Privacy Policy
Contents
- Who We Are (Data Controller)
- Information We Collect
- What We Do NOT Collect
- Legal Bases for Processing (EEA / UK Users)
- How We Use Information
- How We Share Information
- Third-Party Services We Use
- Your Choices and Controls
- Data Retention
- Security
- Children’s Privacy
- International Data Transfers
- Your Rights
- California Residents (CCPA / CPRA)
- Nevada, Virginia, Colorado, and Other U.S. State Privacy Laws
- Do Not Track
- Changes to This Privacy Policy
- Contact Us
This Privacy Policy describes how the developer of the mobile game “Upside” (the “Game,” together with all updates and related services, the “Service”), identified in the applicable app store listing (the “Company,” “we,” “us,” or “our”), collects, uses, discloses, and protects information in connection with your use of the Service.
We have designed Upside to minimize data collection. We do not require you to create an account, and the Game itself stores most gameplay data locally on your device. The main data flows described below arise from the third-party services we use to display ads and to process in-app purchases.
By downloading, installing, or using the Service, you acknowledge that you have read and understood this Privacy Policy.
1. Who We Are (Data Controller)
The Company, identified in the applicable app store listing, is the “data controller” responsible for the processing of personal data described in this Privacy Policy, except where it acts as a joint controller or processor with third-party advertising or payment providers as described below.
For any privacy questions or requests, please contact us through the support channel in the applicable app store listing or within the Service.
2. Information We Collect
The Service collects only the information necessary to operate the Game, deliver advertising, process in-app purchases, and improve the user experience. We divide this information into three categories: (a) information stored locally on your device, (b) information collected automatically, and (c) information collected by third parties.
2.1 Information Stored Locally on Your Device
The following data is stored locally on your device and is not transmitted to us:
- Your gameplay progress, high scores, and local leaderboard entries (stored in a file named “upside_leaderboard.cfg” on your device).
- Your accumulated in-game Points balance (stored in a file named “upside_points.cfg” on your device).
- Your game settings and preferences.
You can delete this information at any time by uninstalling the Game or by clearing the app’s data through your device’s settings.
2.2 Information Collected Automatically
When you use the Service, certain information may be collected automatically, primarily by third-party SDKs integrated into the Game. This may include:
- Device Information — device model, operating system version, unique device identifiers (such as the Apple IDFV “Identifier for Vendor” on iOS and the Android Advertising ID “AAID” on Android), system language, and region.
- Advertising Identifiers — Apple’s IDFA (“Identifier for Advertisers”) if you consent on iOS, or the Android Advertising ID on Android.
- Network Information — IP address, general location derived from IP address (country / region level), connection type, and carrier.
- Usage Information — the number of ads requested and shown, ad engagement events, crash logs, and diagnostic information provided by the game engine or advertising SDK.
- Purchase Information — the product ID of any in-app purchase you make and the time of purchase, as reported to us by the applicable app store. We do not receive or store your payment card details.
2.3 Information Collected by Third Parties
Third-party services integrated into the Game may collect information directly from your device under their own privacy policies. These third parties include:
- Google AdMob (advertising network operated by Google LLC / Google Ireland Limited)
- Apple Inc. (App Store distribution, StoreKit payment processing, device-level privacy controls such as App Tracking Transparency)
- Google LLC (Google Play Store distribution, Google Play Billing payment processing)
We encourage you to review the privacy policies of these third parties. Links are provided in Section 7 below.
3. What We Do NOT Collect
To be clear, the Service does not collect or ask for:
- Your name, address, email, phone number, or other contact details.
- Your government-issued identifiers (passport, national ID, social security number, etc.).
- Your payment card numbers, bank account details, or financial credentials.
- Your precise GPS or geolocation.
- Photos, videos, contacts, microphone recordings, or other personal media from your device.
- Biometric data (fingerprints, face scans, voiceprints).
- Your social media accounts or content from them.
4. Legal Bases for Processing (EEA / UK Users)
If you are located in the European Economic Area, the United Kingdom, Switzerland, or another jurisdiction with similar laws, we process your personal data on the following legal bases under the GDPR and UK GDPR:
- Performance of a contract — to provide the Service and process in-app purchases.
- Legitimate interests — to operate, improve, and secure the Service; to display non-personalized advertising; to detect fraud and abuse.
- Consent — where you affirmatively consent (for example, to tracking for personalized advertising on iOS via the App Tracking Transparency prompt, or to cookies/identifiers where required by applicable law).
- Legal obligation — where we are required by law to process data (for example, to respond to lawful governmental requests).
You have the right to withdraw consent at any time where consent is the basis for processing. Withdrawal does not affect the lawfulness of processing before withdrawal.
5. How We Use Information
We and our third-party service providers use information for the following purposes:
- To operate the Service — to run the Game, save progress locally, and deliver gameplay features.
- To process in-app purchases — to fulfill purchases of Points or other virtual items through Apple’s or Google’s payment systems and credit your Points balance.
- To display advertising — to request, deliver, and measure banner, interstitial, and rewarded video ads through Google AdMob and its mediation partners.
- To personalize advertising (with consent where required) — to deliver ads we believe may be more relevant to you based on device and usage signals.
- To detect and prevent fraud, cheating, and abuse — including invalid ad traffic, fraudulent purchases, and misuse of the Service.
- To improve the Service — through aggregate analytics, crash logs, and diagnostic information.
- To comply with legal obligations — including responding to lawful requests from authorities.
6. How We Share Information
We do not sell your personal information for money. We share information with third parties only as described below:
6.1 Service Providers
We share limited information with third-party service providers who help us operate the Service, including Google AdMob (advertising), Apple (app distribution and payments), and Google (app distribution and payments). These providers are described in Section 7.
6.2 Legal Requirements
We may disclose information where required by law, court order, or government request, or where we believe in good faith that disclosure is necessary to protect the rights, property, or safety of the Company, our users, or others.
6.3 Business Transfers
In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our business or assets, information may be transferred to the relevant third party as part of the transaction. You will be notified of any such change of ownership or control of personal information.
6.4 With Your Consent
We may share information with other parties where you have given us explicit consent to do so.
7. Third-Party Services We Use
The following third-party services may collect information from you when you use the Service. Each operates under its own privacy policy, which we encourage you to review:
7.1 Google AdMob
We use Google AdMob to display banner, interstitial, and rewarded ads in the Game. AdMob may collect device identifiers (including the Android Advertising ID or Apple IDFA where permitted), IP address, and interaction data to serve ads and measure their effectiveness. AdMob may work with mediation partners, which may also collect similar information.
- Google AdMob Privacy Policy: https://policies.google.com/privacy
- How Google uses data: https://policies.google.com/technologies/partner-sites
- Opt out of personalized Google ads: https://adssettings.google.com
7.2 Apple Inc.
If you installed the Service through the Apple App Store, Apple processes your purchase transactions and may collect diagnostic and usage data as described in Apple’s privacy policy. On iOS 14.5 and later, Apple’s App Tracking Transparency (ATT) framework controls whether apps may track you across other apps and websites; the Service will request your permission through the ATT prompt where required.
- Apple Privacy Policy: https://www.apple.com/legal/privacy/
7.3 Google LLC (Google Play)
If you installed the Service through the Google Play Store, Google processes your purchase transactions and may collect diagnostic information. Google also provides the Android Advertising ID, which you can reset or opt out of personalized advertising in your device settings.
- Google Privacy Policy: https://policies.google.com/privacy
7.4 Godot Engine
The Game is built on the Godot Engine, an open-source engine licensed under the MIT License. The engine itself does not transmit data about you to the Godot Engine project.
8. Your Choices and Controls
8.1 iOS App Tracking Transparency
On iOS 14.5 and later, you will see an App Tracking Transparency prompt asking whether you allow the app to track your activity across other companies’ apps and websites. If you select “Ask App Not to Track,” advertising SDKs will not access your IDFA. You can change this choice at any time in Settings → Privacy & Security → Tracking.
8.2 Android Advertising ID Controls
On Android, you can reset your Advertising ID or opt out of personalized advertising in Settings → Google → Ads (exact path varies by device).
8.3 Do Not Personalize Ads
You can opt out of personalized ads served by Google AdMob through https://adssettings.google.com. Even if you opt out, you will still see ads, but they will not be personalized based on your interests.
8.4 Deleting Local Data
You can delete all locally stored game data (including Points balance and leaderboard scores) by uninstalling the Game or clearing the app’s data through your device’s settings.
8.5 Managing In-App Purchases
You can manage or disable in-app purchases through your device’s settings or app store account.
9. Data Retention
Locally stored data (your Points, leaderboard, and progress) remains on your device until you delete it. Information collected by third-party advertising and payment providers is retained in accordance with their own privacy policies and retention schedules.
Where we receive diagnostic, crash, or purchase receipt data, we retain it only as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, to resolve disputes, and to enforce our agreements — typically no longer than 24 months.
10. Security
We take reasonable technical and organizational measures to protect information collected in connection with the Service. However, no method of transmission over the Internet or method of electronic storage is 100% secure. You acknowledge that you provide your information at your own risk, and we cannot guarantee absolute security.
11. Children’s Privacy
The Service is not directed to children under the age of 13 (or the equivalent minimum age in your jurisdiction). We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child has provided personal information to us, please contact us, and we will promptly delete such information.
The Service is designed to operate without requiring personal information. Advertising in the Game is configured to comply, to the extent feasible, with applicable children’s advertising restrictions, including through the use of non-personalized ad configurations where appropriate. Parents should use device-level parental controls to manage children’s access to in-app purchases and advertising.
For U.S. users: The Service is intended to comply with the Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect, use, or disclose personal information from children under 13 without verifiable parental consent.
12. International Data Transfers
The Company is based in the Sultanate of Oman. Our third-party service providers (including Google and Apple) operate globally, and information collected through the Service may be processed in countries other than your country of residence, including the United States, the European Union, and other jurisdictions. These countries may have data protection laws that differ from those of your country.
Where required by law, we rely on appropriate safeguards for international data transfers, such as Standard Contractual Clauses approved by the European Commission or equivalent mechanisms.
13. Your Rights
Depending on your location, you may have the following rights regarding your personal data, subject to applicable law and exceptions:
- Access — the right to request a copy of the personal data we hold about you.
- Rectification — the right to request correction of inaccurate or incomplete data.
- Deletion — the right to request deletion of your personal data.
- Restriction — the right to request that we limit how we process your data.
- Objection — the right to object to our processing based on legitimate interests or for direct marketing.
- Portability — the right to receive your personal data in a structured, machine-readable format.
- Withdrawal of consent — the right to withdraw consent where we process data based on consent.
- Complaint — the right to lodge a complaint with your local data protection authority.
To exercise these rights, please contact us through the support channel listed in the applicable app store. We will respond within the timeframe required by applicable law (typically 30 days).
Because we do not typically hold identifiable information about individual users on our own servers, we may require additional information to verify your identity or may direct your request to the relevant third party (for example, Apple or Google) that controls the data.
14. California Residents (CCPA / CPRA)
If you are a California resident, you may have additional rights under the California Consumer Privacy Act and California Privacy Rights Act, including the rights to: (a) know the categories and specific pieces of personal information we collect, use, and disclose; (b) delete personal information; (c) correct inaccurate personal information; (d) opt out of the “sale” or “sharing” of personal information for targeted advertising; and (e) limit the use of sensitive personal information.
We do not “sell” personal information for money. However, certain uses of device identifiers and advertising data for personalized advertising may be considered “sharing” or a “sale” under California law. You may opt out of personalized advertising through the controls described in Section 8.
We do not knowingly sell or share personal information of California residents under the age of 16 without their affirmative consent (or, for children under 13, the consent of a parent or guardian).
15. Nevada, Virginia, Colorado, and Other U.S. State Privacy Laws
If you are a resident of Nevada, Virginia, Colorado, Connecticut, Utah, or another U.S. state with similar privacy laws, you may have rights to access, correct, delete, and opt out of certain processing of personal information, similar to those described above. To exercise such rights, contact us through the support channel listed in the applicable app store.
16. Do Not Track
Some browsers transmit “Do Not Track” signals. Because there is no industry-standard interpretation of such signals, the Service does not currently respond to Do Not Track signals. You can exercise your advertising choices through the device-level controls described in Section 8.
17. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will update the “Last Updated” date above and, where appropriate, notify you through the Service or the applicable app store. If we make material changes that affect how we process your personal data, we will give you reasonable advance notice and, where required by law, obtain your consent.
Your continued use of the Service after an update to this Privacy Policy constitutes your acceptance of the updated Privacy Policy. If you do not agree, you must stop using the Service.
18. Contact Us
If you have questions, comments, or concerns about this Privacy Policy or our privacy practices, or if you wish to exercise any of your rights, please contact us through the support channel listed in the applicable app store listing for Upside, or through the in-game support option within the Service.
Your privacy matters to us. Thank you for playing Upside.
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