FRVR Ltd ("FRVR", "we" or "us") is dedicated to protecting the privacy rights of our online users ("users" or "you"). This Privacy Policy ("Privacy Policy") serves to inform our users on how we collect, store, process, use, and manage the information you provide us when using Upit ("Service"). This applies whether you access the Service by downloading an authorized version of its mobile application or through our official channels.
The scope of this Privacy Policy is limited to the information collected by FRVR and does not apply to third-party websites.
By using the Service, you are agreeing to the collection and use of your personal information as outlined in this Privacy Policy. We may amend the Privacy Policy from time to time, and we encourage you to consult the Privacy Policy regularly for changes.
Your data will be processed according to the standard of the General Data Protection Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data ("GDPR").
As per our advertisement practices, we also inform you that FRVR Limited participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. FRVR Limited's identification number within the framework is 1107. IAB Europe is the European-level association for the digital marketing and advertising ecosystem.
FRVR Limited, a Maltese limited liability company with VAT no. MT24548624, with headquarters in 61 Saint Paul Street, Valletta VLT 1212, Malta, acts as the data controller in the terms set out in this Privacy Policy.
If you have any questions about this Privacy Policy, the exercise of your rights, or any other matter regarding personal data, FRVR has appointed a Data Protection Officer for these and other matters so please contact us through our dedicated contact form on our website here, by sending us an email to [email protected] or a letter to the address included in the previous paragraph.
For a better understanding of this Privacy Policy, we provide you with a list of definitions:
"Personal data": any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, electronic identifiers, or email of that natural person;
"Processing": the operation or set of operations carried out on personal data, whether by automated or non-automated procedures, such as the collection, registration, organization, structuring, conservation, adaptation or modification, recovery, consultation, use, dissemination by transmission, diffusion or any other form of availability, comparison or interconnection, limitation, erasure or destruction;
"User" or "Data subject": the natural person who uses our Services and who, for some reason, personal data is processed;
"Data controller": the natural or legal person, the public authority, the agency or other body that, individually or in conjunction with others, determines the purposes and means of processing personal data. For the purposes of this Policy, FRVR is the personal data controller;
"Data processor": natural or legal person, the public authority, agency, or other body that processes personal data on behalf and in accordance with the instructions of FRVR;
"Personal data recipient": natural or legal person, public authority, agency, or other body that receives personal data provided by FRVR; and
"Supervisory Authority": means an independent public authority that is established by an EU Member State.
Regarding general principles applicable to the processing of personal data, FRVR ensures that this data is:
FRVR's primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service.
We may collect, process, store, and transfer different types of data, which are grouped into the following categories:
To improve the gaming experience and foster user interaction, some of this data may be used to facilitate real-time engagement within the Service, such as connecting users with friends, enabling multiplayer features, or personalizing the game environment. For instance, data like usernames can be used to enhance social features within the game.
We note that most of this information is treated without certainty regarding the user identity This means that, in many cases, we cannot directly associate gameplay activity with a specific individual. Our systems do not consistently process information in a way that would identify users unless the data, such as an email address, enables such identification.
FRVR collects two types of data on our users: passive and active.
Passive collection is data collected when users play games, whether on their mobile device or the web. This data contains the following information:
This data does not contain any personally identifying information.
Our active data collection is currently limited to gameplay information such as User access token to identify a user from one play session to the next, but we do not gain access to any details about the User. Additionally, we request a username, password, and email address for the purpose of creating an Upit account.
We may also collect data based on direct interactions you have with us such as:
FRVR may also invite you to share other information about yourself that may include but is not limited to your:
Finally, any time you access the Service, we may collect aggregate information including but not limited to internet protocol addresses, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity. We use this information to better tailor the Service to your interests, to provide you with more efficient customer support, and to overall enhance the Service.
However, if non-personal information is collected, for an activity that also requires personal information, FRVR may combine your non-personal information with your personal information to provide you with a better user experience, to improve the quality and value of the Services, and analyze how our Services are used.
FRVR uses cookies or similar technologies on its websites and games. For more information, please read our Cookie Policy.
The Service may contain links to other websites not operated or controlled by FRVR, including social media services ("Third Party Sites"). The information that You share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links We do not imply that We endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
In addition to the information collected as described above, you may choose to share additional information (e.g. through communication channels) about yourself with other users across our Services.
Please be aware that any information you share with other players is considered public and is entirely at your discretion. FRVR is not liable for any consequences arising from your decision to share such information in communication channels or other public spaces.
When you use or connect to the Services by or through a third-party Platform, such as Google, you may consent that FRVR assesses and/or collects information from that platform, if applicable, as informed by such services. Those third parties may also collect information from your interaction with Our services. Such collection is managed by that third party, according to the terms of the agreement and your privacy settings with the third-party Platform.
Users will be asked to give consent to FRVR to access, collect, and process their personal data and share it with third parties, for instance, for advertisement purposes.
In all other cases, the information You provide will not be disclosed, rented, leased, loaned, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely to provide You with and improve the Service.
In case, for any lawful reason where consent is not needed, we communicate Your data with third parties, We will do it in an aggregated and anonymized form, which is not possible for these third parties to identify you as a person.
You understand and agree that we may be required to disclose any personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to avoid liability, to comply with legal process, including but not limited to a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of the public. Note that FRVR is not required to question or contest the validity of any search warrant, subpoena, or other similar governmental request that FRVR may receive.
Additionally, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, customer information may be transferred to FRVR's successor or assignee, if permitted by and done in accordance with applicable law.
FRVR does not transfer personal data to organisations outside the European Economic Area.
We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. In particular, emails sent to or from us may not be secure. Therefore, You should take special care in deciding what information You send to Us via the Service or email. In addition, We are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.
We'll retain Your Personal Information for only as long as we need in order to provide our Service to You, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with Our legal obligations. How long We retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, Our purpose for processing the information, and any legal requirements.
We have implemented technical and organizational measures designed to secure Your personal information from accidental loss and unauthorized access, use, alteration, or disclosure. However, We cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending Us personal information through these mediums.
Among others, We have implemented the following technical and organizational measures:
We will keep working on providing more protection for your data by improving or implementing additional technical and organizational measures thus do bear in mind these might alter.
Services may be used by minors, and submitted with permission given by parents or guardians. In case you are a minor and use the Services, you ensure and warrant to us that you have obtained the necessary permission from your parent or guardian.
Our Services are classified according to the sensitivity of the content shown to our users. This classification materializes by establishing a minimum recommended age for playing our games. The minimum age established in each game might possibly differ based on the games' content. This is not related to the processing of data.
As we mentioned previously, most of our user's game data is processed anonymously, thus we do not gear our Services towards children under the age of 13 and we do not knowingly collect personally identifiable information from children under the age of 13. If we know that a child under 13 has provided us with personal information we will delete such information from our files as quickly as possible.
If you are under 13 and do not understand the content presented in this Policy, please ask for support from your legal representatives - parents or legal guardians.
Regarding personal data processing, our users dispose of rights that may be exercised through our dedicated contact form on our website here, by sending us an email to [email protected] or a letter to the address included in Section II of this Policy. Note that if a third-party data controller, such as an advertising partner, is responsible for the information, we will take reasonable steps to inform them of your request, but we recommend you contact them directly in accordance with their own privacy policies to ensure your rights are executed lawfully. Our users have the following rights:
You may revoke your consent, in processing activities dependent on obtaining consent, without such revocation invalidating the processing of the data while the consent was in force. This shall be applied to all services (games and websites) provided by FRVR as long as the user provides the needed information.
You may also exercise your right of erasure or restriction of processing as regards advertisement by resetting your mobile advertising identifier (IDFA or GAID) or activating "Limit Ad Tracking" in your device's settings to make previously collected data non-linkable to you or your device anymore and limit further data collection.
Although our data processing relies on an anonymised and aggregated basis data breaches might occur. In these cases, and if FRVR is aware of any risks to the data subject's rights and freedoms we will report these breaches to the relevant Supervisory Authority within 72 hours from the moment we are aware of the occurrence. If the risk is considered high, we will also inform our users of the data breach and what FRVR has done to mitigate the risks and future similar breaches.
FRVR Limited has an escalated process to ensure the security of user data. Information about whether or not user data has been part of a breach is available upon request through our contracts made available in this Policy.
By using Our Service, You understand and acknowledge that Your Personal data will be processed and stored in Our facilities and servers in EU and may be disclosed to our service providers and affiliates in other jurisdictions.
Regardless of Your location, We are committed to respecting and upholding Your privacy rights. If You are a U.S. User, You may have specific rights under U.S. privacy laws, such as the right to access, correct, or delete your personal information.
For Users located in the United States, Our legal basis for collecting and processing personal data may differ from those in the European Union. Under U.S. privacy laws, We may rely on Your consent, the necessity of processing for the performance of a contract, and compliance with legal obligations, or Our legitimate interests as the legal basis for processing Your personal information.
If You have any questions or concerns about the processing of Your personal information as an international user, including a U.S. user, please contact our Data Protection Officer at [email protected]. We are dedicated to addressing Your inquiries and ensuring that Your privacy rights are protected in accordance with applicable laws.
By using Our Service, You consent to the terms outlined in this "International Users" section and the overall provisions of our Privacy Policy.
By using our Services, you are agreeing to the collection and use of your personal information as outlined in this Privacy Policy. We may amend the Privacy Policy from time to time, and we encourage you to consult the Privacy Policy regularly for changes. For convenience, we identify the last date of update on the top of this Policy.
This Cookies Policy ("Cookies Policy") will allow you to obtain more information about the use of Upit ("Service") when accessing our website and mobile application and can be supplemented by local provisions.
This does not apply to third-party websites that may be accessed through a link made available on our website and/or application, which are not managed nor controlled by FRVR.
FRVR's Service uses cookies and/or similar technologies that collect and store information as the user interacts with them.
A cookie is a small data file that we transfer to your computer's hard disk, generally to quickly identify a user's computer and to "remember" things about the user's visit, such as your preferences or a username and password. The Service sends cookies to your computer when you access or view content of the Service. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our service, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, although you may not be able to access or use features of our Service.
As for its origin, we can classify Cookies as:
Before accessing our website or application, you will be provided a complete list of the cookies we use as well as the list of entities who manage and store them. You can then choose whether or not you consent on the use of each type of cookie.
As for their purpose, we can classify cookies as:
As for the duration, we can classify cookies as:
Before accessing our Service website or mobile application, you will be provided a complete list of the cookies we use as well as their respective storage periods.
FRVR collects consent of the users at the time of visiting the Service website, downloading the mobile application, or playing the games embedded therein.
You can configure the cookies through your browser to allow, block, or delete installed Cookies. In this case, you should take into account that, although you have only the necessary Cookies to use or navigate the Service website or mobile application, if you disable the remaining cookies you will not be able to access all the features we provide to you. Your browser's "Help" button may provide you additional information on how to configure your browser.
We then explain to you how to do it but keep in account that the procedure may vary depending on the browser you are using:
If you wish to return your browser to a cookie-free state for this domain, find your browser in the list below and follow the instructions:
If you reject the installation of Cookies, you can continue to use the website, mobile application, and games embedded therein but the use of some of its services may be limited and the usability of navigation may be limited.
All your preferences will be stored until you decide to make further changes.
FRVR may modify this Cookies Policy based on new legal requirements, to implement improvements on it by notifying, in the event of significant changes, through an informative notice on our web pages. If you have any questions regarding our Cookies Policy contact us through the communication channels made available through our Privacy Policy.