Privacy Policy

Last Updated August 30, 2024

This privacy policy (" Policy") describes the data processing activities of Uplift Games LLC and its affiliates and its subsidiaries (collectively, " we", or " Company"), with respect to games developed by the Company (" Games"), the websites uplift.games, playadopt.me and any associated domains, sub-pages, and sub-domains thereof controlled by Company and its affiliates or subsidiaries, and any other commercial or professional services offered by Company (collectively the " Services"). This Policy will explain what information we collect from persons who access the Services and their parents (" users", " you"), why we collect it, and how we use it.

By using the Services, you are consenting to this Policy and the processing of your data, including your Personal Information, as defined herein, in the manner provided in this Policy. If you do not agree with the terms in this Policy, please do not use the Services.

We reserve the right to change this Privacy Policy at any time in our sole discretion. We will provide you with notice of such a change. Notice of any changes to the Privacy Policy will be accomplished upon Company announcing such changes through the Services. Such changes will go into effect immediately upon you and/or your child's access to the Services after you are given notice, as described herein. You and/or your child's continued use of the Services following the notice of any changes to this Privacy Policy constitutes your acceptance of such changes. Any information collected by the Services will be dealt with in accordance with the version of this Privacy Policy that was in place at the time of collection.

The Games

The Games are hosted and operate exclusively on the online platform managed by the Roblox Corporation ( "Roblox"). To access and play the Games, you must create a user account on the Roblox website, https://www.roblox.com/. Therefore, the data practices of Roblox will equally apply to you and/or your child when you access the Games. We do not control or have authority over Roblox's data processing activities and, in that regard, we encourage you to review the Roblox privacy policy (" Roblox Policy").

Children

For any child under 13 (or, in some jurisdictions, 16), who create a Roblox account, Roblox automatically sets their account settings to “Privacy Mode.” Under Privacy Mode, children do not have access to certain features of Roblox, which may mean that children do not have access to certain features of the Games. If you are a parent or guardian of a child under 13 (or 16 in some jurisdictions) and you wish to contact Roblox about its collection of your child’s Personal Information, you may contact Roblox at https://www.roblox.com/support. Further, if you believe we have collected or processed your child’s Personal Information from their use of the Games, please contact us at the address listed below.

We do not knowingly collect or process Personal Information from Children under 13 (or 16 in some jurisdictions) with respect to the use of the Services. If you are a parent or legal guardian and you believe we have collected or processed your child’s Personal Information or have a concern regarding your child’s information on our Services, please contact us at the email provided at the end of this Policy. Further, if we learn we are engaged in such processing, we will cease these activities and take reasonable measures to remove the applicable information.

We do not collect any more information than is reasonably necessary to participate in the Services. We will not share Personal Information except for the permissible purposes stated in this Privacy Policy, and, if required by law, only with the prior verifiable consent of a parent or legal guardian.

NOTICE AT COLLECTION- Information We Collect

To provide users with the best possible experience, we may collect certain personally identifiable information (" Personal Information"). Personal Information is any information that can be used to identify you or your household or to contact you, whether online or offline. It can include things like name, email addresses, online usernames, and any data that can be linked to such identifiers.

PLEASE NOTE THAT THE INFORMATION DESCRIBED IN SECTIONS (c) AND (d) BELOW MAY NOT BE COLLECTED BY THE GAMES AND THE GAMES ONLY COLLECT THE INFORMATION DESCRIBED IN SECTIONS (a) AND (b).

We collect Personal Information in accordance with the following:

a. Information Collected During Gameplay

The Services may collect Personal Information when you play the Games. The categories of Personal Information we collect from you when you play the Games are as follows:

Category	Information Collected by the Games
Identifiers	Your Roblox User ID, legal name. Processing this information is necessary to allow you to access the Games. Processing this information is necessary to allow us to record in-Game purchase and to ensure Roblox provides you with any items you may have purchased.
Personal Information as defined by California Civil Code §1798.80(e)	Your Roblox ID. Processing this information is necessary to allow you to access and use the Games.
Commercial Information	In-Game purchase data. Processing this information is necessary to allow us to record in-Game purchase and to ensure Roblox provides you with any items you may have purchased.
Geolocation data	Your Country of origin. Please note, the Games do not collect information regarding precise geolocation, physical address, zip code, city, or state. Your country of origin may be visible by other Players during the Games. Collecting this information is necessary to provide us with analytics to improve our Services.
Internet or electronic network activity information	Your Usage data with respect to your use of the Games including acquired items, how much time you spend in the Games and in what locations, in-Game interactions, Gameplay data, trades, and Roblox usage data, including navigation paths, search queries, crashes, timestamps and other records and data regarding in-Game activity. We process this information create analytics regarding Gameplay to improve the Gameplay experience. We also process this information to monitor the Games and enforce our terms of service (“TOS”) and other guidelines.

b. Information the Games may Collect Automatically

The Games also collect device-identifiable information (DII to allow us to identify the type of device on which you are playing the Games. Please note the information provided in Sections (a) and (b) represent the full extent of the Personal Information collected by the Games.

c. Information we Collect via Your Use of Other Services or When You Visit our Websites

When you visit our websites, we may collect information about the Services you use and how you use them, such as the selections you make on our Services. The Services may collect Personal Information when it is provided to us, such as when you use our Services, contact us, submit a resume or job application, or connect with us on social media or via one of our partners. When you contact us, we may keep a record of your communication as well as the other information in this Policy to help solve any issues you might be facing. If you provide us with an email address via our websites, we may use your email address to inform you about our Services. WE DO NOT PROCESS OR COLLECT SENSITIVE INFORMATION. The categories of Personal Information we collect from you via other Services are as follows:

Category	Information that may be Collected by the Services (Excluding the Games)
Identifiers	Information that you provide to us including name, alias, address, phone number, IP address, online identifier, email address, Roblox ID, social media account info, account name or similar. This can also include any information that you provide to us pursuant to a job application or other professional inquiry. This may also include information you provide to us pursuant to our Influencer Program. Processing this information is necessary to allow you access to the Services. We process your name, email address Discord ID, social media account info, and other identifiers to communicate with you, respond to your inquiries, or as part of the application process for our Influencer Program. We process your IP address to 1) generate analytics to improve the; 2) to monitor activity within the Services and enforce our TOS; 3) to prevent fraud, spam, and abuse; and 4) to ensure security of the Services. If you are a prospective employee or independent contractor, we also process your identifiers to verify your identity as part of the application review process and to send you correspondence related to your application.
Personal Information as defined by California Civil Code §1798.80(e)	This includes any information that describes, relates to, or is capable of being associated with you or your household and includes your legal name, Discord username, your Roblox ID, social media handle, your email, address, IP address, online identifiers, or any similar information that you provide to us. This can also include any information that you provide to us as part of a job application or other professional inquiry. This may also include information you provide to us pursuant to our Influencer Program, including your Roblox ID, Discord username, date of birth, your country of origin, and links to your social media profiles or online content. Processing this information is necessary to allow you access to the Services. We process your name, email address Discord ID, social media account info, and other identifiers to communicate with you, respond to your inquiries, or as part of the application process for our Influencer Program. We process this information to 1) generate analytics to improve the; 2) to monitor activity within the Services and enforce our TOS; 3) to prevent fraud, spam, and abuse; and 4) to ensure security of the Services. If you are a prospective employee or contractor, we may also collect your physical address to verify your identity and send you correspondence, payment.
Internet activity and electronic network information	Including, but not limited to, browsing history, page views, search history, and information regarding your interaction with our websites and how you were referred to our websites. We process this information for the purpose of 1) generating analytics to improve the Services and User experience; 2) to monitor activity within the Services and enforce our TOS; 3) to prevent fraud, spam, and abuse; and 4) to ensure security of the Services.
Professional or employment related Information provided pursuant to a job application or other professional inquiry.	This may include personal contact details, date of birth, education information, employment information, and compensation history. We process this information to evaluate your employment application.

d. Information the Services May Collect Automatically When You Visit Our Websites

When you use our Services, we may also create or collect device-identifiable information (DII), such as unique device and statistical identifiers, and similar identifiers that are linkable to a browser or device by virtue of your use of our websites or other Services, excluding the Games.

From these platforms, we may also receive other information, such as your IP address, user agent, timestamps, precise and imprecise geolocation, sensor data, apps, fonts, battery life information, and screen size.

Our websites also collect information about your interactions, including navigation paths, search queries, crashes, timestamps, purchases, clicks and shares, and referral URLs. We may combine this data with Personal Information and DII. For efficiency's sake, information about your interactions may be transmitted to our servers while you are not using the Services.

NOTICE AT COLLECTION- How We Use Information We Collect

We use the Personal Information we collect from our Services to provide, maintain, protect and improve our Services, to develop new Services and offerings, and to protect us and our users. With respect to the Games, we use the Personal Information we collect to operate the Games and to provide you with and improve your Gameplay experience.

We also use your Personal Information for the following business purposes:

To meet the reason for which the Personal Information was provided.
To provide you with information or services you request from us.
To improve the Games, the Services, and the performance of the contents therein.
To manage and oversee our Influencer Program. For example, you must be 18 years old or over to participate in our Influencer Program, so we collect your birthday for that purpose. We also need to know your email address, contact information, Roblox ID, and your online content portfolios so that we may evaluate your application to join our Influencer Program and communicate with you.
To manage and oversee our Discord Moderator Program. For example, you must be 18 years old or over to participate in our Discord Moderator Program, so we collect your birthday for that purpose. We also need to know your email address, contact information, Discord ID and Discord Username so that we may evaluate your application to join our Discord Moderator Program and communicate with you.
To resolve any technical support or other issues you may experience with the Services.
To resolve disputes.
To prevent potentially fraudulent, prohibited, or illegal activities.
To support employment, including soliciting and processing employment applications, providing compensation and benefits to employees, and managing our team
To enforce our TOS.
To communicate with you upon request.
To perform other duties as required by law.

NOTICE AT COLLECTION- How We Disclose Personal Information to Third Parties

WE DO NOT SELL, LEASE, SHARE, OR OTHERWISE TRANSFER YOUR PERSONAL INFORMATION TO THIRD PARTIES FOR THEIR OWN USE OR FOR THE PURPOSE OF CROSS-CONTEXTUAL BEHAVIORAL ADVERTISING. SIMILARLY, WE DO NOT SELL, LEASE, SHARE, OR OTHERWISE TRANSFER THE PERSONAL INFORMATION OF ANYONE UNDER THE AGE OF 16. WE DO NOT PROCESS OR OTHERWISE COLLECT ANY SO CALLED SENSITIVE INFORMATION AND WE DO NOT COLLECT OR OTHERWISE PROCESS ANY BIOMETRIC DATA OR ANY DATA GENERATED BY AUTOMATIC BIOLOGICAL MEASUREMENTS.

However, there are certain circumstances in which we may transfer your Personal Information to third parties, without further notice to you, as set forth herein. All such transfer or disclosure will be pursuant to one or more legal bases identified below.

We disclose Personal Information and DII to companies, outside organizations, and individuals for limited reasons and the following business purposes, outlined below:

With your consent - We will disclose Personal Information and other data with companies, outside organizations or individuals if we have your consent to do so.
For external processing - We provide Personal Information to our affiliates or service providers to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. We may also disclose Personal Information to service providers and companies that provide services to us, including companies that assist us with hosting, payment and payroll processing services, providing data process services, providing analytics services, account management, technical support, and similar services.
For legal reasons - We will disclose Personal Information to companies, outside organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, detect, prevent, or otherwise address fraud, security or technical issues or protect against harm to the rights, property or safety of our users or the public as required or permitted by law.
In case of a sale or asset transfer - If we become involved in a merger, acquisition or other transaction involving the sale of some or all of our assets, user information, including Personal Information collected from you through your use of our Services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Services.
We may share Personal Information with analytics companies for the purpose of providing analytics to improve and maintain our Services.
We may disclose aggregated information and DII to our partners such as businesses we have a relationship with, advertisers or connected sites. For example, we may disclose information to show trends about the general use of our services.

We use DII to operate our Services and manage user sessions, including analyzing usage of our Services, preventing malicious behavioral and fraud, improving the content, to link your identity across devices and browsers in order to provide you with a more seamless experience online, and helping third parties provide relevant advertising and related metrics. We disclose DII to third parties primarily for advertising and analytics purposes, for external processing, and for security purposes.

Any time we transfer your Personal Information to a third party their use and processing of such Personal Information is subject to your instructions.

Keep in mind that when you broadcast information to third-party services, such information is no longer under our control and is subject to the terms of use and privacy policies of such third parties.

In connection with the Games, in the past month we have disclosed the following Personal Information for the purposes described herein;

Roblox User ID
Commercial Information
Internet or electronic network activity information

In connection with all other Services, in the past 12 months, we have disclosed the following Personal Information for the purposes described herein:

Identifiers
Information that identifies or can be associated with a particular individual
Commercial information
Internet or electronic network activity information
Coarse Geolocation
Professional or employment related information.

How Long Will Your Personal Information be Stored

We generally store Personal Information for as long as we need it to accomplish the business purpose for which such Personal Information is processed. If that purpose has been accomplished, we will delete such Personal Information, but we may store data for up to 14 months or longer if there is a valid business purpose or if we are legally required to do so.

Roblox Privacy Policy- You may access Roblox's privacy policy at https://en.help.roblox.com/hc/en-us/articles/115004630823-Roblox-Privacy-and-Cookie-Policy-. Please note that we do not control Roblox's data processing or data collection activities and Roblox may update its own privacy policy in its discretion. We encourage you to regularly check the Roblox Privacy Policy for any updates.

Legal Bases for Processing Personal Information

The Personal Information we process may qualify for multiple legal bases for processing under Article 6 of the General Data Protection Regulation (and similar laws that require legal bases for processing). Below are our primary legal bases for each type of data for users covered under such laws:

We have a legitimate interest in conducting analytics, measurement of usage and conversions, Game telemetrics, and other internet activity and network information, including your interaction with the Games, to improve our Services and your Gameplay experience. We and our processors have multiple measures in place to minimize any associated privacy impact.
We have a legitimate interest in processing your email address, Discord ID and social media handles, if you provide it to us via communications, to communicate with you, to provide you with updates regarding the Services, and to respond to your emails and messages on our Discord server or via our social media accounts.
We have a legitimate interest in processing Identifiers such as your Roblox ID and information that can be used to identify you for the purpose of monitoring activating on our services and ensuring compliance with our TOS.
We have a legitimate interest in processing Identifiers such as your Roblox ID and information that can be used to identify you for the purpose of securing our Services including the prevention of DDOS attacks. e. We have a legitimate interest in storing users’ purchase history for the purpose of providing users help in fixing purchase and payment issues and to provide users with purchased items.
It is contractually necessary to process your Roblox User ID, Commercial information Internet or electronic network activity information, and similar information to provide you with the Gameplay experience as well as any items or materials that you require in-Game and that you may have purchased.
We have a legitimate interest in processing Personal Information that you provide pursuant to a job application or other professional inquiry to evaluate the application or potential professional relationship.
We have a legitimate interest in processing all of the Personal Information described herein for the purposes of creating and maintaining data backups to guard against loss and data breach.

Third Parties

While we strive to work with reputable companies with good privacy practices, this Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed or linked to you on the Services. We also do not control the privacy policies and your privacy settings with third parties, including social networks and ad networks. We encourage you to be aware when you leave the Services and to read the privacy statements of any other site or application that collects Personal Information.

A Note on Website Analytics

Our goal is to process as little of your Personal Information as possible. However, we do need to process minimal Personal Information to generate analytics to ensure that we can provide you with the best possible experience when using our Services. To accomplish this our websites only use analytics services such as Fathom analytics that only briefly processes your IP address and ensures that all other personal information about you is de-identified. Accordingly, our analytics partners have no way of identifying you. To read more about Fathom's use of your Personal Information to create analytics, you may visit their website https://usefathom.com/. Please note that we have no control over Fathom and this is considered a third-party link, as described above.

Choice

PLEASE NOTE THAT WE DO NOT ENGAGE IN TARGETED ADVERTISING OR SELL YOUR INFORMATION FOR THE PURPOSE OF ADVERTISING.

Many third parties participate in self-regulation to offer you a choice regarding receiving targeted ads. On the web, you can opt out of participating companies by visiting the following sites:

http://optout.networkadvertising.org

http://optout.aboutads.info

http://youronlinechoices.eu/

https://tools.google.com/dlpage/gaoptout

https://support.apple.com/en-us/HT202074

If you wish to similarly opt out of cross-app advertising on mobile devices, you can enable the Limit Ad Tracking flag on the device. Enabling Limit Ad Tracking sends a flag to third parties that you wish to opt out of targeted advertising on that device, and major mobile platforms require companies to honor this flag. Screenshots on how to find these options on various devices are available here: http://www.networkadvertising.org/mobile-choices. To learn how to opt out on other devices, please visit the platform/device's privacy policies for more information.

PLEASE NOTE THAT YOU MAY STILL SEE GENERIC ADS AFTER OPTING OUT, BUT THEY WON'T BE BASED ON YOUR ACTIVITIES ONLINE.

Your Rights

If you are a California, Virginia, Colorado, Utah, Connecticut, Oregon, Texas, or Montana resident or a resident of the European Economic Area, the United Kingdom, or Switzerland and wish to access, update, correct, object to, or delete your Personal Information, or otherwise invoke any of the rights set forth below, you may reach out to us privacy@uplift.games.

You may make any of the following requests yourself or through a designated agent. We may ask you to verify your identity before we can act on your request. Making a verifiable consumer request does not require that you create an account with us. You must provide us with sufficient information to verify your identity, however we will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity. Additionally, if you choose to make a request through a designated agent, we may contact you to verify that you have given such agent the requisite permission.

In some cases, we may have to keep that information for legitimate business or legal purposes and therefore will deny a request to delete the information.

Without limiting the foregoing, in certain circumstances, if you are a resident of the above jurisdictions, you have the following rights with respect to your Personal Information

The right to know, access, update or to delete your Personal Information. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. The right to know, or access includes the right to know the categories of Personal Information about you, the categories of sources from where the Personal Information is collected, the categories of third parties to whom we disclose the Personal Information, and the specific pieces of Personal Information collected about you.
where the Personal Information is collected, the categories of third parties to whom we disclose the Personal Information, and the specific pieces of Personal Information collected about you. Specifically, we will disclose to you, at your request:
- The categories of Personal Information collected about you.
- The categories of sources for the Personal Information we collect about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of Personal Information that we share with third parties
- The categories of third parties to whom we share that Personal Information.
- If you are a resident of Oregon, a list of specific third parties, other than natural persons, to whom we have disclosed your Personal Information.
- The specific pieces of Personal Information we collected about you.
- How you may exercise your consumer rights with respect to your Personal Information
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  - Sales identifying the categories that each category of recipient purchased, or a statement indicating we did not sell your Personal Information; and
  - Disclosures for a business purpose, identifying the categories that each category of recipient obtained.
The right of rectification. You have the right to have your Personal Information rectified or corrected if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Information.
The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
The right to data portability. You have the right to be provided with a copy of the Personal Information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Company relied on your consent to process your Personal Information
The right to opt-out. You have the right to opt-out of the processing of your Personal Information for the purposes of (a) targeted advertising, (b) the sale of Personal Information, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

If we deny the request for any of the above and you wish to appeal our decision with respect to any of the above, please email us at privacy@uplift.games. In your appeal, please state that your message pertains to an appeal and include the date and subject matter of your original request.

Complaint

If you are a resident of the EEA, the United Kingdom, or Switzerland, you have the right to make complaint to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the EEA, the United Kingdom, or Switzerland.

Non-Discrimination

We will not discriminate against you for exercising the rights set forth herein. To that end, and unless permitted by law, in the event you exercise the rights set forth above, we will not:

Deny you goods or services unless it is impossible to distribute or provide such goods or services without the requisite Personal Information;
Charge you different prices for goods or services;
Impose penalties;
Provide you with a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

Information Security

We will take reasonable and appropriate security measures to protect your Personal Information from unauthorized access, disclosure, alteration, or destruction. Unfortunately, no data transmission over the Internet or any mobile or wireless network is 100% secure. As a result, while we strive to protect your Personal Information, you agree and acknowledge that: a) there are security and privacy limitations inherent to the Internet and wireless and mobile networks which are beyond our control; and b) security, integrity, and privacy of all information and data exchanged between you and Company cannot be guaranteed. We recommend that you do your part in protecting your Personal Information. This includes guarding against unauthorized access to your email and social media accounts including via 2-factor authentication, if applicable, by ensuring no one else uses your device or computer when you are logged in, by logging off from the Services when they are not in use, by keeping your password and other Personal Information confidential, and by taking precautionary steps to guard the physical safety and security of your device or computer.

International transfer

Some of our Services are located in the United States and your Personal Information may be transferred or stored in the United States. The data protection laws and rules in the United States may be different than those where you live. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate. To the maximum extent permitted by applicable law, you hereby authorize Company to process your information in the United States or any other locations where we operate. We rely on various legal mechanisms to help lawfully support transfers of information outside the country of collection where appropriate including ensuring all our processors adhere to terms and conditions set forth in the Standard Contractual Clauses, as approved by the European Commission.

Given that our Services are globally accessible, there are times where your data may need to be transferred across different jurisdictions. However, we will not transfer your Personal Information across jurisdictions, unless:

You have provided your consent; or
It is necessary to complete a transaction related to the Services or for another legal basis otherwise described herein; and
We believe that the recipient of such information is subject to a law, contractual obligation, or a binding scheme, that has the effect of protecting your Personal Information in a way that, overall, is at least substantially similar to the way in which information is protected in the European Union, United Kingdom or Switzerland and there are mechanisms you can access to enforce that protection of the law or binding scheme; or
Where otherwise allowed by any applicable legislation.

Merger or Sale

The information collected pursuant to this Policy, including Personal Information, is considered an asset of Company. In the event Company or some or all of the assets related to the Services are acquired by another entity through a sale, merger, or some other change of ownership transaction, Company reserves the right to transfer or assign the information, collected pursuant to this Privacy Policy.

Questions and Contact Info

We welcome your questions or comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy, or if you have any other questions or concerns regarding this Privacy Policy, please privacy@uplift.games.