Privacy Policy

Last updated: 13 November 2025

This Privacy Policy describes how Pallidor Games (“we”, “us”, or “our”) collects, uses, and protects information in the mobile game UP! (“the Game”).

By installing and playing UP!, you agree to this Privacy Policy. If you do not agree, please do not install or use the Game.

1. Data Controller

The data controller under the EU General Data Protection Regulation (“GDPR”) is:

Pallidor Games
Based in Portugal
Email: pallidor@pallidor.com

2. Information We Collect

We do not collect information that directly identifies you (such as your name, address, or phone number). The Game collects only anonymous or pseudonymous data for:

• Analytics – to understand how players use the Game and improve gameplay, performance, and stability.
• Advertising – to show ads and improve their relevance and performance.

2.1 Analytics Data

We may use third-party analytics services (for example, mobile analytics tools) that collect anonymized or pseudonymized information, such as:

• Game events (e.g., level starts/finishes, buttons pressed, session length)
• Approximate location (e.g., country or region)
• Device information (e.g., device model, operating system version, language, screen resolution)
• Crash logs and performance data

This information is used in aggregated form and does not allow us to identify you as an individual player.

2.2 Advertising Data

The Game may display ads provided by third-party advertising partners. These partners may collect and process certain anonymous or pseudonymous information, such as:

• Advertising identifiers (e.g., Google Advertising ID)
• Information about your interactions with ads
• General device information and approximate location (such as country)

This information helps improve ad relevance, limit the number of times you see the same ad, and measure the performance of advertising campaigns.

3. Legal Basis for Processing (GDPR)

As we are based in Portugal and our game may be played by users in the European Union, we process personal data in accordance with the GDPR.

Depending on the specific implementation of analytics and advertising services, the legal basis for processing may include:

• Your consent, when you accept analytics or advertising settings (if we present a consent dialog).
• Our legitimate interests (Article 6(1)(f) GDPR) in improving the Game, ensuring its security and stability, and supporting our business through advertising revenue.

4. How We Use the Data

We use the collected data for the following purposes:

• To operate, maintain, and improve UP!
• To understand how players interact with the Game and make design and balance decisions
• To monitor technical performance and fix bugs, crashes, and other issues
• To show ads and measure their effectiveness
• To prevent fraud and abuse

5. Data Sharing and Third Parties

We may share anonymous or pseudonymous data with trusted third-party service providers that help us operate the Game, such as:

• Analytics providers
• Advertising networks and partners
• Crash reporting and performance monitoring tools

These third parties process data on our behalf and are required to protect it and use it only for the purposes described in this Privacy Policy or in their own privacy policies.

We do not sell your data to third parties.

6. International Data Transfers

Some of our service providers may be located outside the European Union / European Economic Area. When data is transferred internationally, we take appropriate measures to ensure that it is protected in accordance with applicable data protection laws, for example through the use of Standard Contractual Clauses or equivalent safeguards.

7. Data Retention

We retain data only for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for legal, tax, or accounting reasons).

8. Children’s Privacy

UP! is not specifically targeted at children under the age required by local law for consent to data processing (for example, under 13 or under 16 in some EU countries).

If you are a parent or guardian and believe that your child has provided data through the Game without your consent, please contact us at pallidor@pallidor.com so that we can take appropriate steps to delete such data if necessary.

9. Your Rights (EU/EEA Users)

If you are located in the European Union or European Economic Area, you have certain rights regarding your personal data under the GDPR, including:

• The right to access your personal data
• The right to rectification (correction) of inaccurate data
• The right to erasure (“right to be forgotten”) in certain circumstances
• The right to restrict processing in certain circumstances
• The right to data portability
• The right to object to processing based on legitimate interests, including profiling
• The right to withdraw consent at any time, if processing is based on consent
• The right to lodge a complaint with a supervisory authority, such as the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados – CNPD)

To exercise your rights, please contact us at pallidor@pallidor.com.

10. Security

We take reasonable technical and organizational measures to protect data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect changes in the Game, our practices, or legal requirements. When we do so, we will update the “Last updated” date at the top of this page.

We encourage you to review this page periodically to stay informed about how we protect your data.

12. Contact

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Pallidor Games
Email: pallidor@pallidor.com
Website: https://pallidor.com