Privacy Policy

1. Scope of This Policy

This Privacy Policy applies to personal information collected through the Site, including when you:

• browse our website;
• sign up to receive newsletters, updates, announcements, or marketing emails;
• contact us through the Site or by email;
• interact with pages or links that connect to third-party services.

This Privacy Policy does not apply to third-party websites, platforms, storefronts, games, or services that may be linked from our Site, including storefronts such as Steam, social platforms, or external partner pages.

2. Personal Information We Collect

Depending on how you use the Site, we may collect the following categories of information:

A. Information you provide directly

• Email address when you voluntarily subscribe to our newsletter or mailing list.
• Name or company information if you choose to provide it in an inquiry or contact form.
• Any other information you submit when contacting us.

B. Information collected automatically

When you visit the Site, we or our service providers may automatically collect certain technical information, such as:

• IP address;
• browser type and version;
• device type and operating system;
• referring URLs;
• pages viewed and actions taken on the Site;
• date/time of access;
• approximate geolocation derived from IP;
• cookie or similar identifier information, where applicable.

C. Information from third parties

We may receive information from service providers that help us operate the Site or send newsletters, such as website hosting providers, analytics providers, or email delivery platforms.

3. How We Use Personal Information

We may use personal information for the following purposes:

• to operate, maintain, and improve the Site;
• to send newsletters, updates, and promotional communications that you have requested or consented to receive;
• to respond to your inquiries or requests;
• to monitor Site performance, security, and usage trends;
• to prevent fraud, abuse, unauthorized access, or other unlawful activity;
• to comply with legal obligations and enforce our legal rights.

We do not sell personal information for monetary consideration.

4. Legal Bases for Processing

Where required by applicable law, we process personal information on one or more of the following legal bases:

• your consent, including when you voluntarily subscribe to our newsletter;
• our legitimate interests, such as operating and securing the Site, improving our services, and communicating with business contacts;
• performance of a contract or steps requested by you before entering into a contract, where applicable;
• compliance with legal obligations.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that occurred before withdrawal.

5. Email Newsletter and Marketing Communications

If you subscribe to our newsletter, we will use your email address to send you news, updates, release information, company announcements, promotions, or other marketing communications related to Levelup Games and the games we publish or support.

You may unsubscribe at any time by:

• clicking the unsubscribe link in the email; or
• contacting us at [email protected]

We may retain a limited record of your unsubscribe request to ensure we honor your preferences.

6. Cookies and Similar Technologies

We may use cookies or similar technologies to:

• keep the Site functioning properly;
• understand traffic and usage patterns;
• improve Site performance and user experience;
• measure the effectiveness of communications or pages.

You can control cookies through your browser settings. Blocking some cookies may affect Site functionality.

7. How We Share Personal Information

We may share personal information only as reasonably necessary in the following circumstances:

• with vendors and service providers that help us host the Site, send emails, provide analytics, or support our operations;
• with professional advisers, auditors, insurers, or legal counsel;
• with authorities, regulators, courts, or law enforcement where required by law or to protect our rights;
• in connection with an actual or proposed merger, acquisition, financing, restructuring, or sale of assets;
• with your consent or at your direction.

We do not authorize third parties to use your personal information for their own independent marketing purposes except as disclosed to you or as permitted by law.

8. International Transfers

Levelup Games is based in Shanghai, China, and our service providers may operate in other countries or regions. As a result, your personal information may be transferred to, stored in, or accessed from jurisdictions outside your country or region of residence.

Where required by applicable law, we will take reasonable steps to ensure that cross-border transfers are subject to appropriate safeguards and that your personal information receives a level of protection consistent with applicable law.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• while you remain subscribed to our newsletter;
• as needed to respond to inquiries or maintain business records;
• as required to comply with legal, tax, accounting, or regulatory obligations;
• as needed to establish, exercise, or defend legal claims.

If you unsubscribe from marketing emails, we may retain limited suppression information so we can respect your opt-out.

10. Data Security

We use reasonable administrative, technical, and organizational measures to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Depending on your location and applicable law, you may have rights regarding your personal information, including the right to:

• access the personal information we hold about you;
• request correction of inaccurate or incomplete information;
• request deletion of your personal information;
• withdraw consent;
• object to or restrict certain processing;
• request portability of certain information, where applicable;
• complain to a relevant data protection authority.

To exercise your rights, contact us at [email protected]. We may need to verify your identity before fulfilling your request. We will not discriminate against you for exercising applicable privacy rights.

12. California Notice

If you are a California resident, you may have rights under the California Consumer Privacy Act, as amended, including rights to know, delete, correct, and limit certain uses of personal information, subject to legal exceptions. We do not sell or share personal information for cross-context behavioral advertising as those terms are defined under California law.

13. Children's Privacy

The Site is not directed to children under the age of 13, or a higher age where required by local law. We do not knowingly collect personal information from children without appropriate consent. If you believe a child has provided personal information to us, please contact us so we can take appropriate steps.

14. Third-Party Links and Services

The Site may contain links to third-party websites, storefronts, social channels, or services. We are not responsible for the privacy practices, content, or security of third-party services. We encourage you to review their privacy notices before providing any information to them.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the revised version on this page and update the "Last Updated" date above. Where required by law, we will provide additional notice or obtain consent for material changes.

16. Contact Us

If you have any questions, requests, or complaints regarding this Privacy Policy or our handling of personal information, please contact: