Smart Up Terms of Service (“Agreement”)
These terms of service (“Terms”, “Agreement”) apply to your access and use of Smart Up Inc (“Smart Up”)’s games, websites and other services (the “Service”). Please read them carefully.

Accepting these Terms
If you access or use the Service, it means you agree to be bound by all of the terms below. So, before you use the Service, please read all of the terms. If you don’t agree to all of the terms below, please do not use the Service.
You agree you are over 13 years old. If you are between 13 and 18 years old, you need to review and agree by your legal guardian (like parents).
This Agreement sets forth the legal terms for your use of the Service that are made available via the Apple App Store, Google Play, Amazon Appstore, Facebook and/or any related services related to our games.
Also, if a term does not make sense to you, please let us know via our customer service email at support@smartupsupport.com.

Changes to these Terms
We reserve the right, at our sole discretion, to modify or replace these Terms of Service by posting the updated terms on the Service at any time. Your continued use of the Service after any such changes constitutes your acceptance of the new Terms of Service.
Please review this Agreement periodically for changes. If you do not agree to any of this Agreement or any changes to this Agreement, do not use, access or continue to access the Service or discontinue any use of the Service immediately.

Privacy Policy
For information about how we collect and use information about users of the Service, please check out our privacy policy available at http://www.smartupinc.com/privacy/

Third-Party Services
From time to time, we may provide you with links to third party websites or services that we do not own or control. Your use of the Service may also include the use of applications that are developed or owned by a third party. Your use of such third-party applications, websites, and services is governed by that party’s own terms of service or privacy policies. We encourage you to read the terms and conditions and privacy policy of any third-party application, website or service that you visit or use.

Accounts
When you create an account or use another service to log in to the Service, you agree to maintain the security of your password and accept all risks of unauthorized access to any data or other information you provide to the Service.
You understand that if you delete your account, or if we delete your account in accordance with these terms, you may lose access to any data previously associated with your account (including, without limitation, the level or score you have reached in our Games and any Virtual Money or Virtual Goods associated with your account).
You acknowledge and agree that you shall have no ownership or other property interest in any account that you create using any of our services. We may suspend, terminate, modify or delete any of these accounts at any time for any reason or no reason, with or without notice to you.
If you discover or suspect any Service security breaches, please let us know as soon as possible.

Virtual Goods and Virtual Money
Our Games may include virtual currencies such as coins (“Virtual Money”) or items or services for use with our Games (“Virtual Goods”). If you are over 18 years old, you may be able to buy Virtual Goods or Virtual Money. You agree that once purchased Virtual Money and Virtual Goods have no monetary value and can never be exchanged for real money, real goods or real services from us or anyone else. You also agree that you will only obtain Virtual Money and/or Virtual Goods only from us, and not from any third party. You agree that Virtual Money and Virtual Goods are not transferrable to anyone else and you will not transfer or attempt to transfer any Virtual Money or Virtual Goods to anyone else.
The balance of virtual goods or virtual currency does not contain real value. The user agrees that the sales of all virtual currencies and goods are final and that the company does not make refunds once the transactions are complete. When a user purchases virtual goods or currencies from the company, the delivery of goods will be carried out as soon as the purchase is complete and thus, the user agrees that they forfeit the right to withdraw and cancel since they have already received the benefits of the relevant virtual goods and/or currencies.
The company may manage, regulate, change or remove the contents of all virtual currencies or goods without being held liable by the user.
When the company stops or terminates the user’s account without limits to its contents according to the Terms and Conditions of the company, the user will lose all of the virtual currencies and goods they hold and the company will not make a refund and compensate for the loss.

Payment Terms

1. In-Game purchases
Smart Up may license to you certain virtual goods to be used within the Games and which you may purchase with real money or which you may earn or redeem via gameplay (“Virtual Items”). When you obtain such Virtual Items from Smart Up or its authorized designee, you receive a limited, personal, non-transferable, non-sublicensable and revocable license to use such Virtual Items within the applicable Game and solely for non-commercial use.
When you purchase Virtual Items in our Games on third-party platforms such as Apple, Google or Amazon, Smart Up is not a party to the transaction and your purchase will be governed by the third-party platform’s payment terms and conditions. Please review the platform’s terms of service for additional information.
For Virtual Items, your order will represent an offer to us to obtain a limited license and right to use the relevant Virtual Item(s) that will be accepted by us when we accept payment. At that point, the limited license begins.
For orders to obtain a limited license and right to use Virtual Items, by clicking the purchase/order button on the purchase window or page you:
● agree that we will supply the Virtual Items to you as soon as we have accepted your order; and
● if you reside in the European Union (the “EU”), you acknowledge that you will therefore no longer have the right to cancel under the EU’s Consumer Rights Directive (as implemented by the law of the country where you are located) once we start to supply the Virtual Item.
You understand that while you may “earn,” “buy,” or “purchase” Virtual Items in our Services, you do not legally “own” the Virtual Items and the amounts of any Virtual Item do not refer to any credit balance of real currency or its equivalent. Any “virtual currency” balance shown in your account does not constitute a real-world balance or reflect any stored value, but instead constitutes a measurement of the extent of your limited license.
ALL SALES ARE FINAL: YOU ACKNOWLEDGE THAT SMART UP IS NOT REQUIRED TO PROVIDE A REFUND FOR ANY REASON, AND THAT YOU WILL NOT RECEIVE MONEY OR OTHER COMPENSATION FOR UNUSED VIRTUAL ITEMS WHEN AN ACCOUNT IS CLOSED, WHETHER SUCH CLOSURE WAS VOLUNTARY OR INVOLUNTARY, OR WHETHER YOU MADE A PAYMENT THROUGH OUR SITE OR ANOTHER PLATFORM SUCH AS APPLE, GOOGLE, AMAZON, OR ANY OTHER SITES OR PLATFORMS WHERE WE OFFER OUR SERVICES. PURCHASES TO ACQUIRE A LIMITED LICENSE AND RIGHT TO USE VIRTUAL ITEMS ARE NON-REFUNDABLE TO THE FULLEST EXTENT ALLOWED BY LAW.
Additional Payment Terms:
You agree to pay all fees and applicable taxes incurred by you or anyone using an account registered to you. Smart Up may revise the pricing for the Virtual Items it licenses to you through the Services at any time. Smart Up may modify or eliminate Virtual Items at any time, with or without notice. Virtual Items cannot be sold, traded, transferred, or exchanged for cash.

2. Subscriptions
Some of Smart Up’s Games may offer subscription-based Services. If you purchase a subscription, then by clicking the purchase button you are requesting that we begin supplying the subscription Services immediately and you are entering into a monthly subscription contract with Smart Up. You are also authorizing a charge to you on a recurring basis of a monthly subscription fee at the rate quoted at the time of purchase. By purchasing a subscription, we will automatically charge on a recurring basis the payment method associated with your account. For subscription Services purchased in a Smart Up Game played on a platform such as Apple or Google, the applicable platform will charge you for the subscription fee and the platform’s payment terms will apply. Please review the appropriate platform’s payment terms for additional information.
Trial subscriptions are offered free of charge for a certain period of time from activation specified in the relevant trial offer in the Game. If you do not cancel the subscription within such trial period, the trial subscription will automatically convert into a paid subscription for the fees and for the subscription period set out in the Game at the time of the activation of the trial period. You may cancel a subscription during its free trial period using the subscription setting of your account. Any paid subscription you activate begins immediately from the activation of such paid subscription and not after the expiration of any trial period. Any unused trial period will therefore be forfeited if a subscription is activated prior to the expiration of such trial period.
Your subscription will automatically renew each subscription period unless and until you terminate your subscription or we terminate it. You must cancel your subscription before it renews, otherwise payment of the subscription fees for the next period will be taken automatically via your chosen payment method. You are responsible for the timely payment of all fees and for providing Smart Up with valid credit card or payment account details for payment of all fees. In case the subscription fee cannot be taken from your account due to absence of monetary funds, invalidity of credit card or for any other reason, your subscription will be automatically cancelled.
Subscription rates are based on an amount in U.S. Dollars. If you are using a local currency, the actual amount may fluctuate based on currency exchange rates without notice to you. The charges will be applied to the payment instrument or method you provide when you start your subscription (or to a different payment instrument or method, if you change your account information). Please note that prices and charges are subject to change. If we make a change to the monthly subscription rate in U.S. Dollars, we will notify you of such change in advance.
Once you have purchased a subscription, you cannot cancel your subscription for the current subscription period as that is activated as soon as you purchase a subscription. However, you may cancel your subscription for the next subscription period as follows: you can manage and cancel your subscription at any time in your “Account Settings” of your device. For iOS subscriptions, please see Apple’s support page https://support.apple.com/en-gb/HT202039. For Google Play subscriptions, please see Google Play’s support page https://support.google.com/googleplay/answer/7018481?hl=en-GB&co=GENIE.Platform%3DAndroid.
Except where required by applicable law, paid subscription fees are non-refundable. Smart Up in its sole discretion and at any time may modify the subscription fee. Any subscription fee change will become effective at the end of the then-current subscription period. You will be provided reasonable prior notice of any change in subscription fee. If you do not take action to agree to the increase in subscription fee, your subscription shall expire at the end of the then-current subscription period.

Your Content & Conduct
Our Service may allow you and other users to post, link and otherwise make available content. You are responsible for the content that you make available to the Service, including its legality, reliability, and appropriateness.
When you post, link or otherwise make available content to the Service, you grant us the right and license to use, reproduce, modify, publicly perform, publicly display and distribute your content on or through the Service. We may format your content for display throughout the Service, but we will not edit or revise the substance of your content itself.
Aside from our limited right to your content, you retain all of your rights to the content you post, link and otherwise make available on or through the Service.
You can remove the content that you posted by deleting it. Once you delete your content, it will not appear on the Service, but copies of your deleted content may remain in our system or backups for some period of time. We will retain web server access logs and then delete them.
You may not post, link and otherwise make available on or through the Service any of the following:
● Content that is libelous, defamatory, bigoted, fraudulent or deceptive;
● Content that is illegal or unlawful, that would otherwise create liability;
● Content that may infringe or violate any patent, trademark, trade secret, copyright, right of privacy, right of publicity or other intellectual or other right of any party;
● Mass or repeated promotions, political campaigning or commercial messages directed at users who do not follow you (SPAM);
● Private information of any third party (e.g., addresses, phone numbers, email addresses, Social Security numbers and credit card numbers); and
● Viruses, corrupted data or other harmful, disruptive or destructive files or code.
Also, you agree that you will not do any of the following in connection with the Service or other users:
● Use the Service in any manner that could interfere with, disrupt, negatively affect or inhibit other users from fully enjoying the Service or that could damage, disable, overburden or impair the functioning of the Service;
● Impersonate or post on behalf of any person or entity or otherwise misrepresent your affiliation with a person or entity;
● Collect any personal information about other users, or intimidate, threaten, stalk or otherwise harass other users of the Service;
● Create an account or post any content if you are not over 13 years of age years of age; and
● Circumvent or attempt to circumvent any filtering, security measures, rate limits or other features designed to protect the Service, users of the Service, or third parties.

Intellectual Property Rights
Except for the limited license granted above, we and our licensors retain all right, title and interest in and to the Services, including the technology and software used to provide the Services. The Services are protected by copyright, trademark and other laws. If you violate these Terms, you may be breaking the law, including by violating our intellectual property rights. We and our licensors may actively protect our intellectual property rights in the event you violate these Terms (including by seeking injunctive relief). In addition, you agree not to modify, create derivative works of, decompile, or otherwise attempt to extract source code from the Service.
If you provide us with any suggestions for enhancement or feedback regarding the Service, you agree that we will have a perpetual, transferable, sub-licensable, royalty-free, irrevocable, worldwide license to use such suggestions and feedback, including by incorporating your suggestions or feedback in the Service, without any obligation to compensate you. To the extent permitted by applicable law, you waive any moral rights you may have in such suggestions and feedback.

Hyperlinks and Third-Party Content
You may create a hyperlink to the Service. However, you may not use, frame or utilize framing techniques to enclose any of our trademarks, logos or other proprietary information without our express written consent.
Smart Up makes no claim or representation regarding, and accepts no responsibility for third-party websites accessible by hyperlink from the Service or websites linking to the Service. When you leave the Service, you should be aware that these Terms and our policies no longer govern.
If there is any content on the Service from you and others, we don’t review, verify or authenticate it, and it may include inaccuracies or false information. We make no representations, warranties, or guarantees relating to the quality, suitability, truth, accuracy or completeness of any content contained in the Service. You acknowledge sole responsibility for and assume all risk arising from your use of or reliance on any content.

Unavoidable Legal Stuff
The Service and any other service and content included on or otherwise made available to you through the Service are provided to you on an as is or as available basis without any representations or warranties of any kind. We disclaim any and all warranties and representations (express or implied, oral or written) with respect to the service and content included on or otherwise made available to you through the Service whether alleged to arise by operation of law, by reason of custom or usage in the trade, by course of dealing or otherwise.
In no event will Smart Up be liable to you or any third party for any special, indirect, incidental, exemplary or consequential damages of any kind arising out of or in connection with the Service or any other service and/or content included on or otherwise made available to you through the Service, regardless of the form of action, whether in contract, tort, strict liability or otherwise, even if we have been advised of the possibility of such damages or are aware of the possibility of such damages. Our total liability for all causes of action and under all theories of liability will be limited to the amount you paid to Smart Up. This section will be given full effect even if any remedy specified in this agreement is deemed to have failed of its essential purpose.
You agree to defend, indemnify and hold us harmless from and against any and all costs, damages, liabilities, and expenses (including attorneys’ fees, costs, penalties, interest and disbursements) we incur in relation to, arising from, or for the purpose of avoiding, any claim or demand from a third party relating to your use of the Service or the use of the Service by any person using your account, including any claim that your use of the Service violates any applicable law or regulation, or the rights of any third party, and/or your violation of these Terms.

Limited License
Smart Up grants you a non-exclusive, non-transferable, limited license to use the Service in accordance with this Agreement.

Limitation of Liability
In no event shall Smart Up, nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for damages, direct or consequential, resulting from your use of the Service, and you agree to defend, indemnify and hold us harmless from any claims, losses, liability costs and expenses, including but not limited to attorney’s fees, arising from your violation of any third-party’s rights.

Warranty Disclaimer
Your use of the Service is at your sole risk. The Service is provided on an “as is” and “as available” basis. The Service is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, non-infringement or course of performance.
Smart Up, its subsidiaries, affiliates, and its licensors do not warrant that a) the Service will function uninterrupted, secure or available at any particular time or location; b) any errors or defects will be corrected; c) the Service is free of viruses or other harmful components; or d) the results of using the Service will meet your requirements.

Copyright Complaints
We take intellectual property rights seriously. In accordance with the Digital Millennium Copyright Act (“DMCA”) and other applicable law, we have adopted a policy of terminating, in appropriate circumstances and, at our sole discretion, access to the service for users who are deemed to be repeat infringers.

Termination
We may terminate your access to the Service, without cause or notice, which may result in the forfeiture and destruction of all information associated with you. All provisions of this Agreement that by their nature should survive termination shall survive termination, including, without limitation, ownership provisions, warranty disclaimers, indemnity, and limitations of liability.

Entire Agreement
These Terms constitute the entire agreement between you and Smart Up regarding the use of the Service, superseding any prior agreements between you and Smart Up relating to your use of the Service.

Feedback
Please let us know what you think of the Service, these Terms and, in general, Games. When you provide us with any feedback, comments or suggestions about the Service, these Terms and, in general, Games, you irrevocably assign to us all of your right, title and interest in and to your feedback, comments and suggestions.

Questions & Contact Information
Questions or comments about the Service may be directed to us at support@smartupsupport.com

FAQ of Hi Guess the Games

How to play
1.As a puzzle game of hot games, you may use mouse to move letters to the blanks or the keyboard to type in letters.
2.When your spelling of the whole word is right, the word will be yellow, and you may continue with the next level.
3.When your spelling is not completely correct, letters will become red and you have to check your spelling before you move on.
4.This game is testing your knowledge of pop culture as well as your spelling, get started!

Game not loading
This may be due to high volume of traffic, you may reload the game or wait for a few minutes.

Got charged but not receiving coins
Please contact our support department through clicking on Support link and fill out the issue form. We will get back to you no later than 24hrs (Not Including Holidays).

Stuck with a puzzle
You may use hint buttons at the bottom of the game or press Ask Your Friends button to seek for help.

FAQ of Hi Guess the Brand

How to play
1.As a puzzle game of well known brands, you may use mouse to move letters to the blanks or the keyboard to type in letters.
2.When your spelling of the whole word is right, the word will be yellow, and you may continue with the next level.
3.When your spelling is not completely correct, letters will become red and you have to check your spelling before you move on.
4.This game is testing your knowledge of brand culture as well as your spelling, get started!

Game not loading
This may be due to high volume of traffic, you may reload the game or wait for a few minutes.

Got charged but not receiving coins
Please contact our support department through clicking on Support link and fill out the issue form. We will get back to you no later than 24hrs (Not Including Holidays).

Stuck with a puzzle
You may use hint buttons at the bottom of the game or press Ask Your Friends button to seek for help.

FAQ of Hi Guess the Basketball Star

How to play
1.As a puzzle game of well known basketball stars, you may use mouse to move letters to the blanks or the keyboard to type in letters.
2.When your spelling of the whole word is right, the word will be yellow, and you may continue with the next level.
3.When your spelling is not completely correct, letters will become red and you have to check your spelling before you move on.
4.This game is testing your knowledge of pop culture as well as your spelling, get started!

Game not loading
This may be due to high volume of traffic, you may reload the game or wait for a few minutes.

Got charged but not receiving coins
Please contact our support department through clicking on Support link and fill out the issue form. We will get back to you no later than 24hrs (Not Including Holidays).

Stuck with a puzzle
You may use hint buttons at the bottom of the game or press Ask Your Friends button to seek for help.

FAQ of Hi Guess the Character

How to play
1.As a puzzle game of famous characters, you may use mouse to move letters to the blanks or the keyboard to type in letters.
2.When your spelling of the whole word is right, the word will be yellow, and you may continue with the next level.
3.When your spelling is not completely correct, letters will become red and you have to check your spelling before you move on.
4.This game is testing your knowledge of pop culture as well as your spelling, get started!

Game not loading
This may be due to high volume of traffic, you may reload the game or wait for a few minutes.

Got charged but not receiving coins
Please contact our support department through clicking on Support link and fill out the issue form. We will get back to you no later than 24hrs (Not Including Holidays).

Stuck with a puzzle
You may use hint buttons at the bottom of the game or press Ask Your Friends button to seek for help.

Thanks for submitting your message. We normally get back to you within 24 hours. Please also check out the FAQ page, you may get your questions answered there!

FAQ of Hi Guess the Food

How to play
1.As a puzzle game of food brands, you may use mouse to move letters to the blanks or the keyboard to type in letters.
2.When your spelling of the whole word is right, the word will be yellow, and you may continue with the next level.
3.When your spelling is not completely correct, letters will become red and you have to check your spelling before you move on.
4.This game is testing your knowledge of common daily foods as well as your spelling, get started!

Game not loading
This may be due to high volume of traffic, you may reload the game or wait for a few minutes.

Got charged but not receiving coins
Please contact our support department through clicking on Support link and fill out the issue form. We will get back to you no later than 24hrs (Not Including Holidays).

Stuck with a puzzle
You may use hint buttons at the bottom of the game or press Ask Your Friends button to seek for help.

Support

If you encounter with any trouble when using the website, you can check the FAQ page for possible solutions.
If you still have problems, please submit a message below with a detailed description of the problems you encountered with.
We will reply as soon as possible.

Introduction

This policy gives a description on how Smart Up (“us”, “we”, or “our”) collects, uses, shares, and protects information about you for our games on mobile devices, PCs, or on other platforms in order to provide you with excellent service and develop our products.

All Smart Up activities regarding marketing, advertising, and other services (“Services”) are governed by this Privacy Policy. Using or accessing a Service on any platform means that you agree to the use of your information in compliance with this Privacy Policy. This policy also describes how you can withhold or withdraw your consent to the use of your data, including for targeted advertisements, and how to request to know about, correct, or delete the information we hold.

Smart Up is dedicated to transparency, data privacy, and security, and follows the strict regulations required by the CCPA (California Consumer Privacy Act), LGPD (Lei Geral de Proteção de Dados) and GDPR (General Data Protection Regulation), as detailed in this privacy policy.

If you have any concerns, please contact us using the methods provided in the Contact Us section of this document. If you disagree with your information being used as described in this Privacy Policy, please do not install or use the Services.

This Privacy Policy was last updated on Dec 18, 2020.

Information Collection

Your information is collected at the start of using our games and/or other Services. We use this data to provide you with better game experiences and Services for the purpose of optimization, preventing fraud, and for marketing and advertising. We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.

We may collect and process the following types of information:
● The type of your device, IP address, your game ID when using the app, and the country or region that you’re playing in;
● Details about your gameplay on our app, including: amount of time played, if you have left the game on a specific level or if you have cleared it, and your scores on levels, and items you own or use;
● Purchase history on behalf of our payment service providers to keep a record on if a purchase has been successfully made. We do not collect credit card information;
● Information we collect via cookies and other similar technologies, as explained further below;
● Communications between you and us, whether in-game, via email, or through social media channels. We keep a record of these communications to provide customer service by answering your questions and providing you with a better experience using our app;
● Information from our other group companies or other third-party companies who have your consent or have other legal rights to share granted information with us (advertising networks and publishing partners, platforms). This may include your interests, other games you played, demographic and general location information. We use this information as described in this Privacy Policy;
● Information that you provide when you connect to your social network account when creating an account with us. This may include, but is not limited to: your name, address, email address, or other information;
● Information as further set out in this Privacy Policy, including Social sharing features, Marketing and Advertising

If you choose not to connect to your social network accounts when using our games, we still collect anonymous information. There will still be device level identifiers and other information described here, but there will be no personally identifiable information.

We may ask for your approval to collect other information in some circumstances from you or your device. If this situation arises, we will inform you what information we are to collect, the reason we collect it, and how we will be using that information.

Information Usage and Sharing

Optimizing Our Services
We analyze and optimize to provide you the best possible products by using your information from the use of our Services and analysis of de-identified or aggregated data to analyze the performance of our games, troubleshoot problems, verify that our websites work properly on all devices, create updates, and develop and improve the quality of our products.

Customer Services
We may use your information delivered or provided directly to us in any communications in terms of customer service and through its channels. We may use such information to contact you and to manage your account and relationship with us to improve your experience in our Services. Our customer service channel is found at http://www.smartupinc.com/support/.

Analytics and Research
We collect information using analytics tools such as third-party analytics tools to see how you play our games or use our Services. Those tools may contain cookies or other similar tracking technologies. We may use your data for research and analytics purposes to engage with you directly. We may also create reports, analysis or similar services for use by us for the purposes of research or business intelligence.

Social and Community
There are social and community channels we use to communicate with our players. We receive your information only when you initiate interaction on those channels, and any information you provide may be used in connection with those channels. If you choose to interact with our channels, we may communicate with you through those channels and may republish your posts on those channels.

Social Sharing
Our Services may offer social sharing features and other integrated tools that allow you to connect with other media. You must be over the minimum age limit prescribed by the legislation in your country and local government to use such social sharing features which may, depending on the settings you set with the provider, share information with your friends or the public.

Our Services contain social features from the providers listed below. For more information about the processing driven by the third parties regarding social sharing features, please visit the privacy policies of the providers found here:
● Facebook: https://www.facebook.com/about/privacy/
● Game Center: https://www.apple.com/legal/privacy/en-ww/
● Google Play Games: https://www.google.com/policies/privacy/

Other Usage and Sharing
The other main way that we use and share information is for marketing and advertising reasons. This usage is described in more detail below. We do not sell your information.

Marketing

We may serve ads based on your information we collect about you within our Services, or place ads on third party websites, apps and internet-connected devices. This information may include:
● Ad identifiers and other non-personal information collected from your device
● Your interactions with our game and Services, including game play information
● Your age, country or region, and gender
● Other information collected from third parties who have obtained your consent or have a legal right to share it with us.

This information is used to try to make sure that you only see marketing from us that you are interested in, including our other games. Please note that if you opt out, you may still have advertisements in the game, but they will not be targeted advertisements (advertisements that are tailored to your interests by using your information).

Marketing Partners
There are various third-party marketing partners we use to help market our games. With the help of your information collected when you use their services, they make assumptions to ensure that most relevant advertising that you would prefer to see is presented and evaluate the effectiveness of advertisements.

This Privacy Policy does not cover the data use of our marketing partners, but they are required to have a legal basis to use your data for marketing purposes and to provide you the details on how it’s being used. For more information we recommend for you to read our partners’ privacy policies on their websites (a full list can be found here).

Advertising

Our games include advertising for third party products and services. We and our partners use your information to improve advertising and targeting for third party ads that are shown in our games. This information is used to make sure that the ads that you see might be of interest to you or relevant to you.

This information may include:
● Ad identifiers and other non-personal information collected from your device
● Your interactions with our game and Services, including game play information
● Your age, country or region, and gender
● Other information collected from third parties who have obtained your consent or have a legal right to share it with us.

Please note that if you opt out, you may still have advertisements in the game, but they will not be targeted advertisements (advertisements that are tailored to your interests by using your information).

Advertising Partners
Non-personal identifiers and other information that is collected from your device when you play our games or use our Services may be shared with advertising partners in order to deliver ads to your device. Such information may be combined with information that our advertising partners collect separately to serve you with more relevant ads (targeted ads) and to enhance the accuracy of their targeting. For more information we recommend for you to scan through our partners’ privacy policies on their websites (a full list can be found here).

Ad Identifiers
We use ad identifiers that are non-permanent, non-personal identifiers such as the Android and/or Apple’s ID for advertising associated with your device, and similar technologies such as tracking pixels within ads to provide interest-based advertising. These technologies enable us and our third-party advertising partners to recognize you and your device, allow our Services to interact with a third-party social network or platform, and help our payment processors to complete your payment instructions.

Your Rights and Control of Data

Right of Access / Right to Know
All users have a right to know what information we collect about them and how we use or share that information. If you wish to know which information we collect and hold about you, please use the methods described in the Contact Us section so we can verify your identity to provide you with requested information. You may only request your own personal information, and information will not be provided about other users. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons.

Information Correctness
If there is any information we hold about you that you would like to correct, please let us know using one of the methods listed in the Contact Us section. We will make corrections as soon as possible. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons.

Data Retention and Deletion
Smart Up retains the personal information described in this Privacy Policy while you use our Services in order to fulfill the purpose(s) for which it was collected, resolve disputes, conduct audits, or to fulfill legal purposes. All personally identifiable user data is retained for 6 months, and is permanently deleted afterward. If you wish to have your data deleted sooner, please contact us using the methods described in the Contact Us section. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons. Please be aware that if you want to delete your user ID completely, you may be asked to delete our game(s) from your mobile devices.

There may be some information that will be maintained for record-keeping and legal purposes, which will not be shared with Third Parties unless legally required. Some de-identified information or data collected in aggregate that does not contain personally identifiable information may be retained as well.

Account Deactivation
You can deactivate the account you created in our game by contacting us using the methods described in the Contact Us section. You will be required to follow the verification process listed under the “Verification Process” section below for security reasons. Please note that your unspent virtual items will not remain or be recoverable after your account is deactivated.

Verification process
If you request to know about, correct, or delete your personal information, you will be required to open the relevant game to send us a second message using the in-app messaging system to allow us to verify your user ID and use that ID to retrieve any requested information. Without this step we will not be able to verify and provide information related to your account.

Data Portability
You have the right to request the data provided to us to be transferred to another data controller in some circumstances according to the laws in the country where you live.

Restriction of Processing
You may request a restriction of the processing of your data in some circumstances according to the laws in the country where you live.

Right to Object
You have the right to object to the processing of your personal data in some circumstances according to the laws in the country where you live.

Authorized Agents
Authorized agents, including parents or guardians, may make a request on behalf of the user in the same ways as listed above. If you have any questions, please contact us using one of the methods listed in the Contact Us section.

Opt Out
● Direct marketing
Please follow the opt-out link included with our marketing communications (such as emails) if you would not like to receive direct marketing communications from us. If you receive more than one type of marketing communications, you may need to opt out of all of them individually. A few days might take for our records to be effectively updated.
● Push Notifications
We may occasionally use push notifications to send you game updates or other Services-related notifications that may be important to you. You may opt out from receiving these types of communications at any time by turning them off for your phone or tablet settings.
● Preferences for Advertising
You may reset your ad identifier being used for interest-based advertising by changing the settings of your device, usually found under “privacy” or “ads”. You can also opt out from your information being collected if you live in the USA, Europe or Canada by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices (for Canadian users). If you would like to withdraw your consent for targeting advertisements, please contact us using one of the methods in the Contact Us section. Please note that if you opt out, you may still have advertisements in the game, but they will not be targeted advertisements (advertisements that are tailored to your interests by using your information).

Other Important Policies

Our Policy Regarding Children
We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.

California Privacy Rights
According to the California Consumer Privacy Act (CCPA), users who are California residents may request and obtain a list of the Third Parties to whom we have disclosed their personal information (if any) and the type of personal information disclosed to those parties during the prior calendar year. This list may be requested once per year and free of charge.

Non-Discrimination
Users have the right to not receive discriminatory treatment by the business for exercising privacy rights according to the CCPA and other relevant data privacy laws and regulations.

Updates to Our Privacy Policy and Practices
We may revise this Privacy Policy from time to time, as needed. We will notify you via our apps if there are any material changes that affect your use of our services, as required by applicable laws. Changes will also be posted on this website, and the revised version will be applicable immediately after it is posted or notice is received. If you continue to use our services after any changes have been made, you hereby provide your consent to the changes.

We commit to provide information to our users before using their information for any new purpose not stated in this Privacy Policy and give them the opportunity to opt out if they do not agree. If consent for information usage or processing is required by law or contract, Smart Up will comply with the law or contract.

Contact Us

If you have any questions or concerns about this Privacy Policy, including to exercise any of your rights, you may contact us via our customer service email at support@smartupsupport.com.

For information collected under this Privacy Policy, the data controller is Smart Up Inc.