Privacy Policy

This Privacy Policy applies to those who access, register, or in any other way use the products and/or services of Level Up (My Account) and/or the Hype platform.

Before we go into detail on everything herein, it is worth clarifying some important concepts for understanding this Policy:

Personal Data means any information that allows your identification. Like, for example, your name, social security number, age, home or electronic address, and phone number, among others.

Sensitive Personal Data are personal data related to your personality traits and personal choices, like racial or ethnic origin, religious belief, political opinion, data concerning your health or sexual life, and genetic or biometric data when linked to you.

Personal Data Processing means any operation involving personal data, like collection, production, reception, classification, usage, access, reproduction, transmission, distribution, handling, archiving, storage, deletion, evaluation, or the control of information, modification, communication, transfer, diffusion or extraction, performed with personal data.

Level Up is a company that has been operating for over 16 years in the commerce of online games. To enable our operation, and the provision of our products and services to you, some of your personal data may be collected and used as described in the present Policy, and in accordance with the information provided to you during your interactions with Level Up.

We are committed to your privacy and security, and we invest our resources into the development of technological solutions capable of not only allowing for the delivery of products and services but also safeguarding your privacy and protecting your personal data when you interact with Level Up.

To perform our activities, we need to process personal data for various purposes, like carrying your registration on our website and digital platforms (Level Up (My Account) and Hype), as well as presenting content with novelties, deals, and other information that may be relevant to you.

 

These are just a few examples that show how some of our activities depend on the processing of personal data. We take the enforcement of laws protecting your privacy very seriously, and this Privacy Policy describes how your personal data are collected, used, shared, and stored. If, after reading this Policy, you still have questions, feel free to contact Level Up using the contact information listed at the end of this document.

This Policy applies to our web pages (Level Up main website and websites from games sold by Level Up), our digital platforms (Level Up (My Account) and Hype), and our operation as a whole,

covering all kinds of processing that we may give to personal data, including data collected through offline means, such as in organizing E-Sports tournaments and in-person events.

The amount and type of personal data collected by Level Up depend on the interactions that you have with our company.

Below, you can find how we collect your personal data:

From the registration for the Level Up (My Account) website or the Hype platform:

On the account creation step of the Level Up (My Account) website or Hype platform, Level Up asks for the name, email, date of birth, and social security number of the owner, so you can finish your registration by creating a login and password.

The collection of these data is necessary for account creation and user authentication in our systems.

Although it does not prevent access to our websites, the user will not be able to use certain services from the Level Up (My Account) and/or the Hype platform that requires email validation and/or the provision of a social security number.

 

From the game account creation:

To create a game account, the user must create a Level Up account on the Level Up (My Account) website – which will process the personal data indicated in the previous topic (name, email, date of birth, and social security number of the owner) – and then inform a username (login) and a password for the chosen game. In-game, the user may have to inform the name(s) of the character(s) for the chosen game.

The collection of such data is necessary for Level Up to be able to identify and support the user in eventual needs and questions sent, for applying the rules of conduct, and for behavior analyses and actions performed on the game account.

 

From the Hype platform:

For the order payment processing, the chosen payment method will determine the data that will be collected, which can be the name, email, date of birth, social security number, phone number, and full address of the person responsible for the account/user. If the data are different from those of the person responsible for the purchase, we will also collect these same data from them.

 

For the redemption of credits (Hype Pin), the data collected will depend on the product/credit that is being redeemed and can include name, email, date of birth, social security number, phone number, and full address.

 

From data from public sources and/or publicly accessible:

Level Up may use data for analysis and measures to prevent money laundering, anti-fraud mechanisms, as well as for compliance with regulatory obligations related to the subject.

From the sending of institutional and marketing communications, newsletters or physical awards and market research:

For you to stay up to date with everything that happens in Level Up (My Account) and the Hype platform (news, actions, deals, partnerships, releases, etc.), we collect your name, email, date of birth, state, ID, social security number, full address, phone number with area code, browsing data from our portal, and your purchase history and game access history.

 

From the support center:

In order to help with whatever you need, our support center must have access to the information required to analyze and solve your issue.

The collection of this data happens so that only the essential for the analysis is requested for us to offer support in our channels (ticket, chat, and WhatsApp). As we explained, the data collected vary from case to case, but in general, the data requested in our support processes are: name, email, date of birth, social security number, IP, the username of the Level Up account, the username of your game accounts, full address and phone number with area code.

 

For analysis and preventive measures:

For the purpose of analysis and measures to prevent and combat fraud activities, Level Up may collect the IP address from the users of its platforms.

 

Improvement of our services:

To always improve what we do, we can also use data related to your interactions with Level Up and the Hype platform, so we can perform improvements in our internal practices and processes with the aim of better understanding your needs; identifying consumption and behavior patterns to plan our marketing actions, fix issues, bugs and inconsistencies in our platforms; and enable the overall improvement of our products and services. Whenever possible, we will use anonymized data (data that do not allow for the identification of a person as an individual) or pseudonymized (data that, by itself, can’t identify a person as an individual, except when it is combined with other data that allow for the identification) for these purposes.

 

Communities:

Level Up has forums with chat areas where users can exchange ideas and communicate with each other. When posting a message, you have to take into consideration that the information is publicly available. If the user’s Personal Data is posted in one of our community forums against their will, they can report this fact to the moderators and request the respective deletion. The

user can also contact Level Up through the support center, via the data processing option, or through the email address of the data protection officer, to notify this fact and request the deletion of data unduly posted.

 

Google Analytics:

Level Up websites use Google Analytics, an Internet data analysis service offered by Google, Inc. (“Google”). Google Analytics helps the website operators by using cookies to analyze how visitors use the website.

On behalf of the website operator, Google will use this information to evaluate the usage of the website by its users, in order to compile reports on the website activity and provide the website operators with other services related to the website activity and the use of the Internet.

The user can refuse the use of cookies by selecting the appropriate settings in the browser. However, it must be taken into consideration that, in this case, the user may not be able to use all functionalities present on the website.

You can learn more about how Google Analytics collects and use data at: www.google.com/policies/privacy/partners

In addition to that, it is possible to prevent Google from collecting and processing data on your usage of the website by downloading and installing a browser plug-in through the following hyperlink: http://tools.google.com/dlpage/gaoptout?hl=en

 

Through the use of cookies:

When the user visits our webpage, our portal asks for your browser to store a small piece of data (text file) called cookies on your device.

This file has the purpose of remembering information about you, such as your language preference or login information.

 

What are cookies and what are they used for?

Cookies are small text files stored on your computer. These small files are used to recognize, track and store your browsing as a user on the Internet.

Cookies are used to track and store information that allows Level Up to offer a custom service, according to the characteristics and interests of its users. An example is the offering of specific content and advertising, improving the user experience in our environments and on the Internet.

Please note that cookies do not transfer any kind of virus or malware to your device, since they act merely as records of the user activities and preferences, being updated whenever the portal is visited.

 

Why do we use cookies?

Level Up uses cookies for the following reasons:

 

Authentication:

We use cookies to recognize when you access our products and services. This technology helps us customize your experience according to your settings, facilitating your access and browsing.

An example is the use of cookies to save items that you may have added to your cart while browsing our website.

 

Preferences and features:

We use cookies to improve the customization of your browsing experience and to expand the features of our products and services.

An example is the use of cookies to identify your browser.

 

Custom content and advertising:

We use cookies to target custom content from the information on your interaction with our platforms.

An example is the use of cookies that record interactions with our products, allowing us to offer helpful and relevant information related to your profile and preferences whenever you come back to our website or shopping platform.

 

Website performance measurement:

We use cookies to understand how our products and services are being used and, therefore, to improve your user experience.

An example is the use of cookies that identify how many times a certain page was visited, helping us to better understand our public and improving the user experience.

 

Strictly necessary cookies:

These are the cookies needed for the website to work, so you can browse it and use our services and features. An example is the security cookies used to authenticate users.

 

Are third-party cookies used?

Third-party cookies are the ones created by other websites which, in turn, have part of the content – such as advertisements or images – that you see when you visit the webpage.

Level Up makes use of third-party cookies. So when providing services to Level Up, authorized third parties can use their own cookies in the Level Up platform.

 

How can I change, remove or block cookies?

Level Up has a cookie management mechanism on its websites. There, you can manage cookie settings for Level Up websites and the Hype platform, or you can use direct settings from your browser to know which cookies you have installed and change or delete them if you want.

 

For convenience, on the links below you can find instructions according to the browser you are using.

Firefox

https://support.mozilla.org/pt-BR/kb/limpe-cookies-e-dados-de-sites-no-firefox

Google Chrome

https://support.google.com/chrome/answer/95647?co=GENIE.Platform=Desktop&hl=pt-BR

Safari

https://support.apple.com/pt-br/guide/safari/sfri11471/mac

Internet Explorer

https://support.microsoft.com/pt-br/topic/como-excluir-arquivos-de-cookie-no-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

Microsoft Edge

https://support.microsoft.com/pt-br/windows/microsoft-edge-dados-de-navega%C3%A7%C3%A3o-e-privacidade-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd

Opera

https://help.opera.com/en/latest/web-preferences/

Brave

https://support.brave.com/hc/en-us/articles/360048833872-How-Do-I-Clear-Cookies-And-

 

To find information related to other browsers, please visit their developer’s website.

Please note that the use of cookies allows for a better experience in our products and services. If you opt to block cookies, or if you decide to not allow the operation of some of them, we cannot guarantee the proper functioning of all features in our environments. Furthermore, it is possible that certain functions and pages do not work properly.

 

Can the use of cookies ever change?

Aiming for the continuous improvement of our services, we can update the use of cookies. If we make any relevant changes that require a new consent, we will post an update on this Privacy Policy and request your consent.

Level Up has a partnership with other companies for distributing our products and services. Also, we need to comply with the current legislation. This can entail the sharing of your data with public bodies and relevant authorities. Here are some of the situations where we can share your personal data:

 

Our Suppliers, Service Provides, Level Up Economic Group, and Partners:

Level Up is part of an economic group, and has several partners, service providers, and suppliers hired to facilitate our operation and the provision of our products and services. Some of them may process part of the personal data that we collect, such as partners/providers and payment method integrators that provide fraud prevention or credit analysis services, license the right for us to operationalize their games, and so on.

It is important for you to know that Level Up evaluates and selects its partners and suppliers through contractual obligations for information security and personal data protection, in order to minimize risks regarding your data.

 

Public Authorities:

We have a commitment to law enforcement. So, if we are subject to any legal or regulatory obligation that determines the provision of personal data to any authority, we are required to do so. Furthermore, if a judge or an authority with legal or regulatory competence demands Level Up to share certain personal data to subsidize an ongoing investigation, for example, we may also be required to do so. If Level Up deems a certain order as abusive or excessive, we will always defend the right to privacy and the protection of the data under our control, sharing data only when necessary, and legally.

 

Advertisements:

We can also share data for the purpose of fulfilling requirements for commercial actions, deals, contests, or data related to your interaction on our websites to facilitate the targeting of relevant advertisements based on your Level Up profile. However, all shares with third parties for this purpose shall be carried out anonymously (unidentifiable), which is possible through the limited use of demographics (such as approximate age, approximate region of residence, and preferences arising from interactions with Level Up) and non-personally identifiable data.

Yes! Although Level Up is headquartered in Brazil, and its products and services are intended for persons located in this region, where Brazilian laws for the protection of Personal Data are

applied, the personal data collected by us may eventually be transferred to other countries. These transfers are carried out on account of the relations with certain suppliers and partners of Level Up, and the economic group that Level Up is part of, which may be located in such places.

Level Up and its partners shall take all technical and organizational security and confidentiality measures, and protections to ensure an adequate level of Data protection.

It is our responsibility to take care of your personal data, and use them only for the purposes described herein. To ensure your privacy and the protection of your personal data, we adopt good market practices and advanced technological resources to guarantee the safety and privacy of all data processed by Level Up.

Our measures to preserve your Data against non-authorized use, change, disclosure or destruction include physical and logical protection of the assets, encrypted communications, access management, commitment to secure software development and internal compliance policies that insert security into the life cycle of our Services.

If anything, we may request the data subject to provide information so we can confirm their identity. We can also use means to validate the legitimacy of this personal data. Moreover, for the use of certain Level Up services, we may request the data subject to validate their personal email. This measure aims to safeguard the security of personal data on data subjects.

We strive to protect the privacy of your personal data, but the total assurance of this security also depends on you! Account, password, and data sharing, as well as the non-authorized use of your information by third parties and other external factors, may compromise the security of your personal data.

So, your role is key to the maintenance of a safe environment. If you identify or become aware of any factor that may compromise the security of your Personal Data, please contact Level Up immediately.

Account, password, and data sharing; registration in unofficial websites or websites that are not official Level Up partners; as well as the non-authorized use of your information by third parties and other external factors are not practices recommended by Level Up. By undertaking any of these practices, you bear the risk of the frailty of your data, registers, and accounts, in addition to taking responsibility for all and any damage, directly or indirectly, caused as a result of your actions.

You, as a personal data subject, have a number of rights related to personal data and guaranteed by law. We are committed to the fulfillment of these rights. In the following table, we will break down what are these rights and how to exercise them.

 

Rights / Breakdown

 

Confirmation and Access

You can request to Level Up a confirmation on the existence of processing of your personal data, so you can know which records we have on you.

 

Data correction

You can request the correction of your personal data if they are incomplete, inaccurate, or outdated.

 

Data anonymization

You can request to Level Up the anonymization of data without the possibility of reversal. Anonymization is the means by which data loses the possibility of an association, directly or indirectly, with an individual. Data anonymization may not be possible when Level Up needs to keep your data in the following situations: (i) as long as necessary for the purpose of legal, administrative, and arbitral proceedings; (ii) in compliance with legal and/or regulatory obligation; (iii) for the regular exercise of rights.

 

Information on sharing

You have the right to know what are the public and private bodies with which Level Up shares your personal data.

 

Revocation of consent

You can opt to revoke your consent, at any time. Please note that this will not affect the processing of data carried out prior to your revocation.

 

To request the exercise of any of the rights mentioned above, please contact our support center: http://lup.vc/centraldesuporte

 

Talk to the DPO

Marjorie Medeiros

Mailing address: Avenida Jabaquara, 3060 – 8º andar, Mirandópolis. São Paulo/SP, 04046-500 – Brasil

Email to contact: [email protected]

 

For your safety and privacy, whenever you request to exercise your rights, Level Up may request some information and/or documents as proof of identity of the holder.

Some requests may not be answered immediately, but Level Up undertakes to answer all requests within 15 days, as outlined in the general Law on Protection of Personal Data (LGPD).

We do not allow minors under the age of 13 (thirteen) to register themselves at Level Up (My Account) or the Hype platform.

We also do not allow anyone under the age of 18 (eighteen) to make purchases on or shopping platform (Hype). In these cases, the minors must be represented or assisted by a legal guardian, in accordance with the law.

Level Up does not intentionally collect personal data of minors under the age of 13 (thirteen). If Level Up becomes aware that information of a minor under the age of 13 (thirteen) was collected without proper representation of a legal guardian, we will cancel the eventual account created, and the personal data related to it will be anonymized.

Level Up will keep your personal data for as long as necessary to fulfill the purposes for which it was collected, including the compliance with any legal and/or contractual obligations, accountability, or a request from competent authorities.

All data collected will be anonymized in our serves when requested by you, or when the data is not needed or relevant anymore for us to offer our Services, unless there is any other reason for it to be kept, such as the eventual legal obligation for data retention or the need to preserve it to safeguard Level Up rights.

 

To determine the proper retention period for personal data, we consider the amount, nature, and sensibility of the personal data, the potential risk of damage caused by the non-authorized use or disclosure of your personal data, the purpose of processing your personal data, and if we can achieve such purposes through other means, as well as applicable legal requirements.

To get information on personal data, and if you have any further questions or suggestions related to this Policy, please contact our support center: http://lup.vc/centraldesuporte

And select the category: Registration data / Processing of personal data / Talk to the DPO and pick the option that better suits you.

Level Up is always seeking to improve our services and the way we operate. For this reason, this Privacy Policy may go through updates that reflect these improvements.

We recommend checking this page frequently, so you can stay up to date with all the changes done to this policy. You can track if any change was applied by checking the date of the last update.

Remember: By continuing to access the Services after the changes come into effect, you agree to be bound by this new version of the Policy.