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.

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, Discord communities)

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:

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:

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.

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:

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:

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:

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: