Introduction

OneUp Games Ltd. ("OneUp", "we", "our" or "us") develops and operates mobile-based games ("Apps") available at: [fill in link to website], its subdomains and its related features ("Website", collectively "Services"). OneUp is dedicated to protecting you privacy rights and making our practices regarding your personal data more transparent and fair. This Privacy Policy ("Policy") was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit our Website or otherwise access or use any of our Services. Specifically, it describes our policy regarding

1. 1- What types of data we collect?
2. 2- Tracking Technologies
3. 3- Why we process your Personal Data?
4. 4- With whom we share your data?
5. 5- Your rights
6. 6- Transfer of data
7. 7- How we protect your data
8. 8- Minors
9. 9- Retention
10. 10- Updates to this Policy
11. 11- Contact Us

You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience of using our Services. This Privacy Policy is integrated into and forms part of the OneUp Terms of Use, and is incorporated therewith by reference. By using the Services, including our Apps and Website, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our Services. Your continued use of the Services following the posting of changes to this Privacy Policy will mean that you accept those changes.

1. What types of data we collect

We collect two types of data from you: Personal Data ("Personal Data") and non- Personal Data. Personal Data means any information which may potentially allow your identification with reasonable means (for example, email address or name). Non-Personal Data, by contrast, can be defined as any information that does not relate to an identified or identifiable natural person. This may include, for example, your aggregated usage information and technical information transmitted by your device (e.g. the device you use, the type of browser and operating system your device uses, language preference, access time, etc.). This section sets out how and when we collect those types of data from you

1. 1.1. Account Information. If you choose to register an account with our Services, we collect your full name, email address, phone number, birthdate and username. If you choose to log in, access or otherwise connect to the Services through a social networking service or a single sign on service (such as Facebook, Twitter, Instagram, Google, Apple etc.), we may collect your user ID and/or username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access
2. 1.2. Information. When you decide to deposit money in our Services, you will be required to provide use with your billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your name and card information.
3. 1.3. Usage Information. When you use our Services, we collect certain usage and gameplay about your interaction with our Services. Such information may include geolocation data, clicks, pages viewed, information regarding your scoring, win/loss rates and other gameplay data, which relates to your activity in the Services.
4. 1.4. Technical Information. When you use our Services, we collect technical information about your device. Such information may include geolocation data, IP address, unique identifiers (e.g. MAC address and UUID), operating system, browsing history, language, mobile carrier, device information etc.
5. 1.5. Communication Information. When you send us an email or contact us via the support in our Services, we collect the Personal Data you provide us. This may include your name, email address and any other information you choose to provide.

2. Tracking Technologies

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services' performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests

OneUp may use non-Personal Data for commercial, marketing, and/or business purposes, such as reporting and conducting research and development in order to enhance our existing Services and/or develop new products and services. We may share this information internally and/or with third parties for our or their purposes in an anonymous or aggregated form that is designed to prevent anyone from identifying you.

2.1 What types of Tracking Technologies do we use?

When you use or access our Services, we use the following categories of Tracking Technologies:

1. (a) Strictly Necessary Tracking Technologies - these Tracking Technologies are automatically placed on your computer or device when you access our Services or take certain actions on our Websites. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services. We do not need to obtain your consent in order to use these Tracking Technologies;
2. (b) Tracking and Advertising Tracking Technologies - these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers, publishers and ad networks. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy /cookie policies and principles, which the Company does not control;
3. (c) Functionality Tracking Technologies - these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
4. (d) Performance Tracking Technologies - these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

2.2 How and by whom Tracking Technologies are stored on your device?

We store Tracking Technologies on your device when you visit or access our Services (for example, when you are visiting our Website) - these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners, and advertisers), who run content on our Services - these are called "Third Party Tracking Technologies". Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods for managing your Tracking Technologies preferences include: changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity; However, please note that certain features of the Website may not work properly or effectively if you delete or disable cookies. To learn more about how can manage your cookies, below is a list of useful links that can provide you with more information on how to manage your cookies:

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

• The Interactive Advertising Bureau (US)
• The Interactive Advertising Bureau (EU)
• European Interactive Digital Advertising Alliance (EU)

3. Why we process your Personal Data?

This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage.

4. With whom we share your data?

We may share your Personal Data as described below:

1. (e) - Affiliated companies: we may share Personal Data internally within our affiliated companies, for the purposes described in this Policy.
2. (f) - Payment processors: we share your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf.
3. (g) - Service providers: we work with service providers that work on our behalf that may need access to certain personal data in order to provide their services to us. These companies may include, but are not limited to, cloud storage providers, analytics services, fraud prevention, identity verification provider, etc.
4. (h) - Third party advertisers: we may partner with third parties to either display advertising on our Services or to manage our advertising on other websites or apps. Our third party advertisers may use Tracking Technologies to gather information about your activities on our Services and other websites and apps in order to provide you advertising based upon your browsing activities and interests.
5. (i) - Third Party Integrations: the Services allow you to integrate with certain third party services, such as in order to connect your Facebook or Apple account to our Services or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook). Please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.
6. (j) - Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party's property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual's Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
7. (k) - Auditors and advisers: we may share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards.
8. (l) - Mergers and acquisitions: we may transfer, sell or otherwise share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.

5. Your rights

This section addresses the specific rights you may have concerning your Personal Data.

You may request to:

1. 1 - Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.
2. 2 - Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
3. 3 - Request rectification of your Personal Data that is in our control.
4. 4 - Request erasure of your Personal Data.
5. 5 - Object to the processing of Personal Data by us.
6. 6 - Request to restrict processing of your Personal Data by us.

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions, requests or complaints through our contact details below.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the competent supervisory authority.

6. Transfer of data

We may transfer your Personal Data to third parties, as set out in this Policy. Such third parties may reside in various jurisdictions around the world. In such circumstances and where required by law, we have put in place contractual measures to ensure that the recipients of your Personal Data provide appropriate safeguards for your data (for example, by training its staff and implementing effective technological and organizational security measures) and are only using it for the purposes of performing their services, or otherwise for those purposes for which we have disclosed your information to them.

7. How we protect your data?

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. Such breaches can lead to things such as reputational harm, fraud or identity theft. Therefore, we encourage you to exercise discretion regarding the Personal Data you choose to disclose. If you feel that your privacy was treated not in accordance with our Policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our contact details available below.

8. Minors

We do not knowingly collect or solicit Personal Data from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected Personal Data from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

9. Retention

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

10. Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted on our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

11. Contact Us

If you have any further questions, please contact us by email at: legal@oneupgames.gg

OneUp Games LTD., Medinat Ha'yehudim 85, Herzliya.