GearUP Privacy Policy
Last Updated: July 11, 2024
Welcome!
This Privacy Policy provides you with information about how we collect, use, and share your personal information (sometimes called "personal data") when you use our Services that link to this Privacy Policy. It also explains your legal rights and choices associated with your personal information. Your access to and use of our Services is subject to the Terms of Use.
We have updated our Privacy Policy to provide clearer, more accessible information on how we handle your personal information. We streamlined and organized this version of the policy according to the sources of personal information we collect as well as your activities on our Services, so that our privacy information is easier to read and understand.
We may update this Privacy Policy again from time to time. By continuing to use the Services after this Privacy Policy has been updated, you acknowledge that personal information will be handled in accordance with the most recent version.
This Privacy Policy does not apply to any other third-party websites, applications, or services that you may be able to access through our Services or that link to the Services. We suggest contacting those services directly for information on their privacy practices.
YOUR PERSONAL INFORMATION
Personal Information We Collect
Personal information is any information or data that relates to you as an identified or identifiable individual. Below are the categories of personal information we collect about users of our Services.
- Information You Provide:
- Identity, contact & demographic details (including name, screen name, or other similar unique identifier; title; date of birth / age; country / region; government-issued identification; email / phone number / postal address; messaging / social account ID)
- Billing & transaction data (billing / delivery address, payment or financial account details, details about your purchases and transactions with us)
- Account & profile information (username and password, security questions and answers, avatar, third-party social media or gaming platform account ID, and other information you share through your account or profile)
- User-generated content (content, items, or assets you create, share, or upload within our Services; your feedback, reviews, or comments about our Services; your posts, comments, and engagement on our social media sites)
- Usage data & preferences (information about how you use and configure the Services, including your choices regarding cookies and similar technologies; your gameplay settings, languages, and interests; your other expressed preferences)
- Survey & research data (information you voluntarily provide in user surveys or research, including occupation, gender, or racial / ethnic information)
- Marketing preferences (your choices regarding marketing / advertising that is displayed or provided to you, including your preferences in receiving newsletters, surveys, and other promotional content)
- Communications with us (details of your email, chat, and other messages to us)
- Information We Collect Automatically:
- Location information (city / country / region based on IP address; cell-ID and Wi-Fi connection)
- Device, network & technical information (IP / MAC address and other similar device identifier; device model, operating system, regional / language settings, and internet service provider; screen resolution, frame rate, and ping value; stack information (e.g., crash reports and core dumps) and server health indicators (e.g., CPU and memory usage, I/O usage, and load average); date and time stamps of actions and events within the Services; other network and technical information)
- Gameplay information (data related to how you play and actions you take in our games, including character appearance and attributes, progression and results, virtual assets, currencies, and items, tasks and rewards, social connections, chat logs, gameplay screen capture)
- Information We Collect from Third Parties:
- Social media or game platform account information when you bind, connect, or log in with your third-party account on our Services (name / nickname / username as it appears on your platform profile, profile pictures, friend lists, platform account ID, email address, age, country / region, and other information shared by the third-party platform)
- Payment information when you use a third-party payment processing service (such as hashed identifier, country / region from which your payment originated, and transaction details)
- Advertising or marketing data (information about your engagement with our content on our Services, in communications we send you, or other sites or apps)
Sensitive Information. Except for demographic information in connection with user surveys and research (which you can choose not to provide), we do not ask for or collect "special category data" such as social security number, religion, political affiliation, sexual orientation, criminal history, or trade union / association memberships. Please do not send any other sensitive personal information to us or disclose it on or through the Services.
How We Use Personal Information
We use personal information only for the purposes for which the information was collected. Under applicable data protection laws, companies also must have a legal basis to process your personal information. Below, we describe our purposes and legal bases for processing personal information.
|
What you do |
What we collect |
Why we collect it |
Legal bases |
|
Use a GearUP Service (for example: play a game, visit a website, sign up for an account) |
Identity, contact & demographic details
Billing & transaction information
Account & profile information
User-generated content
Usage data & preferences
Survey & research data
Marketing preferences
Communications with us
Location information
Device, network & technical information
Gameplay information
Social media or game platform account information
Payment information
Advertising or marketing data |
To operate and provide the Services to you, such as: ● enabling you to download, install, and run our software on your device ● allowing you to customize your preferences and providing you with a tailored experience ● enabling you to connect and interact with other users ● communicating with you about the Services
To troubleshoot and improve the Services and our business, including: ● System debugging, troubleshooting, and diagnostic testing ● Conducting performance analyses of our systems and Services ● Testing new system and Service features ● System and log maintenance ● Providing you with technical support
To promote the safety, security, and integrity of the Services, including: ● Identifying, preventing, and enforcing against fraud, cheats / hacks, and other prohibited behavior ● Administering community standards ● Moderating inappropriate content ● Responding to user reports
To comply with legal obligations relating to our operation of the Services, such as: ● Implementing age assurance and verification measures ● Completing "know your customer" requirements ● Responding to a valid legal request ● Maintaining business books and records
To operate and administer our business, including: ● Conducting internal audits ● Facilitating mergers, acquisitions, and other reorganizations or restructurings (including prospective transactions) |
Performance of our contract with you (the Terms of Use)
Your consent, in connection with the specific purposes of processing disclosed to you at the time of collection
Our legitimate interests to: ● operate, troubleshoot, and improve the Services and our business ● Promote safety, security, and integrity outside of the performance of our contract with you ● Understand our users and how they interact with Services ● Perform internal analytics concerning the Services ● Comply with legal requirements or defend our legal rights
Fulfillment of our legal obligations related to providing the Services |
|
Sign up for a Services account or bind, connect, or log in with your third-party platform account |
Identity, contact & demographic details
Account & profile information
Usage data & preferences
Communications with us
Location information
Device, network & technical information
Gameplay information
Social media or game platform account information |
To enable you to set up an account / profile on the Services, allowing for a customizable and continuous experience, and to communicate with you about your account
To comply with legal obligations relating to account creation and maintenance, such as: ● implementing age assurance and verification measures ● authenticating your identity and securing your information |
Performance of our contract with you (the Terms of Use)
Your consent when setting up your account
Our legitimate interests to operate and improve the Services and to comply with legal requirements or defend our legal rights |
|
Purchase a product or service (including digital content such as Virtual Goods and Virtual Points) |
Identity, contact & demographic details
Billing & transaction information
Account & profile information
Usage data & preferences
Communications with us
Gameplay information
Payment information |
To fulfill the purchase agreement, including processing and shipping your order or providing you with access to digital content
To comply with legal obligations and defend our legal rights related to consumer purchases, such as administering complaints or refunds |
Performance of our contract with you (the purchase agreement)
Your consent to the purchase
Our legitimate interests to comply with legal requirements or defend our legal rights
Fulfillment of our legal obligations related to your purchase |
|
Use or enable location-based functions |
Location information |
To provide location-based Services and features you request, such as regional in-game events, tournaments, and matches |
Performance of our contract with you (the Terms of Use )
Your consent when you enable location-based functions |
|
Contact us for customer support |
Identity, contact & demographic details
Billing & transaction information
Account & profile information
User-generated content
Usage data & preferences
Communications with us
Device, network & technical information
Gameplay information
Social media or game platform account information
Payment information |
To provide customer support in connection with the Services, including: ● facilitating and addressing user inquiries, requests, comments, and complaints ● sending you information you request ● assisting you in using the Services
To comply with legal obligations and defend our legal rights in connection with providing the Services and customer support |
Performance of our contract with you (the Terms of Use)
Your consent, in connection with your specific inquiry or request
Our legitimate interests to understand our users and how they interact with the Services and to comply with legal requirements or defend our legal rights
Fulfillment of our legal obligations related to customer support |
|
Subscribe to one of our newsletters or participate in a survey, contest, or promotion |
Identity, contact & demographic details
Account & profile information
Usage data & preferences
Survey & research data
Marketing preferences
Communications with us
Device, network & technical information
Gameplay information
Social media or game platform account information
Advertising or marketing data |
To promote our Services and inform you about new releases, updates, offers, surveys, and other news about us
To inform you about and administer rewards, contests, and other promotional offers
To conduct analysis and studies about our user base and user experience in order to improve our Services |
Your consent when you sign up for related communications
Our legitimate interests to improve and promote our Services and manage our relationships with our players |
|
Engage with us or our content on third-party platforms (for example: Facebook fan pages) |
Identity, contact & demographic details
Account & profile information
Usage data & preferences
Marketing preferences
Communications with us
Social media or game platform account information |
To facilitate and respond to comments, posts, feedback, reviews, and other messages about our Services |
Our legitimate interests to operate, promote, and engage with interested individuals about our Services |
Data Retention: We retain personal information only for as long as reasonably necessary to fulfill the purposes we collected it for, including to satisfy any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or the reasonable prospect of a legal claim.
Data Security: We implement appropriate administrative, technical, and physical safeguards to protect your information from accidental or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If we become aware of unauthorized disclosure of your information, we will notify you as required by law and take steps to secure your information. However, no internet transmission is ever fully secure or error free; please keep this in mind when disclosing any information online.
How We Share Personal Information
We do not share your contact details (such as your name, phone number, email, or postal address) with independent third parties without your knowledge, except for limited purposes as described in this Privacy Policy (such as enforcing the Terms of Use, securing the Services, or if we are required to do so by law or legal process). We do not sell your information.
We share personal information with third parties as described below:
- Social media and gaming platforms. When you choose to bind, connect, or log in with your third-party social media or gaming platform account, the third-party service receives information about how you interact with our Services in accordance with their own privacy policies. We do not control the privacy practices of these third parties, so please be sure to review the policies of any third-party services you use.
- Service providers. We share your information with service providers who operate on our behalf for the purposes discussed above (see“How We Use Personal Information”above).
- Related companies. We share your information with GearUP-controlled affiliates and corporate subsidiaries for purposes consistent with this Privacy Policy.
- Business transfers. In the event we are involved in a corporate sale, merger, reorganization, dissolution, or similar event, or due diligence related to such event, your information may be part of the transferred assets.
- Legal requirements and harm prevention. We may disclose your information where we reasonably believe it to be necessary to comply with law, regulation, or other legal process or obligation. We may disclose your information to prevent harm to us or our users or to defend our rights and our users' rights.
Data Transfers: Our service providers, affiliates and subsidiaries, and partners are located in various countries around the world. Your personal information may be transferred to, and processed in, these countries, which may be different from the territory in which you reside. These countries may have data protection laws that are different from those of your jurisdiction (and, in some cases, may not be as protective). These entities commit to processing information in compliance with applicable data protection laws and to implementing appropriate security measures to protect your information.
EEA / UK / Switzerland: When transferring personal information from these countries, we implement the following safeguards:
- Adequacy Decisions: We rely on the adequacy decisions to transfer data to Canada, Japan, and the UK (the full list of adequate countries is available here for the EEA, here for the UK, and here for Switzerland).
- Standard Contractual Clauses: We rely on the standard contractual clauses issued by the European Commission and the UK ICO for transfers to countries which are not considered adequate, such as Singapore and Hong Kong. You may obtain a copy of these measures by contacting us.
YOUR PRIVACY RIGHTS & CHOICES
Exercising Your Rights
Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, and may apply only in certain circumstances.
- Access & Portability: Request access to or a copy of your personal information.
- Deletion: Delete your personal information.
- Correction: Correct or update your personal information where it's inaccurate.
- Objection: Object to processing of your personal information or ask us to restrict processing of your personal information.
- Withdrawal of Consent: Where applicable, withdraw your consent without affecting the processing already undertaken before your withdrawal or the processing of your personal information on other lawful grounds.
- Complaints: Complain to a data protection authority about our processing of your personal information.
- You can file a claim with the Data Protection Authority in the EEA country in which you live or work or where you think we have infringed data protection laws, or with the UK Information Commissioner's Office, as applicable to you. Contact details for Data Protection Authorities in the EEA are available here and the UK ICO can be contacted here.
You may submit a request to exercise your privacy rights to us at legal@gearupbooster.com or at 1 Raffles Quay #49 Singapore (048583). Please include "Privacy Rights Request" in the subject of your message. We will not discriminate against you for exercising any of these rights.
To verify your identity and protect against fraudulent requests, we may request further information regarding your identity and your interactions with us before processing your request. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account.
If we deny your request, you may appeal our decision by contacting us.
Opt Out of Advertising & Marketing
We partner with advertising and marketing providers to serve ads about our Services and to measure our ad performance on third-party services. Where required by law, we seek your consent before sharing your information for advertising and marketing purposes. You can withdraw your consent or opt out at any time by going to "Account Center" → "Ad Settings" or by adjusting your cookie preferences.
We also use email and push notifications to send you marketing messages about the Services. To opt out of email messages, please follow the unsubscribe instructions included in the email or contact us at legal@gearupbooster.com. To disable push notifications, please select the relevant app in your device settings.
Cookies & Similar Technologies
We use cookies and similar technologies to collect information such as browser type, time spent on the Services, pages visited, language preferences and other traffic data. We do not currently respond to browser do-not-track signals. To learn more about how we use cookies, or to opt out of the collection and use of cookies, please see the Cookie Policy applicable to the specific Service(s) that you are using.
Your browser may allow you to delete all cookies, allow cookies only from specific sites, or indicate when a cookie is being sent. Instructions on how to manage cookies in popular browsers are available at: Internet Explorer, Firefox, Chrome, Safari (iOS), Safari (Mac), and Opera. You may not disable necessary cookies as the site will not be able to function properly otherwise.
INFORMATION FOR PARENTS & GUARDIANS
Our Services are intended for a general audience. For certain Services that may appeal to younger players, we take measures to verify player ages, require verifiable parental consent for processing of children's personal information, and implement high privacy-by-default settings to protect children's privacy. These measures also include:
- Providing Service-specific privacy notices to parents and guardians about what personal information we may collect, use, and disclose from their child.
- Seeking verifiable parental consent to process a child's personal information as required by law.
- Limiting the processing of a child's personal information to what is reasonably necessary to provide the Service(s).
- Providing parental controls to enable visibility and granular control over a child's privacy settings.
At any time, parents and guardians can withdraw permission for further processing of personal information from their child or ask us to delete the personal information we have collected in connection with their child's account by contacting us at legal@gearupbooster.com.
If you think that your child is using a Service that processes their personal information without your consent, please contact us at legal@gearupbooster.com.
For the purpose of this section, "child" or "children" means a minor who is under the age of digital consent required by local applicable law. (For example, the age of digital consent in the UK is 13.)
REGIONAL INFORMATION
Additional Information for U.S. Residents
This section supplements the information above and further describes how we collect, use, and disclose personal information we collect about U.S. consumers who use our Services.
Our Collection & Use of Personal Information. As detailed above, we collect personal information for a range of different purposes, but the main reason we collect information is to provide and operate the Services. We collect the following categories of personal information:
- Identifiers (contact information and unique personal identifiers, including username, email address, IP address, device identifiers, and other similar identifiers);
- Personal information as defined in California's customer records law (such as contact information and – if you choose to provide it – physical characteristics or description);
- Characteristics of protected classifications if you choose to provide them (demographic information: date of birth / age, gender, and racial / ethnic information);
- Commercial information (purchase or consuming histories, tendencies, or preferences);
- Internet or electronic network activity (information related to app, game, or website usage);
- Approximate geolocation data (country / region);
- Audio, electronic, visual, or similar information (such as profile photo, user-generated content, or voice chat);
- Other "personal information" as defined under applicable law (such as your credit or debit card information);
- Inferences drawn from any of these categories (for example, your city / country / region based on IP address); and
- Sensitive personal information relating to account log-in combined with access credentials.
The section "How We Use Personal Information" describes the business and commercial purposes for collecting your personal information. The section "How We Share Personal Information" describes the third parties with whom we share personal information and for what purposes.
Your Rights. In addition to the privacy rights described in "Exercising Your Rights" above, you may have the following rights:
- Right to Opt Out of Sale: You have the right to know whether we sell your data and to opt out of such sale if we do. We do not sell the personal information of our users.
- Right to Opt Out of Sharing for Behavioral Advertising: You have the right to opt out of the sharing of your personal information for purposes of behavioral advertising. You may opt out of this sharing by navigating to "Account Center" → "Ad Settings" or by adjusting your cookie preferences.
- Authorized Agents: Designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf.
Certain browser plug-ins provide options for communicating opt-out preference signals, such as the Global Privacy Control ("GPC"). We treat GPC signals as a request to opt-out of targeted advertising or the "sharing" of personal information in relation to your browser or device that sends the GPC signal. If you are not logged into your account, the request through the GPC signal will not extend to any account information, as the connection between your browser or device and account is not known to us.
We do not share personal information with third parties for their direct marketing purposes.
We do not knowingly "sell" or "share" personal information of minors under 16 years of age.
Removal of Publicly-Posted Content. If you are a resident of California and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services when you were under the age of 18 by emailing us at legal@gearupbooster.com or by contacting in-game customer service. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
Notice of Financial Incentive / Bona Fide Loyalty Program. We offer users the opportunity to obtain nominal in-game currency and other rewards ("Rewards"), which may provide benefits to those who choose to participate ("Members"). Rewards may be considered a "financial incentive" or a "Bona Fide Loyalty Program" under California and Colorado state law.
Our collection of Members' personal information (including name, email address, and phone number) allows us to provide the Rewards. We use Members' personal information both to award, and to enable Members to redeem, benefits. The amount of personal information that we collect from a Member or non-Member may vary and is dependent on the level of interactions and engagement that the Member or non-Member has with us, including the Rewards in which the Member chooses to participate.
We use personal information collected in connection with the Rewards program for marketing and other purposes described above. The types of personal information that we collect from Members who participate in Rewards are generally similar to the types of Personal Information that we collect from consumers who do not participate in Rewards. We do not collect sensitive personal information in connection with Rewards.
Solely for purposes of California privacy law, we estimate the value of a Member's personal information to be reasonably related to the value of the benefits that Members obtain through participating in Rewards. We have based this good faith estimate on the value that arises from increased customer interactions, the costs, and expenses we incur in offering Rewards, the types of Rewards provided, and the collection and retention of the personal information of consumers who have voluntarily chosen to participate in Rewards. The value of Rewards to Members varies significantly, as individual Members take advantage of Rewards to varying degrees.
Members who are California or Colorado consumers may exercise their privacy rights and may choose not to receive marketing communications or offers at any time without any effect on their eligibility to participate in Rewards. A Member may revoke their consent to participate in Rewards at any time by emailing us at legal@gearupbooster.com or by contacting in-game customer service.
ABOUT US
This Privacy Policy applies to Services offered by GearUP Portal Pte. Ltd. For purposes of applicable law, GearUP Portal Pte. Ltd. is the "Data Controller" of personal information collected through the Services. Our mailing address is 1 Raffles Quay #49 Singapore (048583). If you have any questions about this Privacy Policy, please contact us at our mailing address or email legal@gearupbooster.com.
We have appointed Prighter as our data protection representative in the EEA and the UK. If you live in the EEA or the UK, you can contact us through Prighter using the contact details set out below. Please include GearUP Portal Pte. Ltd.: ID-15721674950" in the subject line of all correspondence:
- For the EEA:
- PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG
- c/o GearUP Portal Pte. Ltd.
- Address: Schellinggasse 3/10, 1010 Vienna, Austria
- Website: https://prighter.com
- For the UK:
- PrighterUK-Rep by Prighter Ltd
- c/o GearUP Portal Pte. Ltd.
- Address: 20 Mortlake High Street, London, SW14 8JN, UNITED KINGDOM
- Website: https://prighter.com