Last updated: July , 2026
This Privacy Policy aims to give you information on how Upstep processes your personal data. The words “we”, “our”, and “us” refer to Upstep group of companies.
This Policy extends to mobile applications, published by Upstep or our partners, and related services.
WHERE DO WE GET YOUR DATA FROM?
You Directly
We may obtain personal data directly from you. For instance, when you create or manage your account, you may provide information such as your gaid,user id.
Data Collected Automatically
Your internet browser (such as Mozilla Firefox or Google Chrome) automatically transmits some information to us every time you access content on one of our apps. Examples of such information include the URL of the particular web page you visited, the IP address of the computer you are using, or the browser version that you are using to access the website. We may collect information about your mobile device, such as a unique device identifier.
Third Parties
We receive information from our advertisers and promotional partners that we work with to help us deliver ads and personalized content to you. This may include pseudonymous advertiser identifiers that some advertisers or other third-party ad platforms choose to share with us. We also receive information from the application stores where our applications are published (e.g., information about your in-app purchases).
HOW LONG DO WE PROCESS YOUR DATA?
Your personal data is retained for as long as it is necessary to fulfill our processing purposes and in line with our legitimate interests, legal obligations, and technical requirements for data storage. Once the retention or processing period expires and there are no contrary legal or contractual obligations, we will delete or anonymize your data.
Please note that we may continue to retain certain user data in the following cases:
We have a lawful basis to continue processing your data beyond your consent (for example, to comply with tax, accounting, know-your-customer, anti-money laundering, or other legal requirements and obligations).
Your User data has been anonymized so that it can no longer identify you, thus no longer constituting personal data (for example, data that is processed to analyze users’ behavior may be further used in aggregated form).
HOW DO WE SHARE YOUR PERSONAL DATA?
We share certain personal data with trusted partners, service providers, and affiliates who help us support various aspects of our Services. They only receive the data needed to provide their services to us. We have agreements with our service providers that say they cannot use any of this data for their own purposes or for the purposes of another third party. We prohibit our service providers from selling data they receive from us or receive on our behalf. We require service providers to use data only to perform the services we have hired them to provide (unless otherwise required by law). These partners are contractually required to apply appropriate safeguards, follow our documented instructions, and maintain strict confidentiality.
Gaming and Other Digital Platforms. We share your data with our business partners who are involved in the distribution of our Games via various third-party platforms, which allow our Users to access our Services through these platforms. This also enables user support and provides all features related to our Services for those playing our Games on these platforms. Some of these partners are located outside the EEA. For example, App Store operated by Apple, or Google Play operated by Google.
Authorization Platforms. You can log into our Services using credentials from third-party partners offering SSO services, such as Apple Game Center, Google Play, and Amazon. In these cases, we share login data with our partners.
Payment Service Providers. We use authorized payment service providers to process payments for our Services. Depending on your region, your data may be shared with licensed payment service providers operating within your respective region or country.
Advertising Partners. We work with advertising partners who assist us with the delivery of ads, tracking and analytics. We may share anonymized information such as your device, location, purchase data, and usage of our Services. These partners may combine this data with their own to enhance their advertising targeting.
Security and Anti-Cheat Tools. We may use third-party security and anti-cheat tools that process user data to protect the integrity of the gaming environment by detecting, preventing, and responding to fraudulent activities, unauthorized access, cheating, and other malicious behavior that could compromise the fairness or security of the game.
Operating Partners. We work with trusted server hosting and database providers who store and manage the data required to deliver our Services online. These partners ensure the secure storage and efficient handling of the data necessary for the functionality, reliability, and availability of our Services.
Email Providers. Email providers are third-party services that facilitate the delivery, receipt, and management of email communication between us and data subjects. These providers process personal data such as email addresses, message content, timestamps, and metadata to ensure the secure and reliable transmission of emails.
Cookies and Tracking Technology Providers. These providers help ensure the smooth and efficient operation of our Services, including features such as user authentication, site security, and user preferences. We also use these technologies to collect data on how users interact with our Services. This data aids us in understanding user behavior, identifying trends, and improving our Services.
Business Service Providers. We may share personal data with third-party service providers, such as software developers, corporate or administrative service providers, who help us operate and manage our Services.
Auditors. In cases where an audit or financial reporting requirement is mandated by applicable law, we may share data with third parties to meet these obligations. We carefully evaluate each situation and ensure that only the minimal necessary data is shared.
Governmental Bodies. We may share data with government authorities, either directly or through our partners, if required by applicable law, if legally requested by authorized bodies, or when necessary to protect the rights or interests of our users or ourselves. In such cases, we carefully assess what data to share, providing only the minimal necessary information.
CHILDREN DATA
We do not intentionally collect, store, or process any personal data from users under the age of 16 unless we have obtained consent from their parent, legal guardian, or another person who holds parental responsibility. We also do not identify or categorize users by age in a way that would affect the provision of Services.
If we become aware that we have collected personal data from a child without appropriate consent, we will promptly restrict access to the relevant Services and delete the data, unless the law requires us to keep it.
Parents or guardians who believe we may have unintentionally collected data from their child can contact us using the contact details provided in Section 11 to request access, rectification, or erasure. Please note that for some Services, data can only be erased through in-game settings. To process such a request or expedite the erasure, we may ask you to provide clear evidence that the child has not yet reached the age of 13 (or the applicable age of digital consent in your jurisdiction) and that you hold parental responsibility for the child.
We strongly encourage you to remind children never to share real names, addresses, phone numbers, payment data, or other sensitive information while using our Services.
YOUR RIGHTS
Depending on the applicable data protection laws, you have the following rights regarding our data processing:
Right to Be Informed. You have the right to be informed how we collect and use your personal data.
Right to Access. You have the right to request information about the data we hold about you and to receive a copy of it.
Right to Rectification. You have the right to request corrections to your personal data if it is inaccurate, incomplete, outdated, incorrect, unlawfully obtained, or no longer needed for processing.
Right to Restrict Processing. You have the right to limit the use of your data in certain circumstances, either fully or partially, unless we are required by law to continue processing it.
Right to Withdraw Consent. If your data is processed based on your freely given consent, you have the right to withdraw that consent at any time.
Right to Object. You have the right to object to the processing of your personal data at any time. Upstep may continue processing your data if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or if the processing is necessary for the establishment, exercise, or defense of legal claims.
To exercise your rights, you need to submit your request to app@arrow-rush-beauty-puzzle.com.
FOR UNITED STATES RESIDENTS
If you reside in a U.S. state where consumer privacy laws are in force, subject to certain exceptions, you may have the rights listed in Section 8, as well as the following additional rights:
Right to opt-out of “sale” or targeted advertising: we do not engage in the traditional "selling" of your personal information, meaning we do not trade your phone numbers, email addresses, or other personal details for any compensation. However, like many companies, we may share some of your personal information with third parties to help personalize and enhance advertising on external websites or apps. In certain states, these actions might be considered a "sale" or "sharing" of personal information for targeted advertising, and as such, you have the right to opt out.
Right to be free from discrimination: we will not deny goods or services, charge different prices, except when you voluntarily join a promotion or incentive that uses your data (for example, a loyalty discount). In any case, we will not impose penalties because you exercise your privacy rights.
Right to appeal: if we refuse your request, you can ask us to review that decision.
Right to use an authorized agent: you may designate a representative to submit a request on your behalf; we will require proof of the agent’s authority and your identity.
To learn more about how to exercise your rights related to your personal data, refer to Section 8.
HOW TO CONTACT US?
If you have any questions about this Privacy Policy or our data processing practices, or if you wish to exercise your privacy rights, you can contact us using:
our email: app@arrow-rush-beauty-puzzle.com.