Privacy Policy

1. What Personal Data We Collect

We will collect the Personal Data such as the following in lawful and fair manner: (a) personal data you provide directly to us; (b) personal data collected automatically when you use our Services; and (c) personal data we receive from third parties. We will only collect personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

1.1 Personal Data You Provide to Us

• Account Profile: We collect the nickname and avatar you select from our pre-defined internal library. These profile elements are provided by the game and are not customizable or open-ended.
• Customer Service Data: We collect data that you provide directly to us when you contact customer support, give feedback, participate in surveys or activities, or subscribe to our communications. This information may include your nickname and any other details you provide. The specific data collected varies based on the service you are using.
• User Uploaded Images: To provide the requested feature and to fulfill our legal obligation to maintain a safe environment, we may process the images you uploaded. This includes using automated tools and human review to detect prohibited content. Any images you upload within the Service are strictly for your own use and system processing. These images are not shared with or visible to other users of the app. Please do NOT upload images containing personal data, such as real photos of people, identity documents, or private details (e.g., phone numbers, addresses).

1.2 Personal Data We Collect Automatically

When you use our Services, we automatically collect certain data, which includes:

• Identifiers Data: a unique, randomly generated user ID, device ID (e.g. IDFV, Android ID), advertising ID (e.g. IDFA, GAID), third-party unique ID (e.g. Pangle ID, AppsFlyer ID), IP-derived country and region information (raw IP addresses are not retained);
• Device & Technical Data: device model, device time zone, device country, system language, information of CPU, information of storage capacity, information of screen, information of network, information of operating system, and other technical data;
• Gameplay Data: data about your interaction with our Services, for example, game access time, usage logs, progress, achievements, play time and other gameplay information;
• Ad Interactive Data: data about your interaction with advertisements within our Services. For example, information that you have viewed or clicked an ad. We use this information for advertising measurement, optimization, and fraud prevention.

1.3 Personal Data We Received from Third Parties

We may receive information about you from authorized third parties, specifically in the following scenarios:

App Marketplaces

• Logins: If you choose to log in using your Google or Apple Account, we use their authentication services to verify your identity. We only collect the necessary login tokens to maintain your session. Once verification is completed, the login tokens are promptly deleted.
• In-App Purchases: If you make in-app purchases through Google Play or the App Store, we receive transaction details (e.g., Device ID, transaction time, encrypted order details, and status) to fulfill your order. We do not collect or store any payment card details. All financial transactions are processed securely and exclusively by Google Play or the App Store.

Please note that data handled by these platforms is governed by their own privacy policies. We recommend reviewing them: Google Privacy Policy | Apple Privacy Policy

Social Media Platforms

By using the in-game sharing feature, you will be redirected to an external social media platform. This is a one-way redirection; we do not access your social media profile or personal data. Please be mindful of your privacy and review your content before posting on external platforms.

1.4 About Sensitive Personal Data

Sensitive personal data refers to personal data that, once leaked or illegally used, will easily lead to infringement of human dignity or harm to the personal or property safety of a natural person. The scope of sensitive personal data may vary pursuant to different applicable data protection law. Our Services will not intentionally collect your sensitive personal data.

2. How We Use Your Personal Data

We use your personal data for the following purposes:

3. How We Share Your Personal Data

We do not sell your personal data to third parties. We may share your personal data with the following categories of third parties:

3.1 Service Providers

We work with third-party service providers who perform services on our behalf, such as analytics, advertising, cloud hosting, customer support, and payment processing. These providers are contractually bound to protect your data and use it only as instructed.

3.2 Advertising Partners

We work with advertising partners to deliver personalized ads within our games. These partners may collect identifiers and ad interaction data to serve relevant ads.

3.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of the transaction. We will notify you of any such change.

3.4 Legal Requirements

We may disclose your personal data if required by law, court order, or government authority, or to protect the rights, property, or safety of Level Up Media Ltd, our users, or others.

3.5 With Your Consent

We may share your personal data for any other purpose with your explicit consent.

4. International Transfer of Data

Your personal data may be transferred to and processed in countries other than your own. These countries may have different data protection laws. When we transfer data internationally, we take steps to ensure adequate protection in accordance with applicable law, including using standard contractual clauses approved by relevant authorities.

5. Data Security and Data Retention

5.1 Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.

5.2 Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. When your data is no longer needed, we will securely delete or anonymize it.

6. Your Legal Rights

Depending on your location, you may have the following rights regarding your personal data:

• The right to access your personal data
• The right to correct inaccurate personal data
• The right to request deletion of your personal data
• The right to restrict or object to processing
• The right to data portability
• The right to withdraw consent at any time
• The right to lodge a complaint with a supervisory authority

To exercise any of these rights, please contact us at Support@levelupmedia.online.

7. Children's Privacy

Our Services are not directed to children under the age of 13 (or a higher age threshold where required by applicable law). We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13 without parental consent, we will take steps to delete that information promptly.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us at Support@levelupmedia.online.

8. Changes to this Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last Updated" date at the top of the Policy. We encourage you to review this Policy periodically. Your continued use of our Services after the updated Policy becomes effective constitutes your acceptance of the changes.

9. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

10. Jurisdiction Specific

European Economic Area (GDPR)

If you are located in the EEA, you have rights under the General Data Protection Regulation (GDPR), including access, rectification, erasure, restriction, portability, and the right to object to processing. The legal bases for our processing are contractual necessity, legitimate interests, legal obligation, and consent. To exercise your GDPR rights, contact us at Support@levelupmedia.online.

California (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know, delete, correct, and opt-out of the sale or sharing of your personal information. We do not sell your personal data. To exercise your California rights, contact us at Support@levelupmedia.online.

Brazil (LGPD)

If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including access, correction, deletion, portability, and the right to revoke consent. To exercise your LGPD rights, contact us at Support@levelupmedia.online.

South Korea (PIPA)

If you are located in South Korea, you have rights under the Personal Information Protection Act (PIPA). The operator responsible for your personal data is Level Up Media Ltd. To exercise your PIPA rights, contact us at Support@levelupmedia.online.

Japan (APPI)

If you are located in Japan, you have rights under the Act on the Protection of Personal Information (APPI). To exercise your APPI rights or for inquiries, contact us at Support@levelupmedia.online.