• Privacy Policy

    • June 3, 2020

    UpSmart Games (collectively, “UpSmart Games” or “we”, “us”, “our”) create and publish mobile games and applications. This Privacy Policy (“Policy”) applies to all of our games, websites and related services, collectively referred here as our services. This Privacy Policy explains how we, and affiliated companies collect, use, secure, and/or disclose end-users’ (“you” or “your”) or otherwise processes your personal information when you use our services.


    When you use our services, we may ask you to provide us with some personally identifiable information that can be used to contact or identify you. Personally, identifiable information may include, but is not limited to your name (“Personal Information”, “Personal data” or “data”).

    Personal information includes:

    • Your name,
    • Email address or any other contact details,
    • Any information you submit to our customer service team in the services or via email.

    Apart from that, we may also collect certain data automatically such as;

    • Data/analytics about your usage (e.g. play progress, levels, games played, session length, preferred settings, which in-game adverts you may have viewed,
    • IP address and device identifiers such as your Advertising ID, Device ID numbers,
    • Device type and the operating system of the device that you use,
    • General geographic location (e.g. country or city location) based on your IP address and GPS location, with your consent.

    Some of these data may be collected using cookies and/or similar technologies such as “software development kits, or “SDKs”.

    We may also collect data from third-party sources (third-party service providers, social media platforms, and Ad Networks). These sources help us to understand the marketing dynamics and improve the services we cater to you.


    We can collect and process some of your data for different legitimate purposes when you install and use any UpSmart Games mobile applications. The below are the explanations regarding the reasons why UpSmart Games may collect data and the legal bases our company relies on in each case.

    To provide and maintain our services, recognize you when you return to our games and perform the essential business operation,
    Legal basis: such data processing is strictly necessary for the service(s) asked

    • To administer and protect our services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data).
      Legal basis: legitimate interests for running our business, provision of administration, and services.
    • To cross-advertise our services and products and to send push notifications for changes to our services,
      Legal basis: Legitimate interests to be able to advertise our services and products to our users and keep our users updated about our services and our new features in accordance with their preference.
    • To serve ads tailored to your preferences and interests and allow us to continue to offer free services and products
      Legal basis: Legitimate interests in running our business.


    We will not rent or sell your personal data to third parties, but we may share your information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that provide automatic data processing technologies for the games. We do not control or influence these third parties’ tracking technologies or how they may be used.

    We may share your personal data for the following business purposes:

    • Third-party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
    • Providers that help us generate and collate reviews in relation to our goods and services;
    • Our advertising and promotional agencies and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or
    • service providers that assist us in providing our services,
    • In order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.

    We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our services.

    Ad Partners: that allow us to monetize the ad inventory of our games and provide users with free products and services. Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:

    Analytic companies: that provide us with tools and technologies that allow us to better understand how users interact with our services and will help us improve it. Those partners also usually collect data via their own SDKs. You will find a list of our partners implementing analytical SDKs through our applications hereafter:


    We are an international organization providing our games to our users around the world. We and third-party organizations that provide automatic data processing technologies for the services or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

    Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to use and disclosure of information about you, including personal data, as described in this Privacy Policy.


    You may access, correct, update, or request the deletion of your personal information. We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. You can exercise your data protection rights by contacting us using the information in the “Contact Us” section below.

    Users’ Rights in the European Countries.

    We are a data controller with respect to any personal information collected from individuals accessing or using our services. If you are located in the European Union, European Economic Area, United Kingdom, or Switzerland, you have the following data protection rights:

    • The Right of Access / The Right to Know
      You may request a copy of your personal information in our files without undue delay and free of charge, unless we are permitted by law to charge a fee. You may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller,” where technically feasible.
    • The Right to Rectification
      You may request to correct or update any of your personal information in our files.
    • The Right to Deletion
      You have a right to have your personal information in our files deleted.
    • The Right to Restriction
      You have the right to restrict our processing of your personal information.
    • The Right to Object
      You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests.
    • Automated Individual Decision-Making, Including Profiling
      You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

    Users’ Rights in California

    As a California resident, you may exercise the following rights in addition to the rights listed in the previous section regarding the personal information we collect about you, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”):

    • The Right to Opt-Out of Personal Information Sales
      You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt-in, or to have a parent or guardian opt-in on your behalf, to such sales.
    • The Right to Non-Discrimination
      You have the right not to receive discriminatory treatment for exercising any of the rights described above.
    • “Shine the Light”
      California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

    To exercise your right to know and right to deletion, please submit a request by contacting us with the subject line “California Rights Request” in the “Contact Us” section.


    Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. Like many services, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our services. On the other hand, we may occasionally use push notifications through our services to send you game updates, high scores and other services-related notifications. You may turn them off at the device level if you do not want to receive these types of communications.


    We retain your personal data for as long as needed to provide you services, unless we are required by law to delete or if requested to delete the information. If you no longer want us to use your information that we physically access and store, you can request that we erase your personal information and close your account.

    We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


    The security of your personal data is important to us. We take reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data.

    Unfortunately, remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.


    Our services are not intended for use by children under the age of sixteen (16). We will not knowingly collect personal information directly from children under the age of sixteen (16) without parental consent. In order to request the deletion of personal data, for any reason, please contact us.


    This Privacy Policy is effective as except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. In some changes to this Privacy Policy, we may notify you either through the email address you have provided us, or by placing a prominent notice on our service.

    11) CONTACT US

    If you have any questions about this Privacy Policy or further information related with this scope, please contact us at this email : support@smartbrainpuzzles.com