You agree that we cannot control these
websites and/or mobile apps and we shall not be responsible for any use of such
websites and/or mobile apps.
9.
International Transfers:
We store information that we collect from your device on our and
our service providers’ servers in the United States. Accordingly, please note
that if you do not live in the United States, we will transfer your information
to and store it in, the United States.
The GDPR Angle:
Upopa Game and ironSource Mobile Ltd. are
based in Israel, which is considered by the European Commission to be offering
an adequate level of protection for the Personal Information of EU Member State
Residents.
We will
transfer personal data to third parties located outside of the European
Economic Area, the United Kingdom, or Switzerland based on standard contractual
clauses. You can ask us for a copy of these clauses by contacting us through
the below contact details.
10.
Changes to This Privacy
Policy:
We may revise
this Privacy Policy from time to time. The most current version of the policy
will govern our processing of your information and is posted on the relevant
title’s store listing. If we make a change to this policy that, in our sole
discretion, is material, we will notify you via a banner on this website and by
posting the revised Privacy Policy. By continuing to access or use an app
containing our services after those changes become effective, you agree to be
bound by the revised Privacy Policy.
11.
Contact Us
Upopa Games
grow_dpo@unity3d.com
121 Menachem Begin Rd., Tel Aviv, Israel
12. Representation for data subjects in the EU
We value your
privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of
contact.
Prighter gives you an easy way to exercise your
privacy-related rights (e.g. requests to access or erase personal data). If you
want to contact us via our representative Prighter or
make use of your data subject rights, please visit the following website https://prighter.com/q/13822340265.